HomeMy WebLinkAbout20190088.tiffCOLORADO
Department of Pulelic
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 18, 2018
Dear Sir or Madam:
RECEIVED
DEC 21 2018
WELD COUNTY
COMMISSIONERS
On December 20, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Wells Ranch AE08 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
i?LJ D Re_k ew
I!z/l9
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
cc:ACTP', M LLSS1,
NILSMlettl t /VA
l2/21/I2)
2019-0088
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Wells Ranch AE08 Econode - Weld County
Notice Period Begins: December 20, 2018
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: Wells Ranch AE08 Econode
Oil and gas exploration and production facility
SWNW Sec 8 T6N R62W
Weld County
The proposed project or activity is as follows:. Source is requesting to vent gas from an existing VRT
Separator to a flare and no longer route the gas to the pipeline.
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 18WE0723 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. Any such comment must be submitted in writing to the following addressee:
Carissa Money
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
RADO
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0723 Issuance:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Noble Energy, Inc.
Wells Ranch AE08 Econode
123/9B97
SWNW SEC 8 T6N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT
Separator
017
Venting of gas from a Vapor Recovery
Tower (VRT) Separator
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et 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 (the Division) no later than fifteen
days of the latter of commencement of operation or issuance of this permit, y
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation Number 3, Part B, Section 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 shall
I, COLORADO
Air Pollution Control Division
Dppvtitere Rdiae )4ngn 3,r r`, r Prt
Page 1 of 9
on. It is xser or op • responsibito self-
onditions = • demo ate ompliance ':ithin 180
t in ocati •f the •_ rmit. A f certi motion form and *•ance on
-certi a* lean f ., ed b e ` .....,, y be obta x - ;ine at
www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen 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. 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.
(Regulation Number 3, Part B, Section III. E. )
5. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
VRT Separator
017
---
---
17.1
2.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall
be determined on a rolling twelve (12) month total. By the end of each month a
twelve month total is calculated based on the previous twelve months' data. The permit
holder shall calculate actual emissions each month and keep a compliance record on
site or at a local field office with site responsibility for Division review.
COLORADO
Air Pollution Control Division
Page 2 of 9
7.
e emissio
issions co
the limit
acility
Equipment
ID
oint
of e
tabli
AIRS
Point
ble belo
as listed i
permi
(Regula
e opera a maintain with the
educe ssio to less th ` `or equal
Numb 3, Part B, Secti III.E.)
Control Device
Pollutants
Controlled
VRT
Separator
017
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT Separator
017
Gas Venting
5.1 MMSCF
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.
9. The owner or operator shall continuously monitor and record the volumetric flow rate
of gas vented from the VRT separator(s) to the flare using the flow meter. The owner
or operator shall 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
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g.
123/4567/001) shall be marked on the subject equipment for ease of identification.
(Regulation Number 3, Part B, Section III.E.) (State only enforceable)
11. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.5.)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
OPERATING Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
this per
plementa
CE TE
e O&M • ` I subject
Number 3ction II
Initial Testing Requirements
14. The owner/operator shall complete an initial site specific extended gas analysis
("Analysis") within one hundred and eighty days (180) after commencement of operation
or issuance of this permit, whichever comes later, of the natural gas vented from this
emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -
hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream.
Results of the Analysis shall 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 shall be submitted to the Division as part of
the self -certification and must demonstrate the emissions factors established through
the Analysis are less than or equal to, the emissions factors submitted with the permit
application and established herein in the "Notes to Permit Holder" for this emissions
point. If any site specific emissions factor developed through this Analysis is greater
than the emissions factors submitted with the permit application and established in the
"Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in
a timeframe as agreed to by the Division, a request for permit modification to address
this/these inaccuracy(ies).
15. The owner or operator shall 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, Sections XVII.B.2. and XVII.A.16)
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part
A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX 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.
COLORADO
Pollution Control vision
Page 4 of 9
nge in th a ow or opera facility, ocess, or
$3 p �r�. \xi y
ver n- `contrnt is ins
control egir ' .. . ' rep `- a' -' isting
• Whenever a permit limitation must be modified; or
enever a differ
equipment,
type of
• No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) 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 Number 3, Parts C and
D).
GENERAL TERMS AND CONDITIONS
18. 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.
19. 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.
20. 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.
21. 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.
22. 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
COLORADO
Air Pal 'ton Coattro L
Page 5 of 9
rmit, con
Division
fore the
on a per ontested '•wner or . rator, or
the own Y for of a rc ay requehearing
the Div r on's ac
23. -7-114. �..aC.R.:. that ,°°� e - �xr_d to file . j lution
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.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Carissa Money
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc. for venting of VRT
separator gas.
CO►LORADt
Air Pollution C zs#rs2I
Notes t s.,= ermit Hol at t--, iil this per +ce:
1) Th rmit hold, s re•=;E ed ay fees f3, e p -ssing ti ` for his permit ,:`n invoice
for :-se fe l be i� ed a the •tea` mit is d Th ` ermit holder s pay the
i in 30 da = eip oice. he invoic ult 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 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:
https: //www.colorado.gov/ pacific / cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon
the process limits as indicated in this permit. This information is listed to inform the
operator of the Division's analysis of the specific compounds emitted if the source(s) operate
at the permitted limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT
Separator
017
Benzene
71432
5,829
291
Toluene
108883
4,275
214
Ethylbenzene
100414
214
11
Xylenes
1330207
1,071
54
n -Hexane
110543
31,290
1,566
2,2,4-
Trimethylpentane
540841
1,613
81
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 017:
CAS #
Pollutant
Weight
Percent
of Gas
(%)
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
---
182.11
182.11
AP -42, Table
13.5-1
COLORADO
Air Poitutiotx. Control Division
Departront ar Row
Page 7 of 9
71432
Benzene
0.65
1146.5
57.326
CO
V
134
.0
So ,SYS)
Source (HYSYS)
108883
Toluene
0.47
840.71
42.036
Source (HYSYS)
100414
Ethylbenzene
0.03
42.117
2.1064
Source (HYSYS)
1330207
Xylene
0.12
210.58
10.528
Source (HYSYS)
110543
n -Hexane
3.49
6154.0
308.07
Source (HYSYS)
540841
2,2,4-
Trimethylpentane
0.18
317.21
15.860
Source (HYSYS)
Note: The controlled emissions factors for this point are based on the enclosed 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
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, HAPs
NANSR
Synthetic Minor Source of:
VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60,
Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
COLORADO
r Pollution Control Division
Page 8 of 9
63.1440-63.6175
Subpart QQQ - Subpart YYYY
Subpart z rt Z
. 200 E - S
MACT
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End _
Subpart NNNNN - Subpart XXXXXX
COLORADO
Pollution Control Division
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Carissa Moixey;,
Package #: 9:s3v43
Received Date: 0/'3/2018''
Review Start Date: 12/ri/2018
Section 01- Facility Information
Company Name: Noble energy, arc.
County AIRS ID: 123
Plant AIRS ID: eyy
Facility Name: wells R
Physical
Address/Location: SWNW quadrant of Section 8, Township 6N, Range 62W
County:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Carbon Monoxide (CO)
Weld:County
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
5,WNW,
bN
52.
Particulate Matter (PM) Ozone (NOx S VOC)
AIRs Point it
Emissions Source Type
Equipment Name
Emissions
Control?
Permit ft
Issuance 8
Self Cert
Required?
Action
Engineering
Remarks
333
parat0r rertng
VRT Separate -
;;;, yes
18WE0723
tmtisl
*es
` F
��
iiiiin
3
333 3
,,,,
v'�Ell �
���•o�.
$
3
Section 03 - Description of Project
Noble is requesting to remove an existing vapor recover
the pipeline.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? wxgng•;5ytstfietie
unit
- 3 33If(
vapor recovery tower (VRT) and r,4tv+t rOutetile crib
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? •,�
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here 502
Prevention of Significant Deterioration (P50)
Title V Operating Permits (OP)
SO2
NOx
CO VOC PM2.5 PM10 TSP HAPs
NOx
CO VOC PM2.5 PM10 TSP HAPs
tJ El
Colorado Air Permitting Project
Non -Attainment New Source Review (NANSR)-
� T
Separator Venting Emissions Inventory
017 Separator Venting
Facility AIRS ID:
123'.
County
97
Plan
Poin
Enclosed f?a
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Limit Throughput =
';':MMscf per year
MMscf per year
Requested Monthly Throughput = 0 MMscf per month
Potential to Emit (PTE) Throughput =
Equipped wah a VRU:
5 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBLo
liquids throughput:
Section 04- Emissions Factors & Methodologies
Weight %
Helium
CO2
N2
methane
ethane
propane
isobutane
n -butane
isopentane
n -pentane
cyclapentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
CBI -Heavies
IMMINSIEMIMA
OggNga4
0.18'.
0';47
2
Total
VOCWt%
99.99
76.07
Btu/sd
scf/bbl
b/Ib-rool
Displacement Equation
Ex=q"MW"xx/C
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
89477.5884
4473.8794
Benzene
Toluene
764.5645
552.8391
35.2876
141.1504
4105.1240
211.7256
38.2202
27.6420
1.7644
7.0575
Ethylbenzene
Xylene
n -Hexane
224 TMP
205.2562
10.5863
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
PM2.5
18.382
18.382
1.451
500
NOx
CO
167.756
764.770
Emission Factor Source
Emission Factor Source
Pilot Light Combustion
Rating
Pollutant
0.73 MMsd/yr
lb/MMscf lb/yr
tpy
VOC
5.5
4.015 0.002
5.548 0.003
5.548 0.003
0.438 0.000
PM10-
PM2.5
7.6
7.6
0.6
100
84
SOx
NOx
CO
73 0.037
61.32 0.031
3 of 6
K:\PA\2018\18 W E0723. CPixlsm
-SIffloator Venting Emissions Inventory
Section 05 - Emissions Inventory VOC Buffer
1.5
- Emissions include waste gas + pilot light
VOC and HAP emissions are mu tiplied by a buffer
Criteria Pollutants
-
Potentialto Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10, -.
PM25
Sox
NOx
VOC
CO
0.05
0.00
0.00
0.05
0.05
8
0.05
0.00
0.00
0.05
0.05.
8
0.00
0.00
0.00
0.00
0.00
- 1
0.43
0.00
0.00
0.5
0.5
79
227.47
0.00
0.00
341.2
17.1.
2898
1.94
0,00
0.00
2.0
2.0
335
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Source's values
Uncontrolled
(abs/year)
Controlled
(lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224-TMP
3887
0
0
5831
292
5,829
291
2811
0
0
4216
211
4,275
214
179
0
0
269
13
214
11
718
0
0
1077
54
1,371
54
20872
0
0
31308
1565
31,290
1,566
1077
0
0
1615
81
1,E13
81 .
Section 06 - Reeulatory Summary Analysis
Regulation 3, Parts A, e
Regulation 7, Section XVII.B, G
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
Source requires a permit
Source is not subject to Regulation 7, Section XVII.B.2, G
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
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 maybe appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific 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? Yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value In section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monimred process parameter is natural gas vented. The following questions do not require an answer.
4 of 6 K:\PA\2018\ 18WE0723.CP1.xlsm
Separator Venting -€missions Inventory
Section 08 - Technical Analysis Notes
I w 11. use source's cekies ri the peimit since they are slightly different than mine. There wasno regulate
fractured or recempleted after t/1/2014 She emailed me back stating no.
Section 09 - InventorySCCCodingandEmissions Factors
AIRS Point it
Process e SCC Code
017 01 - 3-10-001-60 Flares
or date provided on th
5of6
a Salgado w th Noble if any wells were newly seestructed,lsydraulically
'Adjusted to account for buffer andpilot. light. HAP EF are bas
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 - 19.47 - 0 Ib/MMSCF..-
PM2.5 19.47 0 lb/MMSCF
SOx 1.54.. 0 Ib/MMSCF.
NOx 182.11 0 Ib/MMSCF
VOC 134218 95 Ib/MMSCF'
CO. - 776.83 0 Ib/MMSCF
Benzene - 1146.5 95 lb/MMSCF
Toluene 840.71 - 95 Ib/MMSCF
Ethylbenzene 42.117 - 95 Ib/MMSCF
Xylene 210.58 95 Ib/MMSCF
n -Hexane 6154:0 95 Ib/MMSCF
224 TMP 317.21 95 Ib/MMSCF
•-K:\PA\2018\ 18WE0723.CP1xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Ra ulation 3 Parts A and B -APEN and Permit Requirements
Source is in the Nan -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 ll.D.le)?
2. Aretotal facility uncontrolled VOC emissions' greater than 5 TPY, NOn greater than lO TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Sectien 11.03)?
'Not enough Information
NON -ATTAINMENT
1. Are uncontrolled ernisslonsfrom any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Pat A, Section ll.D.1.x)?
2. Are total facility uncontrolled VOCemsslont from the greater than 2TPY, NOx greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section ll.D.2)?
'Source requires a permit •
Colorado Regulation 7, Section MI
1. Was thewell newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
'Source is not subject to Regulation 7, Section XV II.B.2, G
Section XVII.B,2 — General Provisions for Air Pollution Control Equipment and Prevention of emissions
Section XVILG - Emissions Control
Alternative Emissions Control (Optional Section) '
a. Is thisseparator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that Is not enclosed?
'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 Ad„ 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 `rocommend,"may,""should,'and "can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as }nusf" 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.
Y4/ S ce Req
id? ce Source Rey
f' . Source is n, -
The control
LDN
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
RCk, iF
NI2) UP
B Ta19
e 012
yree
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural 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. 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 at:
www.colorado.gov/cdphe/apcd.
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:
(0C C3t13
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: VRT Separator
014-
123 /9B97/TBD-
TBD-
AIRS
AIRS ID Number:
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: WELLS RANCH AE08 ECONODE T6N-R62W-S8 LO1
Site Location: SWNW SEC8 T6N R62W
Mailing Address: 1625 Broadway, Suite 2200
(Include Zip Code)
Denver, CO 80202
E -Mail Address': janessa.salgado@nblenergy.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Janessa Salgado
Phone Number: 303-228-4196
'Please 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 APCD via e-mail to the address provided.
Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017
383941
COLORADO
A 1V',
Permit Number:
AIRS ID Number: 123 / 9B97/ TBD ,;
[Leave blank unless APCD has already assigned a permit # and MRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.501, -104.3558
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp-
CF)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
0 Upward with obstructing raincap
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
%
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating:
Type: VOC Burner
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95 %
Waste Gas Heat Content
Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating
Btu/scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
COLORADO
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
Permit Number:
AIRS ID Number: 123 / 9B97i TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? O Yes ❑ No
efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO.
VOC
VOC Burner
95%
CO
HAPs
VOC Burner
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:
r
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
'Actual Aual Emissions
nn
Requested Annual Permit`_-
Emissionitmtt(s)5
`"' ii
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
. Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
7.60
Ib/mmscf
HYSYS/AP-42
0.00
0.00
SOX
0.60
Ib/mmscf
HYSYS/AP-42
0.00
0.00
NO.
0.1821
lb/mscf
HYSYS/AP-42
-
0.46
0.46
VOC
134.2425
lb/mscf
HYSYS/AP-42
341.88
17.10
CO
0.7768
lb/mscf
HYSYS/AP-42
1.98
1.98
Benzene
1.1445
lb/mscf
HYSYS/AP-42
2.91
0.15
Toluene
0.8392
lb/mscf
HYSYS/AP-42
2.14
0.11
Ethylbenzene
Xylenes
0.2102
lb/mscf
HYSYS/AP-42
0.54
0.03
n -Hexane
6.1431
lb/mscf
HYSYS/AP-42
15.64
0.78
2,2,4-0.3167
Trimethylpylpentane
lb/mscf
HYSYS/AP-42
0.81
0.04
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
pqi COLORADO
5 Cam.
1![]1T b Envuun.nen�
Permit Number:
AIRS ID Number: 123 /9B97/ TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
A Sc ao\& 06/14/2018
Si nature of Legally Authorized Person (not a vendor or consultant) Date
Janessa Salgado
Environmental Engineer
Name (please print)
Title
Check the appropriate box to request a copy of the:
�✓ Draft permit prior to issuance
E Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
Form APCD-211 -Natural Gas \,/nting APEN - Rev 03/2017
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
6 Pie
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