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HomeMy WebLinkAbout20195168.tiffPvbljc ReV:evw of/o6 /2o COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 December 11, 2019 Dear Sir or Madam: RECEIVED DEC 2 0 2019 WELD COUNTY COMMISSIONERS On December 12, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Ottenhoff 29 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft 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, G2vernor I Jill Hunsaker Ryan, MPH, Executive Director cc: Pc_erN, Hi- 0-K), Pw( /e.R/cH/ck-), OTC t) 12 9k' a 2019-5168 3M Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Ottenhoff 29 Sec HZ - Weld County Notice Period Begins: December 12, 2019 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: Ottenhoff 29 Sec HZ Well Production Facility NENE of Section 29, Township 5N, Range 64W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for twenty (20) condensate storage vessels and ten (10) produced water storage vessels at a new synthetic minor oil and gas well production facility located in the ozone non -attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0798 Et 19WE0799 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 wilt receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO Department of Public Health & Environment 'COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0798 Issuance: 1 PDC Energy, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Ottenhoff 29 Sec HZ 123/A079 NENE SEC 29 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 001 Twenty (20) 538 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 25% 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 Page 1 of 11 COLORADO Air Pollution Control Division Department of Public Health& Enviroomernt Dedicated to protecting and improving the health and environment of the people of Colorado 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 shall 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 shall 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 oni 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.) F.4. ) 3. The operator shall 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 shall 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 shall 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 NOX VOC CO TK-1 001 --- 1.8 19.0 3.6 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall 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 shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 11 COLORADO) Air Pollution Control Division Department ofPuvc Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6. The owner or operator must use the 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 shall 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-1 001 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 25% annual downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly. records of the actual processing rates shall 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-1 001 01 Total condensate throughput 1,554,400 barrels Condensate throughput during VRU downtime. 388,600 barrels 02 Combustion of pilot light gas 1.51 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall 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 shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime shall be defined as times when emissions from the condensate storage vessels are routed to the Page 3 of 11 COLORADO Air Pollution Control Division Department of Public Heatth b Ei iror eot Dedicated to protecting and improving the health and environment of the people of Colorado enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate 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) shall 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, Section XII. ' The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, `reporting and emission control requirements for condensate 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, Section XII.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.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 XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; 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 following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall 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 May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available Page 4 of 11 COLORADO Air Pollution Control Division Department of Public Health E. Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, Section XVII.C.2. OPERATING a MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator shall 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 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct, periodic testing, unless otherwise directed by the Division or other state or federal requirement. ....... .__..: ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) ) • Annually by"April 30 t`� whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 1OO tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Page 5 of 11 COLORADO Air Pollution Control Division DeOartment of Public: Health & Eo iroilmen€ Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation Number 3, Part D shall 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). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the .issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until ' the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This, permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or ' operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by, the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization b.y the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a Page 6 of 11 COLORADO Air Pollution Control Division Department of Public Health & Bri iroornent Dedicated to protecting and improving the health and environment of the people of Colorado permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Description Issuance Date Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for twenty (20) condensate storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 11 COLORADO Air Pollution Control Division Department of Public Heaeth f E vironr ont 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 shall 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 shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 7,435 93 Toluene 108883 9,013 113 Ethylbenzene 100414 292 4 001 ` Xylenes 1330207 3,327 42 n -Hexane 110543 65,287 816 2,2,4- Trimethylpentane 540841 92 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 11 COLORADO Air Pollution Control Division Department of Public Health & Erviro; tment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Process 01: Condensate Throughput 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 8.58x10"3 --- 8.58x10"3 TNRCC CO 1.71x10"2 --- 1.71x10"2 V0C 1.9515 0.00 9.757x10'2 ProMax 71432 Benzene 4.783x103 0.00 2.392x10"4 108883 Toluene 5.798x103 0.00 2.899x10-4 100414 Ethylbenzene 1.877x10-4 0.00 9.384x10"6 1330207 Xylene 2.14x10"3 0.00 1.07x104 110543 n -Hexane 4.2x10'2 0.00 2.1x10"3 Note: The controlled emissions factors for this point are based on a control efficiency of 100% when emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the enclosed combustors) 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 samplewas obtained from the outlet of the HLP separator for the Ottenhoff 29R 323 well, on 07/08/2019. The sample temperature and pressure are 116°F and 19.2 psig 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 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) N0x and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a gas molecular weight of 45.5493 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, a VOC mole % of 67.14% and a heat content of 2,557.47 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 Page 9 of 11 COLORADO Air Pollution Control Division Department of Public Health b Erwiroornent Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors (lb/M/Ascf) Controlled Emission Factors (lb/MMscf) Source CO 352.16 352.16 AP -42 Chapter 13.5 VOC 6.13 6.13 AP -42 Chapter 1.4 Table 1.4-2 Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP -42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136 Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP -42 Chapter 1.4 emission factor by a ratio of 1,136 Btu/scf to 1,020 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot gas. Pilot light fuel flow is based on a constant rate of 15.6 scf/hr. There are a total of eleven combustors used to control emissions from the condensate storage vessels. As a result, the total pilot gas fuel flow is 171.6 scf/hr. Total actual emissions are obtained from the sum of emissions resulting from the storage vessels and combustion of waste gas from the storage vessels (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall 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, n -Hexane and Total HAPs NANSR Synthetic Minor Source of: VOC and NOx PSD True Minor Source of: NOx and CO Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable Page 10 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK 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 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison Slaughter 430962 7/26/2019 9/26/2019 Section 01- Facility Information Company Name: PDC Energy, Inc County AIRS ID: 123 Plant AIRS ID: A079 Facility Name: Otteniloff 29 Sec HZ Physical Address/Location: NENE quadrant of Section 29, Township 59, Range 64W County: Weld County Type of Facility: What industry segment? t Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NENE Particulate Matter (PM) E Ozone (NOx & VOC) 29 SN 64 AIRS Point 9 Emissions Source Type Equipment Name Emissions Control? Permit ft Issuance # Self Cert Required? Action Engineering Remarks 001 i k TK-1 -yas" 19WE0798 SY ` Permit irFitfaG.- r�5sUanc- Section 03 - Description of Project PDCEnergy Inc. (PDC) submitted an application requesting permit coverage for several newsources ata new synthetic minor oil andgas 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 loadout;'and natural gas fired reciprocating internal combustion engines (RICE). The RICE are obtaining permit coverage under the GP02, and the loadout is` obtaining coverage under the GP07. The produced water storage vessels are addressed under permit #19WE0799. This preliminary analysis only addresses the twenty (20) 538 barrel condensate storage vessels. - !. This source is AP EN 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 requires( because the uncontroled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation 3 Part B, Section II.D2.a.);. Public comment is required for this source because new synthetic minor limits are being established in order avoid: other requirements and the change in VOC emissions as a -:result oft project are greater than 25 tpy. _. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Rer.F Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. y Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants her( SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP HAPs No NOx CO VOC PM2.5 PM10 TSP El HAPs ❑ ❑ Condensatae S orae! Tank(s; tinisslcns Inventory Sedan CR EgmwneM Description ne.Ps =`,2n —"'`a aim BB1 ................ bdssioncontrd oewae fIaporlev. Requested VPU ol VPU al Hours Polanlm ml: Peeples,.snclosed eomb.amrCono-ol Efficknoy Endres. combustor p bonelHours Ra.m.d pewee we a xnP cone, ma,.nm PFecsInP PM. Inform.. for Crn.lons MIrnetes Prima, Prnigalons TanXs) Bartels (Irbil pervear !Requested er ,ousbput 1iauae? Barrels (bb) per year Paten.. Emn(PPE)cendaneeteTbrwy:pu rtenea level Per Veer Retested Condensate ThrougtreutduringVIIU downActual Condensate Tnrougnpueduring VFW seueede,embeione-coudeueuoeotrdeelsi Hear content aste gas e pceaEafryuMs 'ti 'pC�B./ue ,....215[1111.1:1 produced aa/ebl Actual heat contentolwasts gas routed to con,useon dew., Request. Pea [content ofwaste gm routed. com...eon elev.0 _eta. Barrels (el) per Year PPS,. Barrels lbm) perveu Pet[rItt2. waste gas routedrombusdon device. a tq. xumberof-Combustors: PlloILIghtPete tree Mot AnnualPtxeag�rtene ":_CC4UMec >_>r,_a MM,nrrear Plot pilot �twa[ content routed to combustion device: Sctinbq emissions Factorsel M..odu.eic wdl.ls smote an R Belt na�n e,�mroi ProMe.aa.,Rete x200 MB./yeer bel reer Actual Condensate Throughout.. Ertlisslons Controls operating Requested monthly Throughput. MULE Barrels (bbl per non. BTU event BTU pc year PP,Iee MMBTU eery., pollutant wm22, 101 On/ntl Total Waste Oa, Pats(./dri 200,31 2.4649.533 Toluene EmNbemene 0..7,5085 %lames mlielane 521.2* ennellax Endo bn Nee, Pollute. Condensate Tank MIETE (vas eat eel (Co dame e WI MMIIEIMMEr 0 a' „o Buts ® M7M!MMIll WOMEN, 0 Y:r:. ::.,. .:. ..........: IZMMZE Pollutant cometraril 0 ME Controlled EmleslorePenon Wad lnBrrme Controlled ETEWon Controlled Emission Pollutant Factors during Veld o ['q.t.', Factors Wed During lel [P.M.. PNeell Source Toluene - - SIPP.OP SUB specIllc E.E. E[bylbenna vWer.e Ate sneer', E.E. - Bltespeac E.F. _ agTMP ao.. s93_CEvs She spec. E.P. • ....lute.. paten.I to EMt Uncontrolled (else/wA ACIII21 mbslons Uncontrolled Ions/year) I.m1eml Requested P erml[UmIts trlled uPans/swad 1,222/0..,1 Requested Mone*UCIC boiled lee/monm1 R.CL5 CO 0.10. OM trle L1' Hada.../Ur Pollutants Potential to Emit Uncontrolledon llm/yea,( U (*Merl Il.r1eo11 u . Fa Controlled Uncontrolled Pee/Yeed Iles/rear) Etbytl.man. YW nutetoN SM mmary <n alVelr Petrdellon 7. section 5, P Population ,Secifortlel., ReIuledan 7, Section Pell., 00 C.B aaxegotemlasr.CtaR - x_.3 Peeula eon ar[AxePs subpart. RegulaeonautAxi3Eubwrcaaao NSPS 0000a Pegulatlon a Part E, MPCT..bearcxx (see ,221.t2 IV .pp 112* 5)27 91,225222 for data lad *2.5321 Condensate Storage Tank(s) Emissions Inventory Sad. m. Igtlaland Fmnedmsamplmondnaanenavulmnanta Does camper, use the state dantdam,ssaaanctorsmerde¢ maim. Ilya,are tae uncontrolled actual or requested on:armnaestimated eaba greater than or equal ea Minns w[ per year, ver, apamdtwrvmnwn anIn.Campltaeces¢mngrwalramentm develop as. spedmemsmnafactor hasmanpldelmer In MN.=(ISM. Does the company use asite:pmnaen.¢wnafactor menma¢emsoonae If yes and Ilthere are 'lash emasians,are ldna lquu sample drawn a.. Nlybelna pauMt¢itrnb smnppk should Demrobeea repmenta...generallymeansshe-specific and appriom«mVt.n rem,. lroaeve., V0,,ha not been modified Ie.e. no new ...brought m ughton-00 men farm, he appropriate ea usean older late-spmncaampla, owing requiremenr dewlap a specific arn,,,fans factor.. on auidd Does,. company repumtacontrattlevicaeldancygraalzr than 95,i fora 'Urea, combust:Ion alevka, na. op.,.mr aaealopaa slam span. mmmrar hears. ,,,,,,,,,.,,,,,.,==°,..,°^''''''' dt5 k esP tS>•ildfieaf tEn h -E- ed a wet Wn v ooaa,Idey!plum MVlerttYul ,Sdka7PnAP e T min using th_ r, „2,sz<xewG P.IV1 8 mistllensthemlt.gt.dtl,VM [R nrkry [ sillvnyveoas(, )Writ IIG. ram/afli / 1IP.071.182 tnuscrle,0 ! ^.. ,, orHtam fie gzdvbeaEnpu ( l pkaaka,Q M 1npHr lranmmin).. ▪ , cllmvl'ussaavNr-+3'1355. edm,U:epids sax n to alas ia: t�eta=A�'A.�nry. 1.4.eor<0'oused u awl dmuev-a p tIpurrtatt 1 aievivr) Banc. ed VO4,on(4 PPOoa/mn11(0 , n nolr'3:�a tt/ J h(mn rs] ine ma ate,,o, m e rnrxara*xsa ro.M.. n=a3(w rHn�uss nnmm.t l Pw <xnlnn,ar� ee,,eiss,.,.,,,, des_ a,.. rt.., p mm''""y sass ameadove ,� areal mw>b . ,xts.amrpermR ,purposes s,,,,,. memmraa.mdmer lnmkna,Hare. was Hta,nnewr, avaar<.re amty..ccatuwts_rwra +ceai«z.rec�ue m mj.mlatarf,ation,nesamp,e Fah, le , ra��a • ,,aPunan sale:a nap n.,.a..E. g scene fire ,aek: arr esah nn sere spec. emas HHrancra. umnt¢aas 3jsry5 hra ad•aanbetueeirApre_ cmrt w_ m/oe(s _ mipra f..s ter. a<s<r:ma ne'enm taw produce ficen„cones oe nee Hn nom theNWaafo n Apc.. SzsamRaz m the .re sat m.rury oauc...,, t bs,,,,,,,,,,,,,,,,,,,,,,,,ors. tea'''r pa.I4 tst«c,.uut rAmedcamt4stailsl serve n afn".t tl k fie ....''qukne(enePem pemtetlte0atk u5ng1 m P''o'" pi'""'eO m ,r Y',otr t',, - f I Th ,, kn h I I I„ 'f / k doe f E kn I bad fl tl Oyd'bledadlm d mti bpdo • dja av u tees w f ret lea `ntl0xtd " ,alt;, fey rmmler join th4550 *stIe NMknotastara an saute a a ka¢saVypot,uklarmsl svoraeH Par pn o ma?pp h M m I Btl Ntul eudng norm. op tin rout. na endo.to b4uarn}T 6i,. Tiaf l at«, e. p ayar,ualnale tl ,,, ,, a os¢damnael-elfth ' throughput. hrough�3fg do and:rnm IsP 5nce.F...conw ae:red named tl,.rent conuen, k.m Pke m.ovec.�H�vimh etYAU tla condensate ugnpuraueeg vcuaa mHmrr,r H H alp Hn.e. ce u ,nmveumwt a emnn r .onvnt m.aanlgru edv >. ine a.rm twi cHnen rwuroeesslAntoval:'e mil ,wenate rn,au�,voa lad �tH re,re55 04 requess w..- .ate mrot Hn Pue 355.W re Ne,rl� .e seal nm,tuaBrefrrzpee- uc.�,uat_ mef38s aVVvearl.-rhe Nhat on total,onoes,,,,,,,HMutlnmrpo2¢a„C,^stew,,,,<.t,nztoec.nwh�leine M,,,,,,„„0nar 1. nit) re me VAV a,eaune ez eAXnno-J m..erryco my mess, contra <,rce c tcrral..a,-rmr r mss Mud nera�e.i-r ove11 tcletrtrla5y.s tau itru• .e a,stl9 X Hntm).xHvre,�er,s �amemerrra«;a, t« a< relaasswtb ets- w¢dam,n antadadaaam/nu. one wamttaPaw ttsowd¢o-mnmkn s..H.t., met„ ,.n e.stanwr fi 'fits ...alt„n<al.u.tedmat.bkas onus:baeaaeama:� nt� eaemstlHn rnatHrtus.e fiat., Hasa n m, maw .. a, , s .�. vu.al .alts n' I, ,an CO. reratn ear. LLaEt J see%alp;? nxPOlq¢ne,;,,, _. . x rnm m t nsarencrnv�m 00 I.< ti K u6 P5e tale i W p '.rtit PP t mhwtrfrnlalS fps W,WtWnr�) pia a data Iuua H11 f neeanvN Nanteral em,fpl N M ce;'Sddpnraalltly Sln °a.,edut Weponmmta naaaaaPatt tyhi po pub, aa1 si d�m 'w,ra win vz. fi dEafi bey anrcPmtmresb lea ws:ncnmmama.,krt rjbm alb a ore a nn mrape;i Pv m¢N485Ybmiaedeiea¢oiafagg5 afieNbs its been, dm,he o. mto`t m iFbtivM& Wean 09 -Inventory src rain, and armadas Faders Pall oUrrt • Factor NOx VOL Banana Fotene Emylhentana avian 22•111.1P cornra hose'•' b/1,000 pllsnt canden¢¢ 55u1hpat b/1,[mpllomrondenaatemrou,bput b/1,0.vpllona contlew¢ mmuehpu b/;PM plmm rondenaa¢ mroubhpar b/;0.W aSms wndenu¢ mrotghput Allan SHughput !/;¢Oplon ¢mroughpu /;OOOpllon metro b/;¢Opllonamndensa¢mroughput b/;mnpllona condensate mroudhput b/;aMplbns wndensa¢mrouHnpm Contlensete Tank RegUlatory Analvalf Wormheet ATIAINMIK Ivau m3wventwrunmfxlmx�..xna;azee xi� enutaumlon IztnuP,...,,:t.,tm nune......znunnxl...P e. 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COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0799 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Ottenhoff 29 Sec HZ 123/A079 NENE SEC 29 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment ID AIRS Point Equipment ' Description Emissions Control Description TK-2 002 Eight (8) 400 barrel and two (2) 210 barrel fixed roof produced water storage vessels connected via liquid manifold. None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or Page 1 of 8 COLORADO Air Pollution. Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons, per Year PM2.5 NOX VOC CO Emission Type TK-2 002 1.9 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 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. PROCESS LIMITATIONS AND RECORDS 7. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-2 002 Produced Water Throughput 324,990 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 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.) E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 10. This source is subject to the odor requirements of enforceable) OPERATING Et MAINTENANCE REQUIREMENTS Regulation Number 2. (State only 11. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14. 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 Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 15. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). GENERAL TERMS AND CONDITIONS 16. 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. 17. 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. 18. 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. Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. 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. 20. 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. 21. 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. 22. 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. Permit Histo Harrison Slaughter, P.E. Permit Engineer Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for ten (10) produced water storage vessels at a new synthetic minor oil and gas well production facility. Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions ((b/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 350 350 Toluene 108883 431 431 Ethylbenzene 100414 15 15 Xylenes 1330207 135 135 n -Hexane 110543 79 79 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 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.137x10-2 1.137x10"2 Flash Liberation Analysis 71432 Benzene 1.077x10-3 1.077x103 108883 Toluene 1.326x1O3 1.326x103 Note: The site specific emissions factors in the table above are based on a flash liberation analysis conducted on a site specific pressurized water sample obtained on 06/20/19 from the Ottenhoff Page 6 of 8 a„.„ COLORADO Air Pollution Control Division Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado 29R-323 well. The results of the analysis provided a speciation of the flash gas, a gas to water ratio of 0.20 cf/bbl and a flash gas molecular weight of 46.41 lb/lb-mol. The emission factors were determined using the results of the flash liberation analysis in conjunction with the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4- 3).The flash liberation analysis was evaluated at atmospheric storage tank conditions of 12.5 psia and 70° F. 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, n -Hexane and Total HAPs PSD True Minor Source of: NOx and CO Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC and NOx MALT H Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Narrlsori Slaughter' 403962 '7/26/2019 9/30/2019 Section 01- Facility Information Company Name: ,PDC Energy, Inc. County AIRS ID: 123 Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration&PmductlonWell pad' What industry segment? Oil & f atisiI Gas Pin faction & Proce Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) A079 Ottenhoff 29 Sec HZ NENE quadrant of Section 25, Township 5N, Range 64W Weld County Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant Section Township Range NENE Ozone (NOx & VOC) 29 5N 64 AIRs Point if Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 002 ,,. ' pioduce'ii' il8teI .T nk. � TK-2 Ncs ! 25\MlE0799 1 -Yes Permit fniti ; `" ESBtSa�Ce's_� Section 03 - Description of Project PDC Energy Inc. (PDC) submitted an application requesting permit coverage for several new sources et a. new synthetic minor oil and gas well production facility located in the ozone non- attainment area. With this application, the operator is requesting permit coverage far condensate storage vessels, produced water storage vessels, hydrocarbon loadout, and natural gas. 'fired reciprocating internal combustion engines (RICE). The RICE are obtaining permit coverage under the GP02,and -the loadout isobtaining coverage under the GP07. The condensate storage vessels are addressed under permit #19W E0798. This preliminaryanalysis only addresses 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 l3-B.3.a.)Additionally,. the source is permit required t because the uncontrolled VOC emissions from all APEN. required sources at the facility are greater than 2tpy (CO AQCC Regulation 3, Part 8, Section ll.D.2.a.)t Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? RequestingsyntheticMi Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? 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? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) S02 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants herE 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO J VOC PM2.5 PM10 TSP ❑ ❑J HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank !Facility AlRs ID: Plant Point Section 02- Equipment Description Details Detailed Emissions Unrt Elul t(ti 4066 r aadn Description. Emission Control Device lystmi from this so rc e arei Description: Requested Overall VOC & HAP Control Efficiency °A: bar t 0 d oaf produced wai Section 03- Preo sing Rate Information for Emissions Estimates Actual Produced Water Throughput While Emissions Controls Operating= Requested Monthly Throughput- 27602 Barrels (bbl) per mpnth 'Requested Permit Umit Throughput Potential to Emit (PTE) Produced Water Throughput = ,. ..x;324;930'; Barrels (bbl) per year 499:DI Barrels (bbl) per year Secondary Emissions- Combustion Devlro(s) Heat content of waste gas= /. Btu/scf Volume of waste gas emitted per BBL of liquids produced = scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device= Potential to Emit (PTE) heat content of waste gas routed to combustion device= Section 04- Emissions Factors & Methodologies Ex = Q5MW a Xx/C Ex = emissions of pollutant x Q= Volumetnc Flow rate/volume of gas processed MW = Molecular weight of gas =55 of gasMW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/Ib-mol) at SDP and 1 atm MW GWR 46'.i)ll Ib/Ib-mol F02 cf/bbl Weight Percent (a) Hydrogen Sulfide CO2 N2 methane ethane propane isobutane n -butane isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylcydohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes CO 't"'FT'9S.f .83 5:75 000 D' Oil 73 0.5'. 0'. w la% x,'Ms,,7,41 C10 C11 earmatmol Total VOC Wt % 100.00 41,.47 Will this storage tank emit flash emissions? 0 MMBTU per year 0 MMBTU per year 0 MMBTU per year 2 of 4 ID\PA\2019\19 W E0799. W 1 Produced Water Storage "Tank(s) Emissions Inventory Secmn 05-- Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Goiters Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) VOC t-847 0.540 0.540 L047 5.847 304 PM10 0.000 0.000 0.000 0.000 0.000 0 PM2.5 0.000 0.000 01000 0.000 6.000 P. NOx 0.000 0,000 0,000 0,0400 0,0000 0 CO 0,000 0.140 0.000 0,004 0.000 0 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibis/year) Ilts/vcarl Ilbs/yearl (Ibis/year( (Ibs/year) Benzene 349.91 29119 291,59 349,90 349.91 Toluene 491.08 330,24 599,24 431.00 430.00 Ethylbemzene 14.01 12,26 02,26 14.71 14.01 Xyiene 134.30 111,97 111.9'2 1:4.30 134.00 n -Herne 70.11 06.99 00,59 - 78.70 20,71 224 TMP 0.09 0.00 0,00 0.00 out Section OS - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section )(VILE, Cl,,C3 Regulation 7, Section XVII.C2 Regulation 6, Part A, NSP5Subpart 0000 SOPS Subpart 0000a (See regulatory applicability worksheet for detailed analysis) omit Storage Tank I. not soilless to Regulation 7, Suction 10VII Storage Tank is not subject to Regulation '1, Sec :un 0011.0.2 Storage 70nit 10 not suhioct to NSPS 0000 Storage 'Vass a not subject to N00100000 Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use site specific emissions factento estimate emissions? If yes and If there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means she-spedflc 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 n alder site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site spedflc emissions factor. See PS Memo t0,s 5.9 and 5.12 for additional guidance On testing. Does thecompany request a control device efficiency greater than 95% for a flare at combustion device? yt__=_t/N/A - emissions {TOT this source are not controlled. If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section oO -Technical Analysis Not. 1. Site spec fk emnsions factors developedfor this? narys,s provided a speciatioaof tfr-s. flash gas, a gas 70.9 14 should b004 od thatfl hllbera o naly"s onlyes cis for Chef towing reasons. (I)'.DN sf00 gu da5000 orkng aedbo az,0glosses.would likely be ',Mimai:4o 2 9,n Sene nnd00iuene are the only HAPSWt1, emnaons about 3. Since the operalor used the" 00Rwkh volts of acruaI-cu 0c feel/hbl :I. (P1 01/11)=(o -2052/r2) = (sis psra)clvla/15300( - (1 7 pr1aj'(320 4.Y clenornInaT00.10M errernisslOrktactoccOculation5, the operators chore :. Permitting pufpos09 asrtespeef ic pressurzedwater sample obtained on06/20/19 from the Ottenhoff29R-323•wellThe results' of the' ight 0046.41 Ib/Ib-tool_The flash liberation analysis Was evaluated at atmospheric storage tank condnfans of 12-5 psis and gnu vessels. How ever, twos determined the working -and breathing porcnn of em-ssonf didnotneed., - be estimated in this produced water vessels does not provide Inforroanon on methods for estimating workng and breathIng losses and lib The _. imaaet:on the overall ernisson factor or emssmns. _ __-- resulthey areshe,':only 021 for which' emss Cn factors are';iudel in ihepermfx,'•• rted004 sI 2 0 to actual vn'to In titzase, the motor volume of ar[;deal gas w d have been calculated. follows:,` nountits_apps catwn,this operatortltl rot 00000e to 000 40is erslon: Since the molar volume appears In the • 00010010011119010114510 t,veestr at of• 50 sons, Asa ,ftoe operator's' a lnlat eacceptable for o Colorado Regulation 7 Section XVll requres produced water smog toles h(1".un lissactYd., ily0C .5f00,5gie.aterthan 5 tpy to be controlled wth an enclosed combustion deuce This control requrements also aonsdered to beoACT fOr yoducedwatertanks inthe ozone now -attainment area. ln-thisNst? cis uncontrolled e0000li4Ceimlys,oni(torn she produced w"te,tank are less than 5tpy. As a res011,. the sourCe oot rep recto be controlled Lbrough elthe00egulatibn 7 "or RAC 1, 5, Thee erbtorwas prowdedwith a draft permit and APEN redline to r ew o5or pub c , en[ Theo nnmen on rev comn p�ra[or reviewed bandac,. sand expressed they had no menu on the MEN redline and provided one cprtsmenTon." the draft-permlt:Th menf-0141,0d aiss.the.pivisioess r esponse are ssfollows.(flComment Permit Condition 1:Requirement to Submit a Notice of Startup (NO5)—1 have also 500110 II an eNOS for theproduce0Waterstorage -tanks toassoci9YethertgtiEe of:ster040Ytl theirresp c4vepermtt 'timber .in1A1RS I(L Can this: 00rmie condition please b'r mull dll ha e attached d copy of the enlOS for your review. Response: Thank you luopruvdllieacopyofthe etiMsubm10000 t84toi,icvlly.9,j,eXtleNO3 has':',been submtttedtgth_ D lsion, the cond'0onhas peen removed from the mica. requested. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Pointe 002 Process e m 5CC Code 4-04-003-15 Feed Roof Tank, Produced Water, working+btnethmg+flashing losses Pollutant Uncontrolled Emissions Factor PM10 0,00E+00 PM2.5 0140000 NOx - 0:00₹+00 VOC 2.010-01 CO 0.0001100 Benzene 02.56E-02 Toluene 3.100E-02 Ethylbenzene 1.00E-03 Xylene 9.34E-09 n -Hexane S.7'70.04 224 TMP 0.00£+00 Control % Units O b/1,000 gallons liquid throughput O 6/1,000 gallons Iiquidthrouehput O b/1,000 gallons llquidthrqughpot O 6/1,000 gallons liquidthroughput O b/1,000 gallons liquid throughput O b/1,000 gallons liquid throughput O b/1,000 gallons liquid throughput O b/1,000 gallons liquid throughput tl b/1,000 gallons liquid throughput O b/1,000 gallons liquid throughput O b/1,0%X1 gallons liquid throughput 3 014 Ki\PA\2019\19WE0799.CP1 Produced Waterstorage Tank Regulatory PnalysIs Worksheet please note that NSPS Kb might be might be applicable for certain tanke et watermina/modem, Irdedbn 6altie..113h. tents you are rsvbwing ere et one of them facilities, please review NSPS Nb. Ce?an. Ilse bha Pam A and a-nagxend permit aequlamems IS,.e:., w In%Fa KfTAINIMNT dual minions from anydam pduamslmmNU Idlvuualaoumeernaid than ETP IReeufition S. Pan, sealun 11.o1e7t 1. the Inks than lu crude d and Is the rant looted eta mnmmmw.lfacility for procctsngob and gas mutant. (Regulation 3, Pane,smimll.o.l.a7 3. Aretmal fadl0yumamrol4dwembalom', at. -thane env, uargruta.dun loin' oreo emleswnareatertFan loTsv illegulauon 3. Pan a section .31i Ha Indhmadtxteo-tee Ion the NanA.ahmnemz-ea NONAVAININIENT Ana uncontrolled�. pd,uents from the Individual aouaewtes TPv Igeguletlonl,Partgsnlonll.o.leli 2. Is Ole cede. then %dN N ncmdedl and etank located mnamaw at a mlfidllry red pmmsingoe and gas was... iRes"UaPvt..... m 3. Pvt....11.0.1.M1 3. Are muihal uncontrolled weenbsbre eivtothanx iIN, NO: gtiterthen 5rworc0 =lesions areatethan 30 'MY lliwhtbne. Part e,xtlor ll.o.3)x Iaa.ra „,„rose ec„m.. Colorado 1. la NY tank mllsslm/at»gefeadiryr a. is dIF Prdu=a lee Plea dpa exploration enal porn* po .weu wpdmwn feelihi, natural Rae wmmcr- m.erinatural rv� paey Plant. 3. U. prdutd nkl 4. Aro oncontrdled actual ...Wm,' atoragetank equal to orgreater than a tons puree,. Iwo: Section XVII.. —Gummi Provisbris for Air Pollution Controlrot and Prevention ofE....a Section xvil.C.1.....lons cceltrel end boo 5. bees the produced water store eta.caltaln onl "eehllhd'll Weis nrUrutsuye<:een add, Sedan -Cm ne Or5tanceiankt and with Alr Pdlution mewl FqulPmort 40CfP, Pert ab,5Wpae COM, Siederda of performance to, [rd. Oil end Natural sea nedudlereTransmhahan and blmf4rnon a produced water stoasevessel located ace facility lnthe onshore dl ad mural gas production uralps processing segment or natural gastnnsmbaloc andetorageseemeetdthe Ibdmvvl 2. Washe produced construct. reconstructed, ormdindls.eddnniona 40 CM,fi011between August 23,1011 adSepernnbo 111,x015? 3. e.Ndtddualn ualtp year? a. ...Ws prduW water store mad the chnhlan ol"gam�uwd' pveo5430? I5to - 24,SM:O. Subpart 0.General ProvUlpns per. 0.5425 Table3 40.3S95. -Emissions rant. shda. fo-wC 460..5413 -ceding end Procedures 46o55aslal-uall4.non, ner.oning and Pemdkapre gmWarnaas 560.341001 -Conrad Clad vent swtum Monitoring Requirements §6D.3417 -Control Device nonaorina Requirements INo.eel I mewudy dasrmind to be euaed to NSPSO000 du to*May .ilea. an per yamV.on.s...1311ny date neuon d.te, It should ameNeublento NSPSCOO0 per ao551151e1131 even!, polendei voc *Wagon drop below a tom pm,. dl ,V3 CPR, Pen so,s,e1part. Oces,Stenclarde for.. Oil and HatursIGea anuatlan Commented After Septamiler 1e, x015 1. WasFig product erred constructed, dlseadel nnlonis 40 CP, s0.xlafter Septmbv11110151r 1. tas produced water staageunstl men the definition of"dotage vessel"' per 300? le roihh agdb%sd wat.sirmvmfl 1.04 at a really In Ole a... and neural ga.producton eegmentnatural eas',Mimsng segment penal., vs transms.on endmnaseseementd the Indurl'y7 4. Ara potmnal VOL missions from the Incilirlduel storage veasel welter then crewel tee tom per vet 5. lathe east with reerrbenementaiore menials an Parta05wnrtma..4odm Pert e3 Su Mil. ISa- ere ra..,araw:laate.l-2._a�oa AARr.vl.w Ira required a Regd.vanx eeae rot apply/ND nm.tenkb ndre mnetanm.rrt ere• lithe tank meld. lea), ulted. then avl.w RAErrequhaman. Oleclelenar r22 doouarenl mills apace,. Palm calrmfning applkablly of cwleln re0ubamenls coma Clean ACAnq Ile Implementingmguklbns, end ANoveIM ConfmlComMsskn mpulefbns. This tlocumenl anl SOY lo a particular satiation 9..2, Me 1.10.21 facts 20 ckumslancm This docigneryt does not change CY substitute for nylaw regulation. other legally binding reguremel and is rml Ngelb nAxcenbh.ln the avant clang corm, between lha language eggs document err,the language oldie Glean Pie. 024.Itshwlementig reguMbns. and Ar Ouebly Cant. Commission regulations. the language Willa stalule orra9uklkn Wlcnbd. ...C. of naa0endefmy Mguageauch ea Yem� mmdmay "shock' and 'can' Is Inland., to describe APCOingwpmmllons and recommendations. Mandatory le minhgy each as 1ws1 and haqu4M ere Wan. la describe 00 49rp amphorae,. undo, the farms of the Glean A4 Act end ANOually Conhd CanchIssbn(2900bns, Dug Cisdocumanl acesnleChilAsh k(ally binding requberne0x k and 0502?!. yes Aom rce AMEN. Go to the neat questron Got° newt connnue-You have d the mace otegory on the',gaa Summery ContInue-Vouhave Indoted melecihy hmeonthe pram mmarysMs. Co to the newt civet. smagerank 1. nd sus. toaegulenan?,sewlan Mvll tomgeTeals not sugerttonegu1nke l.smb#MVII.L2 row hew mdl.0d roc enure category n me Pram snmmaa a oat. 5twaeeTank le not suged NSP50oob-Mb tenkwes constructed onside dtheapglabllity date. GI:110.161,. question storapeTank 1. non sugar 152500002. 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1GtWEerNg AIRS ID Number: 123 iftOl l X60 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Ottenhoff 29 Sec HZ Site Location: NENE Sec 29 T5N R64W 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 Address2: 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. RU 1t vtd 1\21661 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 1 I K �� Permit Number: ICI OE 01-1'; AIRS ID Number: its 'A -/ O [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action lI NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit D Request coverage under a General Permit ❑ GP01 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) 0 Change in equipment 0 Change company name3 O Change permit limit 0 Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) 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: Condensate Storage Tanks Company equipment Identification No. (optional): TK-1 For existing sources, operation began on: 04/29/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑� Exploration & Production (E&P) site 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? I9 Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? II Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.003603 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No 0 ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIgi emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ®V 'COLOR ADO 2 I ix.,m y,«nc of nnic, ' H.ali1kFEr.vl.amm�v, Permit Number: 'ct ()Tit AIRS ID Number: p /A041/ co' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 1,295,335 From what year is the actual annual amount? Projeced Average API gravity of sales oil: 51.6 degrees LI Internal floating roof Tank design: ❑✓ Fixed roof 1,554,400 RVP of sales oil: 9.1 ❑ 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 20 10,760 8/2018 4/2019 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43639 Ottenhoff 29M-263 0 05 - 123 - 43646 Ottenhoff 29M-353 17 05 - 123 - 43647 Ottenhoff 29R-203 19 05 - 123 - 43643 Ottenhoff 29R-253 BI 05 - 123 - 43641 Ottenhoff 29R-303 19 s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.37596 / -104.56816 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) N/A Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) o Circular ❑ Square/rectangle O Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ,COLORADO 3 , e• Department Env Permit Number: MLLE C5+9 ? AIRS ID Number: � )- icl / col [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor 0 Recovery Unit (VRU): Pollutants Controlled: VOC & HAPs Size: Make/Model: Flogistix Compressor Requested Control Efficiency: 100 VRU Downtime or Bypassed (emissions vented): 25 ❑ Combustion Device: Pollutants Controlled: VOC & HAPs Rating: MMBtu/hr hr Type: Enclosed Combustors Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 98 10 x Cimarron 48", 1 x Cimarron 60" Waste Gas Heat Content: 2,567 Btu/scf MMBtu/hr O.ot O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19.2 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator 7,.''f v ?oiaje-ck (y,,i W 1cdionS . Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 t1IL5lIq (COLOR ADO 4 1 A- F..0 Permit Number: tQ Oep. p AIRS ID Number: l.t-S 1,401-/ L73' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form?. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C Enclosed Combustors and Tank VRU 98.75 % • NOx CO HAPs Enclosed Combustors and Tank VRU 98.75% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP -42, Mfg. etc) ) Emissions (Tons/year) Emissions$ (Tons/year). Emissions (Tons/year) Emissions (Tons/year) VOC Iblbb Iwl ,q5 t5 / 10.13 m.+•lyoG ?ro,0•x `Ai tL 1263.90 • 15.80 • 1516.68 ' 18.96 ' NOx 0.113$ lo•M, Ib/MMBtu ¶CIQ(,4 -tii. ►4AA4 1:45. a -a9 (.`tS +VA i.FL 178₹ t.1 -7 - Co o.L}cc ` 0.31 Ib/MMBtu 1c Q1g-`'Z, #' '•oy 2 7 So .% NA 3.91 3:33 3.55 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (Pounds/year) Benzene 71432 0.0048 • Ib/bbl ProMax 6,195.64 • 77.45 • Toluene 108883 0.0058 • Ib/bbl ProMax 7,510.65 ' 93.88 . Ethylbenzene 100414 0.0002 • Ib/bbl ProMax 243.09 (DM) • 3.04 (DM) • Xylene 1330207 0.0021 • Ib/bbl ProMax 2,772.03 • 34.65 • n -Hexane 110543 0.0420 • Ib/bbl ProMax 54,405.60 ' 680.07 • 2,2,4- Trimethylpentane 540841 5.88E-05 Ib/bbl ProMax 76.12 (DM). 0.95 (DM)* 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 71c. 1vv.,5 ?or q -e co-kwla r'titnto, Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 X05 tt�•t,�I�� COLOR A DO 5 1 v En+ Permit Number: `clLoan-oN AIRS ID Number: (- /AO -19/ co1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Zd Sign : re of Legally Authorized Person (not a vendor or consultant) Date Jack Starr Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: ❑� 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-B1 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 Or visit the APCD website at: https: / /www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6I Ay COL08o[ DAD0 OL O Haa Fnrlmnmun� E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: PDC Energy, Inc. Source Name: Ottenhoff 29 Sec HZ Emissions Source AIRS ID2: / / 123 - R0101-00 I Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 43645 Ottenhoff 29R-323 1� 05-123-43642 Ottenhoff 29R-353 05 -123 - 43640 Ottenhoff 29R-423 1 05 -123 - 43646 Ottenhoff 29U-243 0 05 -123 - 43644 Ottenhoff 29U-343 - - ❑ - - ❑ - - ❑ - - ❑ - - � - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ . - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 TK-1 Addendum 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store 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-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /� AIRS ID �t l of W�' 01 0 Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': pDC Energy, Inc. Site Name: Ottenhoff 29 Sec HZ Site Location: NENE Sec 29 T5N R64W 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 Address2: Jack Starr (303) 860-5800 Jack.Starr@pdce.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. gui vtA I \2Q 11 � Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 1 _ o �u _ Permit Number: 'ci tzE0-1-91 AIRS ID Number: `-Lt / / cot [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 o Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a 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. 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: Produced Water Storage Tanks TK-2 4/29/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 0 Exploration Et Production (MP) site days/week 52 weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ✓ 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 p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 ',COLORADO 21 •' �e r Ha�Yi1.b Few' Permit Number: kquD6 64-e AIRS ID Number: -j /AO1/ OO2.- [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 270,825 Requested Annual Permit Limits (bbl/year) 324,990 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof Projected O 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 10 3,620 12/2018 4/2019 Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites Only) API Number Name of Well Newly Reported Well 05 -123 -43639 Ottenhoff 29M-263 1 05 -123 -43648 Ottenhoff 29M-353 ✓ 05 -123 -43647 Ottenhoff 29R-203 ✓ 05 -123 -43643 Ottenhoff 29R-253 ✓ 05 -123 -43641 Ottenhoff 29R-303 ✓ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.37596 / -104.56816 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) N/A Indicate the direction of the stack outlet: (check one) ❑ Upward 0 Horizontal ❑ Downward ['Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 3 I A7Department o oP.blic Fns Permit Number: tze Q19q AIRS ID Number: in / / 007_ [Leave blank unless APCD has already assigned a permit # 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 0 Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: Rating: Type: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: % Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EttP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19.2 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLOR ADO 4 of Puck Permit Number: V:\ LO O -V 9°I AIRS ID Number: . /A0 / 007_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC NOx CO HAPs Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Ye ) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) to Controlled Emissions (tons/year) VOC 0.0114 • Ib/bbl ProMax 1.54 • 1.54 . 1.85 • 1.85 , NOx CO Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS ( ) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) (pounds/ ear Controlled Emissionsg (pounds/year) Benzene 71432 0.0011 . Ib/bbl ProMax 291.53 • 291.53 • Toluene 108883 0.0013 • Ib/bbl ProMax 359.16 . 359.16 . Ethylbenzene 100414 ci•71xio 5 Ib/bbl ProMax 12.25 (DM) . 12.25 (DM) . Xylene 1330207 4.13E-04 Ib/bbl ProMax 111.95 (DM) • 111.95 (DM) • n -Hexane 110543 2.42E-04 Ib/bbl ProMax 65.58 (DM) . 65.58 (DM)• 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 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 emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 �vi COLORADO fioalffiE Faw' Permit Number: E c1.o`c1 AIRS ID Number: i /Aci-q/ O07 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit 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. A AC -q/z≤-720(g Signat a of Legally Authorized Person (not a vendor or consultant) Date Jack Starr Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 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 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 AVCOLORAQO 6I E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: Ottenhoff 29 Sec HZ Emissions Source AIRS ID2: / I 12?) -P- (n a " O0Z Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 43645 Ottenhoff 29R-323 1 05 -123 - 43642 Ottenhoff 29R-353 a 05 -123 - 43640 Ottenhoff 29R-423 4 05-123-43646 Ottenhoff 29U-243 4 05 -123 - 43644 Ottenhoff 29U-343 I� - - ❑ - - ❑ - - ❑ - - ❑ - - - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 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-2 Addendum Hello