HomeMy WebLinkAbout20133167.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphestatem.us
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
November 5, 2013
Dear Sir or Madam:
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
RECEIVED
WELD COUNTY
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On November 8, 2013, the Air Pollution Control Division will publish a public notice for Noble Energy, Inc.
— Battery #415829206, in the The Greeley Tribune. 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 date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B I
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
�i-PL( fit (it)
"h3/1
2O13-3167
STATE OF COLORADO
John W. Hickenlooper, Governor
Christopher E. Urbina, MD, MPH
Executive Director and Chief Medical Officer
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr. S.
Denver, Colorado 80246-1530
Phone (303) 692-2000
Located in Glendale, Colorado
http://www.cdphe.state.co.us
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Noble Energy, Inc. — Battery #415829206 — Weld County
Released To: The Greeley Tribune
On: November 5, 2013
Published: November 8, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
of Public Health
and Environment
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: Noble Energy, Inc.
Facility: Battery #415829206
Oil and gas E&P wellhead site
SWSW Section 14, T6N, R63W
Weld County
The proposed project or activity is as follows: Operating and maintaining an oil and gas exploration and
production site
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 13WE1731 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 www.colorado.gov/cdphe/AirPublicNotices
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:
Stephanie Chaousy, PE
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1791
Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Battery #415829206, located in the SWSW of Section 14,
Township 6 North, Range 63 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
AIRS
Point
Description
006
Eighteen (18) 500 BBL fixed roof storage tanks used to store
condensate. Emissions from these tanks are controlled by an
enclosed flare.
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 sect), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN
THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days after issuance of this permit, by submitting a Notice of Startup form to the
Division. The Notice of Startup form may be downloaded online at
www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of
the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No.
3, Part B, Section III.G.1 and can result in the revocation of the permit.
2. Within one hundred and eighty days (180) after 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. (Reference: Regulation
No. 3, Part B, II.G.2).
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
AIRS ID: 123/9A73 Page 1 of 8
Condensate Tank SM/M Version 2012-1
Health and Environment
it Pollution Control Division
months or mggl,fyi�/fio ••t to r ion wg ,a reasonable time of the
estimated completion date. The •Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. 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.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. 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
6 Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
006
---
22.0
---
Point
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 be less than 8.0 tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
7. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
006
Enclosed Flare
VOC
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or operator
and made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
Process/Consumption Limits
AIRS
Point
Process Parameter
Annual Limit
006
Condensate throughput
1,000,000 BBL/yr
AIRS ID: 123/9A73
Page 2 of 8
bli Health and Environment
it Pollution Control Division
The owner or •,,,r}" ' h. ; . c nt r• s rat- ed 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
9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
11. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions of
volatile organic compounds to comply with Section XII.D, it shall 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. The operator shall comply with all applicable
requirements of Section XII.
12. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). If a flare or other combustion device is used to control
emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed,
have no visible emissions during normal operations, and be designed so that an observer
can, by means of visual observation from the outside of the enclosed flare or combustion
device, or by other convenient means approved by the Division, determine whether it is
operating properly. The operator shall comply with all applicable requirements of Section
XVII.
14. The condensate storage tanks covered by this permit are subject to Regulation 7, Section
XVII emission control requirements. These requirements include, but are not limited to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
natural gas drip stations and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic compounds
equal to or greater than 20 tons per year based on a rolling twelve-month total
shall operate air pollution control equipment that has an average control
efficiency of at least 95% for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this section
XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to
ensure that it is operating at least as often as condensate is loaded out from the
tank, unless a more frequent inspection or monitoring schedule is followed. In
addition, if a flare or other combustion device is used, the owner or operator shall
AIRS ID: 123/9A73 Page 3 of 8
bli Health and Environment
it Pollution Control Division
vis ec • st as often as condensate is
loaded out from the tank.
XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant to
this section XVII.C., the date, time and duration of any period where the
air pollution control equipment is not operating. The duration of a period of
non -operation shall be from the time that the air pollution control
equipment was last observed to be operating until the time the equipment
recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed from
the device.
w a'- ions
OPERATING & MAINTENANCE REQUIREMENTS
15. 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 your O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with Condition 11, using EPA Method
22 to measure opacity from the flare. The observation period shall be a minimum of fifteen
consecutive minutes.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. 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 (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change
in annual actual emissions of one (1) ton per year or more or five percent, whichever
is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted; or
AIRS ID: 123/9A73 Page 4 of 8
For a
to
olor5.y Depa e
pvx , �itti° p
f blic'Health and Environment
it Pollution Control Division
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.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall
apply to this source at any such time that this source becomes major solely by virtue of a
relaxation in any permit condition. Any relaxation that increases the potential to emit above
the applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
19. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization
section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
AIRS ID: 123/9A73 Page 5 of 8
Health and Environment
r Pollution Control Division
24. Each and eve part hand is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc. Newly permitted
condensate tanks at a synthetic minor facility.
AIRS ID: 12319A73
Page 6 of 8
Notes to Permit Holder
Health and Environment
it Pollution Control Division
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of the
owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form
must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as
possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.cdphe.state.co.us/reclul ations/airregs/100102agcccom m onorovisionsreq.pdf.
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 #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
006
Benzene
71432
A
4,300
Yes
215
Hexane
110543
C
31,000
Yes
1,550
5) The emission levels contained in this permit are based on the following emission factors:
Point 006:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/BBL
Condensate
Throughput
Emission Factors
Controlled
lb/BBL
Condensate
Throughput
Source
VOC
0.88
0.044
Engineering
Calculation (WinSim
+ EPA Tanks)
110543
n -Hexane
0.031
0.0016
Engineering
Calculation (WinSim
+ EPA Tanks)
71432
Benzene
0.0043
0.0002
Engineering
Calculation (WinSim
+ EPA Tanks)
Note: The controlled emissions factors for point 006 are based on the flare control efficiency of 95%.
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
AIRS ID: 123/9A73
Page 7 of 8
blidHealth and Environment
it Pollution Control Division
shall be submitted of n r - s - • he rm e ' Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, n -hexane
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Area Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.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 Z777 — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
httplAmAniv.cdphe.state.co.us/ap/oilqaspermiftinq.html
AIRS ID: 123/9A73
Page 8of8
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Noble Energy, Inc.
Permit Number:
13WE1731
Source Location:
Battery #415829206
SWSW Section 14, T6N, R63W, Weld County (non -attainment)
Equipment Description:
Condensate tanks
AIRS ID:
123-9A73-006
Date:
May 15, 2013
Review Engineer:
Stephanie Chaousy, PE
Control Engineer:
Chris Laplante
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
Section 3 — Applicant Completeness Review
Was the correct APEN submitted for this source type?
X
Yes
No
Is the APEN signed with an original signature?
X
Yes
No
Was the APEN filled out completely?
X
Yes
No
Did the applicant submit all required paperwork?
X
Yes
No
Did the applicant provide ample information to determine emission rates?
X
Yes
No
If you answered "no" to any of the above,
when did you mail an Information Request
letter to the source?
On what date was this application complete?
January 22, 2013; Operator requested a change in
throughput on 6/17/13. New APEN was submitted to
redline original APEN
Section 4 — Source Description
AIRS Point
Equipment Description
006
Eighteen (18) above ground 500 bbl atmospheric condensate storage tanks.
Emissions from these tanks are controlled by a flare.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
X
Yes
No
If "yes", for what pollutant?
PM10
CO
X
Ozone
Is this location in an attainment maintenance area for
any criteria pollutant?
Yes
X
No
If "yes", for what pollutant?
(Note: These pollutants are subject to minor source
RACT per Regulation 3, Part B, Section III.D.2)
PKo
CO
Ozone
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Regulation 7, Sections XII and XVII.C may apply)
X
Yes
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
006
Source provided site -specific emission factors using gas sample, WinSim and E&P
Tanks. See Section 14 for calculations.
Did the applicant provide actual process data for the emission inventory?
Yes
X
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
006
1,000,000 BBL per year
Basis for Actual Emissions Reported Durina this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
006
NA
--
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
006
NA
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
006
01
Flare
95
Section 6 — Emission Summa
(tons per year)
Point
NO,
VOC
CO
Single HAP
Total HAP
PTE:
006
---
440.0
---
15.5 (Hexane)
17.7
Uncontrolled point
source emission rate:
006
---
440.0
---
15.5 (Hexane)
17.7
Controlled point
source emission rate:
006
---
22.0
---
0.8 (Hexane)
0.9
Section 7 — Non -Criteria / Hazardous Air Pollutants
Uncontrolled
Are the
Controlled Emission
Pollutant
CAS #
BIN
Emission Rate
(Ibtyr(
emissionsreportable?Rate
(Ib/yr)
Benzene
71432
A
4300
Yes
215
n -Hexane
110543
C
31000
Yes
1550
Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non -criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
006
01
VOC,
HAPS
PS Memo 05-01
Liquids Analyses
according to PS
Memo 05-01
Page 2
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
PSD
X
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
X
Yes
No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
Yes
X
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
006
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator
of a source shall allow or cause the emission into the atmosphere of any air pollutant which
is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings
taken at 15 -second intervals for six minutes. The approved reference test method for
visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July,
1992)) in all subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner
or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes.
Regulation 2 — Odor
006
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are
measured in excess of the following limits: For areas used predominantly for residential or
commercial purposes it is a violation if odors are detected after the odorous air has been
diluted with seven (7) or more volumes of odor free air.
Regulation 3- APENs Construction Permits, Operating Permits, PSD
006
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in a non -attainment area with uncontrolled actual emissions
of one ton per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 ton per year VOC)
006
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a)
Regulation 6 - New Source Performance Standards
Page 3
006
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
§60.110b Applicability and designation of affected facility.
(a) Except as provided in paragraph (b) of this section, the affected facility to which this
subpart applies is each storage vessel with a capacity greater than or equal to 75 cubic
meters (m ) that is used to store volatile organic liquids (VOL) for which construction,
reconstruction, or modification is commenced after July 23, 1984.
1 barrel [US, petroleum] = 0.15898729493 cubic meter
500 bbl tank = 79.49 cubic meters
Is this source greater than 19,800 gallons (471 bbl)? Yes
Is this source subject to NSPS Kb? No
WHY? Operator provided information for this source. They stated that these tanks are all
prior to custody transfer and therefore meets exemption § 60.11ob(d)(4): Vessels with a
design capacity less than or equal to 1,589.874 m3 used for petroleum or condensate
stored, processed, or treated prior to custody transfer.
Regulation 7 —Volatile Organic Compounds
006
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
since it is located in a non -attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are
greater than 20 tpy of VOC.)
Regulation 8 — Hazardous Air Pollutants
006
MACT EEEE: Organic Liquids Distribution
This source is not subject to MACT EEEE because it is not located at a major source of
HAP.
006
MACT HH
1.Is facility a production field facility per 63.761 (Refer to Section 14 for definition)? Yes
2. If facility is defined as a production facility, then is it a major source of HAPS when
summing up dehydrator and flash tank emissions? No
3.ls this facility considered MAJOR for HAPS? No
4.Is this source subject to MACT HH? No
Section 13 —Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
006
01
E&P Condensate
Storage Tanks
20.8405
lb/1000 gal
VOC
No
Engineering Calculation
(WinSim + EPA Tanks)
95
0.1046
lb/1000 gal
Benzene /
71432
No
Engineering Calculation
(WinSim + EPA Tanks)
95
0.7381
lb/1000 gal
n -Hexane
/ 110543
No
Engineering Calculation
(WinSim + EPA Tanks)
95
SCC
40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses
Page 4
Section 14 — Miscellaneous Application Notes
AIRS Point
006
Condensate Storage Tanks
A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold).
Operator provided site -specific emission factors with the application. The operator used WinSim for flashing losses
and E&P Tank for W+B losses. The operator provided 2 gas analyses which both were sampled on 1/14/13, less
than a year of the submittal application date. The operator took an average between the two samples (different wells
at the same site) and averaged them to get the input for WinSim.
VOC calculation:
WinSim VOC emissions = 124.23 TPY with a projected production of 600,000 bbl/yr
WinSim VOC emission factor =(124.23*2000)/600000 = 0.4141 lb/bbl
E&P VOC emissions (for 1 tank) = 7.69 TPY " 18 = 138.35 TPY with a projected production of 600,000 bbl/yr
E&P VOC emission factor = (138.35*2000)/600000 = 0.4612 lb/bbl
Add the two together for the total VOC E.F. = 0.4141 + 0.4612 = 0.8753 lb/bbl (APEN shows 0.88 lb/bbl)
Convert that to lb/1000 gal = 20.8405 lb/1000 gal
The same method was used to calculate the emission factors for benzene and n -hexane:
Component
WinSim
Emissions
(TPY)
WinSim
E.F.
E&P Tank
emissions
(TPY)
E&P Tank
E.F.
Total E.F.
(lb/bbl)
Total E.F. (lb/1000
gal)
Benzene
0.90
0.0030
0.399
0.0013
0.0043
0.10461b/1000 gal
n -hexane
5.62
0.019
3.80
0.013
0.031
0.7381 lb/1000 gal
MACT HH includes requirements for both major and area sources of HAPs. The definition of major source for MACT
HH (63.761) states:
(3) For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage
vessels with the potential for flash emissions shall be aggregated for a major source determination. For facilities
that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a
major source determination.
The following definitions from 63.761 are also needed to determine major source applicability:
Production field facilities means those facilities located prior to the point of custody transfer
Custody transfer means the transfer of hydrocarbon liquids or natural gas: after processing and/or treatment
in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment,
including product loading racks, to pipelines or any other forms of transportation. For the purposes of this
subpart, the point at which such liquids or natural gas enters a natural gas processing plant is a point of
custody transfer.
Natural gas processing plant (gas plant) means any processing site engaged in the extraction of natural gas
liquids from field gas, or the fractionation of mixed NGL to natural gas products, or a combination of both.
Based on the definitions above, this source qualifies as a production field facility.
May 20, 2013: During operator DRAFT review, the operator requested that the PTE throughput (864089 bbls) and
corresponding emissions be used in the permit instead of the actuals listed on the APEN. I made these changes to
the permit and PA.
June 17, 2013: The operator sent an email requesting if they could increase the throughput because they are adding
8 additional wells. I figured that since the permit was still in draft, and was at supervisor review, I would make these
changes to avoid out of compliance before the permit is issued. I made the changes to the PA, permit and history file
on 6/28/13.
Page 5
Air Pollutant Emission Notice (APEN) — and — Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
Current Status (Check all that apply)
AIRS ID 1/1: 123-9A73 — n °G
GPO]
13 WE1731
Reason for APEN
Submittal (Check all that
only°
to existing sources
for coverage under
request for individual
for or Modification
permit amendment
apply)
general permit no. GPOI and
pemmit6:
■ APEN update
P1/ New or previously unreported battery
■ Modification
• Previously grandfathered battery'
■ Registration
IS Synthetic minor facility
cancellation
® Application
r Located in the 8 -hr Ozone Control Area3
of an individual permit
• Registered under general permit no.
• Administrative
• Permitted under individual permit:
• Other:
For individual permit applications, check if you wants:
analysis conducted by the Division
of the permit prior to issuance
:/ A copy of the preliminary
0 To review a draft
Company Name9: Noble Energy, Inc OGCC Operator #: 100322
Mailing Address10: 1625 Broadway
tphillips@nobleenergyinc
City: Denver State: CO Zip: 80202 E-mail: .can
Contact Name: Taryn Phillips Phone: (303) 228-4362 Fax: (720)587-2037
Tank Battery Namel I: BATTERY #415829206
Number of tanks:
capacity [bbl]:
2012
18
Location12 (QQ Sec. Twp. Range.): SWSW SECI4 T6N R63W County: Weld Total tank
9000
Calendar year for which "Actual" data applies13:
Control Description15: FLARE
2012
Year(s) tank(s) were placed in service °:
Control Efficiencyl6:
95%
Condensate Throughput)? [bbl/year] Requested1e:
Actual29
Other equipment at facility22:
1uw(ik�U Maximum
for PTE calculation19:
While Controls Operational21
-864 89- l CGC 0�? O.
/
7-20-845
7413;075 .244V)
Comments:
Estimated emissions at throughputs listed above. Use N/A for requested
throughput/ emission
Check if site -specific
Requested
Uncontrolled26
yy O
values unless
emission factors provided
Emissions18
Controlled22
'
requesting an individual
to calculate
Actual Emissions�0
Uncontrolled26
31.6.8
permit
emissions23.
Controlled29
15.8
• Check if the Division is to calculate emissions. 0
Emission Factor
Pollutant24 [1b/bbl]
VOC [tons/year] 0.88
Battery
Pita'
it -t Q .3864' 1
NOx [tons/year]
CO [tons/year]
Benzene [lbs/year] 0.0043
2YE-373r5-.6/
tl3C-C,
a[5
3;6963—
13478—
n -Hexane [lbs/year] 0.031 j[
i`,C•. .26g.S64,-✓
3i 000
( 5 -Si;
?121722.3'
1-116.1
Wells serviced by this tank or tank battery281-�
API #: 05-123-35527 Name: WELLS RANCH AA14-62-1HN - we % tli(iq p c
Well
Well
Well
Well
Well
Well
Well 's
Well �'-
./ Newly Reported
API #: 05-123-35524 Name: WELLS RANCH AA14-63-IHN
0 Newly Reported
API #: 05-123-35526 Name: WELLS RANCH AAI4-64-1HN ���.�
0 Newly Reported
API #: 05-123-35525 Name: WELLS RANCH AA14-65-11-IN j / r.1,\,1_ \
0 Newly Reported
API #: 05-123-35613 Name WELLS RANCH AAI4-67-1 HN i F- - jn13 1.,,
�/ Newly Reported
i
API #: 05-123-35615 Name: WELLS RANCH AA14-66-1HN'` \ _,�t� - __
® Newly Reported
API #. 05-123-35612 Name: WELLS RANCH AA14-68-ll{N \ /7
EI Newly Reported
API #: 05-123-35614 Name: WELLS RANCH AA14-69-1HN �_./
® Newly Reported
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true, accurate, and complete to the best o`
my knowledge and belief. If this is a registration for coverage under general permit GPI, I further certify that this source is and will be operate".I�,
in full compliance with each condition of general permit GPI. '•-
( (�`(ti.h-� 2, /,�V January 22, 2013 -"
Signature of gaily Authorized Persotf (not a vendor or consultant) Date
Taryn Phillips Environmental Engineer
Type or Print Name of Person Signing Above Official Title
Submit this form, along with $152.90 for each Colorado Department of Public Health and Environment For information call:
filing of up to 5 tank battery APENS. Include Air Pollution Control Division, APCD-SS-B 1 (303) 692-3150
$250 General Permit fee for each new GP 4300 Cherry Creek Drive South n O 5 0 Q 1
registration to: Denver, CO 80246-1530 G O v
FORM APCD-205
Page 1 of 2
415829206 WELLS RANCH AAI4 ECONODE.DOC
Air Pollutant Emission Notice (APEN) - and —Application for Construction Permit
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
API #: 05-123-35527
API#: 05-123-35524
API #: 05-123-35526
API #; 05-123-35525
API #: 05123-35613
API#: 05-123-35615
API #: 05-123-35614
API #: 05-123-36156
Name: WELLS RANCH AA14-62-1HN ❑ Newly Reported Well
Name: WELLS RANCH AA14-63-1HN
❑ Newly Reported Well
Name: WELLS RANCH AA14-64-IHN ❑ Newly Reported Well
Name: WELLS RANCH AA14-65-IHN
❑ Newly Reported Well
Name WELLS RANCH AAI4-67-1HN ❑ Newly Reported Well
Name: WELLS RANCH AA14-66-1HN ❑ Newly Reported Well
Name: WELLS RANCH AA14-68-IHN ❑ Newly Reported Well
Name: WELLS RANCH STATE PC USX AAI6-62-1 HNL 0 Newly Reported Well
API 4: 05-123-36182 Name: WELLS RANCH STATE PC USX AA16-69-1HNL
0 Newly Reported Well
Name: WELLS RANCH STATE USX AA16-63-IHNL 0 Newly Reported Well
Name: WELLS RANCH STATE USX AA16-64-IHNL ® Newly Reported Well
Name WELLS RANCH STATE USX AA16-65-IHNL ® Newly Reported Well
Name: WELLS RANCH STATE USX AA16-66-1HNL ® Newly Reported Well
Name: WELLS RANCH STATE USX AA16-67-1HNL ® Newly Reported Well
API #: 05-123-36183 Name: WELLS RANCH STATE USX AA16-68-IHNL ® Newly Reported Well
API 4: 05-123-36157
API 4: 05-123-36043
API #: 05-123-36040
API 4: 05-123-36041
API 4: 05-123-36042
Page 2 of 3 415829206 WELLS RANCH AA14 ECONODE
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