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Home My WebLink About20162697.tiffCOLORADO 4u6 18 2018 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 1150 O St PO Box 758 Greeley, CO 80632 August 15, 2016 Dear Sir or Madam: On August 18, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - REtR Farms East Pad. 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /. 1, t' 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 Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer i,k lic- 1F�0 ViQ.AA ) �sfa("If l% cc, pLCmm/"fe) pt,J(R ICH/ sTnlC- /la/ICo 2016-2697 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - REtR Farms East Pad - Weld County Notice Period Begins: August 18, 2016 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: REtR Farms East Pad Exploration and production well pad SESW Sec. 29 T5N R63W Weld County The proposed project or activity is as follows: New exploration and production facility for the production of condensate. Natural gas from the wellhead separators is compressed and routed into a sales pipeline. Condensate is routed to twelve 538 -bbl condensate storage tanks. Tank vapors are controlled by enclosed combustors. Produced water is sent to produced water storage tanks. Tank truck loading is conducted by submerge fill; emissions are not controlled. 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 16WE0733 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. Any such comment must be submitted in writing to the following addressee: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 AV OLOR ADO 16WE0733 Construction Permit Air Pollution Control Division Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. R&R Farms East Pad 123/9E8F SESW SEC 29 T5N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 001 Twelve (12) 538 barrel fixed roof storage vessels used to store condensate Enclosed Flares 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/pacific/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.) Storage Tank Version Syn Minor 2015-1 Page 1 of 7 e all i '' ial compliance testing and sampling as required in this ermi : d 5:"" it ' ults ': he 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 shalt not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TK-1 001 --- --- 10.9 1.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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 emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 001 Five (5) Cimarron 48" and One (1) Cimarron 60" Enclosed Combustors VOC, HAPs 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, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 001 Condensate throughput 464,240 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. * COLORADO COIV Air Pollution Control Division V�VV7 unseen n a.. ;c Hnaan e:n:.ec..me Page 2 of 7 STA AND, E R UL t OR; • REQUIRMENTS aa==g ausa 8. 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) 9. 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). 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 12. 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, 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. 13. 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. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COLORADO Air Pollution control Division Page 3 of 7 Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, 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 (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC COLORADO Air Pollution Control Division ;.b}3r'm(: t Y -, Page 4 of 7 Reg4la n m 'er 3t Pa B, Secton II.B. upon a request for transfer of ownership and the 3ubmi of seAi nd thf '?quired fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division Page 5 of 7 No r h :.. ..•, this • 'µ=+ it 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 win 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 (Ib/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 675 34 Toluene 108883 621 31 Xylenes 1130207 259 13 n -Hexane 110543 5383 269 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx --- 0.0038 TNRCC-Flares and Vapor Oxidizers CO --- 0.0076 VOC 0.9399 0.047 ProMax3.2/Site- Specific Sample 71432 Benzene 0.0015 7.50E-5 108883 Toluene 0.0013 6.50E-5 1330207 Xylene 0.0006 3.00E-5 110543 n -Hexane 0.0116 5.80E-4 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Emissions factors for NOx and CO were calculated using 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 COLORADO Pollution Control Division Page 6 of 7 the m r enl a5groated"With ice to dermine the APEN expiration date for each emissions point s erm '"Fdfany Ore Tons 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: V0C NANSR Synthetic Minor Source of: V0C 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 COLORADO Air Pollution Control Division Page 7 of 7 Division Information Engineer: Betsy Gillard Control Engineer: Stefanie Rucker Review Date: 08/04/2016 Application Date: 06/01/2016 Facility Identifiers Permit No. 16WE0734 AIRS County# 123 IWeld Facility # 9E8F Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information Company Name: PDC Energy, Inc. Source Name: R&R Farms East Pad Source Location: SIC: SESW Sec. 29 T5N R63W 1311 Mailing Address Address 1: Address 2: ty, State Zip: PDC Energy, Inc. 1775 Sherman Street, Suite 3000 Denver, CO 80203 Person To Contact Name: Phone: Fax: Email: Elizabeth Duncan 303-860-5800 Elizabeth.Duncan@pdce.com 0 True Minor 0 Synthetic Minor for: I✓VOC rNOx F- CO Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the R&R Farms East Pad, located in the SESW Sec. 29 T5N R63W, Weld County, Colorado. Point Name Type Control Action 002 LOAD -1 Loadout None Newly reported source 002 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 7.4557 psia ProMax M Molecular Weight of Var 52.529 lb/lb-mole ProMax T Liquid Temperature 516.46 deg. R ProMax L 5.67 lb/10^3 gal 2.38E-01 lb/bbl Annual requested Throughput Annual requested VOC emissions 464240 BBL/yr 19498080 gal/yr 110538 lb/yr 55.27 tpy Control: Flare Efficiency: 0.00% Note: Flare only operates on 300,000 bbl/yr. Controlled emissions reflect partial control. NCRPs Component Benzene 0.0021 n -hexane 0.0173 Toluene 0.0019 Xylenes 0.0005 Source: Mass Fraction ProMax Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.2381 lb/bbl 55.3 tpy 55.3 tpy AP -42 Benzene 0.0006 lb/bbl 278.5 lb/yr 278.5 lb/yr AP -42 n -Hexane 0.0045 lb/bbl 2089 lb/yr 2089.1 lb/yr AP -42 Toluene 0.0005 lb/bbl 232 lb/yr 232.1 lb/yr AP -42 Xylenes 0.0002 lb/bbl 93 lb/yr 92.8 lb/yr AP -42 Regulatory Review Regulation 3 - APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section 11.0.1,1 No Yes No STATE OF COLORADO Ca O RTh8 DEP RT It F PL,ticHEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 16WE0734 Issuance 1 DATE ISSUED: ISSUED TO: PDC Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the R&R Farms East Pad, located in the SESW Sect. 29 T5N, R63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description LOAD -1 002 Hydrocarbon Loadout to Tanker Trucks. Emissions are uncontrolled. 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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify (Regulation 3, Part B, Section III.G.5). EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO VOC CO LOAD -1 002 -- 55.3 -- Point See "Notes to Permit Holder for information on emission factors and methods used to calculate limits. AIRS ID: 123/9E8F Page 1 of 7 Health and Environment it Pollution Control Division Compliance "" =nn l b= ed b .rding the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 3. 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -I 002 Condensate Loaded by Submerged Fill 464,240 BBL 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 4. 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. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 5. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 6. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 7. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. AIRS ID: 123/9E8F Page 2 of 7 Iic Health and Environment r Pollution Control Division f n M c. The ovwtr.1bpe(s°r. ;:a&peot=,equip# and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 8. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS 9. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 10. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 11. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) d. 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 (NO,3 in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. e. Whenever there is a change in the owner or operator of any facility, process, or activity; or f. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or g. Whenever a permit limitation must be modified; or h. No later than 30 days before the existing APEN expires. 12. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential AIRS ID: 123/9E8F Page 3 of 7 olor. ,� ;Depa en P Health and Environment r Pollution Control Division to emit abov 'ic- - roe,. hold equire a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 13. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 14. 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 No. 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. 15. 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. 16. 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. 17. 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. 18. 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. 19. 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, AIRS ID: 123/9E8F Page 4 of 7 Health and Environment it Pollution Control Division civil or criminat rcer nt 'a ' .S, un ' . ions 's -115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. AIRS ID: 123/9E8F Page 5 of 7 Notes to Permit Holder me o e Health and Environment it Pollution Control Division 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 (Reference: Regulation No. 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paqename=CBONWrapper 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 Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 002 Benzene 71432 266 Yes N/A n -Hexane 110543 2105 Yes N/A Toluene 108883 236 No N/A 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Pollutant Emission lb/BBL loaded Factors - Uncontrolled Source VOC 0.2381 AP -42 Benzene 0.0006 AP -42 n -Hexane 0.0045 AP -42 Toluene 0.0005 AP -42 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 7.46 psia M (vapor molecular weight) = 52.53 Ib/Ib-mol AIRS ID: 123/9E8F Page 6 of 7 i-Health and Environment it Pollution Control Division T (tem paAttiaitf Ia ,k;S16 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.qpoaccess.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 AIRS ID: 123/9E8F Page 7 of 7 Division Information Engineer: Betsy Gillard Control Engineer: Stefanie Rucker Review Date: 08/03/2016 Application Date: 06/01/2016 Facility Identifiers Permit No. 16WE0733 AIRS County # 123 (Weld Facility # 9E8F Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information Company Name: PDC Energy, Inc. Source Name: R&R Farms East Pad Source Location: SIC: SESW Sec. 29 T5N R63W 1311 Mailing Address Address 1: Address 2: ty, State Zip: PDC Energy, Inc. 1775 Sherman Street, Suite 3000 Denver, CO 80203 Person To Contact Name: Phone: Fax: Email: Elizabeth Duncan 303-860-5800 Elizabeth.Duncan@pdce.com O True Minor Synthetic Minor for: R VOC NOx �. CO Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the R&R Farms East Pad, located in the SESW Sec. 29 T5N R63W, Weld County, Colorado. Point Name Type Control Action 001 TK-1 Condensate Tanks Flare Newly reported source 001 (12) 538 -bbl atmospheric condensate storage tanks Requsted Throughput 464240 bbl Control Flare Efficiency 95.00%I Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 0.9399 lb/bbl 218.2 tpy 10.9 tpy ProMax Nox 0.0038 lb/bbl -- tpy 0.9 tpy TCEQ CO 0.0076 lb/bbl -- tpy 1.8 tpy TCEQ Benzene 0.0015 lb/bbl 675 lb/yr 33.75 lb/yr ProMax n -Hexane 0.0116 lb/bbl 621 lb/yr 31.05 lb/yr ProMax Tolulene 0.0013 lb/bbl 20 lb/yr 1 lb/yr ProMax Xylenes 0.0006 lb/bbl 259 lb/yr 12.95 lb/yr ProMax 5383 269.15 ProMax run based on pressurized liquid sample from R&R Farms East, sampled 5/26/2016. Verified pressurized liquid sample input in ProMax. Verified emissions of V0C and HAPs in ProMax run Regulatory Review 1 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2 — Odor any single source such as to result in detectable odors which are measured in excess of the following limits: Regulation 6 - New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject. NSPS OOOO: for storage vessels in the natural gas production, transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7 — Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS Applicant is subject to the emission control requirements for condensate tanks since it is located in a non - attainment area. XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... Applicant is subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC. r rr CC, Emission Source AIRS ID: d a penny N & AIRS ID] lily how this equipment is referenced within your organization I [Provide Facility Equipment ID to id nested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information y x c a 'J Z 1 E ¢ w 0 :J J 2 G J a Q a C C F Lc E Z a i.) `C L W o a. G Z E O ▪ "n to L v cJ 1 u V V ❑ V ❑ ❑ ®❑ ❑ on c Company Name: R&R Farms East Pad SESW Sec 29 T5N R63W ❑ APEN Submittal for Permit Exempt/Grandfathered source ❑ APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Info. Initial permit request for new facility & Notes: O V V Elizabeth Duncan (303) 860-5838 Fax Numbe Elizaheth.D u nca n(r�pdce.com Section 03 —General Information C) C z Z x c N n N � C U R O O Z Z } } EE v0. i v Q Q V 9 s .. C) — q o y C C C C L G m ava- c- ?..2 a C -,-, C72 > z C u R CO t L- v. C C c a s D v o 0 c ¢ c` cn E O' ^ 6 V V V V^ V C '> _ R L C C _ p ai,'" V > C O L L a z o. c„ ._ A- _ 3) , �v', L N ' 'V C EP ..v R L: .2 E /. n 'O R a G.:= Y C R u Q.Z v -: E R ro cA _ W .o c m a .. z C '.a Y U an L L 7 0. .n <, G R C N c VJ >�—Cc. s ▪ d a n a C .v- c 9 Z. V G in E C m- V= e; E e• L 0- u, cn .7:E "" L L N C U C.C c 7-4 E y Z i d�` 00 c' .E U. - V e+ w 0 m t o .j C O 9 v ^ R E G lc -I,' G L - �� o'' o 4 U¢ v :4 t.: LUaa0 G 03m VI v' V n n r N N N Li :I T O C1 7 - n rn C O m C l nrti z C E Po G t� _L C F— e) o • L G V' j I L C • CO CO C V u ^J V T N CO 3 o to T T L s t] L N e Q ll E. a c s on e c m Date Of First Production (Month/Year) o N h Installation Date of most recent storage vessel in storage tank (Month/Year) in ea Total Volume of Storage Tank (bbl) o in tr o # of Liquid Manifold Storage Vessels in Storage Tank 12 Storage Tank ID ry (E&P Sites Only) Name of Well K&lt Farms 29L-201 K&It Farms 29L-321 R&R Farms 29L-421 It&K Farms 29Q-241 RD C API Number 05-123-41928 M N N N N C en R N C v C a C C G e Ci C AIR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit — Condens Permit Number: For Midstream sites on Section 05 —Stack Information - G E F Direction of stack outlet (check one): Length (inches) — E&P Sites On Information aration Technolo Section 08—Gas/Liquids Se C O C U C O E {-may © E a C L C C E C' C C V f L C C C 0 O C ••E u Emission Factor Data Source TCEQ TCEQ x z J x 2 0 ?. x .- x 2 O C. x 0 O C. Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions CO v } - t N C 2 x 'i0 P C— h y T N ' M y T O - r7 1.00 lb/yr (DM) O T C r - y J N Uncontrolled (Tons/Year) z QC -, N z 675.33 lb/yr i. a e ci L' 20.06 lb/yr (DM) 259.28 Ib/yr 5383.27 lb/yr Actual Calendar Year Emission2 77 vcc _ C a L 33.77 lb/yr T _ G n e .- T P Uncontrolled (Tons/Year) a z 0 m ei a_ Z 675.33 lb/yr 621.48 lb/yr 20.06 lb/yr (DM) 259.28 lb/yr 5383.27 lb/yr Emission Factor Uncontrolled Basis I Units m L ? L .0 :aL 0 La _ _ a L _ GO O 0.9399 0.276 0.0015 M O G O In O. L7'5 N M T O O - -. O -E. N J o = N - .O ^ v^ - y - =- - Zr __ X E v 2,2,4-"Itimelhy 1pentane EHS Professional Elizabeth Duncan C Ca y 0 U C L N E 0 J O C G G C Ca N E .0 C 0 la C C C L y '0 C 0 C E V C • C- Oa cn C a - O -0 . a v v = • O 5 o < 0 n 7 T - y 7' v 111 z0 TA E= C C `C y T L 0 m Ott .v. O C O 2-2., v �z Q 75-1 R.t_ v a- 0 v 0z N Q v E J - v J - T 0 C '_ oo -r a - - _ - 0 v C } v 4_ C C G C 0 C x L U ion report/lest r C C y 04 7Cs C C _? z c- a 0 0 0 FORM APCII-205 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: R&R Farms East Pad Emissions Source AIRS ID2: 123 R -75'F/ CC I Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 41925 R&R Farms 29Q-441 - ❑ - - • - - ❑ - ❑ - - ❑ - ❑ - - • - - ❑ - ❑ - ❑ - - ❑ - ❑ - - ❑ - ❑ - - ❑ - - ❑ - ❑ - - ❑ - ❑ Footnotes: Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 TK-1 Appendix (APEN) & Application for Construction Permit — Hydrocarbon Liqui :using Station APEN to report emissions from service stations and fleet refueling stations_ :55 APCD has already assigned a permit 8 & AIRS ID] Emission Source AIRS ID: / 72 E y c CC -0 C •G 0 C _ a r O Q C L G 0 nested Action (Check applicable request box Section 02 — R Section 01 — Administrative information General Permit GP07 Individual Permit Action Applies To: PDC Energy, Inc. z tati V • J C J N J • o _ C a 'C C V z L vG E e v c Ce Cs > i !LB' C Ce >• L o J T z 3 a C = z • C E - Q CG Z CG ._ d J J _ C C G Ce v z c 0 ❑ R&R Farms East Pad z e SESW Sec 29 T5N R63W U t Ce re▪ . 3 O • la C) c Ce Y C E ✓ G Z C •- ll a- J C i 8 C V ❑ ❑ 1775 Sherman Street, Suite 3000 ❑ Ce E v O. CO v O C LL C U d N ❑ Q t Ce C.T.1 c ▪ v C E o 7 a m d z ✓ 40 J v7-2 T E v - Ce 73 7 � Z 3 r < Q � d - G _ J C 7 t - a Ce C J C Cp • C4 ❑ ❑ 0 CO J N U U a @.) l0 = m W L -o Ce Elizabeth Duncan Person o Comae (303) 860-5838 E z Ce Initial permit request for new facility Z 0 c Section 03 — General Information U7 Ce 3 n -C CD Normal I lours of Source Operation: O N Ce ^J a 0 < :L Ce 7 3 3 Ce ^- ▪ ll Z.Z. = < z o - - _ 7. 7 _ 37, - _ - , a - g 88 47 - C O y J y 7 N F_ V - G V ;,(3, • Ce CO Lo G f Ce C C G _ y .0 r°1 �• Ce Ce c c 0 O Ce � C .'a v c O Ce ti v G. E m o 0 X S • Ce 1 cc. • G y V Y 0 Ce Ce o - z z z z z Ce Ce < < < v v Ce r r r E ❑ ❑ ❑ ❑ 3. v G v v s L G on C C C v • - c v Ce Ce • < 0 a per ADEN & C o W :r - -r r r^, N N N CC C cr. vrr F F e G r C C0 V Ce E L O v -0 o V CD Ce E Ce J 0 v T Ce vL. o ❑ aa. N C 4. C C u • • < J C Y 3 O o .4 v Tank Trucks O Y ❑ .. L La. L — -72 Z v O Q = > • 0 G • < _ LC 7 c C Y 2 Ce Ce C • O L V ' C • C c G Ce > Ce J r G -� E e Ce Ce oG - 3 C 0 0 Co G .t4 If this APEN is bei o > ; Cr) r"- Ce) rn � V' Cr) FORM APCD-208 'API:N-VcrA,l4 nnAPCI-208-1 w G O O Emission Source A 5 F 0 C'7 V a) arj- ti 0 R C O Co E 0 a - Section 06 —Stack (Source 2 c `o ▪ h C m ^ o E • on N N ▪ Az C.; 'C 7r.;' o q L COGCC Website on y co C) O v N N co O 5 44 ▪ <oo — Z N • C co co A < C- E a -Z -73 :n on v N Section 07 — Control Device Information Section 0S— Emissions Inventory Information CC Co C C i v O G L y v N C M C x L x 0 v v L� C . 1 0- U O Estimation Method or Emission Factor Source X 2 2. 0- X 2 P_ d X 2 0_ Please use the APED Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 55.27 266.22 lb/yr 2104.64 lb/yr Y b' N. 266.22 lb/yr 2104.64 lb/yr Y c c c ,O N l[) to Actual Calendar Year Emissions' mu o 55.27 266.22 lb/yr 2104.64 lb/yr Tf } C G J C -0 -- v Co v 55.27 266.22 lb/yr 2104.64 lb/yr E _8 Emission Factor .0 .0 4 Q C 4 Q -13 Uncontrolled Basis r m co o O 0.0045 N O O O Control Efficiency (% Reduction) Identify in Section 07 Control Device Description Secondary T cti 0 5 z 7-'1. U - N V Co u _ z E Elizabeth Duncan Name of Legally Authorized Person (Please print) O T d C J Z mAPCD 208-1 lydrocarhonLiquidl C"1 0 CI rll F Hello