HomeMy WebLinkAbout20203641.tiff Cs
X. COLORADO
____ Department of Public
��e Health&Environment
RECEIVED
NOV 3 0 2020
Weld County - Clerk to the Board WELD COUNTY
1150 0 St COMMISSIONERS
PO Box 758
Greeley, CO 80632
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
PDC Energy, Inc - Barr 11 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 &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �= `d �o",
1
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director ;,i 1°, , , i
Pub I; c Rev;G vJ Cc:PLcrrz Hi-(cs),PwaMIER/cH/ex)i. 2020-3641
12 /iii/moo oG(s�)
l2/09 a°
E. Yu Air Pollution Control Division
CD Notice of a Proposed Project or Activity Warranting Public
CDPHE
M Comment
Website Title: PDC Energy, Inc - Barr 11 Sec HZ - Weld County
Notice Period Begins: November 24, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: PDC Energy, Inc
Facility: Barr 11 Sec HZ
Well Production Facility
SESE quadrant of Section 11, Township 5N, Range 65W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted
emission by reducing requested condensate throughput and adjusting VRU downtime to 40 %.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• The source is requesting a federally enforceable limit on the potential to emit in order to avoid
other requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0104 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:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
z, COLORADO
Department of Public
1 ' °'"E HealthbEnvironment
ray COLORADO
1p Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 9WE0 1 04 Issuance: 2
Date issued: XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: Barr 11 Sec HZ
Plant AIRS ID: 123/A025
Physical Location: SESE Quadrant of Section 11, Township 5N, Range 65W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS
Equipment Equipment Description Emissions Control Description
ID Point
Emissions from the storage vessels are
Twenty-Four (24) 538 barrel routed to a sales pipeline through the use of
TK-1 001 fixed roof storage vessels a vapor recovery unit (VRU). During VRU
used to store condensate downtime, emissions are routed to enclosed
combustor(s). The VRU has a maximum of
40.0%annual downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify.
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
Page 1 of 10
-r4, COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
F.4.)
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS .
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO,t VOC CO Type
TK-1 001 --- 1.9 21.2 3.9 Point
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant 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 criteria pollutants must be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
5. The owner or operator must use the emission factors found in "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.
6. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Control Device Pollutants
Equipment ID Point Controlled
Page 2 of 10
-r.�;: COLORADO
4. Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Emissions from the storage vessels are routed
to a sales pipeline through the use of a vapor
TK 1 001 recovery unit (VRU). During VRU downtime, VOC and HAP
emissions are routed to enclosed
combustor(s). The VRU has a maximum of
40.0% annual downtime.
PROCESS LIMITATIONS AND RECORDS
7. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS Process Process Parameter Annual Limit
Equipment ID Point
Total Condensate 474,445 barrels
01 Throughput
TK-1 001 Condensate throughput 189,778 barrels
during VRU downtime.
02 Combustion of pilot 1.8 MMscf
light gas
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review
8. 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 combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate
throughput volume and total condensate throughput volume during VRU downtime shall be
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly condensate throughput volume records, and the calculation methods established in
the Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.)E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 of 10
isrvv. COLORADO
. tto,44 abAir Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
11. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 202O. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
Page 4 of 10
r.fr COLORADO
410 061° Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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. All previous versions of this permit are cancelled upon issuance of this permit.
20. A revised Air Pollutant Emission Notice (APEN) must 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 (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
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. Federal regulatory program requirements (i.e. PSD, NANSR) must 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
Page 5 of 10
-nyl, COLORADO
`ur/ Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 6 of 10
a
Y COLORADO
?r Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 August 23, 2019 Issued to PDC Energy, Inc.
Issuance 2 This Issuance Issued to PDC Energy, Inc. Operator
reduced permitted emissions by:
• Reducing requested condensate
throughput.
• Decreasing maximum VRU downtime
to 40.0 %.
•
Page 7 of 10
C _ y..... . COLORADO
�,/ Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)'
Benzene 71432 4642 93
Toluene 108883 6180 124
Ethylbenzene 100414 187 4
001 Xylenes 1330207 2228 45
n-Hexane 110543 40267 805
2,2,4-
540841 140 3
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 7.519x10-3 7.519x10-3 TNRCC and Promax
CO 1.501 x10-2 1.501 x1O2 TNRCC and Promax
Page 8 of 10
, _ , COLORADO
itif Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 4.4681 8.9362x10-2 Promax Site
specific
71432 Benzene 9.785x10-3 1.957x10-4 Promax Site
specific
108883 Toluene 1.303x10-2 2.605x1O4 Promax Site
specific
1330207 Xylene 4.696x10-3 9.393x10"5 Promax Site
specific
110543 n-Hexane 8.487x10-2 1.697x10"3 Promax Site
specific
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 combustor(s)
during VRU downtime. The site specific VOC and HAP emission factors in the table above are based on a site
specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax
simulation was obtained from the Barr 3N well on 01/22/2019.The NOx and CO TNRCC emission factors(0.1380
lb/MMBtu and 0.2755 tb/MMBtu respectively)were converted to units of lb/bbl using a heat content of 2580.0
Btu/scf, molecular weight of 45.9 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, and a VOC mol%
of 70.0%.Actual emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput.
Process 02: Combustion of pilot light
Uncontrolled Emission
CAS # Pollutant Factors Source
lb/MMSCF
NOx 77.2 AP-42 Chapter 13.5
VOC 6.1 AP-42 Chapter 1.4
Table 1.4-2
CO 352.2 AP-42 Chapter 13.5
Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5
NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136
Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4
emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a
constant rate of 15.6 scf/hr.There are a total of thirteen (13)combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 202.8 scf/hr.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
Page 9 of 10
CGYM 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
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, n-Hexane, and Total HAPs.
True Minor Source of CO.
PSD True Minor Source of: CO & NOx
NANSR Synthetic Minor Source of: VOC and NOx.
MACT HH Area/Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Diego Chimendes
Package#: 434230 :.
Received Date: 7127/2020
Review Start Date: 10/12/2020 -.
Section 01-Facility Information
Company Name: PDC Energy,Inc Quadrant! Section Township Range
County AIRS ID: 123 SESE i 11. SN 65
Plant AIRS ID: A025
Facility Name: Barr 11 Sec HZ
Physical
Address/Location: SESE quadrant of Section 11,Township 5N,Range 65W
County: Weld County
Type of Facility: -Exploration&Production Well Pad
What industry segment?Oil&Natural Gas Production&.Processing
Is this facility located in a NAAQS non-attainment area? Yes III
If yes,for what pollutant? OzoneI(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRS Point# Permit#
Emissions (leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit
001 Storage Tank TK-1 Yes 19WE0104 2 Yes Modification
Section 03-Description of Project
PDC Energy,Inc.(PDC)submitted an application requesting modification of permit 19WE0104.PDC wishes to reduce requested permitted emission by reducing
requested condensate throughput and adjusting VRU downtime to 40%.This facility utilizes two(2)different kinds of emission control devices for the condensate
storage tanks;Enclosed Combustors and Vapor Recovery Units(VRUs).Tank vapors are routed to a VRU which compresses the gas before it is sold into a pipeline.Any
vapors not recaptured by the VRU are sent to the Enclosed Combustors.
This point source is APEN-required because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is
greater than 250 tpy.(Regulation 3 Part A Section!LB.3.)Point source is permit required because uncontrolled facility-wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section II.D.2).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in cider to
avoid other requirements.(Regulation 3 Part B Sections I1l.C.1.d.):
Point source is not subject to ambient air impact analysis (Regulation 3 Part D Section ll.A 44).
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis 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? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.S PM10 TSP HAPs
Prevention of Significant Deterioration(PSD)
Title V Operating Permits(OP) 1 J ❑
Colorado Air Permitting Project
Non-Attainment New Source Review(NANSR) ✓
Is this stationary source a major source? M"tNo`^',`I"E
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) _
Title V Operating Permits(OP)
Non-Attainment New SourceReview(NANSR)
Storage Tans',,Emissions Inventory
Section 01-Administrative Information
'Facility AIRS ID: 123 -0.025 001
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid Condendaa)e -
Detailed Emissions Unit Twenty-four(24)530 bbl fixed roof condensate storage t nks •>*P,:P ,:,, ¢Y
Description. 1
Emission Control Device VRU with 40%Downtime,and twelve(12)Cimarron 48"and one(1)Cimarron 60"Enclosed Flares.
Description. 3f
Control Efficiency of VRU 100.00
Control Efficiency of ECD 95.00 _ _
Requested Overall VOC&HAP Control Efficiency 56: 98.00 r 284667 bblsat 100%Control(60%of throughput to VRU)0
189,778 bbls at 95%Control(40%of throughput to Enclosed Combustor)
i
Limited Process Parameter Liquid Thrpughp t7 f
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Ta.k(s)
VRU Downtime/Bypass)%) 40.00%
•
Actual Throughput= 395,371.0 Barrels(bbl)per year
Actual Throughput Controlled By VRU= 237,222.6 Barrels(bbl)per year
Actual Throughput Controlled By ECD= 158,148.4.Barrels(bbl)per year
Requested Permit Limit Throughput= 474,445.0 Barrels)bbl)per year Requested Monthly Throughput= 40295.3 Barrels(bbq per month
Requested Permit Limit Controlled By VRU= 284,667.0 Barrels(bbl)per year
Requested Permit Limit Controlled By ECD= 189,778.0 Barrels(bbl)per year
Potential to Emit(PIE)Condensate Throughput= 474,445.0 Barrels(bbl)per year
Secondary Emissions-Combus8on Device(s)
Heat content of waste gas= 2580.0 Btu/scf •
Volume of waste gas emitted per BBL of liquids scf/bbl
Molecular Weight= 45.9 Ib/Ibmol
VOC mol%= 70.00%
Molar Volume= 379.4 scf/Ibmol
Actual heat content of waste gas routed to combustion device= 21,540.6 MMBTU per year
Requested heat content of waste gas routed to combustion device= 25,848.7 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 25,848.7 MMBTU per year
Control Device
Pilot Fuel Use Rate: ` 2028)scfh 1.8 MMscf/yr
Pilot Fuel Gas Heating Value: ,. ". 1136 Btu/scf 2018.1 MMBTU/yr
Section 04-Emissions Faders&Methodologies
Will this storage tank emit flash emissions? nS
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) pb/bbq Emission Fader Source
(Condensate (Condensate
Throughput) Throughput)
VOC 4.4681E+00 8.9362E-02 Site Specific E.F.(includes flash)
Benzene 9.785E-03 1.957E-04 Site Specific E.F.(includes
Toluene 1.303E-02 2.605E-04 Site Specific E.F.(includes flash)S`:
Ethylbenzene 3.947E-04 7.894E-06. Site Specific E.F.(includes flash)
Xylene 4.696E-03 9.393E-05 Site Specific E.F.(includes flash),
n-Hexane 8.487E-02 1.697E-03 Site Specific E.F.(includes flash)'";
224 TMP 2.948E-04 5.895E-06 Site Specific E.F.(includes flash)`.; ,.
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 4.06E-04 AP-42 Table 1.4-2(PM10/PM.2.5)=}.
PM2.5 0.0075 4.06E-04 AP-42 Table 1.4-2(PM10/PM.LS)'
5Ox 0.0006 3.20E-05 Other-Explain
NOx 0.1380 7.519E-03 TNRCC Flare Emissions Guidance(N y. _
CO 0.2755 1.501E-02 TNRCC Flare Emissions Guidance
Pilot Light Emissions •
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Fader Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 8.5 AP-42 Table 1.4-2(PMLO/PM Z 5}'
PM2.5 0.0075 8.5 AP-42 Table 1.4.2(PM10/PM2.5)`-;
SOx 00006 0.7 AP-42 Table 1.4-2(50x)
NOx 0.0680 77.2 AP-42 Chapter 13.5 Industrial Flan.
VOC 0,0054 6.1 AP-42 Table I.4-2(VOC)
CO 0.3100 352.2 AP-42 Chapter 13.5 Industrial Flares`,`
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year). (tons/year) (tons/year) (tone/year) (tons/year) (lbs/month)
3 of 10 K:\PA\2019\19WE0104.CP2
Storage[ m, __og _inventory
PM10 0.1 0.1 0.1 0.1 0.1 17.6
PM2.5 0.1 0.1 0.1 0.1 0.1 17.6
SOx 0.0 0.0 0.0 0.0 0.0 1.4
NOx 1.9 1.6 1.6 1.9 1.9 314.6
•
VOC 1059.9 883.3 17.7 1059.9 21.2 3601.8
CO 3.9 3.3 3.3 3.9 3.9 658.0
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
Ohs/year) (Ibs/year) (Ibs/year) (lbs/year) (Ibs/year)
Benzene 4642 3869 77 4642 93
Toluene 6180 5150 103 6180 124
Ethylbenzene 187 156 3 187 4
Xylene 2228 1857 37 2228 45
n-Hexane. 40267 33556 671 40267 805
224 TMP 140 117 2 140 3
4.of 10 K\PA\2019\19 W E0104.CP2
Storage Tank`s)Emissions Inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Part D,Section I.C,.D,E,F Storage tank is subject to Regulation 7,Part D,Section I.C-F _
Regulation 7,Part D,Section 1.0,C Storage Tank is not subject to Regulation 7,Section I.G
Regulation 7,Part D,Section II.B,C.1,C.3 Storage tank is subject to Regulation 7,Part D,Section II,B,C.1&C.3
Regulation 7,Part D,Section II.C2 Storage tank is subject to Regulation 7,Part D,Section II.C.2
Regulation 7,Part D,Section II.C.4.a.(i) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.a(i)
Regulation 7,Part D,Section II.C4.a.(ii) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.a(u),b-f
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 Subpart 0000a Storage Tank is not subject to NSPS 0000a
Regulation B,Part E,MAR Subpart HH Storage Tank is not subject to MAR HH
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and PeriedicSampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions?
If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions fora condensate storage tank estimated to be greater than orequal to 80 tpy?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
�s°Yy
If yes and If there are flash emissions,are the emissions factors based on a pressurized Squid sample drawn at the facility being
permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample
should be considered 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 14-03.
Does the company requesta control device efficiency greater than 95%for a flare or combustion device? E, -.
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
1.SIte-specific EEmission Factors:The site specific sample used to establish emissions factors for this source was obtained within a year of the first issuance application.The sample was obtained from the Barr 3N well.
This well is one of the twelve wells drilled at this facility and there were no significant changes to the fadlity since thedevelopment of the emissions factors us a result,the permit will not require coital testing in
order to obtain a new site specific sample.It should be noted that the sample includes sample probe temperature and pressurein conjunction with gauge pressure and temperature.
2.Secondary Emissions Calcukations:
21 Operator used the following equation to calculate the annual heat input,
Heat loput(MMBtu/yr)=jUncontrolled VOC(Con%yr)]s[2000(lb/ton)]-MW(lb/lbmol)*[379.41(scf/lbmol)] [1/VOC cool rya]*[Heat Content(Btu/srf)]*[1MMBtu/(1000,000 Btu)].
The values used in the equation were obtained from a ProMax simulation used to calculate emissions and to develop emission fator.The values used are as follow:(i)Molecular weight.45.916/16-cool,(ii)VOC mol
70.0%,(iii)Heat Content 2580.0 Btu/scf.
3.Pilot Light Emissions Calculations:Operator assumed pilot fuel to have the same conditions of field gas which is consistent with the plant design provide by operator.The permit will not contain iniflal or periodic
opacity testing for the enclosed combustor(s)because the O&M plan approved for this source requires weekly visible emissionsobservations of the enclosed combustor(s).A throughput limit is included in the permit
for pilot combustion Emssmnfactors and calculation methods for pilot light combustion emissions are also included in thenotes to permit holder.This informafion is included in the permit because pilot light
emissions contribute to the overall emissions from this source.Additionally it Is important to include this information becane throughput tracking and mission calculation methods are different than those used to
estimate emissions based on the condensate throughput This clarity is important for accurately quantifying actual emissionsat this facility.
Section 09-5CC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point If Process H SCC Code��; Pollutant Factor Control% Units
001 01 . s ?9.E . :':" PjAnti.. .o.n [�E - ;,_?'t,, PM10 0.01 0 lb/1,000 gallons Condensate throughput
PM2.5 0.01 0 lb/1,000 gallons Condensate throughput
50x MIEFI 0 lb/1,000 gallons Condensate throughput
NOx 0.19 0 lb/1,000 gallons Condensate throughput
VOC 106.38 98 lb/1,000 gallons.Condensate throughput
CO 0.39 0 lb/1,000 gallons Condensate throughput
Benzene 0.23 98 lb/1,000 gallons Condensate throughput
Toluene 0.31 98 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 98 lb/1,000 gallons Condensate throughput
-- Xylene 0.11 98 lb/1,000 gallons Condensate throughput
n-Hexane 2.02 98 lb/1,000 gallons Condensate throughput
224 TMP 0.01 98 lb/1,000 gallons Condensate throughput
•
5 of 10 K:\PA\2019\19WE0104.CP2
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re:dation 3 Parts A and 8-APEN and Permit Requirements
6ourcc lsirl th,Non-Aisol na_rnrkre: _
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutantsfrom this Individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? Source Requires en OPEN,Go to
2. Isthe construct d (service d )prior ta 12/30/2002 and not m diked after 12/31/2002(See PS Memo 05-01 Definitions1.12a,d314 and Section 2 for additional guidance on grandfather applicability)? Ga to next question
3. Pretotal facility uncontrolled VOC emissions greater than 5TPY,NOx g eter than lO TPY or CO emissions greater than 10TPY(Regulation 3,Part B,Section 1103)7 Source Requires a permit
IYv. hsomp 0 intit_Uon+.lainmeu ..
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY(Regulation 3,Part A,Section 9.0.1.x)7 kr6"4 Source Requires an APEN.Go to
2. Is the construction date(service date)priorto12/30/2002 and not modified after 12/31/2002(See P5 Memo 05.01 Definitions 1.12 and1.14 and Section 2far additional guidance on grandfather applicability)? kic wit Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2TPY,NO2 greater than 5TPY or CO emissions greater than 1OTPY(Regulation 3,Part 8,Section 11.0.2)? Ylk /a//fl°Source Requires permit
'Sol,,n"mM,, Permit
Colorado Regulation J,Part 0,Section I.C-F&G
1. Is this storage tank located In the 8.hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section 1.0,1)? Continue-You have lndlcatedth
2. Is this storage tank located at oil and gas operations that collect,store,ar handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation],Pert 0,Section IAA)? Yes Continue-You have Indicated th
3. Is thh storage tank located at a natural gas processing plant(Regulation 7,Part 0,Section 1.0)? Na Storage Tank is not subject to RE
4. Does this storage tank contain condensate? -.
S. Daesth'o storage tank exhibit"Flash"(e.g storing non-stabilized liquids)emissions(Regulation],part 0,Section 1.0.2)?
0. Are uncontrolled actual emhslans of this Moragetank equalto or greater Chan glans per year VOC(Regulation 7,Part D,Sectionl0.3.z18)i?
l>Lor,getanis is suhe-i.o i ^n J.
Part D,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part D,Section I.L.2—Emoslon Estimation Procedures
Part 0,Section 1.0—Emissions Control Requirements •
Part D,Section 1.6—Monitoring
Part El,Section I.F—Recordkeeping and Reporting
Storagn Tank Is riot sr,b_t 5n„IanlG
Part 0,Section I.G.1-Emissions Control Requirements
Pert 0,5ectian I.C.1.a and b—General Requirements for Air Pollution Control Equipment—Prevention of leakage
Colorado Regulation],Part 0.Section II
1. Isthu storage tank located at a transmission/storage facility? Na Continue-you have indicated th
2. Isthis storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor station'or natural gas processing plant(Regulation 7,Part 0,Section II.C)? V8S Gots the next question-You ha
3. Does this storage tank have a fixed roof(Regulation 7,Pert 0,Section II.A.v0)7 0.00iSM Go to the next question
4 Are uncontrolled actual emissions oftm:storxgetankequal to or greater than 2 tons per year VOC(Regulation 7,Part 0,Section Il.C2/? 44O1,2 Source A subject to parts of Reg,
I groragetnisk kr suhlsl so ReguiRtsRn],Part R,Section II,R.L.lA C3
Part D,Section 11.5 Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section II.C,1,Emissions Control and Monitoring Provisions
Part 0,Section 11.0.3-Recordkeeping Requirements
5. Does the storage tank containonly"stabilised'liquid(Repletion 7,Part 0,Section ll.C3.6)? fir 'Source is subject to all provision,
13rorage 1. -.0_. 'Rot.
Part 0,Section llC2 Capture and M gf Storage Tanks fitted withA Pollution Control Equipment
Is the controlled storage tank l at d at a wellp d t facility, [ l gas compressorrtation,or natural gas processing plant constructed an or after May 1,2020 or located at a facility that was modified on or after May 1,2020,such
6 that an additional contrMled stomp vessel is constructed to receive an anticated increase in throughput of hydrocarbon liquids 3 do It g Ison],Part D,Section O.C4.a./1/? .c storage Tank is not subject to RE
Is;oag [antis
Is the controlled storage tank locat dat a wellproduction facility, t l gas compressor station,or natural gas processing plant constructed on or after January 1,2021 or located atafacility that was modified on or after January1, pit
7. 2021,such that en additional controlled st g constructed to anticipated increase In throughput of hydrocarbon liquids or produced water(Regulation],Part D Section ll.C4a()? No hkS4i,
Isrirrir'Tank,.enol sl.bRst toR a.a-. Se[rlarll.G.4a,-._
40 CFR,Part60,Subpart Kb,Standards of Performance far Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacitygremerthan or equal to 75 cvblc meters(ma)1-472 BBLs](40 CFR 60.11ob(e)l7 ' As to the next question
a 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Wig.Storage Tank is not subject NSPS
a.Does the vessel has a design capacity less than or equal to 1,589.874 ma["10,000BBL]used for petroleum'or m condeatestared,processed,or treated prior to custody transfer'as defined In 60.111b?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR60.110blal)? piu','TAfe
4. Doesthe tank meet the definition of"storage vessel'i in 60.111b7
5. Doesthestorage vessel store a"volatile organic liquid(VOLT'as defined in 60.1136? C_
6. Doesthe storage vessel meet any one of thefollowing additional exemptions: `-
a.Is the storage vessel a pressure vessel designed to operate In excess of 204.9 g0["25.7 pall and without emissionstothe atmosphere(60.11ob(d)l2ll?;or ,ss:4a+s,Wsnif'tu;;si
b,The design capacity is greater than or equal to 151 ma 1550 BBL]and stores a squid with a maximum true vapor pressures lessthan 3.5 bra/60,110b(b)l7;or `•i:'p
c.The design capacity is greater than or equal to 75M'(`472BBL]hut less than 151 m'[`950 BBL)and stores a liquid with a maximum true vapor pressure'less than 15.0kPa(60.110b(b)l?
7. Dees the storage tank meet either one of the following exemptions from control requirements: �u�
a.The design capacity Is greater than or equal to 151 m'1-950 BBL]and stores aliquld with a maximum true vapor pressure greeter than or equal to 35 kPa but less than 5.2 kPa?;or r8m'c
b.The design capacity is greater than or equal to 75 he h472 BBL)but less than 151 ma I-950BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 bra but less than 27.6 bta? •AvAtiVai
inromge RI,.Is not subRa NSF,r3,
40 CFR,Part60,Subpart 0000/O0O0a,Standards of Performance far Crude Oil and Natural Gas Production,Transmission and gtstrilam'an
1, Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yw Continue-You have indicated th
2. Was the storage vessel constructed,reconstructed or modified(see definitions 40 CFR,60.4 between August 23,2011 and September 18,20157 *Wad Storage Tank Is not subject NSP5
3, Was this storage vessel constructed,reconstructed or modfled(see definitions 40 CFR,60.2)after September 18,2015? iiiRRMOR Go to the next question
4. Are potential VOC emissions'from the individual at snags uoaaol greaterthan orequaito 6 tons per year? Alla Stonaga Tank is not aubisot sum
SDoes tho storage vessel meet he definition of"storage vesseP'per 60.5430/60.543o0 o/A ux
6 Is the storage vessel bj ct to and controlled inac rdance with requirements for storage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? NA 2.a;:"{
[Note:If a storage vessel is previously determined to be subject to NSPS 0000/00O0a due to emissions above 6 tans per year VOC on the applicability determination date,it should remain subject to NIPS 0000/0000a per
60,5365(e)(2)/60,5365a(e)(2/even it potential VOC emissions drop below 6 tons per year]
40 CFR,Part 63,Subpart MACE HH,Oil and Gas Production Facilities
1. Is thestoragetenk located et an oil and natural gas production facilky that meets either of the following criteria: - [icy Continue-you have indicated th
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.76o(a)(2));OR
b.A facility that processes,upgrades armorer natural gas prior to the point atwhich natural gas enters the natural gas transmission and storage source category or 0 delruered to a final end user'(63.760(')(3)/?
2. Isthetenk located eta facility that q majors for HAP.? Storage Tank Is not subject MAC
3. Does the tank meet the definition of"storage vessel"'In 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions'per 63.761? '
5. Is the tank subject to control requirements under 40 CFR Part 60 Subpart Kb or Subpart 0000?
13,--c erankknot subie sin
Subpart A,General provisions per§63.764(a)Table 2
563,766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
463.775-Reporting
RAC[Review
RACT review is required if Regulation]does not apply AND tithe tank is in the non-attainment area.If the tank meets both criteria,then review RACT requirements.
Disclaimer
Thisdocument assists operators with determining applicability of certain requirements of the Clean Air Ad,its implementing regulations and Air Qualify Control Commission regulations This document is not
a role or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute forany law,regulation,
r any other legally binding requirement and is not legally enforceable.In the event of aay conflict between the language of this document and the language of the Clean Air Act„its implamontingnogulations
and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as'rerommond,"'may,""should,"and"can,'isinsnded to
describe APCD interpretations and recommendations.Mandatory terminology such as laust"and'required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name PDC Energy,Inc.
County AIRS ID 123 History File Edit Date 11/18/2020
Plant AIRS ID A025 Ozone Status Non-Attainment
Facility Name Barr 11 Sec HZ
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.8 0.8 0.0 0.0 135.5 2,359.1 0.3 127.6 120.0 0.8 0.8 0.0 0.0 20.7 86.6 0.3 36.3 3.1
Previous Permitted Facility total 0.4 0.4 0.0 0.0 131.2 .2,358.6 0.0 124.0 119.9 0.4 0.4 0.0 0.0 16.4 86.2 0.0 32.7 3.0
001 19WE0104 24-538 bbl Condensate Tanks 1.9 1,059.9 3.9 26.8 1.9 21.2 3.9 0.5 Point updated on 10132020:updating throughput
and VRU downtime.
002 GP07 Condensate Loadout 0.6 118.1 1.2 2.0 0.6 10.0 1.2 0.1 No change
003 GP02 CAT G3306TA 203hp(site)SN:G6X08250 0.2 0.2 36.6 1.4 36.6 as 0.2 0.2 2.0 1.4 3.9 0.5 No change
004 GP02 CAT G3306NA 138hp(site)SN:G6X03295 0.1 0.1 32.1 0.9 18.0 0.4 0.1 0.1 1.3 0.9 2.7 0.4 No change
005 GP02.CN Cummins G855 1791p(site)SN::25434676 f 0.0 00 Cancellation received 6/27/2019:-No'longer exists
at facility
006 GP02.ON t_ j CAT G3406TA,276hp SN CRE00212 0.0 0:0 Cancellation received 10/19/202O-No longer
- - - exists at facility.
007 GPO2 GM Vortec 5.7L,site-rated 88hp,4SRB, 0.0 0.0 11.8 0.6 9.3 0.1 0.0 0.0 0.8 0.6 1.7 0.1 No change
SN:10L59M710230004
008 GP02 GM Vortex 5.7L,site-rated 88hp,4SRB, 0.0 0.0 11.8 0.6 9.3 0.1 0.0 0.0 0.8 0.6 1.7 0.1 Point added and updated on 10113/2020.
SN:13218148 -
0.0 0.0
XA External Combustion Sources 0.3 0.3 4.3 0.1 3.6 0.0 0.3 0.3 4.3 0.1 3.6 0.0
XA Fugitives 0.3 0.0 0.3 0.0
XA Produced Water Tanks 0.1 0.0 0.1 0.0
FACILITY TOTAL 0.6 0.6 0.0 0.0 99.1 1,181.7 0.3 81.8 30.0 0.6 0.6 0.0 0.0 11.8 34.9 0.3 18.7 1.8 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO: Minor(OP),Minor(PSD)
HAPS: Syn Minor(n-Hex,Total)
HH: Area
7777: Area
Permitted Facility Total 0.3 0.3 0.0 0.0 94.8 1,181.5, 0.0 78.2 30.0 0.3 0.3 0.0 0.0 7.5 34.7 0.0 15.0 1.8 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -8.9 -51.5 0.0 -17.6 Pubcom required because source is attempting to
obtain a federally enforceable limit on the potential
to emit in order to avoid other requirements.
Modeling not required.
Total VOC Facility Emissions(point and fugitive) 35.2 Facility is eligible for GP02 because<90 tpy
(4)Change in Total Permitted VOC emissions(point and fugitive) -51.5 Project emissions greater than 25 tpy
Note 1
Note 2
Page 8 of 10 Printed 11/18/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name PDC Energy,Inc.
County AIRS ID 123
Plant AIRS ID A025
Facility Name Barr 11 Sec HZ
Emissions -uncontrolled (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 1.1 0.1 0.1 5.2 66.5 0.2 2.4 44.3 0.1 0.1 0.0 0.0 120.0
001 19WE0104 24-538 bbl Condensate Tanks 4642.3 6179.3 187.3 2228.2 40267.3 139.8 26.8
002 GP07 Condensate Loadout 410.3 3602.5 2.0
003 GP02 CAT G3306TA 203hp(site)SN:G6X08250 901.5 44.7 42.2 25.3 49.0 0.5
004 GP02 CAT G3306NA 138hp(site)SN:G6X03295 719.6 29.1 27.5 16.5 31.9 0.4
005 GP02 C1 Cummins G855 179hp(site)SN;25434676 0.0
006 GP02:CN . CAT G3406TA276hp SN:`CRE00212 0.0
007 GP02 GM Vortec 5.7L,site-rated 88hp,4SRB, 134.0 18.0 17.0 '10,0 0.1
SN:10L59M710230004
008 GP02 GM Vortec 5.7L,site-rated 88hp,4SRB, 134.0 18.0 17.0 10.0 0.1
SN:132 19148
0.0
XA External Combustion Sources 0.0
XA Fugitives 13.5 13.5 13.1 13.2 15.1 0.0
XA Produced Water Tanks 8.8 10.5 0.2 4.3 2.8 0.0
0.0
TOTAL(tpy) 0.9 0.1 0.1 2.6 3.1 0.1 1.1 21.9 0.0 0.1 0.0 0.0 30.0
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minimus •
Emissions with controls(lbs per year
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 1.1 • 0.1 0.1 0.2 0.2 0.0 0.1 1.3 0.1 0.0 0.0 0.0 3.1
001 19WE0104 24-538 bbl Condensate Tanks 92.8 123.6 3.7 44.6 805.3 2.8 0.5
002 GP07 Condensate Loadout 20.5 180.1 0.1
003 GP02 CAT G3306TA 203hp(site)SN:G6X08250 901.5 44.7 42.2 25.3 49.0 0.5
004 GP02 CAT G3306NA 138hp(site)SN:G6X03295 719.6 29.1 27.5 16.5 31.9 0.4
005 GP02.CN Cummins G855 179hp(site)SN:25434676 0.0
006 ...'GP02.CN CAT G3406TA 276hp SN:CRE00212 0.0
9 19WE0104.CP2 11/18/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name PDC Energy,Inc.
County AIRS ID 123
Plant AIRS ID A025
Facility Name Barr 11 Sec HZ
007 GP02 GM Vortec 5.7L,site-rated 88hp,4SRB, 134.0 18.0 17.0 10.0 0.1
SN:10L59M710230004
008 GP02 GM Vortec 5.7L,site-rated 88hp,4SRB, 134.0 18.0 17.0 10.0 0.1
SN:13219148
0.0
XA External Combustion Sources 0.0
XA Fugitives 13.5 13.5 13.1 13.2 15.1 0.0
XA Produced Water Tanks 8.8 10.5 0.2 4.3 2.8 0.0
0.0
TOTAL(tpy) 0.9 0.1 0.1 0.1 0.1 0.0 0.0 0.5 0.0 0.0 0.0 0.0 1.8
10 19WE0104.CP2 11/18/2020
JG r.
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Condensate Storage Tank(s) APEN
40 Form APCD-205
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19WE0104 AIRS ID Number: 123 /A025/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Barr 11 Sec HZ
Site Location
Site Location:
SESE Sec 11 T5N R65W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address': Jack.Starr@pdce.com
' Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
COLORADO
Form APCD-205 Condensate Storage Tank(s)APEN Revision 12/2019 1 I Rio
Permit Number: 19WE0104 AIRS ID Number: 123 1A0251001
au ez,,riv
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
❑ Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment O Change company name3
O Change permit limit O Transfer of ownership' ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes: Requesting new throughput limit and emissions limits for Construction Permit 19WE0104;
Rolling 12 month throughput actuals; Emissions calculated using previously approved site-specific emission factors.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 10/31/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: 0 Exploration&Production(EEP)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No
Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? 0 Yes ❑ No
If"yes", identify the stock tank gas-to-oil ratio: 0.008073 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 0 Yes ❑ No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual 0 Yes ❑ No
emissions a 6 ton/yr(per storage tank)?
lea COLORADO
.rn APCD-205 v_rt_'._ ,sac.. Sto
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Permit Number: 19WE0104 AIRS ID Number: 123 1A025/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbUyear) (bbl/year)
Condensate Throughput: 395,371 474,445
From what year is the actual annual amount? R12
Average API gravity of sales oil: 51.3 degrees RVP of sales oil: 9.7
Tank design: 0 Fixed roof 0 Internal floating roof ❑External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TK-1 24 12,912 4/2018 10/2018
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 45681 Barr 111-221 O
05 - 123 - 45687 Barr 111-301 O
05 - 123 - 45692 Barr 11L-201 O
05 - 123 - 45683 Barr 11L-221 O
05 - 123 - 45682 Barr 11L-301 0
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.407311 /-104.622989
E Check box if the following information is not applicable to the source because emissions wilt not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
❑Upward O Downward O Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
O Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
COIOR ADO
Form APCD-205 Condensate Storage Tank(s)APEN - Revision 12/2019 3 I �
Permit Number: 19WE0104 AIRS ID Number: 123 /A025/001
[Leave blank unless APCD has already assigned a permit 4 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.
Pollutants Controlled: VOC & HAPs
Vapor Size: Make/Model:
0 Recovery
Unit(VRU): Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 40
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
hr
Type: Enclosed Combustors Make/Model: 12 x Cimarron 48",1 x Cimarron 60"
Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,580 Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.018 MMBtu/hr
Description of the closed loop system:
0 Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information(E6tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 26.1 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
ICOLOftADO
Form APCD-205 Condensate Storage Tank(s)APEN - Revision 12/2019 4 I �►
Permit Number: 19WE0104 AIRS ID Number: 123 /A025/001
[Leave blank unless APO has already assigned a permit#and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes O No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall,or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC Enclosed Combustors and Tank VRU 100% 98.00%
NOx
CO
HAPs Enclosed Combustors and Tank VRU 100% 98.00%
Other:
From what year is the following reported actual annual emissions data? R12
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP 42, Emissions Emissions Emissions Emissions
Basis Mfg.,etc.) tons/ ear (tons/year)
(tans/year) ( Y ) f ons/yeary
VOC 4.4681 lb/bbl ProMax 883.27 17_67 1059.93 21.20
NOx 01380 Ib/MMBtu TCEQ N/A 1.56 N/A 1.85
CO 0.2755 Ib/MMBtu TCEQ N/A 3.28 N/A 3.87
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
a Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled,actual emissions of non-criteria Yes O No
pollutants (e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions8
Number Basis Mfg.,etc.) (lbs/year) (ibs/year)
Benzene 71432 0.0098 lb/bbl ProMax 3,868.61 77.37
Toluene 108883 0.0130 Ib/bbi ProMax 5.149.94 103.00
Ethylbenzene 100414 3.95E-04 Ib/bbl ProMax 158.06(DM) 3.12(DM)
Xylene 1330207 0.0047 llo/bbl ProMax 1856.81 37.14
n-Hexane 110543 0.0849 lb/bbl ProMax 33,556.08 617.12
2,2,4-Trimethylpentane 540841 2.95E-04 lb/bbl ProMax 116.54(DM) 2.33(DM)
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
au I COLORADO
Form APCD-205 Condensate Storage Tank(s)APEN - Revision 12/2019 5 I
Permit Number: 19WE0104 AIRS ID Number: 123 /A025/001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
4/2_41(2-01-0
Signal a of Legally Authorized Person(not a vendor or consultant) /Date
Jac Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
QQ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692.3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
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Form l�;l'{_l.-$'d 4G t,-s..t`.'s'.E. 3f- i1 't..:"...; -a"'..m' �' ',c;.;, !1{.p: 6l CRe.*En vw
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E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: Barr 11 Sec HZ
Emissions Source AIRS ID2: 123/A025/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-45689 Barr 11L-321 ❑
05-123-45685 Barr 11 L-341 ❑
05-123-45688 Barr 11L-401 ❑
05- 123-45691 Barr IN ❑
05- 123-45690 Barr 2N ❑
05- 123-45684 Barr 3N ❑
05- 123-45686 Barr 4N ❑
- - ❑
CI
CI
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
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 Addendum
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