HomeMy WebLinkAbout20202136.tiff C. -.�.M.y COLORADO
Y�il Department of Public
c•D' Health b Environment
RECEIVED
Weld County - Clerk to the Board MAY 12 2020
1150 O St
PO Box 758 WELD COUNTY
Greeley, CO 80632 COMMISSIONERS
May 4, 2020
Dear Sir or Madam:
On May 5, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble
Energy, Inc. - SLW Ranch B01 Econode. A copy of this public notice and the public comment packet
are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
of c°to
4300 Cherry Creek Drive S., Denver,Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I iF�j a ' �,
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director k+ ,0 :,t*i
Pub I i c Re vi ec.J cc:PL(r )�µi O-'c),Pt.,(3n/ER/CHkii) 2020-2136
07/2x/20 o�(st-)
O7/15/2O
Air Pollution Control Division
iY • yaa
Notice of a Proposed Project or Activity Warranting Public
CD HE
is44h4,t440
Comment
Website Title: Noble Energy, Inc. - SLW Ranch B01 Econode - Weld County
Notice Period Begins: May 5, 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: SLW Ranch B01 Econode
Oil and gas well production facility
SENE Sec 1 T5N R64W
Weld County
The proposed project or activity is as follows: Applicant proposes to modify permit to decrease limits for
gas vented from low pressure separators and add a new venting source as a vapor recovery tower at an
existing well production facility.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 13WE2740 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:
Brad Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
I I Department of Public
Health 6 Environment
Addendum to doc #420865
Received 04-20-2020
-B.E.
MFMJM..7rr,, Gas Venting APEN - Form. APCD-211
�i
-_- Air Pollutant Emission Notice (APEN) and
,. 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: 13WE2740 AIRS ID Number: 123 /9BE5 /007
[Leave blank unless APCD has already assigned a permit#and MRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: SLW RNCH B01 ECONODE T5N-R64W-S12 L01
Site Location
Site Location: SENE SEC1 T5N R64W 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: 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.
COLORADO
Form APCD 211 Gas Venting APEN Revision 12/2019 1 e �. ,
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/007
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership's 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info ft Notes:
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Flare for LP separators
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is: 07/01/2013
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS
(] Yes 0 No
nonattainment area?
Is this equipment located at a stationary source that is ❑ Yes 0 No
considered a Major Source of(HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
0 Yes 0 No
Section XVII.G?
COLORADO
Form APCD 211 Gas Venting APEN Revision 12/2019 2 °Health Environment
"""""""°°"`
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/007
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Process Equipment Information
✓❑ 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 100 tpy? ❑ Yes O No
Vent Value:
1836 BTU/SCF
Gas Venting Heating Valuue::
Process Parameters5: Requested: 55.00 MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput
Process Parameters5• Requested: bbl/year Actual: bbl/year
Molecular Weight: 37.93(modeled),31.99(sampled)
VOC (Weight%) 50.95
Benzene(Weight%) 0.42
Vented Gas Toluene(Weight%) 0.46
Properties: Ethylbenzene(Weight%) 0.02
Xylene(Weight%) 0.19
n-Hexane(Weight%) 3.42
2,2,4-Trimethylpentane(Weight%) 0.13
Additional Required Documentation:
❑✓ Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure)
El pressure)
a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and
pressure)
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.
COLORADO
Form APCD-211 Gas Venting APEN Revision 12/2019 3 Eg, t
Permit Number: 1 3WE2740 AIRS ID Number: 123 /9BE5/007
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(LatitudelLongitude or UTM)
40.4329,-104.4893
0 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.
P Discharge Height Temp. Velocity
Discharge Tem Flow'Rate
Above"Ground Level
Stack ID No (`F) (ACFM) (ftlsec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward 0 Downward 0 Upward with obstructing raincap
o Horizontal ❑ Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches):
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ 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.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency: %
VRU Downtime or Bypassed: %
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
hr
Type: Open Flare Make/Model:
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
COLORADO
Form APCD-211 Gas Venting laPEN Revision 12/2O19 4 I l°`" "�"„`
1th6Envuo,pf
Permit Number: 13WE2740 AIRS ID Number: 123 t 9BE5 i 007
[Leave blank unless APCD has already assigned a permit#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? ❑✓ Yes O 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 j%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
SO.
NO.
CO
VOC VOC Burner 100% 95%
HAPs VOC Burner 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:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
PM 0.2720 Ib/MMscf SamplingAP-42 0.00 0.00
SOX 0.0215 Ib/MMscf SamplingAP-42 0.00 0.00
NO. 128.3999 Ib/MMscf SamplingAP-42 0.32 0.32
CO 572.0450 Ib/MMscf SamplingAP-42 1.43 1.43
VOC 51,019.654 Ib/MMscf Madel/AP-42 127.63 6.38
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 APEN5,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-criteria
Yes El 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
Abstract Source Uncontrolled Controlled
Chemical Name Uncontrolled
Service (CAS) Units (AP-42, Emissions Emissions
Basis Mfg.,etc.) (lbs/year)Number ( y ) (lbs/year)
Benzene 71432 421.2110 Ib/MMscf Model/AP-42 2,107 105
Toluene 108883 457.5313 Ib/MMscf Model/AP-42 2,289 114
Ethylbenzene 100414 16.6072 Ib/MMscf Model/AP-42 83 4
Xylene 1330207 191.0077 Ib/MMscf Model/AP-42 956 48
n-Hexane 110543 3,426.7941 Ib/MMscf Model/AP-42 17,145 858
2,2,4-Trimethylpentane 540841 125.6557 Ib/MMscf Model/AP-42 629 31
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
arth COLORADO
Form APCD-211 Gas Venting APEN - Revision 12/2019 5 I �°� ""°`P"'"`
HwtUib Envi'ammen�
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5 i 007
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
541414 04/20/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Janessa Salgado Environmental Engineer
Name(print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ 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
lto COLORADO
Form APCD-211 - Gas Venting APEN - Revision 12/2019 6 I > "�`"'"°"`Hm1u�6 En+tt!
Addendum to doc #420866
Received 04-20-2020
-B.E.
MFG,,M Gas Venting ADEN - Form APCD-211
i414411 Air Pollutant Emission Notice (APEN) and
,, 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: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit II and MRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: SLW RNCH B01 ECONODE T5N-R64W-S12 L01
Site Location: SENE SEC1 T5N R64W Site Location Weld
County:
NAICS or SIC Code: 1311
Matting Address: 1625 Broadwa Suite 2200
(Include Zip Code) y�
Denver, CO 80202 Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E-Mail Address2: janessa.salgado@nblenergy.com
I 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.
COLORADO
Form APCD 211 Gas Venting APEN Revision 12/2019 1eI ,
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit#and AIRS 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 ❑ Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
CI Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info&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:
For new, modified, or reconstructed sources, the projected start-up date is: 07/01/2013
▪Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS
Yes 0 No
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of(HAP) Emissions? ❑ Yes No
Is this equipment subject to Colorado Regulation No. 7, ❑ Yes 0 No
Section XVII.G?
COLORADO
Form APCD 211 Gas Venting APEN Revision 12/2019 2 Ihrosnentnent
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Process Equipment Information
❑✓ 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 100 tpy? O Yes O No
Vent Gas 2677 BTU/SCF
Gas Venting Heating Value:
Process Parameters5: Requested: 3.00 MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput
Requested: bbl/year Actual: bbl/year
Process Parameters5
Molecular Weight: 46.13(modeled),45.13(sampled)
VOC (Weight%) 80.3684
Benzene(Weight%) 0.58
Vented Gas Toluene(Weight%) 0.59
Properties: Ethylbenzene(Weight%) 0.02
Xylene(Weight%) 0.23
n-Hexane(Weight%) 4.69
2,2,4-Trimethylpentane(Weight%) 0.16
Additional Required Documentation:
❑✓ Attach a representative gas analysis(including BTEX£t n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX a n-Hexane, temperature, and
pressure)
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.
COLORADO
Form APCD 211 Gas Venting APEN Revision 12/2019 3 ( OI amt
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or`UTM)
40.4329,-104.4893
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.
Discharge Height
Operator Temp. Flow Kate Velocity
Above Ground.Leve!
Stack ID No. F) (ACFM) (fit/secj
- e
(Feet)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward O Downward ❑ Upward with obstructing raincap
❑ Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width (inches): Interior stack depth(inches):
❑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.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
hr
Type: Enclosed Burner(s) Make/Model:
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ✓❑ Yes O No Pilot burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 12/2019
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit#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? ❑✓ Yes O 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
NO.
CO
VOC VOC Burner 100% 95%
HAPs - VOC Burner 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:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions
Basis Mfg:,etc.) ytons/ ear tons/ ear
(tons/year) (tons/year) (tons/year)) (tons/year)
)
PM 0.9242 Ib/MMscf Model/AP-42 0.00 0.00
SOx 0.0730 Ib/MMscf Model/AP-42 0.00 0.00
NO. 194.1786 Ib/MMscf Model/AP-42 0.29 0.29
CO 840.0015 Ib/MMscf Model/AP-42 1.26 1.26
VOC 95,753.36 Ib/MMscf Sampling 143.63 7.18
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-criteria 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 Uncontrolled Abstract Source Uncontrolled Controlled
Service(CAS) Units (AP-42, Emissions Emissions6
Basis Mfg.,etc.) tbs/ ear
Number ( Y ) (lbs/year)
Benzene 71432 705.4765 Ib/MMscf Model/AP-42 2,117 106
Toluene 108883 716.6307 Ib/MMscf Model/AP-42 2,151 108
Ethylbenzene 100414 24.4073 Ib/MMscf Model/AP-42 73 4
Xytene 1330207 280.2060 Ib/MMscf Model/AP-42 841 42
n-Hexane 110543 5,715.1286 Ib/MMscf Model/AP-42 17,153 858
2,2,4-Trimethylpentane 540841 199.5990 Ib/MMscf Model/AP-42 599 30
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 12/2019 5 °��"m`""`"`°""„fimlthb Envuu�mcnt
Permit Number: 13WE2740 AIRS ID Number: 123 /9BE5/014
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
�,,, 5 04/20/2020
Si ature of Legally Person (not a vendor or consultant) Date
g g Y
Janessa Salgado Environmental Engineer
Name(print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term,or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
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
liteCOLORADO
Form APCD-211 Gas Venting APEN Revision 12/2019 6 > t
STATE OF COLORADO
aQ
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE:(303)692-3150 '
1876
CONSTRUCTION PERMIT
PERMIT NO: 1 3YY E2740
Issuance 2
DATE ISSUED:
ISSUED TO: Noble Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the SLW Ranch B01 Econode, located in the SENE of Section
1, Township 5 North, Range 64 West, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Ten (10)above ground 500 bbl atmospheric condensate storage
TANKS 004 tanks. Emissions from these tanks are controlled by an enclosed
flare.
Truck 005 Truck Condensate Loadout.
Loadout
Two (2) 60 bbl and four(4) 500 bbl above ground atmospheric
PW 006 produced water storage tanks. Emissions from these tanks are
controlled by an enclosed flare.
Venting of gas from low pressure (LP) Separators. Gas from LP
LP 007 separators is routed to an open flare during vapor recovery unit
(VRU) downtime.
Venting of gas from vapor recovery towers (VRTs). Gas from VRTs
VRT 014 is routed to enclosed combustor(s) during vapor recovery unit
(VRU) downtime.
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 THOSE GENERAL TERMS AND CONDITIONS INCLUDED
IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days(180)after issuance of this permit,compliance with the
conditions contained in this permit shall be demonstrated to the Division. It is the owner or
operator's responsibility to self-certify compliance with the conditions.Failure to demonstrate
compliance within 180 days may result in revocation of the permit. (Reference: Regulation
No. 3, Part B, III.G.2).
Colorado Department of Public Health and Environment
Air Pollution Control Division
2. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i)does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii)discontinues construction fora period of eighteen
months or date. The Division may grant extensions of the deadline per Regulation No. 3,
Part B, and III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
3. Point 007: Within one hundred and eighty days (180) after issuance of this permit, the
operator must install a flow meter to monitor and record volumetric flow rate of gas vented
from the low pressure (LP) separators covered by this permit. Until the flow meter is
installed, the operator must monitor and record condensate/crude produced through the
separator and estimate the gas flow rate based on standard cubic feet(scf)per barrel (bbl)
of 10.40 scf/bbl estimated in the permit application.
4. Point 014: Within one hundred and eighty days (180) after issuance of this permit, the
operator must install a flow meter to monitor and record volumetric flow rate of gas vented
from the vapor recovery towers (VRTs) covered by this permit. Until the flow meter is
installed, the operator must monitor and record condensate/crude produced through the
separator and estimate the gas flow rate based on standard cubic feet(scf)per barrel (bbl)
of 7.97 scf/bbl estimated in the permit application.
5. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self-certification,with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO. VOC CO
TANKS 004 --- 3.5 --- Point
Truck 005 --- 4.5 --- Point
Loadout
PW 006 --- 2.0 --- Point
LP 007 --- 6.4 --- Point
VRT 014 --- 7.2 --- Point
See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
AIRS ID: 123/9BE5 Page 2 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from
each emission unit, on a rolling twelve (12) month total. By the end of each month a new
twelve-month total shall be calculated based on the previous twelve months' data. The
permit holder shall calculate emissions each month and keep a compliance record on site or
at a local field office with site responsibility, for Division review. This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TANKS 004 Enclosed flare VOC & HAP
Truck 005 Enclosed flare VOC & HAP
Loadout
PW 006 Enclosed flare VOC & HAP
LP 007 Open Flare VOC & HAP
VRT 014 Enclosed flares VOC & HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or operator
and made available to the Division for inspection upon request. (Reference: Regulation 3,
Part B, II.A.4)
Process/Consumption Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
TANKS 004 Condensate throughput 700,000 BBL/yr
Truck 005 Condensate loading 700,000 BBL/yr
Loadout
PW 006 Produced water throughput 300,000 BBL/yr
LP 007 Venting of gas from LP separators to 5.0 MMSCF/yr
open flare during VRU downtime
VRT 014 Venting of gas from VRTs to enclosed 3.0 MMSCF/yr
combustors during VRU downtime
The owner or operator shall calculate monthly process rates based on the calendar month.
AIRS ID: 123/9BE5 Page 3 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months'data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
10. Point 007: Upon installation of the flow meter, the owner or operator must continuously
monitor and record the volumetric flow rate of gas vented from the low pressure (LP)
separators to the open 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.
11. Point 014: Upon installation of the flow meter, the owner or operator must continuously
monitor and record the volumetric flow rate of gas vented from the vapor recovery towers
(VRTs)to the enclosed combustors using the flow meter.The flow meter must be calibrated
and maintained per the manufacturer's specifications and schedule. The owner or operator
must use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and AIRS ID point number(e.g. 123/4567/890)shall be marked on the
subject equipment for ease of identification. (Reference:Regulation Number 3, Part B, III.E.)
(State only enforceable)
13. Visible emissions shall 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 shall 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.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. &4.)
14. This source is subject to the odor requirements of Regulation No.2.(State only enforceable)
15. Point 004: The flare covered by this permit is subject to Regulation No. 7, Section XII.C
General Provisions (State only enforceable). If a combustion device is used to control
emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed,
have no visible emissions, and be designed so that an observer can, by means of visual
observation from the outside of the enclosed combustion device, or by other means
approved by the Division, determine whether it is operating properly. The operator shall
comply with all applicable requirements of Section XII.
16. Point 004: This source is subject to the recordkeeping, monitoring,reporting and emission
control requirements of Regulation 7, Section XII. The operator shall comply with all
applicable requirements of Section XII.
17. Point 004: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B
General Provisions(State only enforceable). If a flare or other combustion device is used to
control emissions of volatile organic compounds to comply with Section XVII, it shall be
AIRS ID: 123/9BE5 Page 4 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
enclosed, have no visible emissions during normal operations, and be designed so that an
observer can, by means of visual observation from the outside of the enclosed flare or
combustion device, or by other convenient means approved by the Division, determine
whether it is operating properly.The operator shall comply with all applicable requirements
of Section XVII.
18. Point 004: The condensate storage tanks covered by this permit are subject to Regulation
7, Section XVII emission control requirements. These requirements include, but are not
limited to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
natural gas drip stations and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic compounds
equal to or greater than 20 tons per year based on a rolling twelve-month total
shall operate air pollution control equipment that has an average control
efficiency of at least 95%for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this section
XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to
ensure that it is operating at least as often as condensate is loaded out from the
tank, unless a more frequent inspection or monitoring schedule is followed. In
addition, if a flare or other combustion device is used,the owner or operator shall
visually inspect the device for visible emissions at least as often as condensate
is loaded out from the tank.
XVI I.C.4. Recordkeeping:The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant
to this section XVII.C., the date, time and duration of any period where
the air pollution control equipment is not operating. The duration of a
period of non-operation shall be from the time that the air pollution control
equipment was last observed to be operating until the time the equipment
recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed from
the device.
19. Point 007, 014: 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.)
OPERATING & MAINTENANCE REQUIREMENTS
20. Point 004, 005, 006, 007, 014: Upon startup of these points, the owner or operator shall
follow the most recent operating and maintenance (O&M) plan and record keeping format
approved by the Division, in order to demonstrate compliance on an ongoing basis with the
AIRS ID: 123/9BE5 Page 5 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
requirements of this permit. Revisions to your O&M plan are subject to Division approval
prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
21. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
22. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
23. All previous versions of this permit are cancelled upon issuance of this permit.
24. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5)tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds(VOC)and nitrogen oxides sources(NOX)in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a
change in annual actual emissions of one (1)ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more,whichever is less, above the level reported
on the last APEN submitted; or
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.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed,or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
25. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential to emit
above the applicable Federal program threshold will require a full review of the source as
though construction had not yet commenced on the source. The source shall not exceed
the Federal program threshold until a permit is granted. (Regulation No. 3 Part D).
AIRS ID: 123/9BE5 Page 6 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
26. MACT Subpart HH-National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
27. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
28. If this permit specifically states that final authorization has been granted,then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division,it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
29. 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.
30. 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.
31. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit,the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
32. 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.
33. 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
AIRS ID: 123/9BE5 Page 7 of 13
Colorado Department of Public Health and Environment
Air,Pollution Control Division
enforcement actions under Sections 25-7-115(enforcement), -121 (injunctions), -122(civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Bradley Eades
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 April 29, 2014 Issued to Noble Energy, Inc. Newly permitted
condensate tanks, truck loadout and produced
water tanks.
Issuance 2 This Issuance Issued to Noble Energy, Inc.
Modification to decrease throughput and
emissions limits for Point 007. Add venting from
VRT as Point 014.
AIRS ID: 123/9BE5 Page 8 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
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 shall pay the invoice within 30 days of receipt of
the invoice.Failure to pay the invoice will result in revocation of this permit(Reference:Regulation No.3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice(APEN)and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s)operate at the permitted limitations.
AIRS ID: 123/9BE5 Page 9 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
Uncontrolled Are the Controlled
AIRS Emission Rate emissions Emission
Point Pollutant CAS# (lb/yr) reportable? Rate(Ib/yr)
Benzene 71432 350 Yes 18
004
Hexane 110543 4,200 Yes 210
Benzene 71432 1,400 Yes 70
n-Hexane 110543 2,800 Yes 140
005
Toluene 108883 2,100 Yes 105
Xylenes 1130207 700 Yes 35
Benzene 71432 2,100 Yes 105
006
Hexane 110543 6,600 Yes 330
Benzene 71432 2,107 Yes 105
Toluene 108883 2,289 Yes 114
Ethylbenzene 100414 83 No 4
007
Xylenes 1130207 956 Yes 48
n-Hexane 110543 17,145 Yes 858
2,2,4-TMP 540841 629 Yes 31
Benzene 71432 2,117 Yes 106
Toluene 108883 2,151 Yes 108
Ethylbenzene 100414 73 No 4
014
Xylenes 1130207 841 Yes 42
n-Hexane 110543 17,153 Yes 858
2,2,4-TMP 540841 599 Yes 30
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Emission Factors Emission Factors
Uncontrolled Controlled
CAS# Pollutant lb/BBL Ib/BBL Source
Condensate Condensate
Throughput Throughput
VOC 0.2 0.01 WinSim and EPA
Tanks
110543 n-Hexane 0.006 0.0003 WinSim and EPA
Tanks
71432 Benzene 0.0005 0.00003 WinSim and EPA
Tanks
Note: The controlled emissions factors for point 004 are based on the flare control efficiency of
95%.
AIRS ID: 123/9BE5 Page 10 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
Point 005:
Emission Factors- Emission Factors—Controlled
Uncontrolled
CAS Pollutant lb/1000 gal Source Lb/1000 gal Source
loaded loaded
VOC 6.15 AP-42 0.3075 AP-42
71432 Benzene 0.0476 DOC#EPA- 0.0024 DOC#EPA-
4531R-94-002a 453/R-94-002a
108883 Toluene 0.0714 DOC#EPA- 0.0036 DOC#EPA-
453/R-94-002a 453/R-94-002a
1330207 Xylenes 0.0238 DOC#EPA- 0.0012 DOC#EPA-
453/R-94-002a 453/R-94-002a
110543 n-hexane 0.0952 DOC#EPA- 0.0048 DOC#EPA-
453/R-94-002a 453/R-94-002a
The uncontrolled VOC emission factor was calculated using AP-42,Chapter 5.2,Equation 1 (version
1/95) using the following values:
L= 12.46*S*P*M/T
S =0.6 (Submerged loading: dedicated normal service)
P(true vapor pressure)=6.9 psia
M (vapor molecular weight)=62 lb/lb-mol
T(temperature of liquid loaded)=520°R
Point 006:
Emission Factors Emission Factors
Uncontrolled Controlled
CAS# Pollutant lb/BBL lb/BBL Source
Condensate Condensate
Throughput Throughput
VOC 0.262 0.0131 PS Memo 09-02
110543 n-Hexane 0.022 0.0011 PS Memo 09-02
71432 Benzene 0.007 0.0004 PS Memo 09-02
Point 007:
Emission Emission
Factors Factors
CAS# Pollutant Uncontrolled Controlled Source
(lb/MMscf) (Ib/MMscf)
NOx 128.40 128.40 AP-42 Chapter 13.5
& Extended Gas
CO
572.04 572.04 Analysis
VOC 51019.65 2551.17
71432 Benzene 421.21 21.06
108883 Toluene 457.53 22.88 ProMax/Extended
1330207 Xylenes 191.01 9.55 Gas Analysis
110543 n-hexane 3426.79 171.40
540841 2,2,4-TMP 125.66 6.28
Note: The uncontrolled VOC and HAP emissions for this point were calculated using a pressurized
liquid sample and ProMax. Source also submitted an extended gas analysis from the LP
AIRS ID: 123/9BE5 Page 11 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
separator collected 3/2/20. More conservative(i.e. higher)emission resulted using ProMax
modeled composition,which is represented in the table above(MW of vapors 37.9 Ib/Ibmol,
51% VOC by weight).. The controlled VOC and HAP emissions factors for point 007 are
based on the flare control efficiency of 95%.
Point 014:
Emission Emission
Factors Factors
CAS# Pollutant Uncontrolled Controlled Source
(lb/MMscf) (lb/MMscf)
NOx 194.18 194.18 AP-42 Chapter 13.5
& Extended Gas
CO
840.00 840.00 Analysis
VOC 95,753.36 4,785.32 Extended Gas
Analysis
71432 Benzene 705.48 35.27
108883 Toluene 716.63 35.83
1330207 Xylenes 280.21 14.01 ProMax
110543 n-hexane 5,715.13 285.96
540841 2,2,4-TMP 199.60 9.98
Note: The uncontrolled VOC and HAP emissions for this point were calculated using a pressurized
liquid sample and ProMax as well as an extended gas analysis from the LP separator
collected 3/2/20.The More conservative(i.e. higher)emission factor between the modeled
composition(46.1 Ib/Ibmol,75.8%by weight VOC)and sampled composition(45.1 lb/Ibmol,
80.4% by weight VOC) is used for each pollutant, as represented in the table above. The
controlled VOC and HAP emissions factors for point 014 are based on the flare control
efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this
permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall
be submitted no later than 30 days before the five-year term expires. Please refer to the most recent
annual fee invoice to determine the APEN expiration date for each emissions point associated with this
permit. For any questions regarding a specific expiration date call the Division at(303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC, n-hexane, total HAPS
NANSR Synthetic Minor Source of:
VOC
MACT HH Area Source Requirements: Not Applicable
8) Full text of the Title 40,Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
AIRS ID: 123/9BE5 Page 12 of 13
Colorado Department of Public Health and Environment
Air Pollution Control Division
NSPS 60.1-End Subpart A—Subpart KKKK
NSPS Part 60, Appendixes Appendix A—Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-63.599 Subpart A—Subpart Z
MACT 63.600-63.1199 Subpart AA—Subpart DDD
MACT 63.1200-63.1439 Subpart EEE—Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:
www.colorado.gov/cdphe/oilgaspermits
AIRS ID: 123/9BE5 Page 13 of 13
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Bradley Eades
Package #: 319568
Received Date: 10/17/2019
Review Start Date: 2/5/2020
Section 01 - Facility Information
Company Name: Noble Energy, Inc Quadrant Section Township Range
County AIRS ID: 123 SENE 1 5N 64
Plant AIRS ID: 98E5
Facility Name: SLW Ranch 801 Econode
Physical
Address/Location: SENE quadrant of Section 1, Township SN, Range 64W
County: Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
Permit #
AIRs Point #
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned) Permit l� pp
Permit Combined 'y h
p or e .:.,�� LP Sep ; 1 Modification Pt 014
Se. itraL t Periniara:oi? 1.3��E fi M di
CN received
Fugitive Component Leaks Fugitive Em ssi t3W.VE2743 Cancellation 1/22/15
Newly
Reported Point
Permit Initial and combine
014 Separator Venting LP & VRT Gas Stream Yes 13WE2740 2 Yes Issuance w/ 007
No Action
004 Condensate Tank TANKS 13WE2740 2 No Requested No change
No Action
005 Liquid Loading Truck Loadout 13WE2740 2 No Requested No change
No Action
006 Produced Water Tank PW 13WE2740 2 No Requested No change
Section 03 - Description of Project
Modification request received 10/17/2019 to decrease limits for LP Gas Flaring (point 007) as well as to request a permit for gas venting from the VRT. This point
was not previously permitted and Noble indicates via application cover letter "Noble recently performed an evaluation and determined that the VRT stream
requires a permit."
Noble indicates that vapors from the LP separators and VRT are currently sent to a vapor recovery unit (VRU) and compressed eito the sales line. (vapors are
combusted during VRU downtime). With this modification, Noble is requesting to remove the VRU compressors at this site,in which case all vapors from the LP
separator and VRT will be vented to combustors.
An application was received to modify Pointn 007 in October 2014, which is also included in this package. That application was never processed due to internal
processing issues (package had to be located by APEN Technician upon receipt of Oct 2019 application. PTS entries indicated the point was cancelled and was
inactive, however, upon investigation by APEN Technician and myself, there was no record of a CN request by Noble). As a result, the October 2014 application was
added to this package. The analysis herein reflects the most recent APEN addendums received 4-20-2020.
Prior to April 2020 revisions (superseded by request in the following paragraph): After extensive discussions with Noble, the following was indicated in March 2020
via email about the process setup at the facilitiy (via Janessa Salgado): that VRU's would be removed from the facility such that all gas would be combusted and "The
LP gas stream will be combined back into the LP oil dump line and that combined stream will be sent to the VRT. The gas fromthe VRT will be sent to the enclosed
combustors, so we will only be able to use one meter, please see attached diagram". As a result, it was agreed to combine the LP seprator venting and VRT venting
into a single emission point since the volume will be metered together. The most conservative gas composition (between VRT gas and LP gas) was used for each
pollutant. As a result of this change, Point 007 was to be cancelled and an APEN addendum was submitted for Point 014 on 4-1-2020.
In mid April 2020, upon review of the draft permits, I was notified that Noble was requesting to revert to a previous version of the application prior to revisions
received in April. I requested that Noble submit a complete revised application. On 4/20/2020, an ammended application was received with revised calculations,
O&M Plans, and APEN addendums. With this applicaiton, Noble will continue to track and report emissions from LP separators (Point 007) separately from VRT gas
(Point 014).
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
'VRT venting is a new point with synthetic minor limits.
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP) H HI I RI
Non-Attainment New Source Review (NANSR) ./
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2NOx CO VOCPM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) 1 1
Title V Operating Permits (OP) r
Non-Attainment New Source Review (NANSR)
Separator Venting Emissions Inventory
Section 01 - Administrative Information
123 9BE5 014
Facility AIRs ID:
County Plant Point
Section 02 - Equipment Description Details
Venting of gas from low pressure (LP) separators to enclosed combustor
Detailed Emissions Unit Description:
Enclosed Combustor
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Limited Process Parameter Natural Gas Vented
Gas meter Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 5.0 MMscf per year
Requested Permit Limit Throughput = 5.0 MMscf per year Requested Monthly Throughput = 0.42 MMscf per month
Potential to Emit (PTE) Throughput = 5.0 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value: 1836.0 Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: 10.404 scf/bhl
Control Device
Pilot Fuel Use Rate: 20.83333333 scfh 0.2 MMscf/yr
Pilot Fuel Gas Heating Value: 1000 Btu/scf
Section 04 - Emissions Factors & Methodologies
Description
Gas from the LP separators are sent to the open flare. Applicant modeled emissions using a pressurized liquid sample (collected 3/19/20) from the VRT outlet and used ProMax and operating conditions of the VRT and LP separator to
model stream composition upstream of the LP Separators. The resulting modeled LP Separator gas stream composition is represented as Composition #2 below. The operator also pulled a gas sample from the LP Separator on 3/2/20
(33 psig, 69F). That composition is reflected as composition #1 below. The most conservative (resulting in higher emissions) weight percent for each pollutant in the analsyes below is used to develop the respective emission factor.
COMPOSITION #1 (LP SEP GAS SAMPLE) COMPOSITION #2 (ProMax)
MW 32.0 Ib/Ib-mol I NANA/ 37.9 Ib/Ib-mol Displacement Equation
Ex = Q ` MW '` Xx / C
Weight % Ib/MMSCF Weight % Ib/MMSCF
Helium Helium 0.0
CO2 2.4 CO2 1.3
N2 0.1 N2 39.5
methane 22.4 methane 2.4
ethane 20.1 ethane 5.7
propane 21.2 propane 15.7
isobutane 4.9 isobutane 3.9
n-butane 13.5 n-butane _ 10.9
isopentane 4.3 isopentane 3.0
n-pentane 5.7 n-pentane 3.7
cyclopentane 0.3 cyclopentane 0.6
n-Hexane 1.41 1. n-Hexane 3.43 3433.52
cyclohexane 0.37 cyclohexane 4.10
Other hexanes 1.59 Other hexanes
heptanes 0.85 heptanes 2.41
methylcyclohexane 0.14 methylcyclohexane 0.77
224-TMP 0.02 14.94 224-TMP 0.13 125.90
Benzene 0.23 197.76 Benzene 0.42 422.05
Toluene 0.10 86.60 Toluene 0.46 458.44
Ethylbenzene 0.01 4.30 Ethylbenzene 0.02 16.64
Xylenes 0.02 19.50 Xylenes 0.19 191.39
C8+ Heavies 0.18 155.73 C8+ Heavies 1.31 1314.62
Total 100.0 Total 100.0
VOC Wt % 54. 46324.56 VOC Wt % 51. 1 51120.50
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Separator Venting Emissions Inventory
Emission Factors Separator Venting
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf) Emission Factor Source
Pollutant
(Gas
Throughput) (Gas Throughput)
VOC 51120.50 - 2556.0250 Extended gas analysis
Benzene 422.0451 21.1023 Extended gas analysis
Toluene 458.4374 22.9219 HYSYS
Ethylbenzene 16.6401 0.8320 HYSYS
Xylene 191.3860 9.5693 HYSYS
n-Hexane 3433.5152 171.6758 Extended gas analysis
224 TMP 125.9045 6.2952 Extended gas analysis
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 13.6800 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 13.6800 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 1.0800 AP-42 Table 1.4-2 (5Ox)
NOx 0.0680 124.8480 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 569.1600 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 0.0075 7.4510 AP-42 Table 1.4-2 (PM10/PM.2.S)
PM2.5 0.0075 7.4510 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx 0.0006 0.5882 AP-42 Table 1.4-2 (SOx)
NOx 0.0980 _ _ 98.0392 AP-42 Table 1.4-1 (NOx)
_
CO 0.0824 82.3529 AP-42 Table 1.4-1 (CO)
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 0.0 0.0 0.0 0.0 0.0 6
PM2.5 0.0 0.0 0.0 0.0 0.0 6
SOx 0.0 0.0 0.0 0.0 0.0 0
NOx 0.3 0.3 0.3 0.3 0.32 54
VOC 127.6 127.6 6.4 127.63 6.38 1084
CO 0.0 1.4 1.4 1.4 1.43 243
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 2107 2107 105 2107 105
Toluene 2289 2289 114 2289 114
Ethylbenzene 83 83 4 83 4
Xylene 956 956 48 956 48
n-Hexane 17144 17144 857 17144 857
224 TMP 629 629 31 629 31
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XVII.B, G Source is not subject to Regulation 7, Section XVII.8.2, G
Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
y,. rr y,`., -7 Yi
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-widepermitted emissions of VOCgreater than or equal to 40 tonsperyear? ' '''` �T
Y q i�.��:;�: ;G,. ,
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? No
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? ,1!M
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
Section 08 - Technical Analysis Notes
As discussed in Section 04, the applicant provided both an extended gas sample from the VRT and a ProMax simulation. More conservative factors for all pollutnats was produced using the ProMax simulation results. The scf/bbl factor to be used for
the first 180 days until the meter is installed is based on the ProMax model. .
Applicant indicates that LP Sep gas is measured by a dedicated meter (i.e. only measures LP separator gas to flare) at the flare inlet.
Emission factors calculated by applicant differ slightly from what is calculated in this analysis. As such, I will accept their values. The difference is due to rounding. The emission factors used by the applicant are below:
FC.';,ta,lt
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Separator Venting Emissions Inventory
NOx 128.40 128.4C
CO 572.043 572.0,4
VOC 51019.65 2551 17
Benzene 421.21 21 .0
Toluene 457.53 22.88
Xylene•s 1 •1 01 9.5=.
n-re<ane 3425.79 171.41;
2.2.4-TMP 125 65 6 28
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units
014 01 3-10-001-60 Flares PM10 13.7 0 Ib/MMSCF
PM2.5 13.7 0 Ib/MM5CF
SOx 1.1 0 Ib/MMSCF
NOx 124.8 0 Ib/MMSCF
VOC 51120.5 95 Ib/MMSCF
CO 569.2 0 Ib/MMSCF
Benzene 422.0 95 Ib/MMSCF
Toluene 458.4 95 lb/MMSCF
Ethylbenzene 16.6 95 Ib/MMSCF
Xylene 191.4 95 Ib/MMSCF
n-Hexane 3433.5 95 Ib/MMSCF
224 TMP 125.9 95 Ib/MMSCF
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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 Requirements
Source is in the Non-Attainment Ares
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? i
2. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Re
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 II.D.2)? Yes Source Re
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? No Source is i
Source is not subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? _ No The contri
The control device for this separator is not subject to Regulation 7, Section XVILB.2.e
Section XVII.B.2.e - Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, 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 to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend, " may," +should, "and "can,"is
intended to describe 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 not establish legally binding requirements in and of itself.
Separator Venting Emissions Inventory
Section 01 - Administrative Information
123 96E5 014
Facility AIRS ID: County Plant Point
Section 02 - Equipment Description Details
Venting of gas from vapor recovery towers (VRTs) to enclosed combustor
Detailed Emissions Unit Description:
Enclosed Combustor
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Limited Process Parameter Natural Gas Vented
Gas meter Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 3.0 MMscf per year
Requested Permit Limit Throughput = 3.0 MMscf per year Requested Monthly Throughput = 0.25 MMscf per month
Potential to Emit (PTE) Throughput = 3.0 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
10.4 scf/bbl
Separator Gas Heating Value: 2677.0 Btu/scf 2677
Volume of waste gas emitted per BBL of LP Gas
liquids throughput: 7.969 scf/bbl 7.969148101 10.40391344
Control Device
Pilot Fuel Use Rate: 20.83333333 scfh 0.2 MMscf/yr
Pilot Fuel Gas Heating Value: 1000 Btu/scf
Section 04 - Emissions Factors & Methodologies
Description
Liquids from the low pressure separators are directed to VRTs. Gas from the VRTs are sent to the enclosed combustor. Applicant modeled emissions using a pressurized liquid sample (collected 3/19/20) from the VRT
outlet and used ProMax and operating conditions of the VRT and LP separator to model stream composition upstream of the LP Separators. The resulting modeled VRT flash gas stream composition is represented as
Composition #2 below. The operator also pulled a gas sample from the VRT on 3/2/20 (1 psig, 43 deg F). That composition is reflected as composition #1 below. The most conservative (resulting in higher emissions)
weight percent for each pollutant in the analsyes below is used to develop the respective emission factor.
COMPOSITION #1 (VRT GAS SAMPLE) COMPOSITION #2 (ProMax)
MW 45.1 Ib/Ib-mol MW 46.2 Ib/Ib-mol Displacement Equation
Ex = Q * MW * Xx / C
Weight % Ib/MMSCF Weight % lb/MMSCF
Helium Helium 0.0
CO2 0.9 CO2 1.5
N2 0.3 N2 12.9
methane 5.0 methane 1.8
ethane 12.8 ethane 8.0
propane 28.2 propane 24.4
isobutane 7.0 isobutane 6.1
n-butane 20.0 n-butane 16.9
isopentane 6.8 isopentane 4.5
n-pentane 8.6 n-pentane 5.4
cyclopentane 0.5 cyclopentane 0.9
n-Hexane 2.80 3326.7€ n-Hexane 4.72 5759.06
cyclohexane 0.82 cyclohexane 5.58
Other hexanes 2.93 Other hexanes 0.00
heptanes 1.90 heptanes 3.09
methylcyclohexane 0.35 methylcyclohexane 0.99
224-TMP 0.04 53.47 224-TMP 0.17 201.14
Benzene 0.45 532.99 Benzene 0.58 710.93
Toluene 0.14 171.26 Toluene 0.59 722.17
Ethylbenzene 0.01 10.23 Ethylbenzene 0.02 24.60
Xylenes 0.03 40.70 Xylenes 0.23 282.37
C8+ Heavies 0.42 493.77 C8+ Heavies 1 .53 1858.95
Total 100.0 Total _ 100.0
VOC Wt % 81.0 96447.78 VOC Wt % 75.3 92364.50
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Separator Venting Emissions Inventory
`Emission Factors Separator Venting
Uncontrolled Controlled
(lb/MMscf) (Ib/MMscf) Emission Factor Source
Pollutant
(Gas
Throughput) (Gas Throughput)
VOC 96447.78 4822.3890 Extended gas analysis
Benzene 710.9261 35.5463 Extended gas analysis
Toluene 722.1664 36.1083 HYSYS
Ethylbenzene 24.5959 1.2298 HYSYS
Xylene 282.3706 14.1185 HYSYS
n-Hexane 5759.0578 287.9529 Extended gas analysis
224 TMP 201.1409 10.0570 Extended gas analysis
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.0075 19.9463 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 19.9463 AP-42 Table 1.4-2 (PM10/PM.2.5)
i
SOx 0.0006 1.5747 AP-42 Table 1.4-2 (SOx)
NOx 0.0680 182.0360 AP-42 Chapter 13.5 Industrial Flares (NOx)
CO 0.3100 829.8700 AP-42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
_ PM10 0.0075 _ 7.4510 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 _ 0.0075 7.4510 AP-42 Table 1.4-2 (PM10/PM.2.5)
SOx _ 0.0006 0.5882 AP-42 Table 1.4-2 (SOx)
NOx 0.0980 98.0392 AP-42 Table 1.4-1 (NOx)
-
CO 0.0824 82.3529 AP-42 Table 1.4-1 (CO)
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 0.0 0.0 0.0 0.0 0.0 5
PM2.5 0.0 0.0 0.0 0.0 0.0 5
SOx 0.0 0.0 0.0 0.0 0.0 0
NOx 0.3 0.3 0.3 0.3 0.28 48
VOC 143.6 143.6 7.2 143.63 7.18 1220
CO 0.0 1.2 1.2 1.2 1.24 211
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 2117 2117 106 2117 106
Toluene 2151 2151 108 2151 108
Ethylbenzene 73 73 4 73 4
Xylene 841 841 42 841 42
n-Hexane 17153 17153 858 17153 858
224 TMP 599 599 30 599 30
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XVII.B, G Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XV11.8.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
sy
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? ; s' ` ;' SNin)
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? No
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? • • 8 . .
, ;
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
Section 08 - Technical Analysis Notes
As discussed in Section 04, the applicant provided both an extended gas sample from the VRT and a ProMax simulation. The scf/bbl factor to be used for the first 180 days until the meter is installed is based on the ProMax model. .
Applicant indicates that VRT gas is measured by a dedicated meter (i.e. only measures VRT gas to combustor) at the combustor inlet.
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Separator Venting Emissions Inventory
Emission factors calculated by applicant differ slightly from what is calculated in this analysis. As such, I will accept their values. The difference is due to rounding. Operator values are below:
Pollutant Uncont,oiled Controlled
NOx 194.18 194 18
CO 840.00 840.00
VOC 95753.36 4785 32
Benzene 705.48 35.27
To uen€ 716.63 35.83
Xylenes 28021 14 01
n-Hexane 5715 13 265 96
2,2,4-TMP 199 b0 9 98
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units
014 01 3-10-001 -60 Flares PM10 19.9 0 Ib/MMSCF
PM2.5 19.9 0 Ib/MMSCF
SOx 1.6 0 Ib/MMSCF
NOx 182.0 0 Ib/MMSCF
VOC 96. 47.8 95 Ib/MMSCF
CO 829.9 0 Ib/MMSCF
Benzene 710.9 95 Ib/MMSCF
Toluene 722.2 95 lb/MMSCF
Ethylbenzene 24.6 95 Ib/MMSCF
Xylene 282.4 95 Ib/MMSCF
n-Hexane 5759.1 95 Ib/MMSCF
224 TMP 201.1 95 Ib/MMSCF
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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 Re uirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
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 II.D.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ILD.1.a)? Yes `" Source Re
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 II.D.2)? Yes ;; Source Re
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? NO '' " Source is r
Source is not subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? WEM The contra
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e— Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, 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 to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend,""may""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 not establish legally binding requirements in and of itself.
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