HomeMy WebLinkAbout20202327.tiff xY COLORADO
Department& ofPublic RECEIVED
Health&Environment
JUL 17 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
July 8, 2020
Dear Sir or Madam:
On July 9, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble
Energy, Inc. - DP 130 BB05-28-A ECO WR ST AA32. 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
61 c'§<
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I o`,:
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director ! (--.=',-- 7..
Cc:PL(rP),NLCD.S w SMIER/cH/G 2020-2327
Pub l : G Qe V 7 e�1 oG(sn) ),P ( �,
og/o3/2O 07/2-7/20
CM,M.M Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Noble Energy, Inc. - DP 130 BB05-28-A ECO WR ST AA32 - Weld County
Notice Period Begins: July 9, 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: Noble Energy, Inc.
Facility: DP 130 BB05-28-A ECO WR ST AA32
Oil and gas exploration and production facility
NENW Sec 5 T5N R63W
Weld County
The proposed project or activity is as follows: The applicant is requesting to permit equipment at an
existing oil and gas exploration and production facility. The source is requesting to route flash gas from
various equipment onsite to an enclosed combustor and to permit fugitive emission leaks.
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 20WE0173 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:
Carissa Money
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530 ..,....,„ COLORADO
�,,O Department of Public
1 I �iir J Health b Environment
•�:•r. COLORADO
iv r Air Pollution Control Division
Department of Pibltc Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0173 Issuance: 1
Date issued:
Issued to: Noble Energy, Inc.
Facility Name: DP130 BB05-28-A ECO WR ST AA32
Plant AIRS ID: 123/AOC4
Physical Location: NENW Section 5 T5N R63W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
Condensate Flash gas venting from knock out tanks,
Knockout 001 scrubbers, and other miscellaneous Enclosed Combustor
Burners equipment onsite
Fugitive emissions component leaks
Fugitives 002 associated with the oil and gas exploration None
and production facility
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 this
specific 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 (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS)form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.govtpacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. 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
Page 1 of 11
-".:•y COLORADO
0. J Air Pollution Control Division
`ti Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
3. 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
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.)
4. The operator must 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.)
5. 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
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID
Point PM2.5 NO. VOC CO Type
Condensate
Knockout 001 --- --- 4.5 --- Point
Burners
Fugitives 002 --- --- 1.4 --- Fugitive
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for both criteria and hazardous air pollutants, 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.
7. 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.
8. AIRS ID 002: The operator must calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent extended gas analyses,
as required in the Compliance Testing and Sampling section of this permit. The operator must
maintain records of the results of component counts and sampling events used to calculate
Page 2 of 11
COLORADO
Air Pollution Control Division
Department cl Publac Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
actual emissions and the dates that these counts and events were completed. These records
must be provided to the Division upon request.
9. 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.)
Equipment AIRS Control Device Pollutants
ID Point Controlled
Condensate
Knockout 001 Enclosed Combustor VOC and HAP
Burners
PROCESS LIMITATIONS AND RECORDS
10. 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
Equipment ID AIRS Process Parameter Annual Limit
Point
Total gas venting to enclosed
Condensate combustor from knock out tanks,
Knockout 001 scrubbers, and other miscellaneous 2.0 MMSCF/yr
Burners equipment onsite
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.
11. AIRS Point 001: The owner or operator must continuously monitor and record the total
volumetric flow rate of gas vented from the knock out tanks, scrubbers and other miscellaneous
equipment onsite using the flow meter. The flow meter must be calibrated and maintained per
the manufacturer's specifications and schedule. The owner or operator must use monthly
throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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.) (State only enforceable)
13. AIRS ID 001: 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
Page 3 of 11
#.4- COLORADO
Air Pollution Control Division
ccrac
Department cf Public Heat to b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
14. AIRS ID 001: The separator covered by this permit is subject to Regulation 7, Part D, Section
II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation
from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must
either be routed to a gas gathering line or controlled from the commencement of operation by
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.
15. AIRS ID 002: This source is located in an ozone non-attainment or attainment-maintenance
area and subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, Section III.D.2. The following requirements were determined to
be RACT for this source.
Facility = AIRS Pollutant RACT
Equipment ID Point
Fugitives 002 VOC LDAR per Regulation 7, Part D, Section ILE
16. AIRS ID 002: Fugitive component leaks at this well production,facility are subject to the Leak
Detection and Repair (LDAR) program requirements, including but not limited to: monitoring,
repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section
F.L. In addition, the operator shall comply with the General Provisions contained in Regulation
7, Part D, Section I.C.1.
17. AIRS ID 002: Fugitive component leaks at this well production facility are subject to the Leak
Detection and Repair (LDAR) program requirements, including but not limited to: monitoring,
repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section
II.E. In addition, the operator shall comply with the General Provisions contained in Regulation
7, Part D, Section II.B
18. 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 Et MAINTENANCE REQUIREMENTS
19. AIRS ID 001: 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
Page 4 of 11
C y...,-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
order to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to the 0£tM plan are subject to Division approval prior to implementation. (Regulation
Number , Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
20. AIRS ID 001: The owner/operator must complete an initial site specific extended gas analysis
("Analysis") within one hundred and eighty days (180) after commencement of operation or
issuance of this permit, whichever comes later, of the combined gas vented from the knock out
tanks, scrubbers, and other miscellaneous equipment onsite in order to verify the VOC,
benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content
(weight fraction) of this emission stream. Results of the Analysis must be used to calculate site-
specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas
vented) using Division approved methods. Results of the Analysis must be submitted to the
Division as part of the self-certification and must demonstrate the emissions factors established
through the Analysis are less than or equal to, the emissions factors submitted with the permit
application and established herein in the "Notes to Permit Holder" for this emissions point. If
any site-specific emissions factor developed through this Analysis is greater than the emissions
factors submitted with the permit application and established in the "Notes to Permit Holder"
the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the
Division, a request for permit modification to address these inaccuracies.
21. AIRS ID 002: Within one hundred and eighty days (180) after issuance of this permit, the
permittee shall complete the initial extended gas analysis of gas samples that are
representative of volatile organic compound (VOC)and hazardous air pollutants (HAP) that may
be released as fugitive emissions. This extended gas analysis shall be used in the compliance
demonstration as required in the Emission Limits and Records section of this permit. The
operator shall submit the results of the gas analysis and emission calculations to the Division as
part of the self-certification process to ensure compliance with emissions limits.
22. AIRS ID 002: Within one hundred and eighty days.(180) after issuance of this permit, the
operator shall complete a hard count of components at the source and establish the number of
components that are operated in "gas service," "heavy liquid service," "light liquid service"
and "water/oil". The operator shall submit the results to the Division as part of the self-
certification process to ensure compliance with emissions limits.
Periodic Testing Requirements
23. AIRS ID 002: On an annual basis, the permittee shall complete an extended gas analysis of gas
samples that are representative of volatile organic compounds (VOC) and hazardous air
pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be
used in the compliance demonstration as required in the Emission Limits and Records section
of this permit.
ADDITIONAL REQUIREMENTS
24. 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:
Page 5 of 11
C :rv::. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
25. 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
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
26. 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.
27. 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.
Page 6 of 11
e COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
28. 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.
29. 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.
30. 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.
31. 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.
32. 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:
Carissa Money
Permit Engineer
Permit History
Issuance Date Description
Issued to Noble Energy Inc. for:
• Venting from knock out tanks, scrubbers, and
Issuance 1 This Issuance other miscellaneous equipment onsite (AIRS
ID 001)
• Fugitive equipment leaks (AIRS ID 002)
Page 7 of 11
C �. COLORADO
uti Ito Air Poll on Control Division
a Department of Pubic Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder 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 alt 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 sources operates at the permitted
limitations.
Equipment AIRS Uncontrolled Controlled
ID Point Pollutant CAS # Emissions Emissions
(lb/yr) (Ib/yr)
Benzene 71432 1,128 56
Toluene 108883 919 46
Condensate Ethylbenzene 100414 660 33
Knockout 001 Xylenes 1330207 417 21
Burners
n-Hexane 110543 6,022 302
2,2,4-
540841 642 32
Trimethylpentane
Fugitives 002 n-Hexane 110543 34 34
Note: AR 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:
Emissions for Point 001 include venting of flash gas from knock out tanks, scrubbers, and other
miscellaneous equipment onsite to the enclosed combustor, combustion of flash gas at the enclosed
combustor and combustion of pilot light gas for the enclosed combustor. Total emissions are based
on the sum of emissions from all three activities.
Page 8 of 11
. w•z COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Venting of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite
to Enclosed Combustor:
Weight Uncontrolled Controlled
Fraction Emission Emission
CAS # Pollutant of Gas Factors Factors Source
(%) (lb/MMscf) (lb/MMscf)
V0C 78.0 90,207 4,495.3 HYSYS
71432 Benzene 0.5 564.98 28.249 HYSYS
108883 Toluene 0.4 460.25 23.013 HYSYS
100414 Ethylbenzene 0.3 330.50 16.525 HYSYS
1330207 Xylene 0.2 208.69 10.435 HYSYS
110543 n-Hexane 2.6 3,015.3 151.09 HYSYS
2,2,4-
540841 0. 3 321.67 16.084 HYSYS
Trimethylpentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Combustion of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment
onsite:
Combustion emissions from flash gas combusted at the enclosed combustor are calculated using
the following emission factors and actual monthly volume of flash gas routed to the enclosed
combustor.
Uncontrolled Emission Factors
CAS # Pollutant lb/MMscf Flash Gas Source
N0x 167.35 AP-42, Ch 13.5
CO 762.91 AP-42, Ch 13.5
Permitted emissions are based on a heat content of 2,461 btu/scf.
Combustion of Pilot Light:
Combustion emissions from the pilot light are calculated using the following emission factors and
most recent monthly volume of fuel to the pilot lights. The pilot light gas throughput shall be
assumed to have a constant value of 0.04 MMBtu/hr for both burners. Monthly pilot gas throughput
shall be determined by multiplying this hourly pilot gas throughput by the enclosed combustor
monthly hours of operation.
Uncontrolled Emission Factors
CAS # Pollutant lb/MMBtu Source
N0x 0.098 AP-42, Table 1.4-4
CO 0.0824 AP-42, Table 1.4-4
Permitted emissions are based on a heat content of 1,000 btu/scf.
Point 002:
The emission levels contained in this permit are based on the following emission factors:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Page 9 of 11
,,. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Connectors 4,578 588 1,458 820
Flanges 632 0 276 20
Open-ended Lines 6 0 0 0
Pump Seals 0 0 4 0
Valves 1,986 196 1,382 280
Other* 524 0 98 100
VOC Content (wt%) 40.0% 100% 100% 100%
Benzene (wt%) 0. 10% 0.25% 0.25% 0.25%
Toluene (wt%) 0.05% 0. 13% 0. 13% 0. 13%
Ethylbenzene (wt%) 0.05% 0. 13% 0. 13% 0. 13%
Xylenes (wt%) 0.05% 0.13% 0. 13% 0.13%
n-hexane (wt%) 0.50% 1.25% 1.25% 1.25%
2,2,4- 0.05%
t0.13% 0. 13% 0. 13%
rimethylpentane
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05
Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06
Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06
Pump Seals 3.5E-04 --- 5.1E-04 2.4E-05'
Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06
Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05
Source: EPA-453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC
content from the most recent extended gas analysis.
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
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) AIRS ID 002: This source is subject to 40 CFR, Part 60, Subpart 0000a—Standards of Performance
for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction
Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective
August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control
Page 10 of 11
+,. .„......=. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website
at: https://www.gpo.gov/fdsys/pkq/FR-2016-06-03/pdf/2016-11971.pdf
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, CO
PSD True Minor Source of: CO
NANSR Synthetic Minor Source of: VOC, NOx
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: 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 I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A-Subpart Z
MACT 63.600-63.1199 Subpart AA Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Carissa Meney
Package#: 423560
Received Date: 1.2/26/2019
Review Start Date: 92172262o
Section 01-Facility Information
Company Name: Noble Energy,.r , Quadrant Section Township Range
County AIRS ID: '223 NUM 5
Plant AIRS ID: 2 - ir
Facility Name: tt a.tas ° ' �Y - - � .; ...
Physical
Address/Location: .._v ,p.S a,Range 63x12
County: Weld County
Type of Facility: Esplorattcis&7sodtictinn Wet.Pad _ Ya
What industry segment?Grl&Plat at Gas c,roduttiort&P;osesiry
Is this facility located in a NASQS non-attainment area? Yes
If yes,for what pollutant? ozone
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point#
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)
Pe,£wit i nitia:
001 _ - Separato,xistsYsnsg ,denssce 3c,u.F ru_3,ss r Yes r 2 _ .,f Iss2u;-r-c L
9 Ni£ rrrr,a
002 Fugitive Component t teaks. Yugnsn es Nu 20%,,,1C-172
Yes i_stiLr-ce
Section 03-Description of Project
Noble isregnestin-top .r nenn a_ Frt 221c2 sYss st e_has commenced C t r.uc;l .t_ _e.;
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? ;'(e;
If yes,why? Re,.lestaig s�^_I ecc ,.r �.,,
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? o
Is this stationary source a synthetic minor?
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PMZ.5 -PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) O O O O O O
Title V Operating Permits(OP) O ® El El O O O
Non-Attainment New Source Review(NANSR) El
Is this stationary source a major source? fdc
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) O O O O O
Colorado Air Permitting Project
Title V Operating Permits(OP) O O O ❑ O O El O
Non-Attainment New Source Review(NANSR) ❑ ❑
Separator'Venting Emiss o is inventory
Section 01-Administrative Information
Facility ID: s2aiCT 021
AlRs
County Plant Point
Section 02-Equipment Description Details
. Detailed Emissions Unit Description. Hea=ting of faith gee-Iron:eminent nott_...::,anrabbanna and -ha n rance, - _ -•a, .
Emission Control Device Description: ttt�sesltcm-t anaanr ^�';
Requested Overall VOC&HAP Control Efficiency%: '
Limited Process Parameter
Gas meter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= a'+: iMMsd Per Year
Requested Permit Limit Throughput !,,,losooritsrotels, MMscf per year Requested Monthly Throughput= 0.2 MMscf per month
Potential to Emit(PTE)Throughput= 2 MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
, Separator Gas Heating Value: 24 1.01:Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: scf/bbl
Control Device
Pilot Fuel Use Rate: ? 66 sdh 0,1 MMscf/yr 0.04166
Pilot Fuel Gas Heating Value: 1Uqy0�0 Btu/scf
it—
Section 04-Emissions Factors&Methodologies
Desrription —
c
• .,,.�€v ,� �do �: ,: n •ef �,as _.,. ., ,_a,z ,s- - ' _._,,. .� _ a - t.._. �s,_ •e ha
m €
.�, .. �., -•:t'sscTeP:� r�ua <� tta�a
•
MW I ,'Ib/Ib-oral Displacement Equation
Ex=Q.MW"Xx/C
Weight
Helium
' CO2
N2
methane
ethane
propane
isobutane
n-butane - ..
, isopentane _
n-pentane
cyclopentane
n-Hexane
cyclohexane ...Other hexanes
heptanes 5-
methylcyclohexane
224-TMP
Benzene
Toluene -
- Ethylbenzene
Xylenes
CS-€-Heavies
Total
VOC Wt%
3 oft C:\Users\cdmoney\Documents\Package 423660\20WE0173.CP1
Separator Venting Emissions.:.,,J,n}c"
Separator Venting
Uncontrolled Controlled
Emission Factor Source
Pollutant (Ib/MMscf) (Ib/MMscf)11111M IDICIVPIA.41..tiril:n; 1116.06Tgar4
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
iirMI fl.0071
0.00
a 0-0004W W,
"t z',itQ" `.67.3480
1,J10 10--V-'''',
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ih/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
¢,3C75,r '-'
0,0275;/",'s%;.
Mlinl O1O,1'0,000s
EAli 0.0s8c1 „L,
``0.30"34:� .
0,0824;4gil
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Umits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 0-5 1,0 00 (.5 0.0 3
PM2.5 7.3 -3.3 0.0 0.0 0.3 3
SOx 0.3 ,.,. 0.0 0.=3 00 3
NOx 0,2 0.3 flu 0.,t5 0.2 31
VOC 50,3 ,. 0,0 90-••-.3 4.5 767
CO 3,8 .-.3 0.0 0,78 0.33 132
Potential to Emit Actual Emissions Requested Permit Limits Source's values
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 11335 0 0 1135 . 1128 56
Toluene 925 0 0 916 u3 919 46
Ethylhenzene 72 0 0 672 3. 660 33
Xylene 3394 0 C 3-'f 20 417 21
n-Hexane 5020 0 ., 633e 3__ _ 6022 302
224 TM P 6,,18. 0 3 646 3. 642 32
Section 06-Regulatory Summary Analysis
•
Regulation 3,Parts A,B - Sourrs requires q permit
Regulation 7,Part D,Section II.B,F 5vti ce is not}Eat to Regulottor.7,Fart G.Section i!.B.t,F
Regulation 7,Part D,Section li.B.2.e "'".=iii control device far this separator is not sc-b;ect to Rego Ear e S-:in°1.3.2.0
(See regulatory applicability worksheet for detailed analysis)
4 of 8 C:\Users\cdmoney\Documents\Package 423660\20WE0173.CP1
Il iSs:J tS ':For
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been 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 mntain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate
that the emission factors are less than or equal to the emissions factors established with this application.
Are facility-wide permitted emissions of VOC greater than or equal to 40-tons per year in the ozone nonattainment
area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area?
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application.
-A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors
are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? 'r'es
If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180
days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Does the company request a control device efficiency greater than 95%bar a flare or combustion device?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02•.y�ofs ,rI-c/1 of s s4I-fl'y//2l/r ® / y ,7,,,/07),,74020;070,,
- o .
4'h,144WDMOar,ellatilVelellMbriNNOMT,C:affegfArM;AC.;;;mji,e*,44br,404:/tiPtikkrhigifi**40,,,A7,':,4'we;re/
OPS5J g..�..c w,A ,. ,a , ..,.x 'a .p, t.p -i »o.:v,. "..,»n '•s.s a.. }.is aZW: £ S / *ReAMO //.
4,:P;„*:1',IllikW'...44;:,611,%4/#0,JOK‘A„,„40,S,101V,,ZligrAmA,06h*TOrVIlMASIOM.*:,444'(AP;',gge;,140,Unti,l(Ofikk,%.g.;N.
�>F r3,.. '3l
sa x,' 33�,�y,v �,
Section OS-Technical Analysis Notes
» - .mss ,-..= _`
gr
7C •
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
AIRS Point# Process# SCC Cade Pollutant Uncontrolled Emissions Factor Control% Units
001 Ol PM10 x-.. • - ._f;-=.
PM2.5
50x i.-. 0 `t;/mW;S€
NOx .133.,2 0 b//'ti'."v:'
VOC __x7_2 AS IS/fa"iIA,SCF
CO ..._ C. Ib/A.f---i5CF
Benzene 5£3.3 ^s5 cis roritSC
Toluene 463.`_ lit/Al t5CF
Ethylbenzene 335.E 95 #b/€/f5CF
Xylene 196:0 9S Ib/tvttSCF-:
n-Hexane 33102 xc IbitliNISC5
224 TMP 324.2. sS Ib/tciMsCF
5 of 8 C:\Users\cdmoney\Documents\Package 423660\20WE0173.CP1
i -
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B APEN and Permit Requirements
Source€s in the Von,ttainment area
ATTAINMENT
•
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NO%greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.D.3)?
..a.t.3:.,,.a_x..₹...t sourct n nt.,,.at:-A3a,rr,nrdvtP ea
NON-ATTAINMENT
1 Are uncontrolled missions from any criteria pollutants from this individual source greater than l TPY(Regulation 3,Part A,Section 11.0.1.a)? .110.z@„,if„lfilS roe Re
2. Are total facility uncontrolled VOC emssons from the greater than 2 TPY,NMgreater than 5 TPY or CO emissions greater than SOTPY(Regulation 3,Part B,Section 11.1.21? '3i3'f.r.,, r.Source Re
ISeu,c, wa_es a perm,
Colorado Regulation 7,Part O,Section II
1. Was the well newly constructed,hydraulically f t d ompleted on or after August 1,2014? Ilf , `., I5ource is:
Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section 11
Section 11.0-Control of emissions from well production facilities
Alternative Emissions Control(Optional Section)
a. is the separator controlled by a back-up or alternM combustion device(i.e.,not the primary control device)that is not enclosed?I -„ ,IThe contra
e,:nc°al t.•:tr ,.t;+r,a....-a«.af.iee',to Repo,,,;9!,i:z.v,:,: .....r
Section II.B.2.e-Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act;itsdmplementing regulations,and Air Quality Control Commission regulations.This document is
not a rule 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 for any law,
regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing
regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,"'may,""should,"and"can,"is
intended to describe ARCO interpretations and recommendations.Mandatory terminology such as"must•and required"are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Qualify Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
•
1 Fugitre Er.iesiens Inventory
Sec1lo n 01-Adminstr..Information
'Facility..ID: 323 A0U '002
County Plant Point
Section 02-Equipment Descrioaon Details
Detailed Emissions Unit Fbg6Nye mldd puce tleeksfrom comp6nents associatedwt* 0Ilonagoas.
Description: 4rfklr6 or ndpigduc6Sdfpfpofl0y -
Emission control Device Dohs.
Description':
settle ate lnMrmatlon for Emissions Estimates
This sectIonis not appldablero fugitives
Section 04-Emissions Pastors&Methodologies
Regulation T Information
Operating Hours: 8760 hours/year
Ern..Factor Source Scrooning EFs-EPA-453/RAS30t7 Tabie28
Control Efficiency Source. None... ..:r Sea Section 07 notes 1,2.8 3 for 60dil opal information
Calculations Emission Factor(kg/hr- '
Service Component Type O.. roe) Central l%)Pollutant Mass Fraction dncommtmdoiled
Table 24 Table 2-8 Emissions 770) Emissions(bey) GAS
Connectors x:4576 2.00E-04 1.00E-05 0.0% VOG 40.00% 2.20E-051blhrls0urce 0.143
Flanges ---07:6S1-00•03.90E-04 5.20E-02 0.0% benzene 0.1000% 1.26E-05 lblhrlsaurra 0.317
Open{ded Lines •17",/-.0--7,7' 2.00E-03 1.50E-05 0.0% Toluene 0.05% 3.31E-05 Iblhr/source
Pumps 1 '33d . 2.40E-03 3.50E-04 0.0% Ethylbenzene 0.050% 7.72E-041blhr/source
Gas(Rebel valves Include 5 memos /198 ;- 450E-03 2.50E-05 0.0% Xylenes 0.05% 5.51E-05 Iblhrhource
compressor seals) Other =b2 :t 8.80E-03 1.20E-04 0.0% n-Hexane 0.50% 2.65E-04 lblhr/souks
Relief Vdves 'r.v._ 8.80E-03 1.20E-04 0.0% 2,2,4-TMP 0.050% 2.65E-04 lb/iv/source
— — — — — Methanol
— — — — — H2S
— — — — Methyl Mnaptan '
Connectors 55&.;. 250E-06 2.50E-06 0.0% VOC 10000%
Flanges 3.90E-07 3.90E-07 0.0% bela6e 0.25%
Open-Ended Lines — - 1.40E-04 7.20E-06 0.0% Toluene 0.13% TOTAL
Pump Seals 0.000.00 0.000.00 0.0% EMylbenzene 0.13% 0352
86510Oil Valves 0716& 8.40E-06 6.40E-06 0 0% Xylenes 0.13% 0.476
Other _ 3.20E-05 3.20E-05 00% n-Hexane 1.25%
Relief Valves — — -- — 21.4-TOP 0.13% 0...
— -- -- — — Methanol 0.0000
— — — — — H2S 0.00% 0
-- — — -- Methyl 00,000tal 0.00% 0 LIQUID
Connectors *84§95 2.10E-04 9.70E-06 0.0% VOC 100.00% 003022_'` 2.14E-051blhrhource 0.119
Manger ,.-3.75,30 1.10E-04 2.40E-06 0.0% Benzene 01900% 0 001'200+» 5.29E-05 lb/Ohm/roe 0.169
Open-Ended L 0"13x„2 1.40E-03 1.40E-05 00%- Toluene 0.13% 000*6335 3.09E-05 lb/hrhource
Pump Seals 04,-1.: 1.30E-02 5.10E-04 0.0% ENybaot,re 0.130% 0000010307 1.12E-03 1Whrh0urce
Light Oil Vaves 21382 50E-03 1.90E-05 0.0% Xylenes 0.13% 0 70207.323 4.19E-0S lb/hi/source
Other t 750E-03 1.10E-04 0.0% 0.95One 125% 0.00690-.,18 2.43E-04 1h/1r/source
RdielVdves '0.&-,.P.: 750E-03 1.10E-04 0.0% 23,4-TOP 0.13% 00005:00335 2-43E-04 lb/la/source
— — — — — OW.. 0.00% 70
— — — — — H2S 0.00% -
- — — — Methyl Meraptal 0.00%
Cannes ��y. 1.10E-04 1.00E-05 0.0% VOC 100.00% - 0Ifi -
9)660 s 2 2.90E-06 2.90E-06 0.0% Benzene 0.2600% 0.4,7.73,0"
Open-Ended Lines 250E-04 3,50E-06 0.0% Toluene 0.13% 50000ITSIti
Pump Seals51 2,40E-05 2.40E-05 00% EMVI�enzene 0.130% 9.004
Water/Oil Valves . ` 9.30E-05 9.70E-06 0% s 0.13% 0000711.3
Other 1,11C, 1.40E-02 5.90E-05 00 0-0% a 135% 000
22.4-T OP— — — — 23,4-TOP 0.13% 000v'_i:s13
—- — — — H2S 0
— — — — — MCNYI Ow,. 0
Section05-Emissions 2761?'mentors/ ,�ffig'
Did operator requed a buffer? '( A"vf y
Requested..m-1%) _riC,L.r..__v.—CV
901101,61 Uncontrolled Emissions Controlled Emissions _ Souse
VOC I $ip7 I Ipy Screening EFs-EPA-45505-95.017 Table 2A 232 TPY
Benzene 7 lb/yr r lb/yr Screening EFs-EPA-45315-95-017 Table 2-6 0.00341662 0.0034186 .
• Toluene -lb/yr -ihr. ScreeningE.-EPA-453.-95017 Table 20 0.0017464 0.0017464
1101)0enzene - 31b/r t lb/yr Screening EFs-EPA-45]15.95017 Table24 0.0017464 0.0017464
Xylenes 0.ItiNr Ih/yr Sc0ning EFs EPA-4531595017 Table 2A 00017464 0.0017464
Hmane Et IhNr 01 lb/yr reamng EFs-EPA-453/R95O17 Table2-3 0.01709312 00170931
2.24-IMP 0 Iblyr 3 MI, Saeenng EFs EPA-45J/R95-017160le2-3 00017464 00017464
Methanol 'Iblyr 0 I07r Sa6enmg E.-EPA-SW/R-95-017 T.le 2A 0 0
H2S lb/yr 7 Iblyr Screening EFs-EPA-453/R-95-017 Tab.2A 0 0
MethylMemaptan __0 lbhr 0 Iblyr Screening.EPA-453/5-93017 Tab.2-8 0 0
Section D6-Re,ulato Summa Anal es
Reg.3 Re/drWReguiali0n3.Part B.Section ILD.2 to deermine is RACTls required, Yps
500.0 Review40 CFR.Pad 50,Subs.KKK M determine 6 appl.able to this..., No '
Review 40 CFR,Pan 60,Subpart 000010 deteanine if 60.5380 and/or 605386 Is applicable9 =-?1 =`Subject to NSPS 00002
6 Review Secton.13 io determine is LOAR is applicable, • .Yes
Additional Regulatory ComIdemtions
Section IIA.1-...as provided in paragraphs 2 through a below,no owner or operator of source shall allow or
cause 06 emission into the atmosphere al any air pollutant whi0h is in exwse 0720%opacity.This standard is
Regulation based on 24 oons9101 eepa i.rmdin0s taken at l5-second Mt ands for six minutes.The approved(0in$®1.1
method for visible 9mi...rs measurement is EPA Method 9(40 CFR,Part 60,Appendb A(July,19925 in di
subsections of Section II.Aand B dths regd...
Section IA-No person,whertner located.shalls orallow the e.ssionorodurous airs emlnants fromany
single source such as to result n detectable odors which are measure in...of the following Emits/For areas
ReOulatlon2 used predominan0y for residential ormmmerdal pumas.d is a violation Waders are detected alter the odorous air
has been diluted,401 seven(7)01.3.',Gumss of.1°1 116°68.
Part A-APEN Requirements
Cdleia Pollutants:For ameria pollute/Sp/Sir Pullet.Emission Notices are required for each indvidual emission
point in a nonaltatnmeiil area with uncontrolled aplaal emisskms done ton per year or more of any individual
criteria pollutant(polufanis are not summed)for which the area is non-atdnment.
Applicant is required to file an OPEN dn.emissions exceed 1 ton per year VOC
Part B—Construction Permit Exempli0ns
Applicant is required to obtain a permit since uncontrolled 000 emissions from this facility are greater
than the TPY threshold(Reg.3,Part 51
. Is this source located n an ozone nona5a nmentaree or attainment maintenance area,
.57.07/50,06,-.3".
If yes,is this source subject to leak delecllon anchrepair(LOAR)requirements per Regulation 7,Secllon XVII F 1
Regulation3 XII.G or 49 CFR Part 60 Subpats KKK 0000 ur 00002, '
...f.10. ...5
Part B,III.D.2-RACT requirements/or new 0r modified minor sources
This section of Regulation 3 requires RACY for new or modified miner sources located in nanattainment or
ati e alnmtImalntenance areas.This source Is located in Me e-hour ozone nonattainment area.
The date of Interestf0,determining whether ate source is new at modified Is therefore November 20,2007
(the dale of the 6-hour Ozone NA area designation).Since thefuglcves will he In service after the date
above,this source is considered"new 0r modified."
This facility M subject to NSPS 00000 as well as Regulation 7,Section 0511.9.Following the leak detection
and repair program per Reg 7 6listfies the RACT requirements of Regulation 3.The permit will contain a
condition reflecting this determination.
cis Inventory
Is Miss...an onshore"natural gas processing plant as defined in 40 CFR,Part 60.6217 No
Old ItS source commences construction,reconstruction,or modification after January 20,1984,and on or before
Augusl23,2011? No
This source is not subject to NSPS KKK because the new equipment covered by this fugitive source will
commence construction after August 23,2011 and Is net located at a natura.I gas processing plant(see
Regulation 6 technical analysis notes)
Old Ibis source commences construction,reconstruction,or modification after August 23,2011 and on or before
September 18,2915? No
Source Is not subject to NSPS 0000 because the new equipment covered by this fugitive source will
commence construction after September 10,2018.
Is this source located in an ozone non-attainment area or aesrrment maintenance area? Yes
Is this sourceat an onshore"natural gas processing pimp as defined a 40 CFR,Pad50.631T No
Facility is not classified as a natural gas processing plant Therefore,this source Is not subject to
Regulation 7 Regulation 7 Section A.G.
Is the facility classified as a well production facility or naturl gas compress.station? Yes
Since ibis facility is classified as well production facility,it is subject to Regulation 7 Sectlan XVll.F.
Is this source-ala"natual gaspmuming plant"as defined in 40 CFR,Pad 63.]01? No
Is Ibis fecuity considered a"major souse"of HAP as specifically defined in 40 CFR,Part 83.751 or sites that are
pc.production field facilities? No
Regulation 8 If you repond"yes"to both questions above,further review ifthe provisions 0040 CFR,Pad 83.?69"Equipment
Leak Standards"apply?
Source Is not subject to MALT HH because the facility's classified as a synthetic minor source of Haps,
Did This sour.commence ecnshuclbn,reconstruction,or modification after September 10,2015?
Yes
Is this soulceal a well site,compressor station or onshore"natural gas processing plant"m defined in 40 CFR,Pan
60.8430x1
NSPS 0000a
Yes
This facility meets the definition of a well productlan facility as defined by40 CFR,Part 50.6120e.
Therefore,tits fugitive emissions at Ibis faculty are subject to NSPS 00092.
SectionTechnical Analysis Notes
TI mponent counts are estimated based an en al.erineludgmenc The gas compositions based on a similar sites and adjusted to be corsenative(gas sample from Hurley
26-11A Econ.,sampled 8/13/2019(.Asa result,the permit will contain an initial compliance lest requiring that an actual hard count of components and an initial extended gas.
analysis..
As zsed above,this source is subject to NSPS 0000a.However,this NSPS has not yet been adopted into Colorado Regulation 6.Asa result he conANon referencing NSPS
0000a will be addressed in the notes to permit holder section of the permit.
The tacky is an E&Pste so it issobiec!to Regulation-7,SecIron XVIF as well as NSPS 0000a.
Source A using emission factors from tab) 13Ncr ening factors)Nom EPA document Protocol for Fpu'pment Leak Emission Estireates.This'z appropriate once components will
be monitoredn accordance with Section AVID
Section OS-InventarySCCcadlne and Emissions Facsors
Uncontrolled
AIRS Polar" Process# SCCCode Polludat Emissions Fatter Control% Source
pj°'"f rI-n'$uelylts- 'j•{jrpay',i Varies by Varies by component
002 Ol L VOC component type type Screening EFs-EPA-053/R-9.017 Table 2-8
Varies by Varies by component
Benzene component type type Screening ER-EPA-053/R-0.01?Table2A
Varies by Varies by component
Toluene component type type Screening EFs-EPA-453/R-95-01)Table 2d
Varies by Varies by component
Ethylbemene component type type Screening EFs-EPA-053/R-9S-ellTable 2-e
Varies by Varies by component
Xylem component type type .reening ES-EPAS53/R-95-01]Table 2-B
Varies by Varies by component
n-Hexane component type type screening EFs-EPA{53/R-95U12 Table.2-8
Varies by Varies by component
224TMP component type type Screening EFs-EPA653/R-9Sa1nTabie2-8
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Noble Energy Inc.
County AIRS ID 123 History File Edit Date 6118/2020
Plant AIRS ID AOC4 Ozone Status Non-Attainment
Facility Name DP130 BB05-28-A ECO WR ST AA32 Last Modified By: Carissa Money The permit application for 20WE0173 was received prior to the GP02 applications but the permit was completed after the GP02 applications.This tab and the
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 ID VOC HAPs VOC HAPs
•
Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total
Previous Permitted Facility total 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
001 20WE0173 Gas Venting 0.2 90.1 0.8 4.9 - 0.2 4.5 0.8 0.2 New point
002 20WE0173 Fugitive Component Leaks . 1.4_ 0.0 1.4 0.0 New point
003 GP02 Caterpillar,G3306TA,203hp,G6X04819 0.2 0.2 32.5 1.4 32.5 0.6 0.2 0.2 2.0 1.4 3.9 0.6 New GP02
004 GP02 PSI,D08.1 L,236 hp,SN:EEPOG402275 0.2 0.2 20.6 1.6 34.6 0.3 0.2 0.2 2.3 1.6 4.6 0.3 New GP02
005 GP02 PSI,D08.1 L,236 hp,SN:EEPOG402360 0.2 0.2 20.6 1.6 34.6 0.3 0.2 0.2 2.3 1.6 4.6 0.3 New GP02
0.0 0.0
0.0, 0.0
APEN Exempt/Insignificant Sources 0.0 0.0
HP Heaters(9) 0.2 0.2 3.0 0.2 2.5 0.1 0.2 0.2 3.0 0.2 2.5 0.1 From Form APCD-102
0.0 0.0
0.0 •
00.0
0.0 0.0
•
FACILITY TOTAL 0.8 0.8 0.0 0.0 76.9 94.9 1.4 105.0 6.1 0.8 0.8 0.0 0.0 9.8 9.3 1.4 16.4 1.5 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO: Syn Minor(OP)and True Minor for PSD
HAPS: True Minor
Permitted Facility Total 0,6 0,6 0.0 0,0 73.9 94.7 1.4 102.5 6.1 0.6 0.6 0.0 0.0 6.8 9.1 1.4 13.9 1.4 Excludes units exempt from permits/APENs
(A)Chan.ge in Permitted Emissions 0.6 0,6 0.0 0.0 6.8 9.1 1.4 13.9 Pubcom required for new syn minor limits
Total VOC Facility Emissions(point and fugitive) 10.7 Facility is eligible far GP02 because v 45 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) 10.5 _Project emissions less than 25 tpy
Note 1
•
Note 2 •
•
•
Page 1 of 2 Printed 6118/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Noble Energy Inc.
County AIRS ID 123
Plant AIRS ID A0C4
Facility Name DP130 8805-28-A ECO WR ST AA32
Emissions-uncontrolled(lbs per year)
POINT'PERMIT I Description Formaldehyde Acetaldehyde ACroleln Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 20WE0173 Gas Venting 1128 919 660 417 6022 642 4.9
002 20WE0173 Fugitive Component Leaks 7 3 3 3 34 3 0.0
003 GP02 Caterpillar,G3306TA,203hp,G6X04819 980 45 42 25 49 0.6
004 GP02 PSI, D08.1L,236 hp, SN: EEPOG402275 381 52 49 29 57 0.3
005 GP02 PSI, D08.1L,236 hp,SN: EEPOG402360 381 52 49 29 57 0.3
0.0
0.0
APEN Exempt/Insignificant Sources 0.0
HP Heaters(9) 106 0.1
0.0
0.0
0.0
TOTAL(tpy) 0.9 0.1 0.1 0.6 0.5 0.3 0.2 3.1 0.1 0.3 0.0 0.0 6.1
'Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de rninimus
Emissions with controls (lbs per year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy)
rPrevious FACILITY TOTAL 0 0 0 0 0 0 . 0 0 0 0 0 0 0.0
001 20WE0173 Gas Venting 56 46 33 21 302 32 0.2
002 20WE0173 Fugitive Component Leaks 7 3 3 3 34 3 0.0
003 GP02 Caterpillar,G3306TA,203hp,G6X04819 980 45 42 25 49 0.6
004 GP02 PSI, D08.1L,236 hp, SN: EEPOG402275 381 52 49 29 • 57 0.3
005 GP02 PSI, D08.1L,236 hp, SN: EEPOG402360 381 52 49 29 57 0.3
0.0
0.0
APEN Exempt/Insignificant Sources 0.0
HP Heaters(9) 106 0.1
0.0
0.0
0.0
TOTAL(tpy) 0.9 0.1 0.1 0.1 0.0 0.0 0.0 0.2 0.1 0.0 0.0 0.0 1.5
2 123A0C4 6/18/2020
Fugitive Component Leak Emissions APEN °EX 2 b 201g
:.Y Form APCD-203
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 fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO)is available if the
specialty APEN options will not satisfy your reporting needs.A list of all available APEN 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: W EV 73 AIRS ID Number: 1 7.3 /4{Gcv/6 0 a-
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: DP130 BB05-28-A ECO WR ST AA32
Site Location: NENW SEC5 T5N R63W Site Location Weld
County:
NAICS or SIC Code: 1311
Mailing Address: 1625 Broadway, Suite 2200
(Include Zip Code)
Denver, CO 80202 Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E-Mail Address2: janessa.salgado@nblenergy.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.
423653`
COLORADO
ij DN`dpeeiG ..m.,,�,
Permit Number: AIRS ID Number:
Section 2 - Requested Action
ID NEW permit OR newly-reported emission source(check one below)
-OR-
I
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change process or equipment 0 Change company name3 0 Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ❑ 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 Ft Notes:
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
Company equipment Identification No. (optional): Fugitives
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 6/14/2020
Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Facility Types:
Well Production Facility
0 Natural Gas Compressor Station
0 Natural Gas Processing Plant
0 Other(describe):
5 When selecting the facility type,refer to definitions in Colorado Regulation No. 7,Section XVII.
COLORADO
2 I Ana.
Permit Number: AIRS ID Number:
Section 4- Regulatory Information
What is the date that the equipment commenced construction? 8/29/2019
Will this equipment be operated in any NAAQS nonattainment area? ❑Q Yes O No
Will this equipment be located at a stationary source that is considered a ❑Yes ❑ No
Major Source of Hazardous Air Pollutant (HAP)emissions?
Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes ❑ No
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑Yes ❑r No
Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes ID No
Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? ❑� Yes O No
Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑Yes (] No
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? O Yes 0 No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? 0 Yes O No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? El Yes O No
Section 5 - Stream Constituents
0 The required representative gas and liquid extended analysis(including BTEX)to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight%content of each applicable stream.
VOC Benzene Toluene Ethylbenzene Xylene n•Hexane 2,2,4
Stream Trimethyipentane
(wt%) (wt%) (wt%) (wt%) (wt%) (wt%)
(wt%)
Gas 40.00 0.10 0.05 0.05 0.05 0.50 0.05
Heavy Oil
(or Heavy Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13
Light Oil
(or Light Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13
Water/Oil 100 0.25 0.13 0.13 0.13 1.25 0.13
Section 6 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43488, -104.46244
Attach a topographic site map showing location
444 COLORADO
Permit Number: AIRS ID Number:
Section 7 - Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
0 LDAR per 40 CFR Part 60, Subpart KKK
❑Monthly Monitoring- Control: 88%gas valve, 76%light liquid valve, 68%light liquid pump
❑ Quarterly Monitoring- Control: 70%gas valve, 61%light liquid valve, 45%light liquid pump
0 LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa
❑Monthly Monitoring- Control: 96%gas valve, 95%light liquid valve, 88%light liquid pump, 81%
connectors
LDAR per Colorado Regulation No. 7, Section XVII.F
0 Other6:
❑ No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
COLORADO
u«,vu. w weK
Permit Number: AIRS ID Number:
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
❑Table 2-4 was used to estimate emissions7.
0 Table 2-8(< 10,000ppmv)was used to estimate emissions7.
Use the following table to report the component count used to calculate emissions. The component counts listed
in the following table are representative of:
0 Estimated Component Count
❑Actual Component Count conducted on the following date:
Equipment Type
Service Open-Ended y
Connectors Flanges Lines Pump Seals Valves Other
Gas
Count8 4,578 632 6 1,986 524
Emission Factor 1.00E-5 5.70E-6 1.5E-5 2.50E-5 1.20E-4
Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source
Heavy Oil(or Heavy Liquid)
Count8 588 196
Emission Factor 7.50E-6 8.40E-6
Units kg/hr/source kg/hr/source
Light Oil(or Light Liquid)
Count8 1,458 276 4 1,382 98
Emission Factor 9.70E-6 2.4E-6 5.10E-4 1.90E-5 1.10E-4
Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source
Water/Oil
Counts 820 20 280 100
Emission Factor 1.00E-5 2.90E-6 9.70E-6 5.90E-5
Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source
7 Table 2-4 and Table 2.8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the actual
calendar year emissions below.
9 The"Other"equipment type should be applied for any equipment other than connectors,flanges,open-ended lines, pump
seals,or valves.
COLOR DO
Permit Number: AIRS ID Number:
Section 9 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data? 'V/„
Use the following table to report the criteria pollutant emissions from source:
Actual Annual Emissions Requested Annual Permit Emission
Pollutant CAS Limit(s)10
Number Uncontrolled Controlled" Uncontrolled Controlled
(tons/year) (tons/year) (tons/year) (tons/year)
voC 1.37 1.37 1.37
10 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.
11 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 10 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes Q 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:
Actual Annual Emissions Requested Annual Permit
Chemical Name CAS Emission Limit(s)10
Number Uncontrolled Controlledti Uncontrolled Controlled
(lbs/year) (lbs/year) abs/year) (lbs/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543
2,2,4-Trimethytpentane 540841
Other:
10 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.
it Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
leCOLORADO
Permit Number: AIRS ID Number:
Section 11 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
n� 12/20/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Janessa Salgado Environmental Engineer
Name(print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
0 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 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303)692-3175
APCD-SS-B1 OR
4300 Cherry Creek Drive South (303)692-3148
Denver, CO 80246-1530
APCD Main Phone Number
Make check payable to: (303)692-3150
Colorado Department of Public Health and Environment
COLORADO
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