HomeMy WebLinkAbout20201228.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
March 25, 2020
Dear Sir or Madam:
RECEIVED
MAR 3 0 2020
WELD COUNTY
COMMISSIONERS
On March 26, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Rohn State LD09 Econode T9N-R58W-S15 L01. 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.
pvbl:G Rev:eJ
5/ii/2o
Colorado Dept. of Public Health Ft Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe
Jared Polls, Governor I Jilt Hunsaker Ryan, MPH, Executive Director
cc PL(TP)� F(l.(LK) P64A/ER/cHM 0,
OG(3n)
�I/27/2.o
2020-1228
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Rohn State LD09 Econode T9N-R58W-S15 L01 - Weld County
Notice Period Begins: March 26, 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: Rohn State LD09 Econode T9N-R58W-S15 L01
Oil and gas exploration and production facility
E1 /2 Sec 9 T9N R58W
Weld County
The proposed project or activity is as follows: Noble is requesting to remove an existing vapor recovery unit
(VRU) and be able to vent the existing vapor recovery tower (VRT) to flare instead of recycling through the
VRU.
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 19WE1052 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
Department of Public
Health & Environment
COLORADO
Air Pollution Control Division
Department of Public Heatth & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE1052 Issuance: 1
Date issued:
Issued to: Noble Energy Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Rohn State LD09 Econode T9N-R58W-S15 L01
123/9CA1
E1/2 Section 9 T9N R58W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment ID
AIRSPoint
Equipment Description
Emissions Control
Description
VRT
016
Three Vapor Recovery Towers (VRTs)
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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.gov/pacific/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
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
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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. )
Monthly Limits:
Equipment ID
AIRS
Point
Pounds per Month
Emission
Type
PM2.5
NOX
VOC
CO
VRT
016
---
---
1,984
Point
Note: Monthly limits are based on a 31 -day month.
The owner or operator must calculate monthly emissions based on the calendar month.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 1,359 pounds
per month.
Facility -wide emissions of total hazardous air pollutants must not exceed 3,398 pounds per
month.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
VRT
016
---
---
11.7
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
During the first twelve (12) months of operation, compliance with both the monthly and annual
emission limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
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. 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 ID
AIRS Point
Control Device
Pollutants Controlled
VRT
016
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. 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
Point
Process Parameter
Annual Limit
Monthly Limit
(31 days)
VRT
016
Gas venting to flare
3.5 MMSCF
0.3 MMscf/month
The owner or operator must monitor monthly process rates based on the calendar month.
During the first twelve (12) months of operation, compliance with both the monthly and annual
throughput limitations is required. After the first twelve (12) months of operation, compliance
with only the annual limitation is required.
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.
10. The owner or operator must continuously monitor and record the volumetric flow rate of gas
vented from all three VRTs to the flare 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.
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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.) I. E.) (State only enforceable)
12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must
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 Number 1, Section II.A.5.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. 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 Ft MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (OEtM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. 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 gas vented from this emissions unit in order to verify the
VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpeni;ane 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.
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Envlrorrnent
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) 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.
18. 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
19. 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.
20. 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 -
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & cnwronment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
21. 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.
22. 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.
23. 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.
24. 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.
25. 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
Issuance 1
This Issuance
Issued to Noble Energy Inc. for venting from
three Vapor Recovery Towers (VRT)
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT
016
Benzene
71432
2,345
117
Toluene
108883
2,223
111
Ethylbenzene
100414
334
17
Xylenes
1330207
866
43
n -Hexane
110543
14,356
719
2,2,4-
Trimethylpentane
540841
1,677
84
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Emissions for Point 016 include venting of VRT gas to the flare, combustion of VRT gas at the flare
and combustion of pilot light gas for the flare. Total emissions are based on the sum of emissions
from all three activities.
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Neatth & Envtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Venting of VRT Separator Gas to Flare:
CAS #
Pollutant
Weight
Fraction
of Gas
(%)
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
VOC
93.6
134,878
6,719.74
Source (Promax)
71432
Benzene
0.5
675.72
33.786
Source (Promax)
108883
Toluene
0.4
640.51
32.025
Source (Promax)
100414
Ethylbenzene
0.1
96.345
4.8172
Source (Promax)
1330207
Xylene
0.2
249.60
12.480
Source (Promax)
110543
n -Hexane
2.9
4,136.4
206.82
Source (Promax)
540841
2'2'4-0.3
Trimethylpentane
483.30
24.165
Source (Promax)
Note: The controlled emissions factors for this point are based on a control efficiency of 9556 -
Combustion of VRT Gas:
Combustion emissions from VRT gas combusted at the flare are calculated using the following
emission factors and actual monthly volume of VRT gas routed to -the flare.
CAS
Pollutant
Uncontrolled Emission Factors
lb/MMscf VRT separator gas
Source
NOx
207.67
AP -42, Ch 13.5
CO '
946.74
AP -42, Ch 13.5
Permitted emissions are based on a heat content of 3,054 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 0.083 MMBtu/hr for all four burners. Monthly pilot gas
throughput shall be determined by multiplying this hourly pilot gas throughput by the flare monthly
hours of operation.
CAS
Pollutant
Uncontrolled Emission Factors
lb/MMBtu
Source
NOx
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.
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) This facility is classified as follows:
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx, HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Not applicable
8) 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
MALT
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 9 of 9
Colorado r Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Carissa tsaes,
Package#: taarit';
Received Date: 11,t7/2019
Review Start Date: �{2D26
Section 01-Facility Information
Company Name: b a* l Quadrant Section Township
s .i ; r,: st Range
County AIRS ID: 12' _,-_
Plant AIRS ID: °CAy
Facility Name: state T Easanr,de stgra K:w S
Physical
Address/Location:
County: Weld County
Type of Facility: ED,plarati,"&Production.-tel Pad
What industry segment?OilR Nator.;;Gas Rrod ct'on&.Pr
Is this facility located in a NAAQS non-attainment area? hf^
If yes,for what pollutant?
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point# Permit#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Fac t r.r,D-fiVar
Out S-�paratorVenting VP" Yes 1 WE,113,,2 a `,'es iss,:ance
Section 03-Description of Project
Noble will be removing the VRUs at this existing E&P site so the VRT gases will no longer be recycled..Instead,the gas will be routed to flare.Noble stated in the cover letter that
when the LP compressors are down,the facility does not operate;thus,they are not requesting to vent the LP separator.
This site was identified as outside the non-attainment area boundary.I confirmed on the division's technical services air pollution map,this site is outside the boundary,.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required?
If yes,why? Fretstestalg tam rate%',-(s-Pas--a
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? ₹40
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor?
If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) �
Title V Operating Permits(OP) J J J I_I
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source? rs
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) - C
Title V Operating Permits(OP) G _
Colorado Air Permitting Project
IINon-Attainment New Source Review(NANSR)
•
yr Vf_.,tng Emissions lnuantCl'y
Section 01-Administrative Information
Facility AIRS
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description: . `a, r' w -
Requested Overall VOC&HAP Control Efficiency%.
Limited Process Parameter
Gas meter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput ?' MMscf per year
Requested Permit Limit Throughput—';t,N, �. 3 �;:;MMscf per year Requested Monthly Throughput= 1.3 MMscf per month 2.579829167 Mscf/hr from original mode
Potential to Emit(PTE)Throughput= 3.46 MMscf per year liquid to VRT
209656 bbl/yr
Secondary Emissions-Combustion Device(s)for Air Pollution Control 193823 bbl/yr from original model
Separator Gas Heating Value: Btu/scF
,y
Volume of waste gas emitted per BBL of i Vn :
liquids throughput: '",j,�, 9 s d/bbl
Control Device
Pilot Fuel Use Rate: s `3* ¢ scfh 0.73 MMscf/yr - 0.083333332 Mmbtu/hr
Pilot Fuel Gas Heating Value: _ a - a. Btu/scf -
Section 04-Emissions Factors&Methodologies
Description
,
MW I 5@e.Ib/Ib-mol Displacement Equation
Ex=Q*MW*Xx/C
Weight
Helium
CO2 j
N2
-methane
ethane �� W
propane v _
isobutane Es
n-butane
isopentane
n-Pentane -)
cyclopentane - -
n-Hexane
cyclohexane
Other hexanes _
heptanes
methylcyclshezane
enB B zenene
Toluene
Ethylbenzene
GCB+Heavies _.,
Total _..
VOC Wt%
3 of 6 K:\PA\2019\19WE1052.CP1
Emission Factors Separator Venting
Uncontrolled Controlled
Pollutant (Ib/MMscf) (lb/MMscf) Emission Factor Source Source's values
(Gas Throughput) (Gas Throughput)
VOC 323,3C 2, _.Y,;.9
-- "'� "134,ST3 6743.90879
—
Benzene - 526 3,325 3232,32 675.7219 33.786095
Toluene 523.3264 31.5523 540.5062 32.02531
Ethylbenzene i i0;&074 5.0404 96.3447 4.817235
Xylene 23.4169 11,520-8 249.6041 12.480205
n-Hexane 4133.19', 3;,-.6513 4,136.41 206.82065
224 TMP 11.>"3« 42718 y 'f.:s?t 483.3046 24.16523
Primary Control Device 0
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 x35R4332 LvJ,.a __<. _ 23474324420,44:42372144X.224742,7,7 .,,
.4,4.3,..3.35.23344,445A:4334,4023,4i342;4443V44'342440
PM2.5 6.vU.%S22.75'2 343,44444,443457153.4133204331.4444424357-43.44p,34.243.442444.4.5
414444425374444234
SO', b,rY_s05 1.72325 s,
iRe
NOx 4₹.0681 347.6720 $
CO "`„48tre 946_.7493 __. • L. ,F•
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source .
(Waste Heat • • - • _- `
Combusted) (Pilot Gas Throughput) -
PM10 '� w O 7.451`591e2 '
PM2.5 ie` h. /. ' T45t0
SOx 7—'' _ .,t 0.5812
NOx .' 994 1,r1 ' 58.3339E ,3.. �..
tiQiitiLlAtailigni
CO O1-1V11O90,4 82,3329
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled •
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 3.0 9.0 0.0 0.3 0.0 r
PM2.5 r 0 ,,.0 0.0 4.. 7
503 0.0 3.0 0.2 7 7 ii..
NOx 0.41 0.0 0.0 ' . 67
VOC -33.5 6.0 0._. .f = 41..3 10084 234.06
CO g;!3. 0.0 0.0 _.• 1.7 34.
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) (Ibs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 7>d5 0 1 2345 117 117.25
Toluene 0 2 -- 2223 111
Ethylbenzene 342 0 0 - - 334 17
Xylene - f: 1 866 43
n-Hexane 3 i5 0 0 _ 14356 719
224 TMP 2.636 0 0 ,-,-2,_ _- 1677 84
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Sc.,trce requires a senor
Regulation 7,Section XVII.B,G _,cars 3;,rb'e• t,Reg cn 7,section 2231 5.2,2,6
Regulation 7,Section 01/11.0.2.e -,e,,_ a,_7.. t.rs 447,452342s rot 4425322 to'09 '5c7 on,,_s T',o X 23.3.2_.
(See regulatory applicability worksheet for detailed analysis)
4 of 6 K:\PA\2019\19WE1052.CP1
Sepa ator Venting Emissions i gen cigv
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 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.
Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes,the permit will contain:
-An"Initial Testing Requirement"to collect a site-specific gal 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?
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%for a flare or combustion device?
If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
s1.
/ /q, ¢erg y
w .n s2r;zydoayi, /; /,,,,.. ;....„gag gggggg,,gogg;g,goggftio.gggggggg,g,g,gggEig,(,ogggfgg.4nov7gxgiro,,ggggg,,g.gg.gg.g.,i
ige/ / •t,v
/ri✓%rvii7-.2" :Si'u4w'-r�5 �9r r /'f/7 /43..0,0",s r r ?x
Section 08-Technical Analysis Notes
re stream and p.._
The November 2019 application was originally based one single pressurized liquids sample collected from the outlet of a low pressure seperator on site which was.hen used in Prem.:,reversipatar to gener gh ate a h ressu ,ezv`
estimated LP gat r this reversioator model,the LP gas was estimated to he at a pressure of 28 psig and the VRT was at 4 psig.Noble then used the simulated HP stream in a separate model hut the LP at3Up-ig and toe VRl 4 prig and
based requested emissions on this mode!I requested Noble to not use the reversipator and simply"forward"model the VRT emissions based on the LP pressurized;quid samples.Noble sent a revised model on 2/1 at 2/2020.the,evisc,lmod,l .I
was HYSY5,not Promax,and booed on combining all 4 of the she-specific LP separator oultet pressurized ligoids samples.This model resulted in itigherVR7 flow but t"eVRT stream VOC corn position slightly detrea<ed from 94.8 Wt%to 536
vrt%However,because of the significantly higher flow estimate,the HYSY5 model is more conservative and will be the basis for the permit.Tbe inlets for this itodel are described inn Orion 04 above
Section 09-Inventory SCC Coding and Emissions Factors
AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
016 01 a'Ps PMi0 22.3 3 !b/P-WASCFF SCC coding withpilat
PM2.5 22.3 0 Its/PAIASCF emissions in lbs divic
5Oz 1.2 0 ib/M1d5CF
NOx 207.7 0 'b/aIM00p
VOC _34223.4 95 ib/MgASCF
CO 945.7 0
Benzene 9-7d.8 - 55 1+/2,td598
Toluene 533,0 90 s/m.01555
Ethylbenzene - 100.3 98 iup'd9918.5
Xylene 230,4 95 tb/rardd,?255
n-Hexane 4'.33.1 35 IL/ry?fa'OCF
224 TMP 489.5 95 Ib/54548
5 of 6 K:\PA\2019\19WE1052.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re ulation 3 Parts A end B-APEN and Permit Reouirements '
SaurcRIs in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions tram any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ll.D.1.a)7 Y=_s' Source Re
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)? .e0 Source Re
ISovrce require;a perm_
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section ll.D.1.a)7
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.21?
"o..n ,e mciicated thus svc.ce is ntlre:tttvInmen`.4,a
Colorado Regulation 7,Section XV II
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,20147 hip: lSource is
I_v:.c vc..4 v.na,Section
Section 0011.0.2 F General Provisions far Air Pollution Control Equipment and Prevention of Emissions
Section XOII.G-Emissions Control
Altemative Emissions Control(Optional Section).
a. Is this p ator controlled by a back-up or alternatecombustion device(i.e.,not the primary control device)that is not enclosed? I. i The caner,
riot s.abica
Section XVII.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean AirAct,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,and the analysis it contains may not apply toe 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 slafute or regulation will control. The use of non-mandatory language such as iecommend,"'may,""should"add-can,"is
intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and'required"are intended to descdbe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Noble Energy,Inc -
County AIRS ID 123 History File Edit Date 3/11/2020
Plant AIRS ID 9CA1 Ozone Status Attainment
Facility Name Rohn State LD09 Econode T9N-R58WS15 L01
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT (PERMIT I Description PM10 PM2.5 H2S 502 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
Previous FACILITY TOTAL 2.0 1.5 0.0 0.0 246.0 371.1 1.2 253.7 30.8 2.0 1.5 0.0 0.0 28.3 85.4 1.2 77.5 7.1 Based on Aug 2019 tab for Points 001-003,006,008,013-
015
Previous Permitted Facility total 1.5 1.5 0.0 0.0 240.1 369.7 0.0 221.0 30:8 1.5 1.5 0.0 0.0 22.4 84.1 0.0 44.7 7.1
001 14WE0639 Thirty-six(36)Condensate Tanks with a total capacity 909.7 11.7 45.5 0.6 Based on 14 of 14WE0639
002 14WE0639 Twelve(12)500 bbl and Two(2)60 061 Produced 117.9 13.1 5.9 0.7
003 14WE0639 One(1)Truck Condensate Loadout operation 158.6 1.9 8.0 0.1
004I.11,141i1JF3`0&S9.,U"ttk t?n@(17,;N.attlYa,11 daOen#(ngat'i2gmscepa)'ator,,MVM. ., "r ,;:',.'4:':::, •xN't ',1"'<:‘.:0::!* ,$, ^r „Vi,:;',,?"' t ,,,, ,5_*,lu.nr d'anceueda, ,,,,,?,:.:.;;;MO, .l
005 '1 fi4NIL0809.CN= 'Fug1ttwe`admgdh4M Leaks` y 0 0' 0.0" Cancelled'
006 14WE0838 CN Caterpillar G35168 RICE,SN:JEF02162 0.0 0:0 Cancellation notice received 10/9/2019
007 14WE0639.CN': Caterpillar 03516B RICE,SN:JEF02207 0,0 I. - 00 r Cancelled 9/13/19,No Longer Exists
008 14WE0639 Caterpillar G3304NA RICE,SN:N4F03309 12.0 0.9 12.0 0.3 0.9 0.6 1.8 0.1
009 :14WE0639.CN. Cummins G8.3 C118 RICE,SN:46593798 0.0 ':00 Cancelled
010 14WE0639,CNr Doosan 0148L RICE,SN:EEZ0G400854., :. ,,, ,. , 0 0 ( , 0.0. Cancelled.
011 .z 14W010035 CNJ Cummtns 0010706 O1esebfired RICO 1,,,^„. .,0,0, 0.0; Cancelled
012C,,,,,,,,,,,,",,, .,e % r ,; tavr ,r ,,.0,0,, x# ,,, .. w 00'...„FerCOOtis;PmntweS,t05eaterbY,Mislake 1 ,
013 GP-06 58 HP Diesel 2.0 2.0 2.1 0.0 2.0 2.0 2.1 00
014 17WE0797.XP Kubota DG972-E2 23.6hp SN:4GA3460 0.0 0.0 0.4 0.7 24.3 0.0 0.0 0.0 0.4 0.7 24.3 0.0 Pilot XP Engine,Not Reviewed,Emissions from APEN
015 GP02 Waukesha L7044GSI S5 1900hp SN:5283705931 1.5 1.5 219.4 12.8 174.5 1.7 1.5 1.5 128 128 27.5 1.7
016 19WE1052 Venting from Vapor Recovery Tower(VRT) 0.4 234.1 1.7 10.9 0.4 11.7 1.7 0.5 New point
- .XA 5 MMBTU/hr Heater Treater 2.8 0.2 2.3 0.0 2.8 0.2 2.3 0.0
- .XA Sepatator Heaters(12) 0.1 1.3 0.1 1.1 0.0 0,1 1.3 0.1 1.1 0.0
- .XA VOC Burners(7) 0,4 0.8 0.3 4.4 0.0 0.4 0.8 0.3 4.4 0.0
- .XA Light Towers(2) 0.0 0.6 0.0 0.7 0.0 0.0 0.6 0.0 0.7 0.0
- .XA Fugitives 1.2 0.0 1.2 0.0
VOC:Syn Minor(PSD and OP)
NOx:Syn Minor(OP)
FACILITY TOTAL 2.0 1.5 0.0 0.0 239.7 1,437.4 1.2 223.0 39.4 2.0 1.5 0.0 0.0 22.0 87.9 1.2 65.9 3.7 CO: Syn Minor(OP)
HAPS:Syn Minor(n-Hexane and Total)
7777:Area
Permitted Facility Total 1.5 1.5 0.0 0.0 233.8 1,436.1 0.0 190.3 39.4 1.5 1,5 0.0 0.0 16.1 86.5 0.0 33.1 3.6 Excludes units exempt from permits/APENs
1 Permitted Emissions 0.0 0.0 0.0. 0.0 -6.3 2.4 0.0 -11.6 Public Comment is required for new syn minor limit
Total VOC Facility Emissions(point and fugitive) 89.1 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) 2.4 _ Project emissions less than 50 tpy
Note 1 operators form 102 shows below GP limits.
Page 1 of 3 Printed 3/17/21120
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 9CA1
Facility Name Rohn LD09 Econode
Emissions-uncontrolled(lbs per year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 14WE0639 Thirty-six(36)Condensate Tanks with a total capacity of 27,000 bbl --- --- 2738 1095 110 657 16863 --- 1862 11.7
002 14WE0639 Twelve(12)500 bbl and Two(2)60 bbl Produced Water Tanks --- --- 6300 --- 19800 --- 13.1
003 14WE0639 One(1)Truck Condensate Loadout operation --- 473 1&r --- 113 2941 1.9
004 14WE0639.CN One(1)Natural Gas Venting from Separator
005 14WE0639.CN Fugitive Component Leaks
006 14WE0639.CN Caterpillar G3516B RICE,SN:JEF02162 0.0
007 14WE0639.CN Caterpillar G3516B RICE,SN:JEF02207 0.0
008 14WE0639 Caterpillar G3304NA RICE,SN:N4F03309 494 20 18 0 11 --- --- 0.3
009 14WE0639.CN Cummins G8.3 C118 RICE,SN:46593798 --- 0.0
010 14WE0639.CN Doosan D146L RICE,SN:EEZOG400854 --- 0.0
011 14WE0639.CN Cummins QSB7G6 Diesel-fired RICE -- 0.0
012 0 0 0.0
013 GP-06 58 HP Diesel 0.0
014 17WE0797.XP Kubota DG972-E2 23.6hp SN:4GA3460 371 5 5 3 0.0
015 GP02 Waukesha L7044GSI S5 1900hp SN:5283705931 1835 418 394 237 458 1.7
016 19WE1052 Venting from Vapor Recovery Tower(VRT) 2345 2223 334 866 14356 1677 10.9
0 0 0
.XA 5 MMBTU/hr Heater Treater 0.0
.XA Sepatator Heaters(12) 0.0
.XA VOC Burners(7) 0.0
.XA Light Towers(2) 0.0
- .XA Fugitives 0.0
TOTAL(tpy) 1.2 0.2 0.2 6.1 1.8 0.2 0.8 27.0 0.2 1.8 0.0 0.0 39.4
Emissions with controls(lbs per year)
POINT'PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 14WE0639 Thirty-six(36)Condensate Tanks with a total capacity of 27,000 bbl --- --- --- 137 55 6 33 844 --- 94 0.6
002 14WE0639 Twelve(12)500 bbl and Two(2)60 bbl Produced Water Tanks --- --- --- 315 --- --- --- 990 --- --- 0.7
003 14WE0639 One(1)Truck Condensate Loadout operation --- --- --- 24 10 --- 0 148 --- --- 0.1
004 14WE0639.CN One(1)Natural Gas Venting from Separator
005 14WE0639.CN Fugitive Component Leaks
006 14WE0639.CN Caterpillar G3516B RICE,SN:JEF02162 0.0
007 14WE0639.CN Caterpillar 035168 RICE,SN:JEF02207 ,0.0
008 14WE0639 Caterpillar G3304NA RICE,SN:N4F03309 110 20 10 11 --- --- --- --- --- --- 0.1
009 14WE0639.CN Cummins G8;3 C11BRICE,SN 46593798 �' --- 0.0
010 14WE0639.CN Doosan D146L RICE,SN:EEZOG400854 --- 0.0
011 14WE0639.CN Cummins QSB7G6 Diesel-fired RICE --- 0.0
012 0.0
013 GP-06 58 HP Diesel I 0.0
2 1239CA1 3/17/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
014
17WE0797.XP
Kubota DG972-E2 23.6hp SN: 4GA3460
38
5
5
3
0.0
015
GP02
Waukesha L7044GSI S5 1900hp SN: 5283705931
1835
418
394
237
458
1.7
016
19WE1052
Venting from Vapor Recovery Tower (VRT)
117
111
17
43
719
84
0.5
-
.XA
5 MMBTU/hr Heater Treater
0.0
-
.XA
Sepatator Heaters (12)
0.0
-
.XA
VOC Burners (7)
0.0
.XA
Light Towers (2)
0.0
-
.XA
Fugitives
0.0
TOTAL (tpy)
1.0
0.2
0.2
0.4
0.1
0.0
0.0
1.4
0.2
0.1
0.0
0.0
3.7
Noble Energy, Inc
123
9CA1
Rohn LD09 Econode
3
1239CA I 3/17/2020
Gas Venting APEN - Form APCD-211
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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit 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-200) 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: 19WE 1052
AIRS ID Number: 123 / 9CA1 /016
[Leave blank antes APLhas ,_esdy assigned d 3 permit a and AIRS, ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: ROHN STATE LD09 ECONODE T9N-R58W-S15 L01
Site Location: E112 SEC9 T9N R58W
MailingCod
Address: 1625 Broadway, Zip Code) y+ Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
,lanessa Salgado
303-228-4196
janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
A.p, COLORADO
1 I kii* Hewnn6En.ro t
Permit Number: 1 9WE 1 052
AIRS ID Number: 123 / 9cam r 016
Section 2 - Requested Action
E NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment O Change company name3 O Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' O Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
1:1 Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et 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
General description of equipment and purpose: VRT Gas Stream
Company equipment Identification No. (optional):
For existing sources, operation began on:
04/21/2014
For new, modified, or reconstructed sources, the projected start-up date is:
❑✓ 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
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
O Yes
O Yes
0 Yes
❑Q No
No
❑ No
COLORADO
Permit Number: 19 W E 1052
AIRS ID Number: 123 / 9cA1 / 016
Section 4 - Process Equipment Information
Gas/Liquid Separator
❑ Well Head Casing
O Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
Heating Value:
3054
BTU/SCF
Requested:
3.4.7
MMSCF/year
Actual:
N/A
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
54.58
VOC (Weight %)
93.3237%
Benzene (Weight %)
0.4692%
Toluene (Weight %)
0.4448%
Ethylbenzene (Weight %)
0.0669%
Xytene (Weight %)
0.1733%
n -Hexane (Weight %)
2.8723%
2,2,4-Trimethylpentane (Weight %)
0.3356%
Additional Required Documentation:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX ix n -Hexane, temperature, and
pressure)
s 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.
Lin 12.
3 1
COLORADO
Noa.mmm a Poem
xnm e;n.mwnmem
Permit Number: 19WE 1052
AIRS ID Number: 123 / 9CA1 /016
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.7773, -103.8613
❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator
p
Stack ID No,
Discharge Height
Above Ground Level
(Feet)
Temp.
(,F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Condensate Knockout
25.25
Variable
Variable
Variable
Indicate the direction of the stack outlet: (check one)
❑✓ Upward O Downward
O Horizontal O Other (describe):
O Upward with obstructing raincap
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches): 48
O Square/rectangle interior stack width (inches): Interior stack depth (inches):
O Other (describe):
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section,
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
f0
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
MMBtu/hr
hr
Type: Enclosed Combustor(s) Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content:
3054
Btu/scf
Constant Pilot Light: l] Yes ❑ No Pilot burner Rating: MMBtu/hr
O
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
COLORADO
Permit Number: 19WE 1052
AIRS ID Number: 123 / 9CA1 / 01 6
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 No
If yes, describe the control equipment AND state the collection and control efficiencies. (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
PM
SOX
NOX
CO
VOC
Enclosed Combusmr(s)
100%
95%
HAPs
Enclosed Combustor(s)
100%
95%
Other:
From what year Is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
� etc.)
Mfg.,
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
1.5672
lb/MMscf
AP -42
0.00
0.00
0.00
SOx
0.1237
lb/MMscf
AP -42
0.00
0.00
0.00
NOX
228.2761
Ib/MMsct
AP -42
0.40
0.40
0.40
CO
963.9845
Ib/MMscf
AP -42
167
1.67
1.67
VOC
134,878.1758
lb/MMscf
HYSYS/AP-42
11.66
234.06
11.66
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees wilt be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
El Yes ❑No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
Ohs/year)
Controlled
Emissions°
Ohs/year)
Benzene
71432
675.7219
lb/MMscf
HYSYS/AP-42
2,345
117
Toluene
108883
640.5062
lb/MMscf
HYSYS/AP-42
2,223
111
Ethylbenzene
100414
96.3447
IbIMMscr
HYSYS/AP-42
334
17
Xylene
1330207
249.6041
Ib/MMscf
HYSYS/AP-42
866
43
n -Hexane
110543
4,136.4130
lb/MMscf
HYSYS/AP-42
14,356
719
2,2,4-Trimethylpentane
540841
483.3046
Ib/MMscf
HYSYS/AP-42
1,677
84
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
is COLORADO
5 I �sw�� m,�'ea
aM:nb ¢n+irmmrn�
Permit Number: 19WE 1052
AIRS ID Number: 123 19CA1 / 016
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
vI
Signbture of Legally Authorized Person (not a vendor or consultant) Date
Janessa Salgado
03/12/2020
Environmental Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692.3175
OR
(303) 692-3148
APCD Main Phone Number
Make check payable to: (303) 692-3150
Colorado Department of Public Health and Environment
COLORADO
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