HomeMy WebLinkAbout20202322.tiff •,.- COLORADO
ta. NV- Department of Public
Health&Environment
RECEIVED
JUN 3 0 2020
Weld County - Clerk to the Board
1150 0 St WELD COUNTY
PO Box 758 COMMISSIONERS
Greeley, CO 80632
June 24, 2020
Dear Sir or Madam:
On June 25, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble
Energy Inc. - DP132 A19-11-A ECO. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
of eek
ii,4300 Cherry Creek Drive S., Demmer,Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I ,� r rs',
0
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director �.)
Pc4,I; G ReV;GLJ CC:PLtrr))H L(Ds), Pw(an/ER/cH/eb() 2020-2322
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M�M�M Air Pollution Control Division
CM
CDPHE Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy Inc. - DP132 A19-11-A ECO - Weld County
Notice Period Begins: June 25, 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: DP132 A19-11-A ECO
E&P Well Pad
NESW SEC19 T6N R64W
Weld County
The proposed project or activity is as follows: Applicant is proposing the construction of a new econode
facility. Permitted equipment will include fugitive emissions, and a point which covers gas venting for
several process units (condensate knockout tanks, scrubbers, and other miscellaneous equipment).
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 20WE0219 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.Rov/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:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
1 I OW _DPNf Health&Environment
, �. COLORADO
ip Air Pollution Control Division
Department cf Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0219 Issuance: 1
Date issued:
Issued to: Noble Energy, Inc.
Facility Name: DP132 A19-11-A ECO
Plant AIRS ID: 123/AOCE
Physical Location: NESW Section 19 T6N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
Condensate Venting of flash gas from knockout tanks, Enclosed Combustion
Knockout 001 scrubbers, and other miscellaneous Device
Burner equipment on site.
Fugitives 002 Fugitive emissions None
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
Page 1 of 12
a�.'f COLORADO
- Air Pollution Control Division
-- Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
4. Point 001: Upon commencement of operation, the operator must install a flow meter to
monitor and record the combined volumetric flow rate of natural gas vented from each
separator and piece of equipment covered by this permit. The flow meter must be installed
at a location where it can monitor and record the total volumetric flow rate of natural gas
routed to the combustion device covered by this permit.
5. 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.)
6. 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
7. 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 NOX VOC CO • Type
Condensate
Knockout 001 --- --- 5.6 --- Point
Burner
Fugitives 002 --- --- 1.7 --- Fugitive
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits must be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimus reporting level) from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total must be calculated based on the previous twelve months' data. The
permit holder must calculate emissions each month and keep a compliance record on site or
Page 2 of 12
C ,r„-_.-. COLORADO
Air Pollution Control Division
c Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
at a local field office with site responsibility, for Division review. This rolling twelve-month
total must apply to all permitted emission units, requiring an APEN, at this facility.
8. 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.
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
1D Point Controlled
Condensate Emissions from the condensate knockout
tanks, gas scrubbers, and other
Knockout 001VOC and HAP
Burner ', miscellaneous equipment are routed to an
Enclosed Combustion Device
10. Point 002: The operator shall calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent gas analysis, as required
in the Compliance Testing and Sampling section of this permit. The operator shall maintain
records of the results of component counts and sampling events used to calculate actual
emissions and the dates that these counts and events were completed. These records shall be
provided to the Division upon request.
PROCESS LIMITATIONS AND RECORDS
11. 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
Condensate
Knockout 001 Natural Gas Venting 2.5 MMSCF
Burner
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
Page 3 of 12
CCOLORADO
qp litre- Air Pollution Control Division
Department of Public F{eatth&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
12. Point 001: Upon installation of the flow meter, the owner or operator must continuously
monitor and record the volumetric flow rate of natural gas vented from the equipment
covered by this permit by using a flow meter located at the inlet to the enclosed combustor
covered by this permit. 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
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. Visible emissions must not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions must not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVII.B.2.b must have no visible emissions. (Regulation No. 1, Section II.A.1. It 4.)
15. This source is subject to Regulation No. 7, Part D, Section I.C General Provisions (State only
enforceable). All condensate collection, storage, processing and handling operations,
regardless of size, must be designed, operated and maintained so as to minimize leakage of
volatile organic compounds to the atmosphere to the maximum extent practicable. The
operator must comply with all applicable requirements of Section XII.
16. Point 001: 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)
17. Point 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
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.
18. Point 001: The separator(s) 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.
Page 4 of 12
C
� COLORADO
NylPie Air Pollution Control Division
Department of Pubt,c}leans&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
19. Point 002: Minor sources in designated nonattainment or attainment/maintenance areas that
are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, must apply
Reasonably Available Control Technology for the pollutants for which the area is
nonattainment or attainment/maintenance (Regulation No. 3, Part B, III.D.2.a). Leak
Detection and Repair (LDAR), as required by Condition No. 20, shall satisfy the requirement to
apply Reasonably Available Control Technology (RACT).
20. Point 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 must comply with the General Provisions contained in
Regulation 7, Part D, Section II.B.1.
B.1.
21. 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
22. Point 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 order to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to the O&M plan are subject to Division approval prior to implementation.
(Regulation Number 3, Part B, Section III.G.7.)
23. Point 002: This source is not required to follow a Division-approved operating and
maintenance plan.
COMPLIANCE TESTING AND SAMPLING .
Initial Testing Requirements
24. Point 001: The owner/operator must complete an initial site specific gas analysis ("Analysis")
within one hundred and eighty days (180) after commencement of operation or issuance of
this permit, whichever comes later, of the commingled natural gas stream collected at the
inlet of the combustion device covered by this permit, in order to verify the VOC 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
Page 5 of 12
C. :rv.....v.f. ' 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
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.
25. Point 001: The owner or operator must demonstrate compliance with opacity standards,
using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any period
or periods of duration greater than or equal to one minute in any fifteen minute period during
normal operation. (Regulation Number 7, Part D, Sections II.B.2. and II.A.23)
26. Point 002: Within one hundred and eighty days (180) of the latter of commencement of
operation or issuance of this permit, the owner or operator must complete the initial gas
analysis of gas samples and that are representative of volatile organic compound (VOC) that
may be released as fugitive emissions. This gas analysis must be used in the compliance
demonstration as required in the Emission Limits and Records section of this permit. The
operator must 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.
27. Point 002: Within one hundred and eighty days (180) of the latter of commencement of
operation or issuance of this permit, the operator must complete a hard count of components
at the source and establish the number of components that are operated in "heavy liquid
service", "light liquid service", "water/oil service" and "gas service". The operator must
submit the results to the Division as part of the self-certification process to ensure
compliance with emissions limits.
Periodic Testing Requirements
28. This source is not required to conduct periodic testing,unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
29. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 6 of 12
,titii COLORADO
j Air Pollution Control Division
`�� Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
30. 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
31. 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.
32. 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 7 of 12
-r:•z. COLORADO
40 wolf Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
33. 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.
34. 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.
f 4.
35. Each and every dondition 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.
36. 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.
37. 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: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance Date Description
Issued to Noble Energy Inc.
Issuance 1 This Issuance New facility wide permit for Gas Venting and
fugitive emissions points at a synthetic minor
facility.
Page 8 of 12
C _ ,,, .....;z COLORADO
Air Pollution Control Division
CDPftf
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-reps
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) (lb/yr)
Benzene 71432 1,412 71
Toluene 108883 1,151 58
Condensate Ethylbenzene 100414 826 41
Knockout
Burner 001 Xylenes 1330207 522 26
n-Hexane 110543 7,538 377
2,2,4-
540841 804 40
Trimethylpentane
Benzene 71432 8 8
Toluene 108883 4 4
Ethylbenzene 100414 4 4
Fugitives 002 Xylenes 1330207 4 4
n-Hexane 110543 41 41
2'2,4 540841 4 4
Trimethylpentane
Page 9 of 12
: COLORADO
410 ilitt,'" ,-ilir Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMscf) , (lb/MMscf)
NOx 181.6908 181.6908 AP 42
CO 775.0661 775.0661
VOC 90,207.1456 4,510.3573
71432 Benzene 564.9316 28.2466
108883 Toluene 460.2589 23.0129
100414 Ethylbenzene 330.4601 16.5230 HYSYS
1330207 Xylene 208.6507 10.4325
110543 n-Hexane 3,015.2455 150.7623
540841 2,2,4- 321.6601 16.0830
Trimethylpentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The emission factors listed above are based on a HYSYS process simulation in which a pressurized liquid sample
(Pressurized sample notes) was modeled through a two-phase separator at a temperature of 120 °F and
separator pressure of 4 psig as a conservative estimate for the "worst-case" gas composition sent to the control
device.
Point 002:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 5,586 588 1,818 1,066
Flanges 722 0 330 26
Open-ended Lines 6 0 0 0
Pump Seals 0 0 4 0
Valves 2,322 196 1,700 364
Other 632 0 116 130
VOC Content (wt. fraction) 0.4 1.0 1.0 1.0
Benzene Content (wt. fraction) 0.001 0.0025 0.0025 0.0025
Toluene Content (wt. fraction) 0.0005 0.0013 0.0013 0.0013
Page 10 of 12
C . r. COLORADO
Air Pollution Control Division
"illi-- Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Ethylbenzene (wt. fraction) 0.0005 0.0013 0.0013 0.0013
Xylenes Content (wt. fraction) 0.0005 0.0013 0.0013 0.0013
n-Hexane Content (wt. fraction) 0.005 0.0125 0.0125 0.0125
2,2,4-Trimethylpentane 0.0005 0.0013 0.0013 0.0013
Content (wt. fraction)
Note: "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 Seats 3.5E-04 NA 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
Note: 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 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) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD True Minor Source
NANSR Synthetic Minor Source of: VOC
Page 11 of 12
C •r.*:•z• COLORADO
Air Pollution Control Division
Department of Pubbc F{eatth&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
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 12 of 12
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer:
Package#:
Received Date:
Review Start Date:
Section 01-Facility Information
Company Name: t Quadrant' Section Township Range
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location: ,n==
County: Weld County
Type of Facility: ie.t teciiktion'Net etc
What industry segment?.. ._., ter t e,_ss.•.g
Is this facility located in a NAAQS non-attainment area?
If yes,for what pollutant?
Section 02-Emissions Units In Permit Application - -• •-
Leave Blank-For Division Use Only
Permit#
AIRS Paint# 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)
gig Segargeke geregg Co^ue,._at_'Knockout Burnet s gine jiggle iskeence
Penn,:eget
issuitive
Section 03-Description of Project
Sections 04,05&1,6-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required?
If yes,why? fie s,_s.:ig Supthet,�tnhstsKP rrsr ,.,.
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? 1140x:'4` ys -"-
If yes,for what pollutants?
�. �.v-.
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 05-Facility-Wide Stationary Source Classification
Is this stationary source atrue minor?
Is this stationary source a synthetic minor?
If yes,indicate programs and which pollutants: 502 NI0--x[ CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ o ❑ ❑ Q, ❑ ❑
Title V Operating.Permits(OP) ❑ C L-.]❑ ❑
Non-Attainment New Source Review(NANSR) C
Is this stationary source a major source? �a
If yes,indicate programs and which pollutants: 502 N0x CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(P5D) ❑ 0 O n ❑ ❑
Title V Operating Permits[OP) ❑ O B ❑ ❑ ❑ ❑
Non-Attainment New Source Review(NANSR)
Section 01-Administrative Information
Facility AIRS ID: AX.3 - 002
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Description: Gas venting for flesh gas from knockout tanks,scrubbers,and other toisceilaneoea.5 uipavtentrmsite. include emissions generated by sales gas separators and
scrubber bottles,a condensate header and fuel gas
Emission Control Device Description: ECD scrubber,all feeding into the condensate knockout vessel,
Requested Overall VOC&HAP Control Efficiency%: 95 which vents emissions to the enclosed combustor.
Limited Process Parameter
Gas meter - Per operator,facility has not yet been constructed and given current O&G prices,will likely not commence
operation until around April 2022.Therefore,will modify gas flow meter requirement condition to allow
Section 03-Processing Rate Information for Emissions Estimates 180 days after latter of commencement of operation or permit issuance-
Primary Emissions-Separator
Actual Throughput= MMscf per year
Requested Permit Limit Throughput= 2,R MMscf per year Requested Monthly Throughput= _ MMscf per month
Potential to Emit(PTE)Throughput= •: MMscf per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 246$.;4 Btu/scf
Volume of waste gas emitted per BBL of •
liquids throughput: scf/bbl
Control Device
Pilot Fuel Use Rate: 41,666%661 scfh - MMscf/yr
Pilot Fuel Gas Heating Value: 1000 Btu/sct MMBtu/yr
Section 04-Emissions Factors&Methodologies
Description
Facility has out yet been constructed,$o these site-specific emfssiott factors were bated on a HMS model which itself wast'rased on a reparaseettative laressttriaed Nola movie from a thither facility.Wifl therefore eeagutee
iaitlai sampling for this paint to verify argit'ssiost factors. •
...
MW I -43.9 lb/Ib-mol Displacement Equation
Ex=QeMW'Xx/C •
Weight%
Helium
CO2
N2 v,ill
methane 7.4',
ethane 23,3
propane
isobutane
n-butane 14.4
isopentane
n-pentane 7,7
cyclopentane
n-Hexane 2,4
cyclohexane
Other hexanes 3,3
heptanes 3.4
methylcyclohexane
224-TMP 5 3
Benzene
Toluene 3,4
Ethylbenzene -
Xylenes
CB+Heavies
Total
VOCWt%
2 of 12 K:\PA\2020\20WE0219,CP1
1=083Separator Venting C ser Y7= a'ta
Uncontrolled Controlled
Emission Factor Source
Pollutant (Ib/MMscf) (Ib/MMscf)
APEN APEN
90207.296 4510.3648
564.982 28.2491
460.2485 23.012425
330.503 16.52515
208.6947 10.434735
3015.2773 150.763865
321.6711 16.083555
Primary Control Device
•
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat c
Combusted) (Pilot Gas Throughput)
Eill "1"
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 0.3 0.0 0.3 1133 3
PM2.5 3.et 0.0 _.7 G.7 3 •'
SOx 3,0 0 0 C „,0 0
NOx _ 0.3 1.0 u.2 0.c 08
VOC ___._ v_0 0.5 112.8 5.5 553 •
CO .... .-.1 r:.: 1.0 3..G 172
•
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene _.._.. 3 0 14-_2 71
Toluene __5_ 0 ., .x313 58
Ethylbenzene _..1 0 52e 41
Xylene _= 0 0 827 25
n-Hexane - _ 0 75333
224TMP _.,ti 0 0 X0.1 -«s.
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B So11r.0,-050" a„3-'r;1..
•
Regulation 7,Part D,Section II.B,F 5003 3213 ;blest ZO 0373123 yr °,,El'.`=.>_.
Regulation 7,Part D,Section 11.B.2.e .-.,. .i e de>+.. € ... c = r,i.r,. .:`.R.2-e ,
(See regulatory applicability worksheet for detailed analysis)
•
3 of 12 K:\PA\2020\20WE0219.CP1
Section 07-Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to MonitorComplianceO888,,,48
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 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? Fie
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? , r
If yes,the permit will contain initial and periodic compliance testing in accordance with PS.Memo 20-02 - .. ..
Qa�Q74 Vaa'Ynry f°w,aye 'fig obi
.. ra„sof A ii
�;41O POgttx,fftatagniCKA'.(i6(*le ;
'citiefflgaliMal6WIF,54101N6a15AbatqtaraggIliia4134.,41)4,440,2;400A40;,000gatAKawbote.,,a;0420
48334.9g3;,43,18.44!,/,,8st° ,arz,1 ss ,d,✓ L:,=aas s.,,,, i �34'fey ,. HProI;v uva�
Section 08-Technical Analysis Notes
HYSYS model was based on a pressurized liquid sample which was collected from a HP separator at the WR State WROSEconode on 6/7/2018,and analyzed on 6/8/2018 Sample was collected at a pressure of 320 psig and 140F.HYSYS model
drops this sample down to VRT pressure(4 psig)in two stages,though no flash emissions occur from first separator in model,with all emissions occurring from the hypothetical VRT emission stream on which these emission factors are based,
a
i ,. erg. ke.0 't'3' _,,...t.. t'. s-
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only),
AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
001 01 ,_ ,a.AS PM10 _.1 0 'F 3 45CF
PM2.5 ,,.' 0 (3/P,tm'uCy
5Ox 0.0 0
NOx 1773 C lb/t 8S,5
VOC 9.0207.3 95 ,8,155;33,03
CO x08.3 u c,/M;85585
Benzene 561.9 45 '5u;fi'hR5C3
Toluene 450.3 „_ }b/%11Y sT
Ethylbenzene 330,5 08 Ibffv1 z 5T
Xylene 206.7 95 I,,,o. sca
n-Hexane 3015.2 ^s5 i7/Ct,atsT
224 TMP 3,31,7 35 15/5,515'S
4 of 12 K:\PA\2020\20WE0219.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re ulation 3 Parts A and B.APEN and Permit Reouirements
c=one is in 11,5 flair-Attei rnnn'_=�
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)? qy�
2. Are total facility uncontrolled VOC emissions greater than 5 TPY,Nox greater than 10 TPY or CO)emisslons greater than 10 TPY(Regulation 3,Part B,Section Il.D-3)? ,va
IYsu ba;e indicated that source=s:P.trio._..attainment Area
NON-ATTAINMENt
'1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than tTPY(Regulation 3,Part A,Section 11.O.1.a/? _ (Source Re
2. Are total facility uncontrolled VOC emissions from the greater than 2TPY.NOx greater than 5 TN or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D2)? .no J Source Re
IS.'ce
Colorado Regulation 7.Part I,section II
1. Was the well newly constructed,hydraulically fractured,or recompleted an or after August 1,2014? .(Source is
I= v T. Section
Section 11.B.2-General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F-Control of emissions from well production facilities
Alternative Emissions Control(Optional Section(
a. Is this separator controlled bye back-up or alternate combustion device(i.e.,notthetirimery control device)that is not enclosed? a i i The contrt
ix not subject 7,Pan 5.,clion
section II.B.2.e-Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean AIrAct,its implementing regullfinns,and AirQuality Control Commis'§ion 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 net 3bange 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 fire statute or regulation will control.The use of non-mandatory language such as"recommend,""may,"°should,"and'can,"is
intended to describe APCD 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 Quality Control Commission regulations,but this document does cmf establish legally binding requirements in and of itself
Colorado Department of Public Health Environment
Air Pollution Control Division
Operation(hrs/yr) 8760 I The default list of TOC emissions factors are based on Table 2-4"Average Emissions Factors"of the EPA Protocal for Fugitive
IEquipment Leaks.If the company qualifies to use Table 2-8"Less than 10,000 ppmv"emissions factors based on provisions of
SCC Code:31000220:All Equip.Leak Fugitives(Valves,flanges,.Connections,seals,drains) I Regulation 7,Section XVII.F,you must update and manually enter the Table 2-8 emissions factors into column"E"below.
Fugitive Component Counts&Emissions _ — ..._—._..__.__ ._-..__....,....
VOC Benzene Toluene Ethylbenzene Xylene n-Hexane
TOC EF
Component Iblhr- TOC EF Control Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled
Service Type Count source kglhr-source (%) (tpy) (tpy) (lb/yr) (lb/yr) (Ib/yr) (lb/yr) (Ib/yr) (lb/yr) (lb/yr) (lb/yr) (Ib/yr) (lb/yr)
Valves 2322 5.51E-05 2.50E-05 0.0% 0.22 _ 0.2 1.1 1.1 0.6 0.6 0.6 0.6 0.6 0.6 • 5.6 5.6
Pump Seals 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Gas Others 632 2.65E-04 1.20E-04 0.0°6 0.29 0.3 1.5 1.5 0.7 0.7 0.7 0.7 0.7 0.7 7.3 7.3
Connectors 5586 2.20E-05 1.00E-05 0.0% 0,22 0.2 1.1 1.1 0,5 0.5 0.5 0.5 0.5 0,5 5.4 5.4
Flanges 722— 1.26E-05 5.70E-06 0.0% 0,02 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0,0 0.4 0.4
Open-ended lines 6 3.31E-05 1.50E-OS 0.0% 0.00 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Valves 1700 4.19E-05 1.90E-05 0.0% 0.31 0.3 1.6 1.6 0.8 0.8 0.8 0.8 0.8 0.8 - . 7.8 7.8
Pump Seals 4 1.12E-03 5.10E-04 0.0% 0.02 0.0 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 _ 0.5 0.5
Light Oil Others 116 2.43E-04 1.10E-04 0.0% 0.12 0.1 0.6 0.6 0.3 0.3 0.3 0.3 0.3 0.3 3.1 3.1
Connectors 1818 2.14E-05 9.70E-06 0.0% 0.17 0.2 0.9 0.9 0.4 0.4 0.4 0.4 0.4 0.4 . 4.3 4.3
Flanges 330 5.29E-06 2.40E-06 0.0% 0.01 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 t).0.. , 0.2 0.2
Open-ended lines 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 'P, 0.0 0.0
Valves 196 1.85E-05 8.40E-06 0.0% 0.02 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.4 0.4
Pump Seals
Heavy Oil Others 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Connectors 588 1.65E-05 7,50E-06 0.0% 0.04 0.0 0.2 0.2 0.1 0.1 - 0.1 0.1 0.1 0.1 1.1 1.1
Flanges 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Open-ended lines ! 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 - ' 0.0 0.0
Valves 364 2.14E-05 9.70E-06 0.0% 0.03 0.0 0.2 0.2 0.1 0.1 0.1 0.1 0.1 0.1"" 0.9 0.9 •
Pump Seals 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Water/Oil Others 130 1.30E-04 5.90E-05 0.0% 0.07 0.1 0.4 0.4 0.2 0.2 0.2 0.2 0.2 0.2 1.9 1.9
Connectors 1066 2.20E-05 1.00E-05 0.0% 0.10 0.1 0.5 0.5 0.3 0,3 0.3 0.3 0.3 0.3 2.6 2,6
Flanges 26 6.39E-06 2.90E-06 0.0% 0.00 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Open-ended lines 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
TOTALS(Spy) 1.5 1.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 F 0.02 0.02
TOTALS lb/r 4 4 4 4 4 41 1
With safety factor: i
TOTALS(Spy) 1.5 1.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 ' 0.02 0.02
TOTALS Ihi r
Emission Factor Source: EPA-4531R-95-017 Table 2-8<10,000 ppmv _
Fugitive emission factors based on a multiple representative gas samples from Y; ,
Stream VOC Fraction(wt) Stream HAP Components(wt fraction) similar facilities,as this facility is not yet constructed.Will therefore require ,,
Gas 040D0 HAP Gas Light Oil Heavy Oil Water/Oil initial sampling for this point toyerify emission factors.
Light Oil 1.0000 Benzene 0.001 0.003 0.00 0.00 - •
Heavy Oil 1.0000 Toluene 0.0005 0.001 0.00 0.00
Water/Oil '1.0000 Ethylbenzene 0.0005 0.001 0.00 0.00 . '
Xylene 0.0005 0.001 0.00 0.00
n-Hexane 0.005 0.013 0.01 0.01
224 0.0005 0.001 0.00 0.00
Regulatory Considerations
Is this source located in an ozone non-attainment area or attainment maintenance area? Yes -
Reg.3 If yes,is this source subject to leak detection and repair(WAR)requirements per Regulation 7,Section XVII.F or XII.G or 40 CFR,Part 60,Subparts KKK or OOOO? Yes
If you repond"yes"to the first question and"no"to the second,this source is subject to Regulation 3,Part B,Section 111.O.2,Reasonably Available Control Technology(RACT)requirements and must implement a
leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7,Section XVII.F.
Is this source at an onshore"natural gas processing plant"as defined in 40 CFR,Part 60.631? N/A
Did this source commences construction,reconstruction,or modification after January 20,1984,and on or before August 23,2011? No
If you answer'yes"to both questions above,this source is subject to the provisions of 40 CFR,Part 60,Subpart KKK"Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing
Plants"contained in Regulation 6,Part A. -
Reg.6 Did this source commences construction,reconstruction,or modification after August 23,2011? Yes
If you answer"yes"to question#1 and#3 this source is subject to the provisions of 40 CFR,Part 60,Subpart OOOO"Standards of Performance for Crude Oil and Natural Gas Production,Transmission and
Distribution". Specifically,review subpart 60.5400 for fugitive component leaks and 60.5380 and 60,5385 if the operator reports compressors.
ft is possible for an onshore natural gas processing plant to have portions of the facility subject to NSPS'IKKK and portions subject to NSPS OOOO based on the specific dates of construction of t11oSe
portions of the facility. If this is the case.the operator will need to report each of those respective fugitive component emissions on separate APENs sod obtain unique emissions points from the Division.
Is this source located in an ozone non-attainment area or attainment maintenance area? Yes
Reg.7 Is this source at an onshore"natural gas processing plant"as defined In 40 CFR,Part 60.631? Yes/No?.
If you answer"yes"to both questions above,this source is subject to the provisions of Regulation 7,Section XI I.G regardless of the date of construction
Is this source at a"natural gas processing plant"as defined in 40-GFR,Part,63:761?,:.., YestNo„
Reg.8 Is this facility considered a"major source"of HAP as specifically defined in 40 CFR,Part 63.761 for sites that are not prodcution field facilities? No
If you repond"yes"to both questions above,further review if the provisions of 40 CFR,Part 63.769"Equipment Leak Standards"apply? N/A
Printed 6/18/2020 Page 6 of 12
Colorado Department of Public Health Environment
Air Pollution Control Division
Summary of Preliminary Analysis - Fugitive Components Source
Company Name Acme Oil&Gas
Facility Name Roadrunner Gulch Compressor Station
Permit No 00AD555
AIRS 001/0000/000
Permit Engineer Jay Peterman
Application Date 1/1/1900
Review Date 1/1/1900
Summary of Emissions
VOC Benzepe Toluene Ethylbenzne Xylenes n-Hexane
(tpy) (Ib/yr) (lb/yr) (Ib/yr) (Ib/yr) (Ib/yr)
Uncontrolled Requested Emissions 1.7 8 4 4 4 41
Controlled Requested Emissions 1.7 8 4 4 4 41
Reportable? I I No No No No No
Total HAP,Uncontrolled(tpy) 0.0
Total HAP,Controlled(tpy) 0.0
Highest HAP,Uncontrolled(tpy) 0.0 n-Hexane
Emission Factors
Emission Factor Source: EPA-453/R-95-017,Table 2-8<10,000 ppmv
Controls Control Efficiencies from Table 5-3, quarterly monitoring (EPA-453/R-95-017)
Stream VOC Fraction: Stream HAP Components(wt frac)
Gas 0.4000 HAP Gas Light Oil Heavy Oil Water/Oil
Light Oil 1.0000 Benzene 0.0010 0.0025 0.0025 0.0025
Heavy Oil 1.0000 Toluene 0.0005 0.0013 0.0013 0.0013
Water/Oil 1.0000 Ethylbenze 0.0005 0.0013 0.0013 0.0013
Xylene 0.0005 0.0013 0.0013 0.0013
n-Hexane 0.0050 0.0125 0.0125 0.0125
Comments/Notes:
Please enter description of the project and any technical notes about corrections made to the application.
Printed 6/18/2020 Page 7 or 12
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 5/21/2020
Plant AIRS ID AOCE - Ozone Status Non-Attainment
Facility Name DP132 A19-11-A ECO
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total REMARKS
AIRS ID HAPs 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 Ncw 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 20WE0219 Condensate Knockout 0.2 112.6 1.0 6.1 0.2 5.6 1.0, 0.3
002 20WE0219 Fugitives 1.7 0.0 1.7 0.0
0.0 0.0
a.0 0.0
o.o o.o
0.0 0.0
0.0 0.0
a.0 0.0
o.o o.o
o.o
0.o o.o
o.o 0.0
FACILITY TOTAL 0.0 0.0 0.0 0.0 0.2 112.6 1.7 1.0 6.2 0.0 0.0 0.0 0.0 0.2 5.6 1.7 1.0 0.3 VOC:Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
• CO:True Minor(PSD and OP)
HAPS:True Minor B,T,X,HCHO&Total
Permitted Facility Total 0.0_ 0.0 0.0 0.0 0.2 112.6 1.7 1.0 6.2 0.01 0.0 0.0 0.0 0.2 5.6 1.7 1.01 0.3 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.2 5.6 1.7 1.0 Pubcom 8 modeling(not)required based on (A change
in emissions)
Total VOC Facility Emissions(point and fugitive) 7.3 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) 7.3 Project emissions less than 25/50 bay
Note 1
Note 2
•
Page 11 of 12 Printed 6/18/2020
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 AOCE
Facility Name DP132 A19-11-A ECO
Emissions-uncontrolled(lbs per year)
POINT IPERMIT 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 20WE0219 Condensate Knockout 1411 1149 825 521 7528 803 6.1
002 20WE0219 Fugitives 8 4 4 4 41 4 0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 0.7 0.6 0.4 0.3 3.8 0.0 0.4 0.0 0.0 6.2
•
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions;de minimus
Emissions with controls(lbs per year)
POINT (PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
(Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 20WE0219 Condensate Knockout 71 57 41 26 377 40 0.3
002 20WE0219 Fugitives 8 4 4 4 -41 T 4 0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL(tpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.3
12 20WE0219.CP1 6/18/2020
9*
��, 1:.. /84,
,7
M�M,N_ Gas Venting APEN - Form APCD-211
‘, ,
Air Pollutant Emission Notice (APEN)and
a
CDPHE 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: z'KrE0241 AIRS ID Number: 103 /AKE/ixI
[Leave:,ank ;mr..,s APCD has a'ready assigned a permit g and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: DP132 A19-11-A ECO
Site Location: NESW SEC19 T6N R64W Site Location Weld
County:
NAICS or SIC Code: 1311
Mailing Address: 1625 Broadwa Suite 2200
(Include Zip Code) y+
Denver, CO 80202 Contact Person: Janessa Salgado
' Phone Number: 303-228-4196
E-Mail Address2: lanessa.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.
424391
COLOCADO
Form APCD-2 I I Ga, Venung AYGJ - r<:."!iron IL 0:9 1 I ®':.°:"=
Permit Number: AIRS ID Number:
Rene''lack.unless APCD has already assigned a permit and Ar..S ID]
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 0 Other(describe below)
-OR
▪ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
13 Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info a 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: Gas venting for flash gas from
knockout tanks, scrubbers and other miscellaneous equipment onsite
Company equipment Identification No. (optional): Condensate Knockout Burners
For existing sources, operation began on: N/A
For new, modified, or reconstructed sources, the projected start-up date is: 03/31/2021 03/31/2022 -BF
06/08/2020
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Per attached
email
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS
nonattainment area? (] Yes ❑ NO
Is this equipment located at a stationary source that is 0 Yes 0 No
considered a Major Source of(HAP)Emissions?
Is this equipment subject to Colorado Regulation No. 7, / Yes ❑ No
Section XVII.G?
as!COLOADOR
Form APCD-'1 i 035 be i'j- Gi+ - Rea's:on 12%2014 2 I ,r
Permit Number: AIRS ID Number:
blank unless A?CD has alread,assigned a permit=and AIRS IDi
Section 4- Process Equipment Information
Q Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
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 1O0 tpy? 0 Yes 0 No
Vent 2461 BTU/SCF
Gas Venting Heating Value:
Process Parameters5: •
Requested: 2.5 MMSCF/year Actual: N/A MMSCF/year
-OR-
Liquid Throughput
Requested: bbl/year Actual: bbl/year
Process Parameters5:
Molecular Weight: 43.88
VOC(Weight%) 77.6292%
Benzene(Weight%) 0.4879%
Vented Gas Toluene(Weight%) 0.3975%
Properties: Ethylbenzene(Weight%) 0.2854%
Xylene(Weight%) 0.1802%
n-Hexane(Weight%) 2.6041%
2,2,4-Trimethylpentane(Weight%) 0.2778%
Additional Required Documentation:
O Attach a representative gas analysis(including BTEX&n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX a 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.
COLORADO
L'-L1 61.; '+-Z,it;:'3.APEN.APEN - Rev skin 1!'2u1% 3 ®�w r
Permit Number: AIRS ID Number: 1 /
(Leave blank unless APCD has al •a.sig.'aii a perm'* and AIRS IDI
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.467860,-104.594140
O 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.
•..r x. 5M• ...i 1•• .«,ti Tr9f.Ff9�.pvt"' A rJ't}M1 r cur• .rv� r "E'; ,;,.;,
e ,yam.• t'• ;t, .+9.
+t..ri. .,.Lastt•'..xt. ,,...t '3,., Ir r+1t •`"�, .+
Condensate Knockout 25.25 Variable Variable Variable
Indicate the direction of the stack outlet: (check one)
❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap
o Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches): 48
❑Square/rectangle Interior stack width (inches): Interior stack depth(inches):
❑Other(describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
Pollutants Controlled; •VOC, HAPs
Rating: 3.88 MMBtu/hr
Type: Enclosed Combustor(s) Make/Model: LEED EC48
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A Waste Gas Heat Content: 2461 Btu/scf
Constant Pilot Light: ❑ Yes O No Pilot burner Rating: 0.0208 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
COLORADO
Gas ;COLORADO
a;'(".it'l,J-L. UvnCI(1`�APEN - 1�c''!ISlC�rl i.l.t i.Ul7 4l a..m.th.r.a•.�
Permit Number: AIRS ID Number: / /
[Leave blink unless ArCD nis a:re3dy assigned 3 permit g and AIRS ID]
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 ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall,or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SOx ,
NOx
'Co .
VOC Enclosed Combustor(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:
Emission Factor Actual Annual Emissions Requested Annual Permit
Pollutant Emission Limit(s)5
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Units (AP-42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.)
(tons/year) (tonsfyeor) (tons/year) (tons/year)
PM 1.0893 Ib/MMscf AP-42 0.00 0.00 0.00
SOx 0.0860 Ib/MMscf AP-42 0.00 0.00 0.00
NOx 181.7103 Ib/MMscf AP-42 0.23 0.23 0.23
CO 775.0825 Ib/MMscf AP-42 0.97 0.97 0.97
VOC 90207.2960 Ib/MMscf HYSYS/AP-42 5.61 112.61 5.61
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 will 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-criteriaEl Yes ❑ No
pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 564.9820 Ib/MMed HYSYS/AP-42 1,411 71
Toluene 108883 460.2485 lb/MMscf HYSYS/AP-42 1.149 57
Ethylbenzene 100414 330.5030 Ib/MMscf HYSYS/AP-42 825 41
Xylene 1330207 208.6947 Ib/MMscf HYSYS/AP42 521 26
n-Hexane 110543 3,015.2773 Ib/MMscf HYSYS/AP-42 7,528 377
2,2,4-Trimethylpentane 540841 321.6711 Ib/MMscf HYSYS/AP-42 803 40
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
COLOR•DO
Form Ar CU 211 Gas Venting APEN • F evts!un 1_ _.:i> 5 I ®i° ',o�
e .�, ,
Permit Number: MRS ID Number: / /
[Leae blank unless APO has already assigned a permit:,and AIRS ID]
Section 9-Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Of WO 5� 01/14/2020
Sign ture of Legally Autho ed Person (not a vendor or consultant) Date
Janessa Salgado Environmental Engineer
Name(print) Title
Check the appropriate box to request a copy of the:
CI 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 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
Form APCD-211 Gas'venty Ai-'Lt - r_;isoin 12:L'i19 6 I
JAN 1 6 2020
...�,.,411 C Fugitive Component Leak Emissions APEN Ar
Form APCD-203 �1= -
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 teak 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-200)is available if the
41
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: .20WEO Z./ei AIRS ID Number: jZ3 /a ce/ OD2.
[Leave blank unless APCD has already assigned a permit»and AIRS ID)
Section 1 -Administrative Information
Company Namet: Noble Energy, inc.
Site Name: DP132 A19-11-A ECO
Site Location: NESW SEC19 T6N R64W Site Location Weld
County:
NAICS or SIC Code: 1311
Mailing Address:(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202 Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E-Mail Address2: 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.
1124392
COLORADO
Form APCD-2O3 Fugitive Component Lear( Emiss,on3 Area Re,is>un i21LOi' 1 ®ice
Permit Number: AIRS ID Number:
(Leave blank unless APCD has already assi;ned a permit 4 and AIRS ID]
Section 2 - Requested Action
NEW permit OR newly-reported emission source(check one below)
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change process or equipment O Change company name3 O Add point to existing permit
❑ Change permit limit O Transfer of ownership4 O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes:
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: N/A
For new or reconstructed sources, the projected start-up date is: .03/31/2021 03/31/2022 -BF
06/08/2020
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Per attached
email
Normal Hours of Source Operation: hours/day days/week weeks/year
Facility Types:
0 Well Production Facility
❑Natural Gas Compressor Station
❑ Natural Gas Processing Plant
❑Other(describe):
5 When selecting the facility type,refer to definitions in Colorado Regulation No.7,Section XVII.
iCOLORADO
Form APCD-2O3 Fu;hive t;o,npoileni Leak E.masion;APEN - Re kiln 12i201 2 I k:
Permit Number: AIRS ID Number: / /
ume>s APCD has already assigned a permit and AIRS'D)
Section 4- Regulatory Information
What is the date that the equipment commenced construction? 09/20/2020
Wilt this equipment be operated in any NAAQS nonattainment area? 0 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? O Yes 0 No
Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes j No
Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes O No
Is this equipment subject to 40 CFR Part 63, Subpart HH? O Yes 0 No
Is this equipment subject to Colorado Regulation No. 7,Section XII.G? O Yes ❑i 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? 0 Yes 0 No
Section 5- Stream Constituents
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.
2
VOC Benzene Toluene Ethylbenzene , Xylene n-Hexane Y,4
Stream (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Trimethylpentane
(wt%1
Gas 40.00 0.10 0.05 0.05 0.05 0.50 0.05
Heavy Oil
(or Heavy Liquid) 100 025 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 UM)
40.467860, -104.594140
Attach a topographic site map showing location
COLORADO
Form APCD-2J3 ri:�lilv7�..'7�TYk�,�'.•ni L�An triti:sions APEN - Revision 12,261,-i .3 I ® w�e
Permit Number: MRS ID Number: / /
[Leave blank unless APCD has already assigned a permit a and AIRS IDI
Section 7- Leak Detection and Repair(LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
O 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
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
❑i LDAR per Colorado Regulation No. 7, Section XVII.F
❑Other6:
❑No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
Ab,ICCILORADO
r.;rin Aru. L r'uTuv-'Cainpunenc LeaN'.Emissions/-\;,--E : - r.9oi,ton 12,[! y 4 I Je®'x°i j1iw
Permit Number: AIRS ID Number:
[Leave biank unless APCD has atready ass,!;e.i a pt a z,!;id AIRS ID;
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.
p✓ 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:
❑✓ Estimated Component Count
❑Actual Component Count conducted on the following date:
Equipment Type
Service Open-Ended y
Connectors Flanges I Lines Pump Seals Valves Other
Gas II
Count8 5,586 722 6 2,322 632
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 1,818 330 4 1,700 116
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
Count8 1,066 26 364 130
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 shalt 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.
COLORADO
Fir'n F1'L' -�JJ - Fugitive Component LeaK Emission;Ari=a - Re',reun i 2;Li]d 5 I ®� ►roaeau.a
Permit Number: AIRS ID Number:
[Leave bian'e unless A?CD has aready a,,;i;,,ed a perm a:1d AIRS ID]
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? N/A
Use the following table to report the criteria pollutant emissions from source:
CAS Actual Annual Emissions Limit
s Requested Permit Emission
Pollutant ( )i°
Number Uncontrolled Controlled" Uncontrolled Controlled
(tons/year) (tons/year) (tons/year) (tans/year)
VOC 1.65 1.65 1.65
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.
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 ID 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)70
Number Uncontrolled Controlled" Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543
2,2,4-Trimethylpentane 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.
ti Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
•
COLORADO
Form APCD 2u3 Fugitive Component yea c r,is ion,a kwisu?n lit Z0 I: 6blontrandeatt
Permit Number: AIRS ID Number: / /
[L ea,e blank unless APCD has already assigned a permit c and AIRS ID]
Section 11 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
S 01/14/2020
Sig ature of Legally Au horized Person(not a vendor or consultant) Date
Janessa Salgado Environmental Engineer
Name(print) Title
_. .
Check the appropriate box to request a copy of the:
0 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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