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Home My WebLink About20192277.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 June 10, 2019 Dear Sir or Madam: RECEIVED JUN 1 4 20e2 WELD COUNTY COMMISSIONERS On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Sandin 24 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MPH, Executive Director and Chief Medical Officer 4�b1�G9\03-tetio PPvi4\ rfAtICAA IGVt� (p/IMitq 2019-2277 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Sandin 24 Sec HZ - Weld County Notice Period Begins: June 13, 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: Sandin 24 Sec HZ Well Production Facility SWNE of Section 24, Township 5N, Range 65W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for twenty-two (22) 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 18WE1191 &t 18WE1192 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public- notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO %paths Ervixos st Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Harrison Slaughter 389725 11/9/2018 4/9/2019 Section 01 - Facility Information Company Name: PDC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range SWNE 24 5N 65 Plant AIRS ID: Facility Name: Physical Address/Location: County: A00C Sandin 24 Sec HZ SWNE quadrant of Section 24, Township 5N, Range 65W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? n Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TK-1 Yes 18WE1191 1 Yes Permit Initial Issuance Section 03 - Description of Project PDC Energy Inc. (PDC) submitted an application requesting permit coverage for several new sources at a new synthetic minor oil and gas well production facility located in the ozone non - attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced \Aster storage vessels, hydrocarbon loadout, and natural gas fired RICE. The RICE are obtaining permit coverage under the GP02, and the loadout is obtaining coverage under the GP07. Thispreliminary analysis only addresses the twenty-two (22) 538 barrel condensate storage vessels. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A,Section II.B.3.a.). Additionally, the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation 3, Part B, Section II.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements, and the change in VOC emissions as a result of this project is greater than 25 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? 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) SO2 No Yes NOx CO VOC No PM2.5 PM10 TSP HAPs NOx CO VOC PM2.5 PM10 TSP HAPs i Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County AO0C Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Twenty-two (22) 538 barrel fixed roof condensate storage vessels connected via liquid manifold. Vapor recovery unit (VRU) routes emissions to pipeline. Emissions are routed to enclosed combustor(s) during VRU Description: downtime. Requested VRU Control Efficiency %: VRU Operational Hours (minimum): Requested Enclosed Combustor Control Efficiency %: Enclosed Combustor Operational Hours (maximum): Requested Overall VOC & HAP Control Efficiency %: 100 5256 hr/year 95 3504 hr/year 98 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= (Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput Requested Condensate Throughput during VRU downtime: Actual Condensate Throughput during VRU downtime: Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 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 1,616,690 Barrels (bbl) per year 1,940,030 Barrels (bbl) per year 1,940,030 Barrels (bbl) per year 776,012 Barrels (bbl) per year 646676 Barrels (bbl) per year 2300.17 Btu/scf 21.74239 scf/bbl Will this storage tank emit flash emissions? ProMax Flow Rate Yes 1,616,690.00 bbl/ ear Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput = 161770 Barrels (bbl) per month 32,341 MMBTU per year 38,809 MMBTU per year 38,809 MMBTU per year Pollutant Flash Gas (lb/hr) W&B Gas (lb/hr) Total Waste Gas Rate (lb/hr) Source VOC 267.3898356 35.47346767 ProMax Benzene 0.706258 0.0606157 0.7668737 ProMax loluene 1.07133 0.0985361 1.1698661 ProMax Ethylbenzene 0.0352964 0.00354768 0.03884408 ProMax Xylenes 0.409175 0.0542134 0.4633884 ProMax n -Hexane 6.18358 0.792507 6.976087 ProMax 2,2,4-TMP 0.0194186 0.0024149 0.0218335 ProMax Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 1.64106 0.032821 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 4.155E-03 8.311E-05 Toluene 6.339E-03 1.268E-04 Ethylbenzene 2.105E-04 4.210E-06 Xylene 2.511E-03 5.022E -OS n -Hexane 3.780E-02 7.560E-04 224 TMP 1.183E-04 2.366E-06 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 3.73E-04 AP.42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) TNRCC Flare Emissions Guidance (NOx) 141.. f)al ' Emissions Guidance (CO) PM2.5 0.0075 3.73E-04 NOx 0.1380 6.90E-03 CO 0.2755 1.38E-02 Section 05 -Emissions Inventory 1,616,690 Barrels (bbl) per year I Controlled Emission Factors Used In Permit Pollutant Controlled Emission Factors used during VRU Operation (lb/bbl) Controlled Emission Factors Used During VRU Downtime (lb/bbl) Source VOC 0.00 8.20529E-02 Site specific E.F. Benzene 0.00 2.07764E-04 Site specific E.F. Toluene 0.00 3.16945E-04 Site specific E.F. Ethylbenzene 0.00 1.05238E -O5 Site specific E.F. Xylene 0.00 1.25543E-04 Site specific E.F. n -Hexane 0.00 1.88999E-03 Site specific E.F. 224 IMP 0.00 5.91522E-06 Site specific E.F. Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly tirnits Controlled (Ibs/month) VOC PM10 PM2.5 NOx CO 1591.85 1326.5.1 26.53 1591.85 31.54 5408 0.14 0.12 0.12 0.14 0.14 25 0.14 0.12 0.12 0.14 0.14 25 2.68 2.23 2.23 2.68 2.68 455 5.35 4.45 4.45 E.35 5.35 908 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene 8061.38 6717.31 134.36 806!._3 161.23 12297.65 10248.03 204.96 12_-17.05 245.95 408.33 340.27 5.81 408.33 8.17 Xylene 4871.14 4059.28 81.19 487!.t1 97.42 n -Hexane 73332.70 61110.52 1222.21 73 32.: ^ 1466.65 224 IMP 229.51 191.26 3.83 22'.51 1.59 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVILB, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 NSPS 0000a Storage Tank is not subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 4 K:\PA\2018\18WE119LCP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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 N/A - operator developed site specific emission factors. Section 08 - Technical Analysis Notes 1. The secondary combustion emissions are calculated using the waste gas flow rate and heat content predicted by the model used to establish the site -specific emissions factors. Based on the ProMax simulation the total waste gas flow rate was predicted to be 0.0963033 MMscf/day (Flash and W&B gas). Additionally, an average heat content was determined u sing the heat content of the flash gas stream (2285.96 Btu/scf) and the W&8 stream (2413.94 Btu/scf) and the following equations: Average Heat Content: [(2285.96 Btu/scf)•(0.08561 MMscf/day)/(0.0963033 MMscf/day)l +1(2413.94 Btu/scf)•(0.0106933 MMscf/day )/(0.0963033 MMscf/day)) = 2300.17 Btu/scf Using this information, the actual yearly heat input of the gas is calculated as follows: Heat Input (MMBtu/yr) = (0.0963033 MMscf/day)•(365 day/year)•(2300.17 MMBtu/MMscf) = 80,852.617 MMBtu/year. It should be noted that emissions from the storage vessels are generally routed to pipeline through the use of a vapor recove ry unit (VRU). As a result, combustion emissions only occur when emissions from the storage vessels are routed to the enclosed combustor(s) during VRU downtime. The operator has indicated that the VRU is down for 40% of the time during the calendar year. As a result, the actual heat input routed to the flare is calculated as follows: (80,852.617 MMBtu/year)•(0.4)= 32,341.0468 MMBtu/year. The GOR used in the combustion calculations in Section 03 above was calculated using the following equation and data from the ProMax simulation: GOR Calculation: [(0.08561 MMscf/day)+(0.0106933 MMscf/day))•(365 day/year)/(1,616,690 bbl/year)*(1,000,000 scf/MMscf) = 21.74239 scf/bbl Typically, the operator uses the following equation to calculate the annual heat input: Heat Input (MMBtu/yr) _ [Uncontrolled VOC (ton/yrj)•[2000lb/ton)/[MW (Ib/Ib-mol)1•[379.41 scf/Ib-mol)'[1/VOC wt %)•[Heat Content (Btu/scf))'[1MMBtu/1,000,000 Btu). The operator expressed the values for molecular weight, VOC wt% and heat content used in the equation were developed by evaluating multiple flash gas analyses in ProMax. The values used in the equation areas follow: (i) Molecular weight: 38 lb/lb -mol, (ii) VOC wt %: 68%, (iii) Heat Content: 2000 Btu/scf. Using these values, the operator calculated an actual heat input 0177,902.39 MMBtu/yr. As discussed above, combustion emissions only occur during the 40% VRU downtime. As a result, the operator calculated heat input is scaled as for lows: (77,902.39)'(0.4)= 31,160.956 MMBtu/year. Since this value is less conservative than the value calculated above using prescribed methods, the operator is required to use data directly from the simulation to calculate corn bustion emissions. 2. The site specific sample used to establish emissions factors for this source was obtained within a year of the application. The sample was obtained from the Sandin 24N-221 well on 10/16/2018. This well is one of the eleven new wells drilled at this facility. As a result, the permit will not require initial testing in order to obtain a site specific sample. It should be noted that the sample includes sample probe temperature and pressure in conjunction with gauge pressure and temperature. According to lab information, the sample probe temperature and pressure are obtained using la b equipment during the sampling process. These values are expected to be more accurate compared to the gauge values and are acceptable for use in the simulation to establish site specific emission factors. 3. Please reference the APEN submitted on 11/09/18 for a list of the eleven new wells at this facility. The wells associated with this tank battery were fractured in July 2018 and began production between August and September 2018. ten of the eleven welts at this facility produce from the Niobrara formation. The eleventh well produces a commingled stream from the Codell and Fort Hays formations. The sample used to establish site specific emission factors was obtained on 10/16/18 from a well that produces from the Niobrara formation. Since the sample was obtained after t he wells at the facility began production, it is acceptable for establishing site specific emission factors. 4. The permit wilt not contain initial or periodic opacity testing for the flare because the O&M plan approved for this source requires weekly visible emissions observations of the enclosed combustor(s). Further it was deemed unnecessary to require an initial Method 22 opacity test because the enclosed combustor(s) serve as back -up control devices that only control emissions during VRU downtime. As a result, requiring the operator to operate the back up control simply to conduct an opacity test was considered counterproductive. 5. When review of this application began, the operator provided a copy of the electronic notice of start-up submitted for this source. The copy of the electronic notice indicated it was received by the Division on 04/17/19. As a result, the condition requiring the operator to submit a notice of start -up as part of the self -certification process was removed from the permit. 6. The operator provided the following information regarding the 300 bbl LO control tank listed on the facility diagram: The vessel on the facility diagram labeled `300 bbl tO Control Tank" is the knockout tank for the facility's loadout flare. Vapors from truck loadout are first routed to this tank, and then to the flare dedicated to controlling loadou t activities. Any emissions associated with this tank are accounted for by the loadout emissions it is not normal operation for ANY condensate to enter this tank In the unlikely event liquid condensate occurs within the tank, either from the condensing of vapors or the flooding of the tank -truck vapor line due to overfilling, the liquid is immediately transferred from the knockout tank to the condensate storage tanks." This information indicates any potential emissions associated with this vessel are appropriately accounted for in the application. 7. According to the application, emissions from the storage vessel are routed to a sales pipeline through the use of a vapor recovery unit (VRU) during normal operation. During VRU downtime, emissions from the storage vessels are routed to enclosed combustor(s). The operator has indicated the vapor recovery units are down for 40% of the time during calendar year. During VRU operation, the operator has requested a control efficiency of 100%. During VRU downtime, the operator has requested a 95% control efficiency for the enclosed combustor(s). Since the control devices ha ye different control efficiencies the operator will be required to track VRU downtime in conjunction with condensate throughput during VRU downtime in order to demonstrate ongoing compliance. The permit will contain a VRU down time tracking condition in conjunction with a process limit on condensate throughput during VRJ downtime. 8. The permit will contain two process limits. One limit will reference total requested condensate throughput (1,940,030 barrel/year). The second limit will reference total condensate throughput during VRU downtime (776,012 barrel/year). The limit on total condensate throughput incorporates all the throughput that occurs while the VRU is operation al. In the event the VRU has less than 40% downtime (i.e. the condensate throughput during VRU downtime is less than the requested limit), the operator should remain in compliance with the emission limits because the VRU is requesting a 100%control efficiency compared to the 95% control efficiency associated with the enclosed combustor(s). As a result, less VRU downtime is beneficial both for the environment and the operator. 9. The controlled VOC and HAP emission factors in Section 04 above are based on the overall control efficiency associated with the VRU (100% control) and enclosed combustor(s) (95% control). However, these emission factors are not the values that will be in the Notes to Permit Holder section of the permit. The Notes to Permit Holder in the permit con tains two sets of controlled emission factors. The first set represents controlled emission factors that must be used when emissions are routed to the VRU. Since a 100% control efficiency is applied when emissions are routed to the VRU , the emission factors for this scenario are all represented as 0.00 lb/bbl. The second set of emission factors represents controlled emission factors that must be used when emissions are routed to the enclosed combustor(s) durin g VRU downtime. These emission factors represent the uncontrolled emission factors multiplied by a 95% control efficiency. The controlled emission factors represented in the permit are calculated in a table in Section 04 abo ve labeled "Controlled Emission Factors Used In Permit." 10. As discussed above, combustion emissions do not occur when storage vessel emissions are routed to the sales pipeline via VRU. As a result, NOx and CO emission factors are not included in the permit for this operating scenario. 11. Prior to public comment, the operator was provided with a draft permit and APEN redline to review. The operator reviewed both documents and provided the following comments: (i) APEN Comment: "It looks like the VOC emissions have been redlined to reflect the emissions mass flow rates from the ProMax report, as opposed to the emissions out put shown on the process flow from the first page of the report. While t agree with this update (though I'm not entirely sure why ProMax doesn't show the same emissions in both places), when using the redlined values I ba ck calculate an uncontrolled VOC emission factor of 1.6411 lb/bbl. This seems to also be reflected in Draft Permit 18WE1191. Even though it's a fairly negligible change, can we redline the APEN for point 001 to show the emissio n factor as 1.6411 lb/bbl instead of the original 1.6409? if you find this change acceptable, please let me know if you need anything from me," Response: This change has been made as requested. I've attached an updated copy of page 5 from the APEN for your records. (ii) Permit Comment 1: 'Condition 9 - Can the definition of VRU downtime be changed? PDC would like to propose the following language: " The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime shall be defined as times when the condensate storage vessel emissions ore routed to the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condenso to 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. " Response: I agree with the requested update to the definition of VRU downtime. The language has been updated as follows: "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 condensates torage vessels are routed to the 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 co mpliance with the process and emission limits specified in this permit." Please review the update and let me know if you agree with the changes. (iii) Permit Comment 2:'Note 6 to Permit Holder — Can the first half of the equation to calculate controlled VOC or HAP emissions be removed as it relates to emissions during VRU operation and will always equal zero regardless of the inputs/actuals used? PDC would like to propose the following equation: Controlled VOC or HAP (lb/month) = ((Condensate throughput,,,, a, , bbl/month)•(Uncontrolled EFL «,a„ Ib/month)•(1.95%)1." Response: After reviewing the note under the emission factor table, I do not believe the equation provides any additional clarity for c alculating actual emissions in this instance. I believe the controlled emission factors in the table along with the note are sufficient without the equation. As a result, I would propos e removing the equation in its entirety. Please let me know your thoughts. The operator reviewed the responses provided, expressed they agreed and had no further comments. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 001 Process p 01 5CC Code 4-04.003-11 Fixed Roof Tank, Condensate, working+breathing+flashing tossgga„mj Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.07 39.1 0.13 9.89E-02 1.51E-01 5.01E-03 5.98E-02 0.90 2.82E-03 Control % Units 0 lb/1,000 gallons condensate 0 lb/1,000 gallons condensate 0 lb/1,000 gallons condensate 98 lb/1.000 gallons condensate 0 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate 98 lb/1,000 gallons condensate throughput throughput throughput throughput throughput throughput throughput throughput throughput throughput throughput 3 of 4 K:\PA\2018\18W E1191.CP1 CendeIPNTa kk..NLTeryi ...Wed. mead. l...ar •... uh. n. 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MM... n.ea _ samara• t rn Iw•rp e.� d.;mw,Api�a eWn 2.,01,7 rM� 0.5413 dpve. 11.05.17. e u n5atewPme'.Nr m n1e• a.•an•rrp vocwas rra.Nra ..wawa Oltrwa m.N..CI ae N.PelVrnaPay Ml wx p aavacml•e a•p Imaw p r•I Y MC Wort MOSAp R.1 ACM 10.0 MN nooc. Mad MR .Cr a 00.0M ea6ma enapal nwf.n nW 4uif, ao.o amenawe5in e.w.hs P.ppP rP p�mrnaramm tr ' we n Ma p lrrs u n i nW or, rep a ...r..unagau .^nn nnmm' b n n ••1 Pcn.nU W. nnewcn.xaPn ap nv leol am•Isegnetopmerr. Ir... WWI032001 MCA ml n'r • va 'which mar w t•Ir to Ms. M .01.0...• I a M.. 03760.1101p Ibru.p up ▪ nu u Yob .1005 by nn rues nobler11 01. mIAAL ml .010 II0.117 .2 SALTS Me 10 a Pins .OM, ▪ aacT.emn •I.aorN.e•tpemrs •.axvaa.wr.a.rwe.w.wt A.•n.we..e...iaur a..ucT..ra mem. Thl papal Wt CyCtTNw nnarnrer•SPsn• w� Inpmorartgcau.ria.i CWmtLd meN..l•rq I pan TIv ..'m.. navreS& rarroum+W,v bl ral�b la m ON NPr�eten geenaen mamv a<rin Nvm�Ns.brear�;v,tn IN rry all .0. bvno � W�fe�M.. NT Npa nNhsree I Irreervabiz mrrerm�um. I�ih,mr �wtammwe oy mu r.d may 21..y. wtai ncrn,v Query.. caurn.r,CCNwl but. mvmrn ♦oulbdaeeww Nara, ad Nmu uec `ur hmw•Namm0m ngm a•.r.ea. Cole. um. IN W a •Nae IIrOY1I IC N x Ttrm Was.. I aae 6.0 it rtle Sten, kJ at. cl.00 NA NA Cot th 01 wee .rear YI ....5nmY. QWnn• V N•1 ebWth n.reegr u mnaWarnnrr. Na �'- NA'° NN nwi YI nrel c,.1 e n n rncrxxmanm an e Y ' n nw COLORADO Air Pollution Control Division Department of Pubic Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1191 Issuance: 1 PDC Energy, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Sandin 24 Sec HZ 123/A00C SWNE SEC 24 T5N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description • Twenty-two (22) 538 barrel fixed roof Emissions from the storage vessels are routed to a sales pipeline through the use of a vapor recovery unit (VRU). TK-1 001 condensate storage vessels connected via liquid manifold. During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of 40% 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 10 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 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 on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator 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 NO,t VOC CO TK-1 001 --- 2.7 31.9 5.4 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 10 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 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. 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 AIRS Pollutants Equipment ID Point Control Device Controlled Emissions from the storage vessels are routed to a sales pipeline through the use TK 1 001 of a vapor recovery unit (VRU). During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of VOC and HAP 40% annual downtime. 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 Parameter Annual Limit TK-1 001 Total condensate throughput 1,940,030 barrels Condensate throughput during VRU downtime. 776,012 barrels 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 enclosed combustors) 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, Page 3 of 10 COLORADO Air Pollution Control Division Department or Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 visualobservation 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 to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubitc Health fl Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Et MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (0EM) 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 0&tM 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 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 5 of 10 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 • 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 asconforming 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 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. Page 6 of 10 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 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 Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for twenty-two (22) condensate storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Pubic 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 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 (ib/yr) 001 Benzene 71432 8,062 162 Toluene 108883 12,298 246 Ethylbenzene 100414 409 9 Xylenes 1330207 4,872 98 n -Hexane 110543 73,333 1,467 2,2,4- Trimethylpentane 540841 230 5 Note: All non -criteria reportable poi utants 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 10 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 5) The emission levels contained in this permit are based on the following emission factors: Point 001: 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 NOx 6.90x10"3 --- 6.90x10"3 TNRCC CO 1.38x10"2 --- 1.38x10"2 VOC 1.641 0.00 8.21x10-2 ProMax 71432 Benzene 4.155x10-3 0.00 2.078x10-4 108883 Toluene 6.339x10-3 0.00 3.169x10"4 100414 Ethylbenzene 2.105x10-4 0.00 1.052x10"5 1330207 Xylene 2.511x10"3 0.00 1.255x10"4 110543 n -Hexane 3.78x10-2 0.00 1.89x10"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 pressunzed liquid sample was obtained from the outlet of the HLP separators on 10/16/2018. The sample temperature and pressure are 118°F and 32.4 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) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a GOR of 21.742 scf/bbl and a heat content of 2,300.17 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. 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: Page 9 of 10 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 Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane and Total HAPs NANSR True Minor Source of : NOx Synthetic Minor Source of: VOC 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 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 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Harrison Slaughter Package #: 389725 Received Date: 11/9/2019 Review Start Date: 4/9/2019 Section 01 - Facility Information Company Name: PDC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range SWNE 24 5N 65 Plant AIRS ID: Facility Name: Physical Address/Location: County: AOOC Sandin 24 Sec HZ SWNE quadrant of Section 24, Township 5N, Range 65W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? I I Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point tt Emissions Source Type Equipment Name Emissions Control? Permit t# Issuance tt Self Cert Required? Action Engineering Remarks 002 Produced Water Tank TK-2 No 18WE1192 1 Yes Permit Initial Issuance Section 03 - Description of Project PDC Energy Inc. (PDC) submitted an application requesting permit coverage for several new sources at a new synthetic minor oil and gas well production facility located in the ozone non - attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon loadout, and natural gas fired RICE. The RICE are obtaining permit coverage under the GP02, and the loadout is obtaining coverage under the GP07. Thispreliminary analysis only addresses the produced water storage vessels. The produced water storage vessels are APEN required because uncontrolled requested VOC emissions are greater than 1 tpy (Cobrado AQCC Regulation 3, Part A, Section Additionally, the source is permit required because uncontrolled VOC emissions from all APEN required sources at the facilityare greater than 2 tpy (Colorado AQCC Regulation 3, Part B, Section II.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established in order to avoid other requirements. Additionally, the change in VOC emissions as a result of the project is greater than 25 tpy. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? 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 herE SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) so No Yes NOx CO VOC No NOx L _ PM2.5 • PM10 TSP HAPs CO VOC PM2.5 PM10 TSP HAPs F Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 County A00C 002 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Eight (8) 400 barrel and two (2) 210 barrel fixed roof produced water storage vessels connected via liquid manifold. Emissions from this source are not controlled. 0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 295,293 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Requested Permit Limit Throughput = 354,350 Barrels (bbl) per year Requested Monthly Throughput = 30095 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 354,350 Barrels (bbl) per year Btu/scf scf/bbl Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Ex = O • MW • Xx / C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas • MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 601 and 1 atm MW 37.8 GWR 0.22 Weight Percent (%) Hydrogen Sulfide 0.00 CO2 14.73 N2 3.17 methane 18.27 ethane 8.90 propane 8.24 isobutane 3.53 n -butane 4.27 isopentane 3.57 n -pentane 3.26 cyclopentane 0.00 n -Hexane 2.08 cyclohexane 2.10 Other hexanes 4.94 heptanes 4.78 methylcyclohexane 2.42 224 -IMP 0.00 Benzene 5.55 Toluene 3.71 Ethylbenzene 0.23 Xylenes L13 CS 3.43 0 L52 C10 0.19 Total VOC Wt% 1c0.00 5194 Will this storage tank emit flash emissions, Ib/Ib-mol cf/bbl Yes O MMBTU per year O MMBTU per year O MMBTU per year Emission Factors Produced Water Tank Emission Factor Source Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 1.20417E-02 1.204E-02 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 1.21602E-03 1.216E-03 Toluene 8.12509E-04 8.125E-04 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Ethylbenzene 5.04120E-05 5.041E-05 Xylene 2.46799E-04 2.468E-04 n -Hexane 4.55680E-04 4.557E-04 224 IMP 0.00000E+00 0.000E+00 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM 10 0.0000 PM2.5 0.0000 NOx 0.0000 CO 0.0000 0 2.f K:\PA\2018\18WE1192.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 2.133 1.778 L773 2.133 2.133 362 0.000 0.000 0.000 0.000 0.000 0 0.000 0.000 0.000 0.000 0.000 0 0.000 0.000 0.000 0.0000 0.0000 0 0.000 0.000 0.000 0.000 0.000 0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 430.90 359.08 359.08 430.90 430.90 Toluene 287.91 239.93 239.93 287.91 237.91 Ethylbenzene 17.86 14.89 14.89 17.86 17.86 Xylene 87.45 72.88 72.88 87.45 87.45 n -Hexane 161.47 134.56 134.56 161.47 161.47 224 TMP 0.00 0.00 0.00 0.00 0.00 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage Tank is not subject to Regulation 7, Section XVII Regulation 7, Section XVII.C.2 Storage Tank is not subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 NSPS Subpart OOOOa Storage Tank is not subject to NSPS OOOOa (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to 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 site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Yee Does the company request a control device efficiency greater than 95% for a flare or combustion device? N/A - emissions from 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 08 - Technical Analysis Notes 1. Site specific emissions factors developed for this source are based on a flash liberation analysis conducted on a site specifc pressurized water sample obtained on 09/20/18 from the Sandin 24N-321 well. The results of the analysis provided a speciation of the flash gas, a gas to water ratio of 0.22 cf/bbl and a flash gas molecular weight of 37.80 lb/lb -mol. The flash liberation analysis was evaluated at atmospheric storage tank conditions of 12.5 psia and 70'F. It should be noted that flash liberation analysis only estimates the flash portion of emissions from the storage vessels. How ever, it was determined the working and breathing portion of emissions did not need to be estimated in this instance for the following reasons: (i) Division guidance on developing site specific emissions factors for produced water vessels does not provide information on methods for estimating working and breathing losses and (ii) The working and breathing losses would likely he minimal from produced water storage vessels and not have an impact on the overall emission factor or emissions. 2. Benzene and toluene are the only HAPs with emissions above APEN reporting thresholds (250 lb/year). As a result, they are the only HAPs for which emission factors are included in the permit. 3. Since the operator used the a GOR with units of actual cubic feet/bbl the molar volume of gas is typically converted from standard to actual units. In this case, the molar volume of an ideal gas would have been calculated as follows: (P19/1/T1) = (P2'V2/T2) = (12.5 psia)'(V1)/(530R) = (14.7 psia)'(379 scf/lb-mol)/(520R) = 454.3 scf/lb-mol. In this application, the operator did not choose to make this conversion. Since the molar volume appears in the denominator of the emission factor calculations, the operator's choice to use the standard volume rather than actual volume results in a conservative estimate of emissions. As a result, the operator's calculations are acceptable for permitting purposes. 4. Colorado Regulation 7 Section XVII requires produced water storage tanks with uncontrolled actual VOC emissions greater than6 tpy to be controlled with an enclosed combustion device. This control requirement is also considered to be RACT for produced water tanks in the ozone non -attainment area. In this instance, uncontrolled actual VOC emissions from the produced water tank are less than 6 tpy. As a result, the source is not required to be controlled through either Regulation 7 or RACT. 5. When review of this application began, the operator provided a copy of the electronic notice of start-up submitted for this source. The copy of the electronic notice indicated it was received by the Division on 04/17/19. As a result, the condition requiring the operator to submit a notice of start -up as part of the self -certification process was removed from the permit. 6. The operator was provided with a draft permit and APEN redline to review prior to public comment. The operator reviewed bothdocuments and expressed they had no comments. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 002 Process # 5CC Code 01 4-04003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Pollutant Uncontrolled Emissions Factor Control % Units PM10 0.00E+00 0 lb/1,000 gallons liquid throughput PM2.5 0.00E+00 0 lb/1,000 gallons liquid throughput NOx 0.00E+00 0 lb/1,000 gallons liquid throughput VOC 2.87E-01 0 lb/1,000 gallons liquid throughput CO 0.00E+00 0 lb/1,000 gallons liquid throughput Benzene 2.90E-02 0 lb/1,000 gallons liquid throughput Toluene L93E-02 0 lb/1,000 gallons liquid throughput Ethylbenzene L20E-03 0 lb/1,000 gallons liquid throughput Xylene 5.88E-03 0 lb/1,000 gallons liquid throughput n -Hexane L08E-02 0 lb/1,000 gallons liquid throughput 224 TMP 0.00E+00 0 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2018\18WE1192.CP1 Produced Water Stange Tank Rolulatory Malyst. 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AIAd. ➢, Irrp�lenagnp1*112 arMNQn2ry C,btl Cad*opld .rDl c?u I0Y 00.11211 u1o1 211261000 * •M lm anay,61,Nam nay nN sppy9•park.•r•Wem&Om. upn Ia...aIfah,M circumstances MY docul.enlOws mlc0 ripen whalitut AV any 0w repulalo46aI2S9 aMely NaMngrepuserrenlandu,l 1paMmNxe 011121 event,ay,nrlamwlen N language of . abcmmNatlNe amp.. of Om Chun7Io1d mhpa3211*.ep26mn4 anIA.0 MContdfbnm6onmpuYYnalm Oawew*.Nest,ecrra2WR0Y22*,nbul TM use oln„manda11y 1anpuepe,uc.m mn*aanpmpulsmelmay n we Ns Mu die Cean*AAelebAk0,M be*21317*dn reple0InforprOehons and vin AWNY'duemlritmlma, ml eat.. Aptly 0Yd1O rmwaemenla as na3e ondfiqvrticr ere n Yhand010510 boatel parte MEN Ia.aa39ree .eaa G 1 19.01313 wee9. You wee 210111 19.,001 pe3919.P.W20wmmary lea. Yea ?am kb amdtl.eleGMayemtwPWmSum ary lee. v„1 T eln,11 g209Aft19.15eemhnl fx„cT N14W .Wra.aw1al? l.aen»tic4 PP 4 - Ye b Yet .4 Yaw 39,14 w 20150 of 1,173919.7141205umm 17 9.aI 010211? 1110 u4120Iu0000 Tmadwe„.Ie.mme.e2 14110 p4Yab1Md.12 G to tleraat e.t.a 0 the ambition ft„13T rib ma .4120 04500'10. COLORADO Air Pollution Control Division Department of Pubhc Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE 1192 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Sandin 24 Sec HZ Plant AIRS ID: 123/A00C Physical Location: SWNE SEC 24 T5N R65W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: 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 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 on which such construction or activity was scheduled to commence as set forth in the permit application Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator 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-2 002 --- --- 2.2 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 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. 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 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 Page 2 of 8 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-2 002 Produced Water Throughput 354,350 barrels 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shallbe marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) I. 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 & 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING a MAINTENANCE REQUIREMENTS 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) shall 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 Heath & 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 NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 15. 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 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, 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 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. 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 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 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. By: Harrison Slaughter Permit Engineer Permit History 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 b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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) 002 Benzene 71432 431 431 Toluene 108883 288 288 Ethylbenzene 100414 18 18 Xylenes 1330207 88 88 n -Hexane 110543 162 162 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/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 1.204x10-2 1.204x10-2 Flash Liberation Analysis 71432 Benzene 1.216x103 1.216x10-3 108883 Toluene 8.125x10-4 8.125x1O4 Page 6 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 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 09/20/18 from the Sandin 24N-321 well. The results of the analysis provided a speciation of the flash gas, a gas to water ratio of 0.22 cf/bbl and a flash gas molecular weight of 37.80 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 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, n -Hexane Et Total HAPs NANSR True Minor Source of : NOx Synthetic Minor Source of: VOC PSD True Minor Source of: NOx and CO Synthetic Minor Source of: VOC 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 Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 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 loadings, 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: (SWE f( 11 AIRS ID Number: /Z3 /450C / 06 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Sandin 24 Sec HZ Site Location: SWNE Sec 24 T5N R65W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: 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 APCD via e-mail to the address provided. 3Eg7Z(/- Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 I A,COLORADO .rat= Permit Number: lc6 wE llq 1 AIRS ID Number: /Am] 0©\ [Leave blank unless APCD has already assigned a permit #J and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source p Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit O Transfer of ownership3 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 Additional Info Et Notes: Initial permit request for condensate storage tanks at a new facility 3 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 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: 8/13/2018 hours/day 7 days/week 52 ❑✓ Exploration Et Production (EftP) site weeks/year O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? Ti Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Ti Yes • No If "yes", identify the stock tank gas -to -oil ratio: o 0038_ 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 TA ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 21 COLORADO Ay°�� wuns[nwwun..0 Permit Number: GCE t`�� AIRS ID Number: 6 /tAjr / col [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 Limit's (bbl/year) Condensate Throughput: 1,616,690 1,91,40, o-2. From what year is the actual annual amount? 2018 R,c,1t.A C- r-' v?.o.ked, ca-lLA.) Average API gravity of sales oil: 50.1 degrees 0 Internal floating roof Tank design: ❑✓ Fixed roof RVP of sates oil: 8.2 .l.t')'S 0 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 22 11,836 12/2017 8/2018 Wells Serviced by this Storage Tank or Tank Battery5 (RIP Sites Only) API Number Name of Well Newly Reported Well 05 - 123- 44668 Sandin 24C-201 12 05 - 123- 44665 Sandin 24C-221 igl 05 - 123- 44664 Sandin 24C-241 FA 05 - 123- 44670 Sandin 24C-301 0 05 - 123- 44661 Sandin 24C-321 17 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEP 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) 40.38759 / -104.60873 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward o Horizontal 0 Other (describe): Indicate the stack opening and size: (check one) o Circular ❑ Square/rectangle ❑ Other (describe): 0 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 02/2017 3 A® COLORADO Fe ME: Fnvnmmend Permit Number: 1:?-_,u3E11ck 1 AIRS ID Number: Ala.Tx2 Uc` [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: \IOC- ARs Vapor N. Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: E O� % VRU Downtime or Bypassed (emissions vented): �O % ❑ Combustion Device: Pollutants Controlled: VOC & HAPs Rating: MMBtu/hr 11 x Cimarron 48", 1 x Cimarron 60" Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: p Yes O No Pilot Burner Rating: Z3oo.1Z Btu/scf MMBtu/hr 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 (EEP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 32.4 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator Kr -3 cot- oizto.kr-d Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 �tuJla.{��vlS, ups 051)111,1 eV'COLORADO 4 I nt al Pub. Health tr Entltaunsnt Permit Number: IsuD6\ AIRS ID Number: /AU! oO\ [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 form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) ) Uncontrolled Emissions (Tons/year) Controlled Emissions? (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 1.64t1 lb/bbl ProMax 1,326.c5 -k �,s' 15`11. `ds 31.V-1 NOx 0.1380 _ Ib/MMBtu TCEQ N/A 5.38 2.1,3 N/A 5.38- 2..'. CO 0.2755 • Ib/MMBtu TCEQ N/A 10.73 `(.`tc N/A 7.z.z3 5.1 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor6 Actual Annual Emissions Chemical Name Abstract (CAS ( ) ) Uncontrolled Basis Units Source (AP -42, Uncontrolled Emissions Controlled Emissions7 Number Mfg. etc) (Pounds/year) (Pounds/year) Benzene 71432 0.0042 - lb/bbl ProMax 6,717.79 . 13'-1. 3b Toluene 108883 0.0063 - lb/bbl ProMax 10,247.98 - Zcr-(.gto Ethylbenzene 100414 0.0002 • lb/bbl ProMax 340.28 . 10.531 Xylene 1330207 0.0025 . lb/bbl ProMax 4,059.31 ' 5$1. t'l n -Hexane 110543 0.0378 . lb/bbl ProMax 61,110.40 ' 1,r:z.i.1 2,2,4- 540841 0.0001 • Ib/bbl ProMax 191.27 (DM) 3 •cb5 (1)46‘) Trimethylpentane 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Ca(C0IOKS 1-k S OSf 7-9 Z cr�l; we S Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 COLORADO 5 I x�w a rnv..nnm.m Permit Number: 1Q,LADG\n AIRS ID Number: tiz /,4 / Do1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that alt information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Sig ure 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: O 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 $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Small Business Assistance Program Environment (303) 692-3175 or (303) 692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 https: //www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 I ®'COLORADO =1",;:', E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: Sandin 24 Sec HZ Emissions Source AIRS ID2: ti._ / Ate! co\ Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 44663 Sandin 24N-221 05 -123 - 44667 Sandin 24N-241 6. 05 -123 - 44671 Sandin 24N-301 I1 05 -123 - 44669 Sandin 24N-321 // 05 -123 - 44662 Sandin 24V-341 ►1 05 -123 - 44666 Sandin 24V-401 // - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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.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: /SWE 11 q2 AIRS ID Number: 123 /Aosgc/oo2- [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Sandin 24 Sec HZ Site Location: SWNE Sec 24 T5N R65W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Jack Starr Phone Number: E -Mail Address2: (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 APCD via e-mail to the address provided. 3x7725 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 ®y COLORADO b Env..vn Permit Number: cLt�t 11q7_ AIRS ID Number. 1?- /, j /002 — [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit O Transfer of ownership3 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 Additional Info ft Notes: Initial permit request for produced water storage tanks at a new facility 3 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: Produced Water Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: 8/13/2018 hours/day 7 days/week 52 weeks/year ❑✓ Exploration a Production (EEtP) site O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? 0 Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production• wastewater for processing? Yes No p Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? El 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 GI Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 02/2017 ®� COLORADO 2 I Hyttn b Enn�o, rvn�� aeunvN Permit Number: 1�ue.1\9Z� AIRS ID Number. ( - / 4j/ cuZ, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Produced Water Throughput: Requested Annual Permit Limit4 (bbl/year) 35 4, 30 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof 2018 4ie\tv't-5 pc% ,' A Ca\ - c .-Zio tA-s . 445 oSI 1 O Internal floating roof O External floating roof 11 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 4/2018 8/2018 Wells Serviced by this Storage Tank or Tank Battery5 (Ef8P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 44668 Sandin 24C-201 0 05 - 123. 44665 Sandin 24C-221 l7 05 - 123- 44664 Sandin 24C-241 51 05 - 123- 44670 Sandin 24C-301 121 05 - 123- 44661 Sandin 24C-321 n 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EftP 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) 40.38759 / -104.60873 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) 0 Upward 0 Downward 0 Horizontal 0 Other (describe): Indicate the stack opening and size: (check one) o Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 3 I AV'°`"""`"`°`° ° ` Munn tr Enminvnonr COLORADO Permit Number: 1Qci7C k k7— AIRS ID Number: 17,'` /AMC/ CM__ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ 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 0 No Pilot Burner Rating: Btu/scf MMBtu/hr 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 (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 32.4 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 02/2017 4 COLORADO a�pow c xuiu a rn�m.m�.n Permit Number: 1ScoCiFtZ AIRS ID Number: l7� / Ate/ c cz. [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 form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC NOx CO WAPs Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP-42, Mfg. etc) Uncontrolled Emissions (Tons/ ear (Tons/year) Controlled Emissions? (Tons/year) Uncontrolled Emissions (Tons/year) (T Y ) Controlled Emissions (Tons/year) Tons! ear ) VOC 0.0120 • lb/bbl GWR 4.G91.1 4.C9 -l.1- 1781 ..t3 1.69.2.13 NOx CO Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor6 Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service (CAS) Number Basis Units (AP -42, Mfg. etc) g Emissions Pounds/ ear (Pounds/year) ) Emissions? (Pounds/ year) Benzene 71432 0.0012 • lb/bbl GWR 3S"► '7359 Toluene 108883 0.0008 • lb/bbl GWR "Di O (.i>"t t-I0 (9M Ethylbenzene 100414 0.0001 ' lb/bbl GWR t ( ) is (DM) Xylene 1330207 0.0002 ' lb/bbl GWR 'i-3 (DM.) 1-3 (mewl.) n -Hexane 110543 0.0005. lb/bbl GWR I -S- (. yin) t'b9 Co)y 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. COLORADO IiuIN tr F .tvvnvneni Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 5 I A' Permit Number: t5c t�9Z AIRS ID Number: 1L� /,/ coZ [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. Sign re of Legally Authorized Person (not a vendor or consultant) Dat Jack Starr Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: O 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 $152.90 and the General Permit For more information or assistance call: registration fee of $250, 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 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 6 I AV ..2"`�`^`^`"" H m6N b En�n�unmun, COLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: Sandin 24 Sec HZ Emissions Source AIRS ID2: ith /AsoD,cJ oo 7. -- Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-44663 Sandin 24N-221 a 05 - 123 - 44667 Sandin 24N-241 a 05 -123 - 44671 Sandin 24N-301 1� 05-123-44669 Sandin 24N-321 05-123-44662 Sandin 24V-341 I 05 - 123 - 44666 Sandin 24V-401 a - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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