HomeMy WebLinkAbout20172771.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
August 3, 2017
Dear Sir or Madam:
RECEIVED
AUG 0 8 2017
WELD COUNTY
COMMISSIONERS
On August 10, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Schaumberg 17 Sec 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe
PL) 1p 1 t Ca John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
i�w CC. PLCn'1f,(TP), HLCUT),
RQAJ Pwc€_RtCHI,3-tn/ctc)
2017-2771
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Schaumberg 17 Sec Pad - Weld County
Notice Period Begins: August 10, 2017
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: Schaumberg 17 Sec Pad
Well production facility
SWNW Section 17 T5N R64W
Weld County
The proposed project or activity is as follows: Condensate storage tanks at a synthetic minor facility. Other
equipment associated with this project are truck loadout of condensate (GP07) and three (3) RICE engines
(GP02).
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 17WE0607 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
. COLORADO
1IM.Vil
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Andy Gruel
363546
6/16/2017
7/31/2017
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: 9F38
Facility Name: Schaumberg 17 Sec Pad
Physical Address/Location: SWNW quadrant of Section 17, Township 5N, Range 64W, in Weld County, Colorado
Type of Facility: Expleatiorr& production
What industry segment? 011&C.NaturahG rodui
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? [,carbon Monoxide (CO)
Weld
Quadrant
Section
Township
Range
N'
7
64
Section 02 - Emissions Units In Permit Application
[Particulate Matter (PM)
ozone (NOx @ VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
Yes
17WE0603
1 :
Yes
Permit lrtftiaf:
Issuance
Section 03 - Description of Project
New facility commenced production in March 2017.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requ
Project also inc
udes GP02 (x3) and GP07 (x1).
ynthetk tviin
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? Na
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑
❑ ❑ o ❑ ❑ ❑ o
❑ O
No
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
❑ ❑
Condensate Storage Tank(s) Emissions Inventory
Section 01.- Administrative Information
Facility AIRs ID:
123
County
9F3B 001:
Plant Point
Section 02 - Eauioment Description Detailk
Detailed Emissions Unit Twentyed roof atmospheric condensate storage tanks.
Description:
Emission Control Device Enclosed combustor (8
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Cimmaron 48", 1 x Cimarron 60")
5
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Condensate
Throughput =
909,920 Barrels (bbl) per year
909,920 Barrels (bbl) per year
1,091,904 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= 2532.733 Btu/scf
Volume of waste gas emitted per BBL of liquid
produced = 31.5555' scf/bbl
Actual heat content of waste gas routed to combustion device =
Request heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Actual Condensate Throughput While Emissions Controls Operating = 909,920 Barrels (bbl) per year
see Section 08 for details -- Applicant calculated a higher amount than I did. I
will accept the applicant's MMBtu/yr amount.
72,724 MMBTU per year
72,724 MMBTU per year
87,268 MMBTU per year
Applicant's calculated heat content of waste gas (requested)
Applicant's calculated heat content of waste gas (PTE)
79,476 MMBTU per year
95,372 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Control Device
Pollutant
Uncontrolled
Controlled
(Ib/bbl)
(Ib/bbl)
(Condensate
Throughput)
'a. 0.006
0.008
0.0003:
0.060 ..............
0.0004........
(Condensate
Throughput)
0.00032
0.00042
0.00002
0.00018
0.00298
0.00002
Uncontrolled Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
(lb/bbl)
0.1380
(Condensate
Throughput)
0.0241
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
VOC
PM10
PM2.5
NOx
CO
1624.3
1353.56
67.68
1353.56
67.63
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6.58
5.48
5.48
5.48
5.48
13.14
10.95
10.95
10.95
10.95
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year(
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
3.5188
2.9323
0.1466
2.9323
0.1466
5865
293
4.5806
3.8171
0.1909
3.8171
0.1909
7634
382
0.1672
0.1393
0.0070
0.1393
0.0070
279
14
2.0099
1.6749
0.0837
1.6749
0.0837
3350
167
32.5245
27.1038
1.3552
27.1038
1.3552
54208
2710
0.2164
0.1803
0.0090
0.1803
0.0090
361
18
2 of 3
K:\PA\2017\17W E0607.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 06- Regulatory Summary Analysis 123-9F3B-001
Regulation 3, Parts A, B
Point requires a permit.
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVIl.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? >yiaf!
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
17WE0607 CP1
Does the company request a control device efficiency greater than 95% for a flare or combustion device? rib r
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section OS - Technical Analysis Notes
Applicant used ProMax to model flash, workir
limit on APEN.
f calculated NOx and CO: emissions based on ProMax model vapor quantities and heat contentfor flashand wfb emissions.: Flash vapors were modeled at 27.001.MMscffy and heat value
Btu/cf. W/b vapors at. 1.712 MMscf/yrand 2956.34 Btafef. Applying a weighted average to these two streams I arrive at an overall heatvalue of 2532.80 Btufd, and addingthew together I get 28.71!
MMscf/yr. This vapor volume is divided by 9099206blfyr to arrive at a vapor generation rate of 31.5555 scf/tiki. These amounts resulted in the MM8tu/yr amounts calculated in Section 03.
HOWEVER, the applicant used a different method to calculate the MMBtu/yr amount for flash gas and they calculated a somewhat higher (10%) amount than my calculations. I accepted the applicant's
method, and their calculated MM8tu/yr amounts are entered in Section 03 in red.
ing emissions, as well as to calculate NOx and CO emissions. Pro
-oughput is 909920bbli
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point #
001
Process #
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
NOx 0.2870 0 lb/1,000 gallons condensate throughput
VOC 70.8359 95 lb/1,000 gallons condensate throughput
CO 0.5729 0 lb/1,000 gallons condensate throughput
Benzene 0.1535 95 lb/1,000 gallons condensate throughput
Toluene 0.1998 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.0073 95 lb/1,000 gallons condensate throughput
Xylene 0.0877 95 lb/1,000 gallons condensate throughput
n -Hexane 1.4184 95 lb/1,000 gallons condensate throughput
224 TMP 0.0094 95 lb/1,000 gallons condensate throughput
3 of 3 K:\PA\2017\ 17WE0607.CP1.xlsm
Non -Attainment
W •
'.
LL
O
C
a
c
U
a
Q7
co
O
0.
a
N
E
4,
E
N
E
T
C
O.
E
U
0
C
C
c
U
N
c
a
E
2
u
m
W
d
d
O.
N
C
0
20
C
0
C)
r
3
y
Z
O
E5
u)
W
N
GI
O
O
d
O
C
O
c)
C
d)
z
0
N
U)
2
W
REMARKS
New Facility - No Previous Total
SSEFs accepted
State Default EFs for Condensate
new GP02 June 2017
new GP02 June 2017
new GP02 June 2017
N
a;
ea
FL
r
0
N
E
LL
Fm June package
FromroJune 2017 2017 package
VOC: Syn Minor (NANSR and OP)
NOx: Minor (NANSR and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hexane & Total
HH: Syn Minor
7777: Syn Minor
Excludes units exempt from permits/APENs
Pubcom required due to new syn minor limits
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
W 4.
0.
1.2'=
O O
O o
ra
r
r
O O
O
N
O
a
0
a r
0 0
in
a
N
O)
Q
a
OO
Nd
OO
r
O
r
TT.
O
O
o
M
is
m
P r
0 V)
LL00
>
O O
o O
M
O
a
06
O O
0
O
o0
C.--
rdd
a
o CO
ro
0
CO
0
.-
o
o
N
o
o
o
m
C.-. 14..
o)a)
r r
Mr
owoa ^
Ox
z
oo
do
ra
06d
V co
co
0
co
o
O
r)
m
r
M M
as
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
N
O
N
a O
a o
o
O
O O
0 0
al
N
I
OO
o 0
a
0
O O
00
a
N
2
a
O O
d o
M
0
M
0
O O
o 0
O
a
0o
00
co
d
0
0
o O
00
G
H =
O O
o d
co
6
co. r
r o
r
0
N
0
O
0
O r
0 0
r
10
O
O
U
c, c,
o 0
o.
�o
o M
a)
a
a)
co
v
a
a
O
v
O
a
LL 00
>
O O
O O
co
O
M
O
O
0
O
≥
o o
0 0
ro
a CO
ro o
CO
o
cil
vi
c-
o
a
N
d
o
N.
a
Oa
2
O
o O
a
a co
O
`
co
r
O
,
(a
M
N
a
0
vi
a
N
O
N
O O
a O
a
0
o
O
a
=
0o
o O
O
a
O
o
of
N
2
a
O O
O O
M
d
M
0
O
0
O
a
OO
00
co
0
a
0
O
0
Description
'Previous FACILITY TOTAL
Previous Permitted Facility total
Condensate Tanks (20)
Truck Loadout
GM Vortec 5.7L, sn.. 1M0109
m
a ,'
N a
J O
r a
Lri r
CI
2 c.7
0oa
a
0
co
w
c
°1
J.
O
a
`m
co
'APEN-Exempt / Insignficants
External Combustion Sources
Fugitives
Produced Water Tanks
Permitted Facility Total
(A) Change in Permitted Emissions
PERMIT
r
O
8
I�
GP07
GP02
GP02
GP02
FACILITY TOTAL
00��0
NM
a
a
OO
r
Q
z
N
O
z
I-
2 0
a¢9
Printed 8/2/2017
F
z
2
z
J
z
w
Ca o
z
d
y.
-
J
xQ�
az�
Oo.
O 0 5
• _
F
W z
Ca
C
C
O
U
a
as
a
U
a)
0
CD
O d
c E
W m
co co s
0- 0I)
m
E
z�
c
• Q
E
O • 0 a
Facility Name
lQ
d
d
H
172
d
O
tJ
U)
0
y
E
W
TOTAL (tpy)
O
O
a0
M
O
r-
.—
O
O
N
O
0
O
0
O
O
co
O
O
O
up
N
O
O
O
a
F
N
N
0
CO
co
N
0
McOH
0
O
N
O
N
N
q
0
n -Hexane
O
I 54208
3276
12
(
a0
00
N
Xylenes
O
3350
a-
0
r
Ethylbenzene
O
rn
h
N
Ndo
a -
Toluene
co
7634
r
I-47
aD
M
Benzene
O
(C
CO
U)
373
O
O
(fl
a—
rM
6)
N
M
Acrolein
O
a-
a-
N
N
O
0
Acetaldehyde
O
O
O
W
N
O
0
Formaldehyde
O
al'
134
209
Csl
O
Description
(Previous FACILITY TOTAL
Condensate Tanks (20)
Truck Loadout
IGM Vortec 5.7L, sn: 1M0109
GM Vortec 5.7L, sn: 10CHMM31030001I
(Red River GM 9.0L, sn: 318913
IAPEN-Exempt / Insignficants
External Combustion Sources
`Fugitives 1
Produced Water Tanks
PERMIT
N -
c)
0
0
w
GP07
IGP02
IGP02
IGP02
2.
Q
F
O
I-
I-
Z
0_
0
00000
N
0
CO
0
0
(O
0
N
N
J
To
E
E
a)
A
N
C
O
CO
N
E
m
a
m
O
O
U
C
m
`a)
3
a
x
m
a)
a
0 0
a)
a
ct
Cu
O
H
N
E
E
aJ
a
V
C
0
E
m
a
m
0
C
0
C
CC))
F-
a)
m
TOTAL (tpy)
O
O
CO
a-
e-
O
a-
O
a-
O
N
O
0
O
0
O
c-
O
CO
N
O
C
O
N
I
O
O
0
CL
I-
.4-
N
N
0
00
O
0
McOH
0co
O
N
0
N
CO
0
al
C
aJ
I
I 2710
I 164
Xylenes
O
167
r
T.
0
Ethylbenzene
O
Nt
'
N
O
0
Toluene
0
N
O
co
-.-
47
Na-
O
Benzene
O
293 I
O
0
0
CO
-
.-
O)
M
Cl
O
Acrolein
O
N-
I-
CV
N
O
0
a)
a:,
a
U
O
CO
CO
29
O
0
Formaldehyde
O
H.
134
209
N
O
POINT PERMIT Description
(Previous FACILITY TOTAL
Condensate Tanks (20)
Truck Loadout
IGM Vortec 5.7L, sn: 1M0109
IGM Vortec 5.7L, sn: 10CHMM31030001
(Red River GM 9.0L, sn: 318913
IAPEN-Exempt / Insignficants I
(External Combustion Sources
Fugitives
(Produced Water Tanks
N.
0
0
0
W
3
GP07
IGP02
IGP02
N
0
d
C7
j
a
J
F
O
0
N
0
0
0
0
0
0
0
r
O
N
N
m
1239F3B.xlsx
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0607
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
PDC Energy, Inc.
Schaumberg 17 Sec Pad
123/9F3B
SWNW Section 17 T5N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1
001
Twenty (20) 536 -barrel fixed roof storage
vessels used to store condensate.
Enclosed Combustor
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. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
3. 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
COLORADO
Air Pollution Control Division
Page 1 of 7
4.
tants s II of exc
g limitations. (Regulation Number 3, Part
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
TK-1
001
---
5.5
67.7
11.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
5. 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
Enclosed Combustors
(8 x Cimarron 48", 1 x Cimarron 60")
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
6. 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
909,920 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
COLORADO
Air Pollution Control Division
3C?ti t' -64ati .ieE,: �. ylectt
Page 2 of 7
7. he pe','t i and to„t AIRS n : ber a =m; gned by the Division (e.g. 123/4567/001)
dentification. (Regulation Number 3, Part
8.
nts ofGa..tion Number 2. (State only enforceable)
9. 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)
10. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; 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.
11. 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.
12. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall 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.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. 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
COLORADO
Air Pollution Control Division
Page 3 of 7
ny fifteen -minute period during normal
B.2. and XVII.A.16)
15. is source i"""`: re'ui"=' o co .0t":' i•dic tes i unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. 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 (NOr) 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.
GENERAL TERMS AND CONDITIONS
17. 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.
18. 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.
19. 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,
COLORADO
Air Pollution Control Division
.' ..rent
Page 4 of 7
rdance with this information and with
er or operator's agents. It is valid only for
dentified on the permit.
20. spe cific 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.
21. 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.
22. 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.
23. 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:
Andy Gruel, P.E.
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
rocess time for this permit. An invoice for these
fe Twill b su- aft he . -I.mit 1 The permi older shall pay the invoice within 30 days
of v'lur-. - invoi11 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 conditionwhich causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
5865
293
Toluene
108883
7634
382
Ethylbenzene
100414
279
14
Xylenes
1330207
3350
167
n -Hexane
110543
54208
2710
2,2,4-
Trimethylpentane
540841
361
18
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
N0x
0.0121
0.0121
TNRCC Flare
Guidance
CO
0.0241
0.0241
V0C
2.9751
0.14876
ProMax model
based on site
specific
pressurized liquid
sample
71432
Benzene
0.006
0.00032
108883
Toluene
0.008
0.00042
100414
Ethylbenzene
0.0003
0.00002
1330207
Xylene
0.004
0.00018
110543
n -Hexane
0.060
0.00298
540841
2 2,4
Trimethylpentane
0.0004
0.00002
COLORADO
Air Pollution Control Division
�L•:;r :� utr€i Gran. mitt
Page 6 of 7
on the flare control efficiency of 95%. NOx
at content of 72,724 MMBtu/yr.
6) In -114. each it Pollutan mission Notice (APEN) associated with
fiv -r ,ray the d was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (total, and n -hexane)
PSD or NANSR
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 7 of 7
Condensate Storage Tank(s) APEN'-
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission
source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil
storage tanks, produced water storage tanks, hydrocarbon liquid loadings, etc.). In addition, the General APEN (Form
APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN
forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
1WL �� 0� AIRS ID Number: 123 /q fag/ 00
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Schaumberg 17 Sec Pad
Site Location: SWNW Sec 17 T5N R64W
Mailing Address: i
(Include Zip Code) 177 ;Sherman Street, Suite 3000
W �a
Den)rr, CO 80203
:iii
fi L
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact:
Phone Number:
E -Mail Address2:
Jack Starr
(303) 860-5800
Jack.Starr@pdce.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
31�3544-1
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 I
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
Q NEW permit OR newly -reported emission source
✓❑ Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment 0 Change company name
❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
Additional Info a Notes: Initial permit request for new facility
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
c,a
Normal Hours of Source Operation:
Storage tank(s) located at;
Condensate Storage Tanks
3/2/2017
24 hours/day 7 days/week 52
0 Exploration & Production (E&P) site
weeks/year
0 Midstream or Downstream (non EEtP) site
Will this equipment be oP6rated in any NAAQS nonattainment area?
•
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
p
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
p
Yes
•
No
If "yes", identify the stock tank gas -to -oil ratio:
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
2 1 A
COLORADO
of ,c
Hcu:n a E,r.�w.roo,.,em
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
❑ Upward
❑ Horizontal
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limit'
(bbl/year)
Condensate Throughput:
909,920
909,920
From what year is the actual annual amount?
2017
Average API gravity of sales oil: 50.7 degrees
O Internal floating roof
Tank design: ❑✓ Fixed roof
RVP of sales oil: 8.6
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-1
20
10720
8/2016
3/2017
Wells Serviced by this Storage Tank or Tank Battery5 (ECtP Sites On y)
API Number
Name of Well
Newly Reported Well
05
- 123-
43088
Schaumberg 17F-202ST
12
05
- 123-
43091
Schaumberg 17F-204
❑✓
05
- 123-
43096
Schaumberg 17F-232
17
05
- 123-
43094
Schaumberg 17F-234
17
05
- 123-
43087
Schaumberg 17F-332
0
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.401 999 / -104.580116
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
I,
..V
Indicate the direction of the 'tack outlet: (check one)
❑ Downward
o Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
o Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017
Ay COLORADO
grommet
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit A 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:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs, BTEX
Rating: MMBtu/hr
hr
8 x Cimarron 48", 1 x Cimarron 60"
Type: Enclosed Combustor Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
)!R
=Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (EaP Sites Only)
What is the pressure of fihe final separator vessel prior to discharge to the storage tank(s)? 31 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 4 I �� a�o�mn,
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
95%
NOx
CO
HAPs
Enclosed Combustor
95%
Other:
From what year is the following reported actual annual emissions data?
2017
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions7
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
2.9743
lb/bbl
ProMax
1353.20
67.66
1353.20
67.66
NOx
0.1380
Ib/MMBtu
TCEQ
N/A
5.48
N/A
5.48
CO
0.2755
lb/MMBtu
TCEQ
N/A
10.95
N/A
10.95
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions7
(Pounds/year)
Benzene
71432
0.0064
lb/bbl
ProMax
5864.67
293.23
Toluene
108883
0.0084
lb/bbl
ProMax
7634.28
381.71
Ethylbenzene
� ,,.100414
0.0003
lb/bbl
ProMax
278.65
13.93
Xylene
-1330207
0.0037
lb/bbl
ProMax
3349.92
167.50
n -Hexane
t110543
0.0596
lb/bbl
ProMax
54207.80
2710.39
2,2,4'
Trimethylpentane
;Y540841
0.0004
lb/bbl
ProMax
360.69
18.03
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 5 I h8
'COLORADO
ofYa.
He nt b Envllnmmwnl
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
S 6M/2 -o/ }
Si ature of Legally Authorized Person (not a vendor or consultant) Date
Jack Starr
EHS Professional
Name (print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
✓❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
sa
Send this form along with Srl52.90 and the General Permit For more information or assistance call:
registration fee of $250, ,if:applicable, to:
:p
Colorado Department of Public Health and Small Business Assistance Program
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
(303) 692-3175 or (303) 692-3148
https://www.colorado.gov/cdphe/apcd
i
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 I =If
COLORADO
Heal.6 Envanarnom
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Schaumberg 17 Sec Pad
Emissions Source AIRS ID2:
/ /
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 43092
Schaumberg 17F-334
I
05 -123 - 43095
Schaumberg 17G-202
1
05 -123 - 43468
Schaumberg 17G-214RD
0
05 - 123 - 43093
Schaumberg 17G-312
05 -123 - 43090
Schaumberg 17G-314
11
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
t
.1
Form APCD-212
TK-1 Addendum
Hello