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Home My WebLink About20210210.tiffCOLORADO Department of Public Health 8 Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 January 13, 2021 Dear Sir or Madam: RECEIVED JAN 19 2021 WELD COUNTY COMMISSIONERS On January 14, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Golden Eagle HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pub l ; c Rear :-e(A) «: PL0-O HL(ostrR)' R(,J(smisvc1-11c 01/2.5/21 OG(sm) O►/an/21 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Golden Eagle HZ - Weld County Notice Period Begins: January 14, 2021 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: Golden Eagle HZ Well Production Facility NENE of Section 6, Township 6N, Range 66W Weld County The proposed project or activity is as follows: PDC Energy Inc. submitted an application requesting permit coverage for condensate storage vessels, produced water storage vessels, and hydrocarbon liquid loadout 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): • 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 20WE0503, 20WE0504 Et 20WE0505 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1 ,IatoRanic De partment o[ Public Health 6 Environment COLORADO Air pollution Control Division DeAan rient cY' RUGI4 HealUi b E1lvgLxvlent Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0503 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Golden Eagle HZ 123/A0E0 NENE SEC 6 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment ID AIRS Point' Equipment Description Emissions Control Description TK-1 002 Six (6) 400 barrel fixed roof condensate storage vessels connected via liquid manifold. Emissions from the storage vessels are routed to a sales pipeline through the use of a vapor recovery unit (VRU). During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of 20% annual 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 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 Page 1 of 12 COLORADO Air Pollution Control Division Deoarvnent o! Pubk Heal[Yi 6 Envtrc.vrteni, Dedicated to protecting and improving the health and environment of the people of Colorado 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.ov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit, application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated 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 operationof 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 Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TK-1 002 --- 1.3 14.5 2.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 Page 2 of 12 COLORADO Air Pollution Control Division Depannent el PuUL. Ffealth fv Envirenme• Dedicated to protecting and improving the health and environment of the people of Colorado 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 Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 002 Emissions from the storage vessels are routed to a sales pipeline through the use of a vapor recovery unit (VRU). During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of 20% annual downtime. 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 available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Process Parameter Annual Limit TK-1 002 01 Total condensate throughput 1,504,490 barrels Condensate throughput during VRU downtime 300,898 barrels 02 Combustion of pilot light gas 0.6 MMSCF The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must monitor and record VRU downtime on a daily basis. VRU downtime shall be defined as times when emissions from the condensate storage vessels are routed to the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate Page 3 of 12 COLORADO Air Pollution Control Division Departmcit cx' Pub. Health Fr TAW cflrneil Dedicated to protecting and improving the health and environment of the people of Colorado throughput volume and total condensate throughput volume during VRU downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly condensate throughput volume 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. 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) 13. 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 visibleemissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.24; 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. 14. 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. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. Page 4 of 12 COLORADO Air Pollution Control Division Otvantneni of PuDM: Health 6 Enwein e,n. Dedicated to protecting and improving the health and environment of the people of Colorado 16. 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 17. 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 OftM 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 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point GP10 123/A0E0/001 123/A0E0/002 21. 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 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 Page 5 of 12 COLORADO Air Ponut On Control Division Dkpanrne,v of Pubhe Healrti 6 Envimgvrie-nt Dedicated to protecting and improving the health and environment of the people of Colorado 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.' 22. 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 enforceablelimitation 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 Section Vl.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID AIRS Point Equipment Description p Pollutant Emissions - tons per year Threshold Current Permit Limit TK-1 002 Condensate Storage Vessels NOx VOC 50 50 22.3 37.0 TK-2 003 Produced Water Storage Vessels LOAD -1 004 Hydrocarbon Loadout ENG-1 006 SI RICE GEN-1 007 SI RICE GEN-2 008 SI RICE Page 6 of 12 COLORADO Air Pollution Control Division otvagtnent cX Rub14 Fiesltff fr Env rervne n Dedicated to protecting and improving the health and environment of the people of Colorado Insignificant Sources Note: APEN and permit exempt 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 23. 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. 24. 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. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned uponconduct 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. 26. 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. 27. 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. 28. 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 Page 7 of 12 jCOLORADO Air Pollution Control Division Dewriment vulilr Heath h Envitablie'K Dedicated to protecting and improving the health and environment of the people of Colorado Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 29. 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 condensate storage vessels at an oil and gas well production facility. Page 8 of 12 1� COLORADO Air Pollution Control Division CsK agment a' Pub L_' f fealth & Invtrcnme• e 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/agcc-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 Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 6,950 70 Toluene 108883 5,098 51 Ethylbenzene 100414 325 3 Xylenes 1330207 1,514 15 n -Hexane 110543 46,227 462 2,2,4- Trimethylpentane 540841 131 1 ote: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 12 COLORADO Air Pollution Control Division rnem €e Put,lc Hear.' b Envircr meet Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Process 01: Condensate Throughput CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors When Emissions are Routed to the VRU (lb/bbl) Controlled Emission Factors During VRU Downtime (lb/bbl) Source N0x 8.25x10-3 --- 8.25x10-3 TNRCC CO 1.65x10-2 --- 1.65x10-2 V0C 1.9271 0.00 9.636x10-2 ProMax 71432 Benzene 4.62x10-3 0.00 2.31x10-4 108883 Toluene 3.389x10-3 0.00 1.694x10-4 100414 Ethylbenzene 2.158x1O4 0.00 1.079x10-5 1330207 Xylenes 1.006x1O3 0.00: 5.03x1O5 110543 n -Hexane 3.073x102 0.00'' 1.536x10-3 Note: The controlled emissions factors for this point are based on a control efficiency of 100%when emission are routed to the VRU and a control efficiency of 95% when emissions are routed to the enclosed combustor(s) during VRU downtime. The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample used as an input for the ProMax simulation was obtained from the outlet of the gas buster for all the wells at this facility on 04/23/2020. The sample temperature and pressure are 103°F and -18:5 prig respectively. Uncontrolled actual VOC and HAP emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. Controlled actual VOC and HAP emissions are calculated by multiplying the uncontrolled emissions by a 100% control efficiency when emissions are routed to the VRU and a 95% control efficiency when emissions are routed to the enclosed combustor(s) during VRU downtime. 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 23.536 scf/bbl and heat content of 2,539.93 Btu/scf. Actual NOx and CO emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput during VRU downtime. Process 02: Combustion of pilot light gas CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source N0x 77.25 77.25 AP -42 Chapter 13.5 CO 352.16 352.16 V0C 6.13 6.13 AP -42 Chapter 1.4 Table 1.4-2 Page 10 of 12 COLORADO Air Pollution Control Division Department c0 Putb9 Health 6 EnyirQomen; Dedicated to protecting and improving the health and environment of the people of Colorado Note: 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. Monthly pilot light gas throughput shall be determined by multiplying this hourly pilot gas throughput by the monthly hours of operation of each combustor. There are four (4) enclosed combustors, each equipped with a single pilot light, used to .control emissions from the condensate storage vessels during VRU downtime. 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 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane a Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et NOx MALT 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.qov/ 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 Page 11 of 12 COLORADO Air Pollution Control Division De anment a Putdr_ Health Er Envircrvne• t Dedicated to protecting and improving the health and environment of the people of Colorado 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 12 of 12 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Harrison Slaughter 430822 5/4/2020 10/22/2020.. Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: 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) PDC Energy, Inc. 123 AOEO Golden Eagle HZ Weld County r hip 6N, Range 66W Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NENE 6 6N 3 66 Leave Blank - For Division Use Only AIRS Point if (Leave blank unless APCD has already assigned) 002 Emissions Source Type Storage Tank Equipment Name TK-1 Emissions Control? Yes Permit # (Leave blank unless APCD has already assigned) 20W E0503 Issuance 1 Self Cert Required? Yes Action Permit Initial Issuance Engineering Remarks Section 03 - Description of Project PDC Energy, Inc. (PDC) submitted a permit application requesting permit coverage for several new sources at a well production facility located in the ozone non - attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon liquid loadout, separator venting, and engines. The engines are requesting GP02 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 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 II.D.2.a.). It should be noted that issuance of this permit serves to cancel the GP10 coverage for this source. Public comment is required because new synthetic minor limits are being established with this application. 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: SO2 NOx CO VOC PM2.5 PMSO TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ E ❑ ❑ Title V Operating Permits (OP) ❑ 2 00 ❑ LEE Non -Attainment New Source Review (NANSR) 0 0 Is this stationary source a major source? 7__ _Na If yes, indicate programs and which pollutants: 502 NOx CO C0 VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ 000 Non -Attainment New Source Review (NANSR) 0 0 missions Inventory, Section 01-AdmmistratIve Information 'Facility Alas ID: Ms se es st .3..S.Mrtstaot Section 02 -Equipment Description Debits Storage Tank Liquid Detailed Emissions Unit Description: Emission Control Device Description: Vapor recovery mit.(VRU) routes emkziobstopipl .Emissions are rooted ea oncimed combustor(s) during VRU downtime. Requested VRU Control Efficiency %: Requested Enclosed Combustor Control Efficiency%: VRV Downtime %: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Section 03 -Processing Rate information fot Emissions Estimates Primary Emissions- Storage Tank(s) Actual Throughput= 5>) X1'25 74OZBarrels(I'M per year Actual Throughput During VRU Downtime= a5o.7..0 Barrels(abl) per year Requested Permit LIMIThroughput= Requested Permit Limit Throughput During VRU Downtime. Potential to Emit (PTE) Throughput= Potential to Emit (PTE) Throughput During VRU Downtime= Secondary Emissions -Combustion Devlce(s) Heat content &waste gas= Volume of waste gas emitted per BBL of liquids produced= Actual heat content of waste gas routed to comhustian device= Requested heat content of waste gas routed to combustion device= ti Barrels (Mal) per year 1303 �i Barrels (bbl) per year So4rA90Lr_ Barrels(WM) per year 1_ !_3.il Barrels(bbl) per year _. ;.6 scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Control Device Requested Monthly Throughput= LPMW, Barrels(MI) per month 14,190.0 MMBTU per year 1'l.9an.C MMBTU per year 17MS. MMBTU per year Section 04 -Emissions Facbrs& Methodologies Will this storage tank emit flash emissions) ProMax Flow Rate 1,253,]40.00 W year Pollutant Flash Gas lib/hr) w&e Gas(lb/hr) Toblwasfe0as aft 116/hr) Source VOC 259.0934922 16.21922032.. _1. Protrim Benzene 0634548 00256072 _ ProMax Toluene .464102 0.0208]26 i -. ProMax. Ethylbemene 0.0294242 0.00 .c0.,,..'.. Promax Xylenes 0.135169 -.. 0.00882063 0.14:: ?ea t ProMax n -Hexane 4.31649 092 4.:`>__ Montan 2,2,4TMP 0.011242B 0.000729B1i 801 n ProMax `. Pollutant Control Device Pollutant Pollutant Condensate Tank Uncontrolled Controlled (lb/MI) PAM) (Condensate Throughput) (Condensate Throughput) Uncontrolled (Ib/MMRtuI Uncontrolled (Ib/bbl) Pilot Light Emissions Uncontrolled (Ih/MMBtu ) Uncontrolled (Ib/MMscf) Emission Factor Source Emisslan Factor Source Emission Factor Source Sean 05 -Em( Ions Inventory 0.004192022 I Controlled Emission Factors Used in Permit Pollutant Controlled Emission Factors used during VRU Operation (Ib/bbl) Used During VRU Downtime PAM) Source VOC -' —" Site specific E.F. Bortzene.. �-.. Site specific E.F. Toluene 42.3[LE Site specific E.F. Ehylbeneene Onx Site specific E.F. Xylene 040 5.03035,,, site. specific E.F. n -Hexane - Site specific E.F. 224 TMP L.ESEL31,06 Site specific E.F. Criteria Pollutants Potential to Emit Uncontrolled (tans/year) Actual Emissions Uncontrolled Controlled (tom/year) (tens/year) Requested Permit Limns Uncontrolled Controlled (tom/year) (tons/year) Requested Monthly Limits Controlled Ms/month) PM10 PM1125 50x Nox VOC CO 0.0M rsose 041fi9 0.069 0.0. 0.01X DUBE 0.059 0.059 11.8 0.005 0.005 0.005 0.005 0.005 0.9 1.242 1.955 1..1 1.1,11 114.4 144H.FS)i 1209,51 1:082 1440.62ti :4.498 2402,] 2_::24 e. ,+_ 2..1 2..574 2..574 Hazardous An Pollutants Potential to Emit Uncontrolled (Ibs/yexri Actual Emissions Uncontrolled Controlled 9M/vearl Ilbs/vearl ' Requested Permit Limits Uncontrolled Controlled labs/year) (Ibs/yeer) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TNT 5.0.01 7.9950,11 92, 6 5= .50 '9 509.06 ' 4249.]8 4248 5000.06 50.98 11.-141 :'10.49 2.11 B14,59 1513.6'2 1261.15 12.61 151:182 15zr 0. 02,11 385224? 38,.. 46222.4. 151.11 Ll.._ 1.. 14.3 151.11 2 of C:\Users\hslaugheDosk[op\313AOE0\20WE0503.CP1 Storage Tank s) Emissions Invent, --e section ns-Re¢ulem summary Anahzis Regulation 3, Parts A. B -P Regulation 7, Part O,SecC'on I C, O, E,P time art. Section t.Cp Regulation], Part O,Sectlon I G .7. n1.0 Regulation ] Part 0,5ect on I.C 1, C 3 't U kitlan Regulation ], Part O,Section MCI 0" Regulation], Part OSecton II C4a it 115 ion lCr d,a[il Regulation], Part 0,5ec[on IlC 4alil Regulation 6, Part A, NSP5 Subpart I. Regulation 6, Part A, NSPS Subpart 0000 .... NSPS subpart 0000a -.ili Regulation e, Part E, MACT Subpart HH ... (See regulatory applkebility workshe.for detailed analysis) Section 0] -Initial and Periodic sampling and Testing Requirements For condensate or crude ail tanks, does themompany use the state default emissions factors to estimate emissions? No dyes, are the uncontrolled actual or requested emissions for a crude oll tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? Oyes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelinesin PS Memo 14-09 Does the company use a.site specific emissions factar to estimate emissions? try. and if there are flash emissions, are tie emissions factors based one pressurized liquid sample drawn at the facility being permitted (for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample should be considered represent.. which generally means site=... and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells -brought on-line), then it may be appropriate to use an older • re -specific sample. 4R4 If no, the permit will contain 'an"Initial Compliance. testing requirement. develop a sire specific emissions factor based on guidelines in Ps Memo 1"403. Does the company request a control deviceefficiency greater than 95% for a flare or combustion device? lives, the permit will contain Initial and periodic..metier e..nu In a...mewith PS Memo 20.2 Section 08 -Technical Analysis Notes N/A -the operator developed site specific em's.. factors. L Please reference the APEN submitted an 05/04/2020 for a listed the fifteen news.. at this facility. The wells associated with this tank battery were fractured between September and November -2019 and began production between January and February 2020. Eleven of the wells at this facility produce from the Nlabaa formation. Three wellsatthix facility produce from the W rlis.{odell-Fort Hays formabons. One well at this facility Codeil-Fart Hays formations. The sample used to establish site specific emission factors was obtained on 04/23/2020 from the aulletafthe gas buster at this facility. Sin.. sample was obtained after the wells. the facility began production, it is acceptable for establishing site specific emission factors. 2. The sample used to establish emission factors was obtained from the outlet of the gas buster for all ache wells at this facilityon 04/23/2020. This is t.last separation step pror to the liquid being sent to the storage vessels. Additionally, the site specific semis. used to establish emissions factors for This source . obtained within a year of the application. As a result, the sample Is acceptable fm..folisMng site specific emission factors. R should be noted Mat the sample includes sample probe temperature antl pressure in conjunction with gauge pressure andtempwature. According. lab information the sample probe temperature and pressure are obtained using lab equipment during the sampling process. These values are expected to be more actuate compared to the gauge values and are acceptable for use In the simulariwr, to establish site specific emission factors. -.3. site specific sample was used in cmijuncton with a ProMaxsmetationmdet mine she specific emission factors and combustion emissions, The results of the simulation 0:emissions (lb/veaflare available for reference in Sections 06 and 04 above. 4, The condensate storage vessels and producer, water storage vessels sauce are controlled by the same four encl.ed combustors: As a result, engineering guidance indicates that ombustion emissions(I.e. NOx and CO) from all the sources summed together In order to determine APEN applicability. lnthis rase, total NO4 and CO emissions from all the sources are above APEN reporting thresholds As a result, the permit f0. each source will coma n emission limits and emission factors for NOx and CO. re 5. Since the condensate storage vessels and produced water storage vessels are controlled by a common control device, pilot light emissions are grouped with the highest emitting sour. coverer, by an Individual permit In this case, the condensate storage vessels are the highest emitting source. As a result, pilot fight emissions are accoun.d for with LhR analysis.The permit for the condensate storage vessels also contains a throughput 11.6 Mr pilot combustion. Emission factors and calculation methods for pilot lightcombtatinn em.lom areal. included int. rotes to permit holder. This Information is included in the permit because pilot lightemisscros contribute to the overall emissions from Orin source. Additionally ith Impora.to include this Informed. because throughput tracldngand emission calculation methods are different than those used to estimate emissions based on the crude oil throughput This darityisimpor.nt for accurately ...tying actual emissions at this facility. 6. Initial and periodic opacity observations are addressed by the 0&M plan. As a result the permit does not...Initialer periodic opacity testing. ]. Typically, the secondary mrnbusuort emissions are calculated using the waste gas flow rate and heat content predicted by the model used to establish the site -specific em.slons factor,.sed on the ProMax simulation,. total waste gas flow rate was predicted to be 0.06848084 MMscf/day (Flash and W&B gas). Additionally, an average heatmrReniwas determined using the heat content of the Rash gas stream (2539.93 0tn/icflmhd the W&B stram (2614.888tu/scf) and the following...Ions, Average Heat Content l{2539.93 etu/scfj*(0.0.4415 MMscf/day(/(¢.06848084 pAtykcf/dayl) T ((2514.88 Btu/ecf)"(0.00403934MMscf/day)/(0,06848084 MMscf/day)( =2544.35 Btu/uf Using this Information, the yearly heat ion. of the gas would be calculaed asf II ws Neat input (MNIMM/yr)=(0.06848084 MMscf/day)^{365 day/year)e(2544.35 MMBtu/MMscfl'(0:2)=12,739.5 MMB./year be calculated at 0.88 tpy and l.]Stpy re ; ectively. rig value, the actual NOx and CO ernissiam would The operator used the following equation M cold.. the annual heat input Heat Input (MMetu/yr)= (Uncontrolled VOC routed to combustor (ton/yrn2000Ib/tool/(MW (Ito/Ib-molt"(379.41 scf/10-mol7ell/VOC cost %('(Heat Content (Btu/scUMM.MMetu/IAW,000 Btu). The operator expressed the values for molecular weight. VOC mai%and heal content used in the equation were obtained from the flash gas stream in the ProMax simulation provided in the application,. values used in the equation are as fallow. (i) MOlecufar weight 45.3569 lb/lb-mot fli)VOCmoI %:66.794615%, iili) Heat Content:753996 Sta/sef. Using these values, the operator cakula.da heat input of 14,990 MMBM/yr-SbIW thisvalue Is more conservative den the value.lculated above using prescribed met O.d, it will be used for permitting purposes. e. Pccordngto the appfiation emissions from the storage tassel are rou.dta asales pipeline through the use of a vapor recovery unit (VRU) during normal operation (wring VRU downtime, emissions from Ox sfmagevessels are routed to encloser, combos -rods]. The operator has Indicated the vapor recovery units are down for 20%of the time during calendar year. Curing VRU operation, the operator has requested a control efficiencyof 100.6 Oaring VRU downtime, the operator hos requested a 95% control efficiency for the endo.d combustor(s). Since the control devices have different control efficienciesdaoperator will be required to track VRU downtime in conjunction with condensate throughput during VRU downtime. order to demonstrate ongoing compliance. The permit will contain a VRU downtime.ckingcondldon in conjunction with a pratess Ibnit on condensate throughput during VRU downtime. 9. The permit wlll<on.in twa process limits with mg...condensate thr.g... One limit will reference total requested condensate throughput (1,504,490 herreUyeark The second limit will reference total condensate throughput during VRU downtime. (300,898 barrel/year)The Hellion total.nderrsMe throughput incorporates all the throughput that occurs while the VRU Is Operational. In the event the VRU has less than 20% downtime (i.e. the condenate throughput durmgVRU downtime is less than the requested limit), the operator should remain incompliance math the emisslonlimlts because the VRU is requesting a 100% control efficiency compared to the 95% control efficiency associated with the enclosed combustor(s).a result, less VRU downtime is beneficial both for the environment antl the operator, 10.224-TMP Is the only HAP below APEN reporting thresholds(I.e. 2501b/year)As:a result, the permit will not contain an emission fartor for this HAP. 11. The NOS for this source wasprovi.d on 05/04/2020.. a result, an updated NOS is not required. part of the self -certification requirements In the permit 12 —The controlled VOC and HAP emfssimh factors in Secdon 04 above are based on the overall control efficiency associated with the VRU(100%contral) and enclosed combustor(1)(95% control). However, these em an factors are not the values that will be in the Notes to Permit Holder section of the permit The Notes to Permit Holder in Oce permit con.os two sets of controlled emission factors. The first set represents controlled emission factors Wt must be used when emissions are rou.d to the VRU. Stn. a 100%control efficiency is applied when emissions are routed tot. VRU, the emission factors for this scenario are all represented as 0.0016/bbl. The second set of emission factors represents cmmol.d emission factors that most be used.. emissions are routed to the enclosed combustors) during VRU downtime. These emission factors represent the uncontrolled...ion factms multiplied by a 95%antraleffidency. The controlled emission factors represented in the permit are calculated in able in Seed. 04 above labeled "Controlled Emission Pastors Used In Permit" O. It should be noted that the operator used en outdated version of the tank loss stencil in the ProMax simulation to calculate working and breathing emissions for this source As are.. an updated Pmrtax simulation using the current version of the tank loss stencil ?.ducted for comparative purposes. This updated ProMax simulation resulted in the following emission factors (I) VOC:1..568] Ib/bbl, (II) Benzene: 0,00.92316/bbl, (0i)Toluene, 00027288.ffibl, (iv) Ethylhenreme: 0.0001]5]1lb/bbl, (v) xylene. 0.000]97116/bbl, '. ,ivi)sn Hexane0066096lb/4bl; and hel)2;2/1.MP: 0.0000741216/bbl. Theefi..el factors ham this updated simulationeisseonservative than the values cal...dim the operator.aresult,the operator provided values were accep.d for permitting purposes. 14. The operator was provided with daft permit and APEN redline to reMew p or. public comment The operator reviewed both documents and expressed they had no comments. section 09-SCC Coding and Emissions Factors (For Inventory Use Onhq AIRS PO.. ssg SCCCode peal Pagufant Uncontrolled EmissionsFactor Control% PMln 3.303 PM25 19.702 sox 9.53fid. NOx 2: 903 VOC CO ,1079,3: Benzene 31.331 Toluene Ethylbemene .�, al:m3 • xylene neleiane 224 TMP __f79. Un. h/1,000 gallons Condensate throughput 6/1,000 gallons Condensate throughput 6/1,000 gallons Condense. throughput 6/1,000 gallons Condensate throughput h/1,000 gallons .ndensa. throughput fi/1,000 gallons Condensate throughput .. 6/1,000 gallons Condensate throughput 3-7 6/1,000 gallons Condensate throughput 7.7 6/11100 gallons Condensate throughput fiMOM gallons Condensate throughput 96 i/1,000 gallons Condense. throughput >? 6/1,000 gallons Condensate throughput 3 afa CMuserslhslaugh.11esktop\123AOE0\20WE0503.c. ngerank Regulatory Analysls Warksheet The regulatory requirements beloW are determined based an requested emissions, ATTAINMENT 1. Are uncoDtrolletl actual...Mons from any criteria p444ants Nom th41,01VIdUal utre greater.an 74,1egulatIonspanaSection 11.111411 on date I mr lo 12/31/1002.and nal mod.11/31/1001 {See xDe, nlonn ss.nm x402 dmona waameonermemma app rob nvll - vupl Ian oxPYo rman xa)w IXeeugtbn3 aN e m r,.,..... x_ are uncontrolled emissions Ilan, anyarte4a pollutants I Fom source rote than 5 w Illeeulmana.Pann.5eabn44.xw 2. Is 'he ronstruclI. 4.4 1,4.44. oxy30/20111and nx/ela63,xe lgubmce ' 3. Are nn lnmyuncontrolled V«emn+ionsgreater than 2il, a eanansmrarmemlwnaoeatertbanxom(�lan.3. v,�e sham �xliumman res. .. `44454414 on candalher appllomtnvll Seaj°nI<.rae 1. Is Ns storaenunk boted In the 044 ozone control area crany zone area or ant/m area 14,0an 2. Is INsalarage lank located at ell.ni1 Lasaperstbans that rolled. store,or �nwro less qr produce.nter AND tdatare14440 rup nears flaw.. preen gplant lBegmeltun ). P.D,..mon l.Aul 3. Is rals.nurage lank located Al a natural gas amgplant Megublmnz enlan hydrocarbon 4. Does,Als Lorne tank contain Does thls gauze tankPbm�plle.g noringnon-nablked 11qulds) emissions laegulatlen apart 0.senlon n4.xll 6. Are uncontrolled actual emleelons or this storaee tank equal to orareater then x Ions er year vac lkealahon), Part 0,3enlon 0.34001 Parc,Seedon ...on Procedures Pa, SettIon Contra! flegulrefnetas Par, Section LE—Nlonitarint Part 13, Section I.F —PecordkeepIng and ReportInt Val< I% Sectbn end la —Genesal Requirements for Air Pollution Control E4LII4rtient —Prevention of lea..4e Colorado... Pan°5e.. 2. Is this.storage tank` located al in oll and gas exploration productIon Doesthis storage lank have fixed utron',Parlt D.Sealen ikAx0lt Ho .w p union facllnv.4.44 43s aomnrestoraleloner natural 34spoEusIne plant'I6eeulatlon 7. Pan O. Section II., fool IReau 4. Are uncontrolled actun emieaons of We storage tank equal to m grater than 1 tons peryearVOC laeeulatbn).Par1 °,5enlon ll.e.i,�l) seetton —mineral No... 1,441r Pollution ContFol Equipment and Prevention of cmisslans reellen Y�mr,+3w'�1 project sum., sheet n. m.Indicated .nlo. the.41MM, on m. project oho project Noram) nN 4not subjeato Begna°on ',Part o, semen 1.G.rouh.veIndicated foal, type onproject summary sheet. u have Indicated facility type n propctsummaryeheet. Coto the i Sown bmbjed to parts of 6egulmim1,paa0.5eetlona ll.B&C.Go Who ne+I question Noe,,.='I ureanaggaa to all pmWslomalP.eplalon).Pan°,5mlon II, Subsection+eo IL4raa rag pant annruned an°rer May; 2020 or...41afaalnyd. wa modawd4n Drafter may 1.x0)4. S. mart ion i st aced mnee•Inureugnputognpreorbon q orerodooewaterlkegomionx.wrtD.sawnllc4.a.11n x caw+ non,ornaw n1,44, rmpng40,044 071 Ilg aenera0umel aterIPeuorboman anairymatwesm°a nee on4raaerxanmry ;xi tnuet tro tae g a+=oplsru .vean.m aortas plaeu rat roul7'vu141 nvarwreon qugsoeroeumewmerlue,mon)Pan 0.3e,Non114.44.001 xa met ers lml(^9x6611 I40440.60.11014417x. Does he sorage vesameeRbe followingexemption x In 64.x3b1O41x 3. Was tmsaorage vessel mnnruned, recnmtmcted,or meelilmtoe aellnitlona 40 C1p,60.1; alter lulyu,xze<14n RB 64116610/ 6. 00• vesselwpsi and without emissbns la me atmosphere 160.x10nIe11xNl:or Lille design opacity Is greater than or equal 14151 rn. Ball and stores a liquid wnha maximum hue vapor pressure' less man B.Skpa 160.1xmRlll;or . Does the slor4ge tank meet either one of the following esemplIons from trol l m-4,950 B611nand store.mgmewnh a maximum nuenpor pressure treater than or equal to 3skpa but Im Illan see Vat or m..� equal. Bailout kse than 151nrl4050 BBlj and nowaa 4.4,h•muilmumnuemwrprm•regreaterthanofequamx5°kPa oaks. unn x)6.1 o` b. deal, rap.aWl,aenerman or�na 40Gm. Part 60, Suborn 0000/0000.. Sean.. of Peforman=eforrmJa Monti Natural GasPmwnlan, )mmmissmnandinsmmtla, olwblente Regulaton).Pan o, Senbn II.C.4 x. Was Ms storage vesel constructed. reconstructed, or modlilealseeaennuent 40 CR 60.xlbnween Augusu.1011 and sptember 1610x5) No......Storage iank b plat mgect nsP50000-Go to the nut wealon to manndeter...n°r NP5400°a applka,011, 6. is the slorate ,es.vel 44, ect te.4.0 tentrelled In acoutlanCe.n re uhreinents for storage vessels In 40 CM Pan 40Subpan kla or 40 C1I1Pan 61 Sub an MO (Note pa stune•Venal Isprevbu+h an•rmined te be subject to 113450000/00004 Jun to= Wens above 6 mm per year VOe on m. appOobOltya.Iermmauon dale,kNo.b remain subject to N5P5004o/o00oa par 6u.5335p11x1/t0.1265alellxl even rc potamlal VOLemksbns drop below Storm p.rr•a•1 40 M.44,14, subpart IMACTI41, and Gas Nerfuctlan ue nk rl at on oll and natural eas. production i Mlle +. nI•enry maepme.4,44 .deser4t atbvdmcarbon uwld+�I614601allbht0efamwmg . A Win,. process...upgrades armored natural gat pn4r to the point in which natural gat emem the natural as transmisrmn end storage source alemryarb delivered to a final end aural65.)6aalt3N) 2. is.e tank located at a 14411, Mal Is majer'forllApsl 3. Doesite lank menthe dellnillon orstorage vessel' In 43.7611 S. ¢mot...46 ea to control q menu under 40 Rk Part 60.w60.5u6pArz gem pn00D01 =comma •you nave Indicated De source alma, on Me Project summary .. Sgbwn A, General pr°vl+lens per463.)6401,.ex 463.714..6ecerdNee114e 443,5.110044 MET RevIew NACINNIn4/1•444044I X empire.. dee+net eppiveND lithe tank le In too nomalmimun1 moo, llthetank meets both after., IFBn mvlow w.R weultemene. Disclaimer This clocumenl as.. ebu�ydaneln requremeae ortne Lben NrAcB in Implemenalplwulallons, anapvouariy Cont. Cmmieskn ogulalbrn. Thisdwr ow',isnot •aebarepulapon, aral�eanalyst catralnsmaynal appytoemar silnurn havw5upc•r tneimivwwlladserdcYcumsmr,c®.r.darn,,.'xeanot change orsuestauYro-eryNw.saywatio�r. nYoMc &gely binding repuiremenlandunol�aly Worn.../n lM1n eventornyconfie beereen I language& isdeurnedend pre NnpuageblM1a Lkm Ai Act. ib impbmerto,armwalims. ass Oueliy cmbol CormusvienMi.,ebylen ahnua.•antl'un.'isinmus-+rte descnbeAPCO iniaprefelions ancl'ammal: .. e dbry bmm'wYsucWm.,' maim., terns Ioeafo,bsconboNpaa0,®aim undo Melvrr.,fhe...^.claN.Ae Dishy cet.camissa'mg. re,13, his damn. des retestae&snlemyland+rermu:ene,trinsrciary.. StorageTanY not subIee114ACT IIII-lhere are Ho MAC,. requirements tor Unks al area sources COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name PDC Energy, Inc. 123 A0E0 Golden Eagle HZ History File Edit Date '1 Pt 1f"LG+4 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) PM2.5 POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 H2S SO2 N Ox VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL Previous Permitted Facility total 0.4 0.0 0.4 0.0 0.0 0.0 0.0 0.0 92.2 87.5 143.3 143.0 0.2 0.2 179.6 175.7 9.4 9.4 0.4 0.0 0.4 0.0 0.0 0.0 0.0 0.0 20.7 16.0 22.7 22.4 0.2 0.2 29.4 25.4 2.1 2.1 1100(1 1101 €001,04041 In P'oror 001 m,',14,1(,a.110 pft€,, bus €010; 0 002 31 40 11.09 O1 003 $=400(bbl etidensate storage tanks'', 4 Produced_water)Starage tankeeO4. NG=Engine NO:Engme4.. NG`Engine Loadout" s' 1e heaters Fugitives iivde4O,O aO6OO 8...100,4 d "4.00.0 00 0,0 0:0 1,44147 7 14.„ 00 o 4'. -4 00 0.0 #a Covered under'point002!(20WE0503)4,' Cavared.undergagint003.(20VVE0504)t.°• CovEr`ed underpomt006(6P02). Gozeted under point007 (6P02,4 Ce9eredundenpo1nt0084(GP02) 44 Covered undernoirit.00'4`.(20WE0505).", , Insignifrca nt Source. InsignificantSource . (V'Uv! :11,4;'(;4: 01 U_S ti b_0 a1ew 1004,00e (Stet 005;4 .>a9( 210011:.:€:000.0 20WEOStY Fn Ffa0gofnatural gas.vented from:one' (1};tWr phase"g"as tiuster`ducing 1 RU tloVVitYf�e . ,. , 1380 HP, SN€ Pd{FVI 0.11,10.41a.1 -1a.:.0 :,11 x`111."111, 1011 1110, a1N, 1' ✓ Y/041t81.1291111 .54.114101a1•11.€829 .,€.... i01.114.01, 181 €6"a", 1011: f9:YO.1114:1O1311:13 External Combustion Sources Fugitives 0.11 a-4 90,11 114 i (€ ?3 0)4,0 0.3 4.0 114 1.8 Neel SO ufs€11 Cangeliationrecel3ed 111121202b,0Elnissron beiov�rAPEN,t eporting thresholds 1,7i."04: 51111140, —11h011111. 1,1€4€,11114€ 41.4111411.014,01, 00! (4101.2 100.0 d0 0.a S7P)?t 4::1FO2 011 6444 a3 .(0).o i K.i91i ;514111'1'4.1 e. i. $4,qL` U"i XA XA FACILITY TOTAL 0.4 2.1 0.4 2.1 0.0 0.0 5.6 133.1 0.1 1,574.9 0.3 0.3 4.7 241.8 0.0 0.0 39.6 0.4 2.1 0.4 2.1 0.0 0.0 5.6 22.3 0.1 37.0 0.3 0.3 4.7 45.7 0.0 0.0 3.9 Insignificant Source Insignificant Source VOL: 0,00 'eMlYmr (k•atit,d. iV FEV l�iiC IRYYT,A Lbi'' 11(1x: Syn Minor 1k141€1010 0a97ci (:kBly Syn MOO)O1OO11 11A#''4.a: Syn Minn O-1.4ex A Total 1111: A ,9>t,r .ce 1r1,14).caa 4O)))))744€ AeZZ..' Area w),-::ar;:rr.e: Permitted Facility Total (A) Change in Permitted Emissions 1.6 1.6 0.0 0.0 127.5 1,574.8 0.0 237.1 39.6 1.6 1.6 1.6 1.6 0.0 0.0 0.0 0.0 16.7 0.7 36.9 14.5 0.0 -0.2 41.0 15.6 3.9 Excludes units exempt from permits/APENs *iti'iF.} 11UR Note 1 Total VOC Facility Emissions (point and fugitive (0) Change in Total Permitted VOC emissions (point and fugi ive) 37.3 14.3 OO01 40. 00y (111.44 0. Note 2 Pagel of 2 Printed 1/11/2021 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACRITY EMISSION SUMMARY- HARe Company Name PDC Energy, Inc. County AIRS ID 123 Plant AIRS ID APED Facility Name Golden Eagle H2 fissions - uncontrolled Ilbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL Spy) Previous FACILITY TOTAL 0 0 0 0 0 0 D 0 0 0 0 D 0.0 0.400 bbl Condensate storag.t8nks ! I 0 0 0 0 reduced water sto age tanks NG Engine 0 0 )+7G G _ NG Emile 0.0 Loaddotilt G 0:0 asheaters o.0 EDltives . 0.0 002 20WE0503 Six (6)400 bbl fixed roof condensate storage vessels 6950 5098 325 1514 40227 Iii 30.1 003 20WE0504 Two (2) 400 bbl fixed roof produced water storage vessels 361 234 i.. 3.8 216 0.4 004 20WE0505 Hydrocarbon Lir uuld Loadout 313 2716 15 005 20WE0506 CN Flar ng of natural gas vented from one (I) two-phase gas bueter during m lrwo-,�i,�,r: 006 GP02 SI RICE Caterpillar G3516, 4SLE, 1380 HP, SN: NBW01381 10127.5 819.3 503.7 43.1 245 5.9 007 GP02 SI RICE PSI 21.9L, 4SRB, 581 HP, SN: EZYOF802980 1101.6 149.9 141 3 84.9 164.4 0.8 008 GP02 SI RICE PSI 21.9L, 4SRB, 581 HP, SN: EZYOF803153 1101.6 149.9 141 3 84.9 164,4 0.8 XA External Combustion Sources 0.0 XA Fugitives 12 12 12 12 14 0.0 TOTAL Jtpy) 6.2 0.6 0.4 3.9 2.7 0.2 0.8 24.6 0.3 0.1 0.0 0.0 39.6 Natal Reportable= all HAPs where uncontrolled emissions > de minimus values Red Text uncontrolled emissions s de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein 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 :GP IC a. 8-400 bbl Condensate storages 0;0 `4, W Produced water srorage_tanxs 0.0 NG EngineC.0 NGEia-e 0.0 NG E_LigI e 00 Loedout 0.0 16 heaters 0:0 Fugitives _. .. 0:0 002 20WE0503 Six (6) 400 bbl fixed roof condensate storage vessels 70 51 3 15 462 0.3 003 20WE0504 Two (2) 400 bbl fixed roof produced water storage vessels 18 12 1 2 i'I 0.0 004 20WE0505 Hydrocarbon Liquid Ld t 16 136 01 �Yt0. ru"ST�`�� 051Q �yv7M1vao FlaTmgoJllatur i'g wanted fr4th'o g}� sef r1 1 � ti" . uh4as��r.'v4•itA. .. m ✓ pt0a '� w "5 ` es -°+s a .. .S�';,+„i.�Oi"s. 4 Fk T '< v��'xt.fri 0sa "1%'4 s�.++-.t1�A".;:.s''d≥r,`,n,....� .tn�*s�.""r^. rs. rk .�`10'�"�i."g;3"a :.E 006 GP02 SI RICE Caterpillar G3516, 4SLB, 1380 HP, SN: N6W01381 2025.5 819.3 503.7 43.1 - 245 1.8 007 GP02 SI RICE PSI 21.9L, 4SRB, 581 HP, SN: EZYOF802980 1101.6 149.9 141.3 84:.9 164.4 0.8 008 GP02 SI RICE PSI 21.9L, 4SRB, 581 HP, SN: EZYOF803153 1101.6. 149,9 141.3 84:9 104.4 0.8 XA External Combustion Sources 0.0 XA Fugitives 12 12 'i2 12 14 0.0 TOTAL 2.1 0.6 0.4 0.2 0.0 0.0 0.0 0.3 0.3 0.0 0.0 0.0 3.9 itpy) 2 123A0E0 1/11/2021 COLORADO Air Pollution Control Division C1exartmeni Cf PublyL Fieitith G Envircwrie-,1 Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0504 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Golden Eagle HZ 123/A0E0 NENE SEC 6 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-2 003 Two (2) 400 barrel fixed roof produced water storage vessels connected via liquid manifold. Enclosed Combustor(s) 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/cdphelair-permit-self-certification. (Regulation Number 3, Part 6, 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 Page 1 of 10 COLORADO Air Pollution Control Division Deza,uner.d a' Pubic Health b nvirctime°n Dedicated to protecting and improving the health and environment of the people of Colorado application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (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 I I .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TK-2 003 --- _0.3 0.5 0.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 ID Point Control Device Controlled Page 2 of 10 COLORADO Mr Pollution Control Division Devarcrrne+ i c6 PuGIK Health 6 nvirtrvnr. n Dedicated to protecting and improving the health and environment of the people of Colorado TK-2 003 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 available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4. ) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-2 003 produced Water Throughput 750,720 barrels 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.24; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or Page 3 of 10 COLORADO Air Pollution Controt Division rtni qt ' Pubk Health b Eiwircrdne-g Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 £t MAINTENANCE REQUIREMENTS 16. Upon startupof this point, the owner or operator must follow the most recent operating and maintenance (OItM) 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. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Permit Number Existing Emission Point New Emission Point Page 4 of 10 COLORADO Air Pollution Control Division Depa tmelt U` Putik Health b Gnvitl:flrne:-A Dedicated to protecting.and improving the health and environment of the people of Colorado GP10 123/A0E0/001 123/AOEO/003 20. 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. 21. 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, Section VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions - tons per year Equipment AIRS Equipment Pollutant Current ID Point Description Threshold Permit Limit Page 5 of 10 COLORADO Air Pollution Control Division Dothan neat SY P rG₹r_ Ffeath [r EnvUc:fimes,7 Dedicated to protecting and improving the health and environment of the people of Colorado TK-1 002 Condensate Storage Vessels NOx VOC 50 50 22.3 37.0 TK-2 003 Produced Water Storage Vessels LOAD -1 004 Hydrocarbon Loadout ENG-1 006 SI RICE GEN-1 007 SI RICE GEN-2 008 SI RICE -' -- Insignificant Sources Note: APEN and permit exempt 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 22. 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. 23. 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. 24. 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. 25. 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. Page 6 of 10 COLORADO Air Pollution Control Division De.ran;nent a Public He9ltri b Envtrerune.); Dedicated to protecting and improving the health and environment of the people of Colorado 26. 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. 27. 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. 28. 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 produced water storage vessels at an oil and gas well production facility. Page 7 of 10 COLORADO Air Pollution Control Division 1 Depaarnerd ee Putylk: Ffeslth b cnoircrvne-� 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/agcc-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 Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) , 003 Benzene 71432 361 18 Toluene 108883 234 12 Ethylbenzene 100414 12 1 Xylenes 1330207 38 2 n -Hexane 110543 216 11 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 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 6.87x10-4 6.87x10-4 TNRCC CO 1.37x10-3 1.37x10-3 VOC 2.498x10-2 1.249x103 Flash Liberation Analysis and EPA Tanks 4.09d 71432 Benzene 4.805x104 2.402x10-5 Page 8 of 10 COLORADO Air Pollution Control Division Ck;.aftrttefd of PutitaG Health h Env11'01 1e -A Dedicated to protecting and improving the health and environment of the people of Colorado Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific emission factors for this source were developed using flash liberation analysis and EPA Tanks 4.09d. The flash liberation analysis is based on a pressurized produced water sample was obtained from the outlet of the three-phase separator for the Golden Eagle 7N -1C -M well on March 26, 2020. The sample temperature and pressure are 107°F and 216 psig respectively. The sample was flashed to ambient conditions of 12.2 psia and 72°F. The weight % values, molecular weight (25.4513 lb/lbmol) and gas -to -water ratio (2.2 scf/bbl) established through the flash liberation analysis are used in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) to calculate the flash portion of the emission factors. The working and breathing portion of the emission factors were developed using EPA Tanks 4.09d. The simulation uses Denver for the location basis and a mixture of 95% water and 5% gasoline (RVP 10) for the liquid basis. The simulation assumes 1/2 of the total throughput flows through each of the storage vessels. 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 4.523 scf/bbl and heat content of 1,100.8265 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total produced water throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane Et Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et NOx 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.Rov/ 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 'COLORADO Air Pollution Control Division C>rsaarnern of PubIK Health b .nwrcorne n 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 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: For Division Use Only Harrison Slaughter 430822 5/4/2020 10/26/2020 Section OS - Facility Information Company Name: -PDC Energy, Inc. County AIRS ID: 123 Plant AIRS ID: A0E0 Facility Name: -:Golden Eagle HZ. Physical Address/Location: County: Type of Facility: :Exploration & Production Well Pad _ What industry segment:0il-&Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Ozone (NOx &VOC) NENE quddrant of Section 6, Township 6N, fiance 66W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NENE 6 6N — 66 Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance # Self Cert Required? Action Engineering Remarks 003 Storage Tank TK-2 Yes 20WE0504 1 Yes Permit Initial Issuance Section 03 - Description of Project PDC Energy, Inc. (PDC) submitted a permit application requesting permit coverage for several new sources at a well production facility located in the ozone non - attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon liquid loadout, separator venting, and engines. The engines are requesting GP02 coverage. This analysis only evaluates the produced water storage vessels. 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 IC6.2:a.). It should be noted that issuance of this permit serves to cancel the GP10 coverage for this source. Public comment is required because new synthetic minor limits are being established with this application.. 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 -Witte 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: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 000000 Title V Operating Permits (OP) ❑ 2000 DOE Non -Attainment New Source Review (NANSR) 0 0 Is this stationary source a major source? No--. . If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) 000000 Title v Operating Permits (OP) DODO ❑ DEO Non -Attainment New Source Review (NANSR) ❑ ❑ - ,Enrage Tank/s) =rnin;ion_ Inver/tor'y mmlonm Equipment Description Details Storage Tank Liquid Detailed EmissionslInit Emission Control Device Oescriptlom Requested Ovemli wC& HAP Control Elf,. Limited Process Parameter Primary Ernissiens Actual Throughput. -St orage i nldsl eq ted Permit Limit Thoughput= GI Barrels Oabl) per year psi q,.,x ws�a`S`..'ar:50,T�q�Barreslbbl rerYear Requested Monthly Throughput= Barrels 10I) per month Potential to Emit (PTE) Condensate Throughput= Secondary Emissions Combustion Devira(a) Heat content of waste gas. Volume of waste gas emitted per L of liquidsproducetl= Actual beat content of waste gas routed to combustion device. Requested heat content of waste gas routed to combustion device = Potentlalm Deft (PTE) heat content of waste gas routed to combustion device= '$Qil9pQBartelz h6l)peryear ,g, Btu/scf sc(/bbl MINETU per year MINH. oar year .G-3 MMa. Per year flash Emissions Thmughout Goa/GL Ib/Ib earl bm/bial .prom bplm.ment Equation Ex=4aEAW`gg/C amnr(lb/hbl) (lb ear) eMa 7,1 50 50 cYcleoentane eth 4-TMP DOS moo lbenzene yle 0.0 g60 0.00000 VOC Working& Breathing: EPA Tonics Throughput. _>_,:._..< bbl/year Pollutant 900 -Ohs/year) Emission Factor ll AO) Benzene GVIZEGI.5 Toluene - -- Ethvlbenzene - Gyiene Will this st a nkemlt flash emissions, Produced Water, Uncontrelled (ro/hbl) Pollutant Oantrolled (Ib/bbp (Produced Water Throughput) (Produced WaterTbrooghpm) Emission Factor Source VoC Pollutant Uncontrolled Uncontrolled Piniimetu) - _ IIb/bbp (waste beat combust.) (Produced Throughput) Pollutant Pilot Laht Emissions Uncontrolled Uncontrolled (m/M ns,GI Ilb/MMsinl IPliot Gas Hem Combust.) IP Gas rnroughput) .$0mbn n5-EmEssm Criteria Pmlumnrs o Emit ncontrolled Unconvolled Actual Emissions Uncontrolled Itom/WaaConvened l Requested Pon. Urn. u Controlled lr nsmGo (toss/m/1 Request.Monthly Limits. Controlled (lbs/mont ) CO - 0.00 a .... 0, 0, 67.46 Hazardous Air Pollutants Potential to Emlt u llbs/vearld A Actual Emissions trolledControlled ulln/year) Ohs/year) Requested Permit Limits u trolled rolled (ibs/year) Ilbs/yearl Etbylbenzene n.li334TeeM1P of4 C:\Dsers\hslaught\Desktop\133ACE0\20WE0504.CF1 Storage Tarp*) En11591OITO Inventory s,ktird.Pt6-R.Matow 9ummew,S. Regd..3, Pan 0. B Part O,Secden 0...Y Regulation 7, Part OSLG. ecdon l.G,e Regulator 7. Part scdonll.C..2 c3 Regulator 7. Part RagWatIon T. Part O.Sedonul.C..a.(R) Regulator Regulation 6, Part A, NSPS Sulanart0000 NSPS Subpart 0000a Reguation 0, Part E, MACT.bpart HH (sea Iregulnary applicability works..[ fur detaibd analysis) <yim Stud. IP .r it en. w__ _ •_ Pesuld ien P. P.. h. section Section 02 -Inds] end pedeak SiMPI.g and Ten.reReoubamarm svbleet to MAT For condensate ore n m estimate i lives. are Me unoantrolled actual or requested emissions fora crude dl tank estimated to be greater than or to 20 tors VOC per yeanOR are theuncontrolled actual or equened een.om fora equal toga Hy, If yes, the permit contain ontain anestimated nitiall.mplianee" resting requirement to develop a sire specific...tins factor based on guidelines in PS Memo 1443. goes the company use a site specific emission: fader toast.. emissiom2 Ryes and dthere are gash ern... are Me...ossfactors based on a pressurized liquid ample drawn at ...Hy being perrnI.d(for produced water tan.. a analyzed gashliberadon analysis).. sample Mould...Id.. represent. which generally means site -sped. and collected within one olr h of[a application received date. However, if the fedi. has not been modified led, no new wells brought on -and, Men It may be appropriate to use an older site -speedo sample. If no, Ma...will contain aelddal mmplianceT.t rag requirement to develop a site specific emissions facto- based on guidelines.. Memo 14,03. .es the company request a wntro( device ed.., greater Nan 95% for a flare or combustion dada. yes, tho permit willentian initial and periodic compliance testing In etadance with PS Memo 20.02 sactien00 Terhelat AnaHsis Notes h.Raw...APEN, PReen(16). waifspr*tothls HO. Please reference Mod,. sohmi..WOO/ for eVs( prthe well met and numbers. According cod.. data, tlm wells at adds were fractured between Sep.mber and. "November 2019 and began production ladweetlanuary and February 2020, Pleven of th..4s. .s fsclltyprduce from the Niobrara maton'Three wels.ths facility pr.uce from the CarlidaSode.Port Hays form tons 902 well cretin radii, 'Coaellded Hays formations. The sample used stabsh ..ash pat). of Me emrselonfactorsw 0bafmd from Moout. of [...me -phase separator for to Golden on March rwithin one of the applications...on. Addeo'sM,w le was obtain. alter al the wells..fd ad. began production and no new w added to the lad. side Me sample obtained. As a result. the sample Is beta. fdorbs-H.0 rag the gash portion of the ern.. factors and. the pumrt will not contain HMI sampl r8, d.t.. -Mn Pohl .pi 1,1 rasa./wan oil storms. yes., .In ogf, mde.elop w 0ahyordnofthaemission factors, the ...tar eflash llbea.n analysts mile ample.... from the Gowan Eagle xN-1C. well (sampled 03/2x/20206 The amp. was flaw from wee -phase sePeratnr Reid ondNbns 01x16 pdga.1,Ftosroragavedel ambient conditions a 122 pda and 727.lheweigta%.)saes, molecular .0dt ..dmwater redo establiMed through defe.l.ration analysts ararasa.cm).cWn dMdre EPA P.stlgn imentay lmwwemencProgram PubEamn:Ydume O, Chapter lO • Olspixament Egad.(10.4-3)....eNe nosh pardon of Me ern.on factah.Thweosialaticos are avalklde.have MS.Pon 0o-. . Emissions hem toa. vessels glade 0ash.4..5 in addition towaMngad baa.ng em.ons. Asa result, the opera.- was required tool... tit waking and ...Mg embv-ots e.g.. with nee garage vesab and SWda.Spool. of ms in Me total ern.ron radar. Thwcperata..dlshed the waking a.lnawng emission factors... EPA Tams 4.a9d The WATa. AmManm used Denver nth¢ load. basis ad amMture of 95%water and STSgasdfne OP.10)fortne liquid bads. Wie water component in de mic.awageded by the operator in the EPA T.cs aemiml oeahaae.Th weer comported was speared using a.pa and liquid ma.Mw ar weigh of MAW. ad following Ar... Cmednf. EPA= T], BB Se 1730.6 end (RUC= 233.43.11. gasoline RVP 10 component Is default [Fleming In w dmdatim database. T Issow Patin imMe hitidt...0quld.tit waterwas tlxtenmiiwd robe meervative herane t.s.de ell ample included fn the ba..tlm'hews asst..,il/Softr tornp.enispciradma for Mrouge d el pa beaus Mevelmsused aweafy the mmpren[nth <hemla matcfiwiNmmmon valuesllnedk dantlb0oks The opera aswmedMa[3/LPfthe twat pdd tM1rmghpttt psss tM1ra+gheadiswego vessel tlur rag coma operatln d.&n.neIPthe only HAP WOeldhsto. above APPH rapPoIng thre.olds(Pe, SSOldSer)„..a result It is Me only HAP. for which an emafdi actngiincluded n tnepermt 5.Tie NOS fOY ws worm wn Wedded ara5/04/2020,.a result, an updated NOS fs not required n: part or tha seirdertlf.don requirements ',the Perm. 6.T. condense. storage trees. ad produced water ...vessels decmu'Ned ',Me same fo. enclosed combustors. As aresult ons lie. N. and CO) fran m. togerhr Plod. to determine APEN apl.tglity.fet. tone. totalNOxad CO emissions (remelt Mesowes are above APEN reeaOng[Frnhltlz Asareuhrthe permit for ach Mat vnll con rt eem.lcup Hefts and ionic). Havre for N. a. CO. 2.Ance the condew aefe and doe.. wa veae. are co.olied',com control dada aRete higher ed. by an idMtl permit,. this.... estorage vessels are tit mem. emiro"ng.H.. Asa teat, pllatld. emissions Gree�nted for wg. No- N.H. f. the condensate Storage lensed (SeamOSWPOS0S.d1 PA. pilaNN mloaWdmsl:... g Initial and pddlc oaa observatia5 are addressed by Me OISM dart As a re.t.tle pemat.. cwt.mart rnmala Peddfcgpatltt.sdng 9 -typically. the stand, combustion eaMalare are calculated using data directly from Me naargacllberatbnanaanlsand PA Tards model. The .owing data from the naM liberation znztysband EPA Tanis are typically used in....Idiom: (i) wF: 2.2 scfAb6111) Neat Conte.1t0a 65HSW&B Heat content: la. B.,(standard value fordo.. water), and(W &B6..H.I6/Ibmd. Using Misdate, Me annual heat Input is rypiallyaaculatea as follows: Hatnput fMMBtu/d)=US25,60abbl/y.H(22uf/bbj1(t.6000 of/MMsc0•111dRB2. MMBtu)MMsfll 11000)55216/hhl)•(eLs,fi0o HWYearWl.W/bmojy3. so. H.(14Se eu.1)/(1.000,000 Bto/MMBW)le 1,519.M5./year. Wing this vaue,the edge Nth.ne co emission: wood be cacuaad. at 0.1 tp end 0.23 ipa rtspdmrery, Tito operator used [...wing .aamla. t. annual heat Pot Neat Input '(MMBiu/yd)• fUnconHolled voC routed tocombuetor(totHyrj71200o lb/tool/NW Iro(Ib nW1113T9a1 Yr/Ibmol]' fl/VOC too dITIHat.nterrc' (Btu/ScHH1MMBIW1,000.000 B.1. The op ...zed the values w molecular wegh4 VOL coal%ad nthe equation sample Included e value utttlnt. equation areas Wow (IT MdeculaarteweigM 250131b/Ihmol, SO 2333%, pt)Nea Cmtet.11 0u./zcf. uurigi meunues, tMaoaramracuaay dcheer,r putufz3115 MMBtuh Smadds sea conservative than the vat...gated above m3%described methods, )twill be used la}+ermhdng y grt 10. The operator was p.m. with adraft permit and pax redline to ...prior top. hgc..amment . operator r.lawed both down.. zed w.f.. they has momments. sanwna scc Coding anEmissions Factors War Inventory via Dnhl AIRS Polntg lin enrolled .Hsiom OLP% b/1000 gallons Prducd Water tlu.ghpm PM. OOP 0 b/1,a00 gallons Produced Water throughput b/1,000 gallons Produced Wa.rworighput NOtt OW 6/1.000 gallon Produced Water ...hod WON gallons Prod.. Water throughput 6/1000 gallons Produced Water throughput b/1000 gallons Pr... Water throughput Toluene b/1,000 gallons Produced Water throughput EMylbentane b/1.000 gallons Produced Water throughput b/1,000 gallons Prdwed Water throughput b/1000 gallons Prmuced water throughput 224 POP 0POP Hi, 55 6/1000 gallons Prducd Water...hod 3 ofd C\UarsthslaughtWesbtop\123AOEOWMNS0504.IP1 Storage Tank xegulamry Analysis Worksheet The regulatory requirements below ore detemhined hosed an requested emissions. ArrAINNINT 1. Are uncontrolled actual emhslons from any coke,. pollutants, rom this Individual source grraterthan7TPV MegulatIon1PartMection 3. Prexn,fa.lty Uncontrolled VOL enossmnrooter Nan S.e,Nener,ertha 3oia or CO emissions geatenhanoTPe(Regulation 3.Part e.mmhn 0.0317 NON-ATTAINMEH[,..r 3. seuncootekad embsionsfmm aoyorltaola pollutants from nix maNklual source greaterthan 1Tp(PeplatIon3.PartA.sect161,11.yi 3. Pretomyac,hv uncontrolled Vue ammbnc neater than 2TP,, noxereater limn 57PY or CO=Wiens Createrthan 3orzY(wuulatlon 3. Part ',motion 11.0.217 Colorado mulagon 7. Part O. Sonion',C..O 1. Is MN storage na. located In the 3, atone control area or any ozone non.attalnment area or attainment/maintenance area (3egniation',Pan o, section(.X317 1. Is thisstora6a tank located at oil and gas oparatIons 3. Nth...rage took tank that O, section G), q rp produced water AND that are located at or upstream of a naturals p earbgplant lkpulatlon 7, Part D, Section l.ntl7 4. Dont. storage tacona con located at a plant Nteabn7.Part I. tlenute7 5. Doe.. storage tank exhibit 'NO'le.e.aonng non-mbilized fnutdslnnlstrans(Peculation ',part D,Sectlon tG.317 3. See uncontrolled actual ombaon .this storage tank equalto or greater than x tons er year VOCIRe ulmmn7,PartD.eauon1.03akh17 Fart 0,Senloni.Gl —General Flopulrementslor err Pollution controlEqulpment—Prevention of Leakage part ',section 1.0 —Emissions Control liegotrookents Part D.sectIonL6—monitoring Part D. Sootton Emlubos Control Requirements Part 0.5ectfon ant( la —General Require,. forAirpollalon control 6NLIIpMent —Prevent.) cl,oaka[o on g 1. Is Os storage 1. located at a sslon/storaeraakty7 3. Is ark storage tank looted at an awl em exploration and product, n operation, well protloolonfxlmy. natural gas conlpfassor station or natural gas processing plant° Inegulamn 7.Patt O. Mnlnn 11,2 a. Argun manual emisannsof this storage tank equal to or greater than 3 tons per year VOC(Regulation 7.PartO.sectlon ll.C.l.cl] Yes .IOW ti�' s Source RoquIres. an AP6N—Coo to the nextquestion Got° not question sour= Require" 'monk Continue •Vou have Mt.. Ole slteanainment status on,. project summary sheet. tooth,. •Vou have g',ruled summary., e Storage YanN6 noteublatto Regulation J. D.Scollon I.G- Vou have...1(.11[v.... Moot ...O h... t•y on the Project summary sheet.oa tothena have lndlaated.0n/type on project summary sheet. Gala the next question ...venh Lublin.Parts, Reguhtion',Pan 0.5ecnonS110.C. Go to the natqumtmn fool, 54murca is subject tog pnMsbns of Regulation l.Part D, smlan II, suhxmmns6 s e tee won Air Pollution Control Pgulprnent lo the controlled located antral gar compressorstatIon.or natural gssprocessing p{aot constructed ono, altar May1.. 2020 oe located at a facility that wao mooliflatl on or attar may1.2020. mho controlled storage tank locanunaval gm compressor statloruor natural ea pr0000.og plant constructed on or atterlanuarvl.rat or boas. at aleHbOh warmnaamd on oralmrlan 40 CM Part 60, Sanaa Kb, Standards of oorlormoota• ge...,, 1. Is the ...hal rtorage vessel ow,. greater than or equal 1. Does ,Mall,, me 75 cubic ters 1,77 Bets]ND FR6D.11ubkll7 a. Does. vessel ryas a design cape. less than or m'i-1 MBym oa,Pmassea,ortraea pnmmcvaoayttanster meenneam 60.11.7 a. Was this storage vossel constructed, m nevulxeaninumns w CFP.60.11 afterluy133,pssellao 0115o11ob(all7no DoestAetankrnage Deathe storage ...store evolaIlle ee rganlclqullOVOy,° as clan. In 50.11167 followIng 5.a. Mho storage um. a prasure Da.tbestorace wad meat any one of Ne del designed to open excess 0204.pwa["3R.7 pal onawaluutemmionstatho atmwpnece 15o.noyanIM or Lo The.. capacity la treater.. r equalto151rti 1-sw Bey and Hares a( yule with a maM1 amtm. vapor pressure' lam than .160.11.0”, c. Ale des. opacity is grooterthan or equal to 75 M'1 -a77 gay but less than 7slm°1'350 gay and stores a Gourd oath a maximum rue raprpremuree loss than LSD kpa(60.sob(bll7 Nom control >. Does. o a. The doot6o opacity ',eater than or equal to m',5e5o BBL, and soma) 1pun n b. The tlmlon opadtv13 ereatethan or equal to 75 M' 1-.77 gay but less than 75150' (^s50 Bey and stores apIfouliaw promote e malmummtNue vapor pressure greats 3.5 kPa ha man or equal m 15.0 Oa but loss than 0..5 FP, NV'VI Storage Took No. subject nsv53b-The storage vessel opacity is below the applicable threshold. NA oD C1H.Fart 50,suboait 0000/0000. StanamsolPedormantern7Cn. Oil and Hasoraj Gas Pmdunlon, mnammlon andu6irltono, I. Is Nib stomp vessel located al a Ia.,. In the onshore oll m natural � eoalinnbns IO cfn, caxl bmwmngnensrtvzuuane Seepnmber 0.eptransmission ad storage xemem of the inewtn] 2. WatM1.sr.orace vessel contrurod.reconshoded.or 3. Was.lsotorage vassal constructed, m (tesaanmwnr+BCFn,5a71 alterfinember1a3m57 4. Are potential IN36 omissions. hom the Intli.ual storage ocool [rooter anon qual to 6 tonsperyear. Doestbhgarageoeoael moot Ole definition of "storage vesssi,per66.5430/60.64300 6. lo the olorage vessel sub eot to and controlled In ocean:lance MO re Wromento for stor e vowels In 40CIP Part 60 Subpart Kb or 441CFP Part 63 Sub ad NN, Yes NA Note: kmry clotorobad to he toyed to MPS 0000/0000o due to nmmOwe e 6 tom peryearVOC an Oa applfobn0yaaermbatwn date. Itthwy ran...Med. MPS 0000/0000i per 50.535s144/5o,s35542) den a ootomklVac omissions drop lelow6 loos pervead 40 CE.A.Part ...Subpart MAU NN. Oil and Ga. Pmeluclion fatllity 1. qs Ne a. Ataalltvthat procooms.upg desoraoaosbydroononaqulan'fallowingtr+te+e. ds(53.76ga117)1.oe orrtores oral ga pdor to the pint at whkM1 natural gas enters One natural,ctransmisuon and storage xurce allegory or,saeirarzd toannatena uses (53.76ga1i3M the tank looted at a faalythai Is major' for 3. Noes the taok nue the dank.] of ,oragovesser.lo 63.7517 517 s. Is the tankbjm FH to control underaDCPart 50.w6prt 36 or subpart 00007 mSummary mm et . StorageTanklon.wni� w5pD000.Outosen q son to continueaearmmabna WSGDomaplkabliny. Go to the nod poestion StarageTa.n4 Ismmsubject ns500nDa_ Ieantmue-vau haremakaease xu,temegory. the PmlmtsumOnary shed. Subpart A. General provisionsper 963.76+y1]abiel 463 s6. Emiaions Control Stantlardo §53.773-ManitorOv ortlkeepint mns -Reporting RACTReHavi RAUma Is repo,. If isolation 7von not apalyAND ne tan. InNenan.aNaFment area. !Metal. moon both vkeaa,lhenreviaxMcrroqubameoe. Modairner xanniff oar.'aquksne, o7neelmn nkAc, 0.a impkmmhtiq rpheeWS will. .rdyeoraceome%.aior agrvktions.Tlu's document, ayois itomm wl mayor; apply to partku'm silwwn based pon Via lmNdualladse d Ckouanbram. This dooumont..noI change asubolauk for any lay, rpwation erarryaMc 1pnlN drore requirement and not bgnlyenlamnhis/n lee event Nanycannicg baittan./anguageof odccumdartllag Fmgrageddre Gen AYAolnainpMreo.p rprnagiao.. ere PN Quality Control Commission regulations. Inelahpungoa'Wale ltot n orregulation wal contd. Thew. rimareroondntbylowo?w ouch as'rzmhmm4—moy,,M...ana 'emr.'uintndadlo .x41200,1,0 interpretations am recommendations. MaMegwyIarNndnd , cgyauoh a.m.,' required,M.o.,'fadexvio ccnbogllag requiremon undericelame of McClean ANAct andN pualiycontrol Cammisim+regukgbhm,b t o aocumenttlws no, oatablun bpally binding requkvnent, arddinan grt.U±§b'. NAt;₹Ftrtt' 5terageTan.nm wblen Meer HH-Thereare no MACE NH Iequirememsfortanks at area source COLORADO Air Pollution Control Division Ck;5atnmeni G' Puble Health Er ar.iri;i rne-A Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0505 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Golden Eagle HZ 123/A0E0 NENE SEC 6 T6N R66W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD -1 004 Hydrocarbon liquid loadout from storage vessels to tank trucks using submerged fill. Enclosed Combustor(s) 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 Page 1 of 10 COLORADO Air Pollution Control Division C�nrnru PubN Health b trwrCnrne*at. 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 retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission T e Type pM2.5 NO, VOC CO LOAD -1 004 --- --- 4.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 5. 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. 6. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 10 COLORADO Air Pollution Control Division Cf.aaarneni as Putik Nesitl'r 6 Erwtri:nrne r1 Dedicated to protecting and improving the health and environment of the people of Colorado Equipment ID AIRS Point Control Device Pollutants Controlled LOAD -1 004 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4). Process/Consumption Limits Equipment 1D AIRS Point process Parameter Annual Limit LOAD -1 004 Hydrocarbon Liquid Loaded 752245 barrels , 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 twelvemonths' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal Page 3 of 10 COLORADO Air Potlution Control Division Deraartme fl e Rut' I-feakh 5 EnvvCrurle l Dedicated to protecting and improving the health and environment of the people of Colorado to 5,000 barrels per year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout threshold. 11. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 12. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 13. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 14. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. Page 4 of 10 COLORADO Air Pollution Control Division Dtvartrneni a Puble.: Health b Dr?vircorneli Dedicated to protecting and improving the health and environment of the people of Colorado • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 15. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 16. 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 formatThe 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 17. 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 your O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Page 5 of 10 COLORADO Air Pollution Control Division Dk-vanrrern d Put. Ffealrh 6 Emtr COP h; Dedicated to protecting and improving the health and environment of the people of Colorado Existing Permit Number Existing Emission Point New Emission Point GP10 123/A0E0/001 123/A0E0/004 21. 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 1O0 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. 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. 22. 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, Section 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: Page 6 of 10 COLORADO Air Pollution Control Division Devanment c Pufilr. Fiesltfi b tnvlrcrnrne:gi Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Equipment Description Pollutant Emissions - tons per year Threshold Current Permit Limit TK-1 002 Condensate Storage Vessels NOx VOC 50 50 22.3 37.0 TK-2 003 Produced Water Storage Vessels LOAD -1 004 Hydrocarbon Loadout ENG-1 006 SI RICE GEN-1'' 007 SI RICE GEN-2 008 SI RICE --- __ Insignificant Sources lote: APEN and permit exempt sources do not have permit limits. However. the PTE of t hese sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 23. 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. 24. 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. 25. 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, Page 7 of 10 COLORADO Air Pollution Control Division .,,afttnent G Pubk Health fa £nvircnmeA Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. 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. 27. 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. 28. 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. 29. 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 (ciiminal 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 hydrocarbon liquid loadout at an oil and gas well production facility. Page 8 of 10 COLORADO ,Air )Pollution Control Division Devinrrient Pubtr_ Health 6 znvecrahe a 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. N (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 313 16 n -Hexane 110543 2,716 136 5) The emission levels contained in this permit are based on the following emission factors: Point OO4: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors . lb/bbl Source VOC 2.36x10-' 1.18x10-2 CDPHE PS Memo 14-02 Benzene 71432 4.16x104 2.08x10-5 n -Hexane 110543 3.61x10-3 1.805x10-4 Page 9 of 10 COLORADO Air Pollution Control Division Departrnera ed rutdic Fieallh 6 Dnvironme•°a Dedicated to protecting and improving the health and environment of the people of Colorado Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-02 for condensate loadout. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid loadout throughput. 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane Et Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: V0C Et NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below:' http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Package #: Received Date: Review Start Date: Harrison Slaughter 430822 5/4/2020• 10/27/2020 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: 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) PDC Energy, Inc. 123 A0E0 Golden Eagle HZ NENE onad, , ;,,. Weld County Range 56JLI Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only AIRS Point # (Leave blank unless APCD has already assigned) Emissions Source Type Equipment Name Emissions Control? Permit # (Leave blank unless APCD has already assigned) Issuance # Self Cert Required? Action Engineering Remarks 004 Liquid Loading _ LOAD -1 Yes 20WE0505 1 Yes Permit Initial Issuance Quadrant Section Township Range NENE 6 6N 66 Section 03 - Description of Project PDC Energy, Inc. (PDC) submitted a permit application requesting permit coverage for several new sources at a well production facility located in the ozone non - attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon liquid loadout, separator venting, and engines. The engines are requesting GP02 coverage. This analysis only evaluates the hydrocarbon liquid loadout source. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy (CO AQCC Regulation 3; Part A, Section II.6.3.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 ILD.2.a.). It should be noted that issuance of this permit serves to cancel the GP10 coverage for this source. Public comment is required because new synthetic minor limits are being established with this application. 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: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) 00020 ❑ Title V Operating Permits (OP) ❑ ❑� ❑' ❑' ❑ 002 Non -Attainment New Source Review (NANSR) o o. 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) 00200 ❑ Title V Operating Permits (OP) DOOOD 000 Non -Attainment New Source Review (NANSR) ❑ ❑ Hydrocarbon Loadout Emissions Inventory Section 01 -Administrative Information "Facility AIRS ID: 123 County AOEO Plant 004 Point Section 02- Equipment Description Details Detailed Emissions Unit Hydrocarbon liqu dloadouf from storage vessel Description: Emission ControlDevice Enclosed Combustor(s):' Description: Is this loadout controlled? Requested Overall VOC & HAP Control Efficiency 56: Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = IRequested Permit Limit Throughput= Potential to. Emit (PTE) Volume Loaded = tank trucks using submerged fill 752,245. Barrels (hbl) per year Y,MIA Barrels (bbl) per year Requested Monthly Throughput= 63889 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas = X Actual Volume of waste gas emitted per year = Requested Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = sg3. Btu/scf 180Cas0 scf/year 71£x2.11 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device= 4,589.25 MMBTU per year 5,507.10 MMBTU per year 5,507.W MMBTU per year Control Device Number of combustors (i.e, pilot lights): Pilot Fuel Use Rate: Pilot Fuel Gas Heating Value: to/scf 0.14 MMscf/yr 155.2 MMBTU/yr Section 04 -Emissions Factors& Methodoloeles Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? efault emissions factors may be used to estimateemfss',ons. Emission Factors Hydrocarbon Loadout Emission Factor Source Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 2.36,E-01 1.18E-02 Condensate Loadout State E.F. Benzene 4.16E-04 2.080E-05 Condensate Loadout State E.F. Toluene 0.00E+00 0.00E+00 Ethylbenzene 0.00E+00 0.00E+DO Xylene 0.00E+00 0.00E+00 n -Hexane 3.61E-03 1.8D50EOd Condensate Loadout State E.F. 224 TMP 0.00E+00 OA0F+00 Control Device Pollutant Uncontrolled Uncontrolled Emission Factor Source (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 5 45E-05 AP -42 Tab1 ,M10/PM2S PM2.5 0.0075 5.45E-05 AP -42 Table Ml0/PM 2 5J SOx -0.0006 't*';'4 4.311 —16 AP -42 Table- TNRCC Flare ErtGuidance {N,� NOx 0.1380 1.01E-03 CO 0.2755 2.02E-03 TNRCC Flare Emissions Guidance Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source Pilot Gas (Waste Heat Combusted) Throughput) PMSO 0.0075 b. -s b3 AP -42 Table 1.42 IPM10/PM.2.5) PMZ.5 0.0075 8.4643 AP -42 Table 1.4-2IPM10/PM.2.5) SOx 0.0006 0.6682 AP -42 Table 1.4-2{90x) NOx .'0.0680 77.2480 'AP -42 Chapter 13.9 Industrial Flares(NOx). VOC > 0.0054; 6.1255 AP -42 Table 1 •' ' ,OC) CO 0.3100 woo 352.150'0 AP -42 Chapter . Udustrial Hares (CO) 2 of C:\Users\hslaught\Desktop\123A0E0\20WE0505.CP1 Hydrocarbon o_oadout Emissions inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tans/vaad Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM30 PM2.5 SOx NOx VOC CO 9.02 a_ :.... 0.02 L 0.08 0.02 4 0 05 0.00 0 99d ._ .. .. 0.39 65 .,-,.+. '50'115 = 4.49 3x54 ... w _ v> 1 _0 N3 Hazardous Air Pollutants Potential to Emit Uncontrolled llbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylhenzene XYlene n -Hexane 224 TMP :. .., _50.7 L- ---_ .. .. _ 940 0.00 _ __ - 0.09 9.90 0.091 _.:.:_ .._ 0.00 9.90 0.00 0.00 0.00 2715.50 2zeszo 113.1.5 ., 135.72 _,..,_ 0.09 0.09' 339 0.00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B tc_ regain-, a permit - Regulation 7 Part D Section II.C.5. (See regulatory applicability worksheet for detailed analysis .<a hydrocarbon liquids loadout source is subject to Regulation 7 Part D Section Section 07- Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08 -Technical Analysis Notes 1. The standard approach to calculating the heat Input rate from the combustion of loadout waste gas is as follows when using the state default emission factors for condensate loadout: Heat Input (MMBtu/yr) _ (73.971 ton/yearr(2000 lb/ton)/(65 Ib/Ibmolr(379 scf/Ibmoi)/(1,000,000 set/MM.-n.(2255 MMetu/MMscf) =1,945.2 MMBhdyear. Using this value, the actual NOx and CO emissions would be calculated at 0.13 tpy and 0.27 tpy respectively. - - The operator used the following equation to calculate the annual heat input: Heat Input.(MMBtu/yr) _ (Uncontrolled VOC routed to combustor (ton/yr)]'(20001b/ton]/[MW (Ib/Ib-mol)N379.41 scf/Ib-moINVVOC mol %]'(Heat Content (Btu/scfr[1MMBtu/1,000,000 Btu]. The operator expressed the values for molecular weight, VOC mol%and heat content used in the equation were obtained from the flash gas stream in the ProMax simulation provided in the application. The values used in the equation are as follow: (1) Molecular weight: 45.156916/Ib-mol, (ii) VOC mol %: 68.794615%, (iii) Heat Content: 2539.93 Btu/scf. Using these values, the operator calculated a heat input of 4,589.25 MMBtu/yr. Shim this value ismore conservative than the value calculated above using prescribed methods, it will be used for permitting purposes. 2.Theone enclosed combustor used to control emissions from the hydrocarbon liquid loadout at this facility is not used to control emissions from any other sources. As a result, only NOx and CO emissions resulting from the hydrocarbon liquid loadout need to be evaluated for APEN applicability. In this case, NOx and CO emissions from the hydrocarbon liquid loadout are below APEN reporting thresholds Due to this, the permit will not contain emission limits or emission factors for NOx and CO. 3. Pilot light emission calculations for the enclosed combustor used to control emissions from the hydrocarbon: liquid loadout are included in this analysis. 4. Initial and periodic opacity observations are addressed by the O&M plan. As a result, the permit does not contain initial or periodic opacity testing. - - 5.The.NOS for this source was provided on 05/04/2020. As a result, an updated NOS is not required as part of the self -certification requirements in the permit. B. According to the O&M plan, the emissions resulting from the loadout are directly routed to the one (1) enclosed combustor. This facility does not utilize a vapor balance system. 7.The:operator: used the state default emission factors to estimate emissions As a result, initial and ongoing sampling is not required in the permit. Section 09 -SCC Coding and Emissions Factors (For Inventory Use Only) AIRS Point# 004 Process # 01 SCC Code 4-06-009-32 Crude Oil: Submerges, Loading Normal Service (5=0.6) L Uncontrolled Emissions Pollutant Factor Control % Units PM10 ..= 9 lb/1,000 gallons transferred PM2.5 0 Ih/1,000 gallons transferred SOx .!055-04 0 lb/1,000 gallons transferred NOx 23,11932 0 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 4.94E-02 0 lb/1,000 gallons transferred Benzene 9.30E-03 95 16/1,000 gallons transferred Toluene 0.09E900 95 lb/1,000 gallons transferred Ethylhenzene 0.00'c,00 95 lb/1,000 gallons transferred Xylene 0.001,00 95 1b/1,000 gallons transferred n -Hexane 8.601-02 95 lb/1,000 gallons transferred 224 TMP 0.003,00 95 lb/1,000 gallons transferred 3 of 4 C:\Users\hslaught\Desktop\123AOE0\20W E0505.CP3. Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B -APEN and Permit Requirements Source is in the Non -Attainment Area 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. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)7 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged RII procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'You have indh:ated that source is et the NoreAttainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than to TPY (Regulation 3, Part B, Section ll.D.2)? '5oU{ee r4".qua, Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant? 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? 'The hydrocarbon SID loadout sorece is subject to Regulation I Part D Ser.tton f. S. Section II.C.5.a.(i)-Compliance Schedule Section II.C.5.a.(ii) - Operation without Venting Section II.C.5.a.(iii)- Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv) - Loadout observations and Operator Training Section II.C.5.a.(v) - Records Section II.C.5.a.(vi) - Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicabildy 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 Ad„ 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. Yes Yes No No No Yes Yes Go to next question. Go to the next question Go to next question Go to next question Go to next question The loadout requires a permit Go to next question. Source is subject to Regulation 7 Part D Section II.C.5. Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: Zip VY 00"3 AIRS ID Number: 123 / AOEO / 002_ Section 1 - Administrative Information Company Name: pDC Energy, Inc. Site Name: Golden Eagle HZ Site Location: NENE Sec 6 T6N R66W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Addressz: Jack Starr (303) 860-5800 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. 430314 1 I S& Depastetterantlftblic COLOR.00 Permit Number: 20WE0503 AIRS ID Number: 123 / AOEO / 002 [Leave blank unless APCD has already assigned a permit t3 and AIRS ID] Section 2 - Requested Action Q NEW permit OR newly -reported emission source El Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) ❑ Other (describe below) Additional Info a 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: Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected s Normal Hours of Source Operation: 24 Condensate Storage Tanks TK-1 1 /20/2020 tart -up date is: hours/day 7 days/week Storage tank(s) located at: 0 Exploration Et Production (E&P) site 52 weeks/year ❑ Midstream or Downstream (non EEO) site Will this equipment be operated in any NAAQS nonattainment area? GI Yes ■ No Are Flash Emissions anticipated from these storage tanks? GI Yes ■ No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? GI Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.004192 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)GI 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? Yes No O ■ Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 2 , COI COLOR•00 bepeevas i at AMY 14.10,.Eb„,oM,en, Redlines per application. (HDS 10/26/2020) ❑ Horizontal Permit Number: 20WE0503 AIRS ID Number: 123 /AOEO/OO2 Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbl/year) 1,253,740 Requested Annual Permit Limits (bbl/yeor) 1,504,490 From what year is the actual annual amount? Projected Average API gravity of sales oil: 43.1 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 7.8 ❑ External floating roof Storage Tank iD # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK-1 6 2,400 1/2020 1/2020 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 50126 Golden Eagle 21C -1-M SI 05 - 123 - 50127 Golden Eagle 21 N-1 B -M l7 05 - 123 - 50119 Golden Eagle 21 N-1 C -M IS 05 - 123 - 50120 Golden Eagle 25C -1-M GI 05 - 123 - 50121 Golden Eagle 25N -1A -M O 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.52094 / -104.814644 (] Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): Interior stack width (inches): ❑ Upward with obstructing raincap Interior stack depth (inches): le*AwilcoLoR•po 3 ( Ile le °6 d� 1 Permit Number: 20WE0503 AIRS ID Number: 123 / A0E0 /002 [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor Q Recovery Unit (VRU): Pollutants Controlled: VOC and HAPs Size: Make/Model: Requested Control Efficiency: 100 % VRU Downtime or Bypassed (emissions vented): 20 % ission ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: MMBtu /hr Type: Enclosed Combustors Make/Model: 4 X 96" IES Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: Waste Gas Heat Content: 2,539.93 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 18.5 psig Describe the separation process between the well and the storage tanks: Three -Phase Separator to Gas Buster Redlines per application. (HDS 10/26/2020) Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 4 I MOP NO I Health litEnvtranteenl Permit Number: 20WE0503 AIRS ID Number: 123 /A0E0/002 [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 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): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) VOC VRU / Enclosed Combustor 100% 100`_. / 95rs NOx CO HAPs VRU / Enclosed Combustor 100% 100" / 956 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source 41, Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP Mfg.; etc.) Emissions (tons/year) Emissions8 (tons/year) Emissions .(tons/year) Emissions (tons/year) VOC 1.9271 / 6.13 Ib/bbl; tb/MMscf ProMax / AP•42 1,208.06 12.08 1,449.68 14.5 NOx 0.1380 / 0.068 ib/MMBtu TCEQ / AP -42 1.06 1.06 1.26 1.26 CO 0.2755 / 0.31 Ib/MMBtu TCEQ / AP -42 2.16 2.16 2.57 2.57 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ❑ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service (CAS) ( Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (Ibs/year) Controlled Emissions8 (Ibs/year) Benzene 71432 0.0046 lb/bbl Pro Max 5,791.7 57.9 Toluene 108883 0.0034 lb/bbl ProMax 4.248.4 42.5 Ethylbenzene 100414 00002 Iblbhl ProMax 270.5 2.7 Xylene 1330207 0.0010 lb/bbl ProMax 1,261.4 12.6 n -Hexane 110543 0.0307 lb/bbl ProMax 38.522.8 385.2 2,2,4-Trimethylpentane 540841 8.72E -OS lb/bbl Pro Max 109.3 (DM) 1.1 (DM) 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Redlines per application. (HDS 10/26/2020) Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 12/2019 5Se COLORADO tr.a,e.M. ,MOlc a..lastrtnrtramrm Permit Number: 20WE0503 AIRS ID Number: 123 /A0E0 /002 Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 77,-C Z —C) SignE re of Legally Authorized Person (not a vendor or consultant) Da'te Jac Starr Senior Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303) 692.3175 OR (303)692-3148 APCD Main Phone Number (303) 692-3150 6,a© COLORADO , .d. Neat* Estrintorment E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: PDC Energy, Inc. Source Name: Golden Eagle HZ Emissions Source AIRS ID2: N/A / [ 123/A0E0/002 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 50124 Golden Eagle 25N -1B -M 4 05 - 123 - 50130 Golden Eagle 28C -1-M ►/ 05 - 123 - 50133 Golden Eagle 28N -IA -M `I 05 - 123 - 50123 Golden Eagle 28N -1B -M • 05 - 123 - 50128 Golden Eagle 28N-1 C -M ►1 05 - 123 - 50131 Golden Eagle 2N -1A -M // 05 - 123 - 50129 Golden Eagle 2N -1B -M y 05 - 123 - 50122 Golden Eagle 7C -1-M 05 - 123 - 50132 Golden Eagle 7N -1A -M /1 05 - 123 - 50125 Golden Eagle 7N -1C -M - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - D - - ❑ - - ■ - - ❑ - - ❑ Footnotes: 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-I Addendum Produced Water Storage Tank(s) APEN Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water 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, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 / AOEO / 60.3 Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Golden Eagle HZ Site Location: NENE Sec 6 T6N R66W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Jack Stars' Phone Number: (303) 860-5800 E -Mail Address2: Jack.Starr@pdce.com ' 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. 130817 `COLORADO Permit Number: 20WE0504 AIRS ID Number: 123 / AOE0 / 003 Section 2 Requested Action 0 NEW permit OR newly -reported emission source E3 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GPM If General Permit coverage is requested, the General Permit registration fee of 5312.50 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each cox below that applies) Ej Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership° ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Initial permit request for produced water storage tanks at a new facility 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. { For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted, Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage Tanks TK-2 1/20/2O20 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tankls) located at: hours/day 7 days/week ❑✓ Exploration li Production (EEiP) site 52 weeks/year ❑ Midstream or Downstream (non EILP) site Will this equipment be operated in any NAAQS nonattainment area? Q Yes ❑ No Are Flash Emissions anticipated from these storage tanks? Q Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes 0No Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? 0 Yes ❑ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes ❑ No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ® Yes 12:1 No t6LflR4D4 2 I Redlines per application. (HDS 10/26/2020) ❑ Upward ❑ Horizontal Permit Number: 20WE0504 AIRS ID Number: 123 /AOEO/003 (Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Produced Water Throughput: 625,600 750,720 r4m what year is the cretuoi annual al aunt Tank design: 0 Fixed roof Projected ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK-2 2 800 1/2020 1/2020 Wells Serviced by this Storage Tank or Tank Battery6 (EftP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 50126 Golden Eagle 21C -1-M Q 05 - 123 - 50127 Golden Eagle 21 N -18-M D 05 - 123 • 50119 Golden Eagle 21 N-1 C -M Q 05 - 123 - 50120 Golden Eagle 25C -1-M (� 05 - 123 • 50121 Golden Eagle 25N -1A -M Q 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable. and should consider future process growth. Requested values are required on all APENs, including APEN updates. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.52094/-104.814644 C7✓, Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/ rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack depth (inches): Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 12/2019 COLORJIDO 3 Permit Number: 20WE0504 AIRS ID Number:' 123 / A0E0 / 003 [Leave blank unless APCD has already assigned a permit N and AIRS ICJ] 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/ del: ❑ Combustion r Device: Pot lutants Controlled: V©C and HAPs Rating: TYpe: Enclosed Combustors Btu/hr Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: Constant Pilot Light: Q Yes 4x96"IES Waste Gas Beat Content: 1,100.83 Btu/scf ❑ No Pilot Burner Rating: 0,02 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: 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)? 216 psig Describe the separation process between the well and the storage tanks: Three -Phase Separator Redlines per application. (HDS 10/26/2020) APCD-207 Produced Water Storage Tank(s) APEN - Revision 1212019 trodnorturesi 354LGRADO Permit Number: 20WE0504 AIRS ID Number: 123 / A0E0 /003 Section 8 - Criteria Pollutant Emissions Information Attach ail emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 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): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) V0C Enclosed Combustors 100% 95% NOx CO 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: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Uncontrolled Basis Units Source (AP -41, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.02498 Ibibbl FLA Ft EEtP Tanks 7.81 0.39 9.38 0.47 NOx 0.1380 lb/Mau TCEQ 0.21 :.0.21 0.26 0.26 CO . 02755 milleMBtu TCEQ 0,43 0.43 0.51 0.51 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual. emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 9 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? QQ Yes ❑ No IT yes, use the rottowing tame To report Tne non -criteria pouutant (r1AI-) emissions rrom source: Chemical Name Chemical Abstract Service CAS (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (lbs/year) Controlled Emissions8 (Ibs/year Benzene 71432 4.805604 Ib/bbt FLA Et EEtP Tanks 300.6 15 Toluene 108883 3.123E-04 ItebbI FLA Et E8P Tanks 1953 IDMj 9.8 (DM) Ethylbenzene 100414 1.644E-05 lb/bbl FLA Et EEtP Tanks 10.3 (DM) 0.5 (DM) Xylene 1330207 5.07E-05 WOW FLA a EEtP Tanks 31.7 (DM) 1.6 (DM) n -Hexane 110543 2.88E-04 Ibtbbl FLA Et EEtP Tanks 180,2 (DM,) 9 (DM) 2,2,4-Trimethylpentane 540841 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based of actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Redlines per email. (HDS 12/28/2020) Produced ;scaler t;C£',tage Tank s-} APEN Revision 1712O19 ,'-COLORADO 5 I >to0 1 a,......"'°' Permit Number: 20WE0504 AIRS ID Number: 123 / A0E0 /003 Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Signue of Legally Authorized Person (not a vendor or consultant) Jack Starr /Dia Senior Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: j] Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Small Business Assistance Program (303) 692.3175 OR (303) 692.3148 APCD Main Phone Number (303) 692-3150 .COlORA00 i Ark E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form Company Name: PDC Eneru, Inc. Source Name: Golden Eagle 112 123/AOEO/003 Emissions Source AIRS ID2: i Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 50124 Golden Eagle 25N -1B -N1 05 - 123 - 50130 Golden Eagle 28C -1-M 05 - 123 -50133 Golden Eagle 28N-lA-. 05 - 123 - 50123 Golden Eagle 281-1 B -M Z 05 - 123 - +0128 Golden Eagle 28N -IC -M El 05 - 123 - 50131 Golden Eagle 2N -1A -M 05 = 123 - 50129 Golden Eagle 2N-IB-M Z 05 - 123 - 50122 Golden Eagle 7C -1-M 05 - 123 - 50132 Golden Eagle 71 -1A -fit 0_ 123-50125 Golden Eagle 7N -IC -tit - - - - - - - - _ ❑ - ❑ , - - ❑ - I ootnotes: Attach this addendum to associated APEN form when needed to report additional wells. '- If this is a newly report source that has not been assigned an AIRS ID by the APCD. enter N/A Form APCD-212 Addendum Hydrocarbon Liquid Loading APEN Form APCD-2O8 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website. 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: i AIRS ID Number: 123 / AOEO f 0(/ Section 1 - Administrative Information Company Name':. PDC Energy, Inc. Site Name: Golden Eagle HZ Site Location: NENE Sec 6 T6N R66W Mailing Address: onciude VD Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: ,Jack Starr Phone Number: (303) 860_5800 E -Mail Address2: Jack.Starr@pdce.com 1 Use the full. legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. r Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 430815 toioaAoo =. Permit Number: 20WE0505 AIRS ID Number: 123 / A0E0 f 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action NEW permit OR newly -reported emission source Q Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the ADEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) • Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership° ❑ 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 & Notes: Initial permit request for condensate liquid loadout 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: Loading of condensate from storage tanks to tank trucks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: 1/20/2020 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? [-]> Yes ❑ No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? ❑ Yes ❑r No Does this source load gasoline into transport vehicles? ❑ Yes ❑' No IS this source located at an oil and gas exploration and production site? ® Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes ❑ No Does this source splash fill less than 6,750 bbl of condensate per year? Yes ❑ No Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes ❑ No Form APCD•208 Hydrocarbon Liquid Loading APEN Revision 12/2019 ahy'GOLORA00 2 I P x°� i �. eroant Permit Number: 20WE0505 AIRS ID Number: 123 / A0E0 /004 Section 4 Process Equipment Information Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 752,245 bbl/year Actual Volume Loaded: This product is loaded from tanks at this faci ity into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") 626,870 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of bulk liquid loading: F True Vapor Pressure: Psia @ 60 F Molecular weight of displaced vapors: lb/lb•mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbl/year Product Density: Ib/ft' Load Line Volume: ft'/truckload Vapor Recovery Line Volume: fN/truckload 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. Section 5 - Geographical/Stack Information Geographical Coordinates (latitude/Longitude or W M) 40,52094 / -104.814644 0 Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (•F) Flow Rate (ACFM) Velocity (ftisec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward CI Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/ rectangle ❑ Other (describe): Interior stack diameter (inches): Interior stack width (inches): ❑ Upward with obstructing raincap Interior stack depth (inches): COLORADO i Permit Number: 20WE0505 AIRS ID Number: of r 123 / A0E0 / 004 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enciosed Combustor Make/Model: TBD Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 99 Minimum Temperature: °F Waste Gas Heat Content: 2.539.93 Btu/scf Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑ 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): Pollutant Control Equipment Description Collection Efficiency (% of total emissions captured by control equipment) Control Efficiency (% reduction of captured emissions) PM SOx NOx CO VOC Enclosed Combustor 100% 95% HAPs Enclosed Combustor 100% 9596 Other. Using State Emission Factors (Required for GP07) VOC ❑� Condensate 0.236 Lbs/BBL ❑ Crude 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actuo( annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions tons/ ear ( Y ) PM SO. NO. 0.1380/0.068 IGJMMBtu TCEQ/AP-42 0.32 (DM) 0.32(DM) 0.39 (DM) 039(DM) CO 0.2755 /0.31 Ib1MMBtu TCEQ / AP -42 0.66 (DM) 0 66 (OM) 0.78 (DM) 0,78 (OM) VOC 02360/6.13 Ib/6bt; Ib/Miscf CDPHE / AP -42 73.97 3.70 88.77 4 44 s 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. C Age‘ARDocotoR ADO 4 i i rs = Redlines per application. (HDS 10/27/2020) Permit Number: 20WE0505 AIRS ID Number: 123 / A0E0 / 004 Section 8 - Non -Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? p Yes [j No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name Chemical Abstract Service CAS Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source fAP 42, Mfg., etc.) Uncontrolled Emissions Obs/year) Controlled Emissionsb Ohs/year) Benzene 71432 0 O00,1 sucoa state Approved 260 re 13 Yi Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 © 0036 crna State Approved 2.263 00 113 15 2,2;4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. 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 GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Si re of Legally Authorized Person (not a vendor or consultant) Date Jack Starr Senior Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303)692.3175 OR (303)692.3148 APCD Main Phone Number (303)692-3150 5i COLORADO Otwsi MAIM* R.404lawmen.. Hello