HomeMy WebLinkAbout20192222.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
May 30, 2019
Dear Sir or Madam:
RECEIVED
a l a to 281(,)
WELD COUNTY
COMMISSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc - Wells Ranch USX AA 13-67. 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 arerequired 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
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
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2019-2222
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc - Wells Ranch USX AA 13-67 - Weld County
Notice Period Begins: June 6, 2019
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 USX AA 13-67
Exploration Et Production Well Pad
NWNW Quadrant of Section 13, Township 6N, Range 63W (Weld County)
Weld County
The proposed project or activity is as follows: Noble Energy is requesting to remove the existing VRU at the
Wells Ranch USX AA 13-67 facility and instead send low pressure gas from the separator to a combustor.
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 18WE0989.CP1 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:
James Ricci
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
'!' COLORADO
ditIV .001 6 RUMo
ADO
Contra
ltc Healt
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0989
X
Noble Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Wells Ranch USX AA 13-67
123/9964
NWNW Quadrant of Section 13, Township 6N, Range 63W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control
Description
008
Venting of low the pressure natural gas
from the separator
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq),
to this specific general terms and conditions included in this document and the following
specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days of the latter of commencement of operation or issuance of this permit,
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
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
COLORADO
Air Pollution Control Division
Department of Pune Hea}tn 6 Environment
Page 1 of 9
in of the pe elf certi orm and • ance on
tify p. = e as req is perm ma be obtainer, •nline at
.gov/ he/. •ermit- ` if-certi tion. ulation NumbePart B,
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. Within one hundred and eighty days (180) after issuance of this permit, the operator
shall install a flow meter to monitor and record volumetric flow rate of natural gas
vented from each separator covered by this permit. Until the flow meter is installed,
the operator shall 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 283 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.
(Regulation Number 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. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
008
--
0.5
20.6
2.2
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 new
twelve month total is calculated based on the previous twelve months' data. The permit
COLORADO
Air Pollution Control Division
Department of Rum 4ealthb Environment
Page 2 of 9
missions •nth and • 3 omplianccord on
ith site r , y for Di ion view.
8. a emis point,w shall opera and maintain with the
m,_ A.�
control m°• � � -nt .��� •rder . �c- - ons to les equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
008
The low pressure gas is routed to an
Enclosed Combustor
VOC and 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. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
AIRS
Point
Process Parameter
Annual Limit
008
Natural Gas Venting
6.4 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.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor
and record the volumetric flow rate of natural gas vented from the separator(s) 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
11. 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)
12. 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.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
COLORADO
Air Pollution Control Division
Department of Rtb Hea;tn & Enwonment
Page 3 of 9
NAN EMENT
14. p of , mr coin per or �� m.. q. �.,. Ft,..o follow th �� � � ecent
operating and maintenance (OEM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the O&M plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. 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 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).
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare
for one continuous hour. (Regulation Number 1, Section II.A.5)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. 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:
COPHE
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
COLORADO
Air Pollution Control Division
Department of Public Health F Environment
Page 4 of 9
pounds (, nitrogen Kati • .ources (NC in ozone
emitting le00 ton V or NO. ' year, a
T" x:
emissi •F of one ton pe -ar or more or fi percent,
ever er, ,�_ vel r • . st APEN;
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. 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
20. 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.
21. 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.
22. 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
COLORADO
Air Pollution Control Division
Department of Public Hen;tn & Environment
Page 5 of 9
only for quipmentperations activity
ermit.
23. :m less s. - catty - ed o ise, : e gener ; nd spy fic conditions c ained in
it have r: - .'^-ter : W ' e AP - ry to assn `"r liance
with the provisions of Section 25-7-114.5(7)(a), C.R.S.
24. 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.
25. 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.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
James Ricci
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc. for venting the
low-pressure separator gas at a synthetic
minor facility in the non -attainment area.
COLORADO
Air Pollution Control Division
Department of Rubltc Health 6. Environment.
Page 6 of 9
Notes t Holy at t this perm dt ce:
1) Th -rmit hold „q; s re' ed ay fees f u ` e p - ssing ti p for "his permit
for se fe l be i:; : ed a the • mit is is d Th .rt ermit holder s
in 30 da r " eip ..:_ voice. �, ; , r_
� � �� - � he invoic
revocation of this permit. (Regulation Number 3, Part A, Section VI.B.)
n invoice
pay the
ult in
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/ cd phe/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.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
008
Benzene
71432
5220
261
Toluene
108883
4865
243
Ethylbenzene
100414
239
12
Xylenes
1330207
1475
74
n -Hexane
110543
29035
1452
2,2,4-Trimethylpentane
540841
1327
66
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.
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Page 7 of 9
5) The ission le
Poi `'008:
ed on the • • k g emissio ctors:
CAS #
.minco _
Emission
Factors
(lb/MMSCF)
trolled
Emission
Factors
(lb/MMSCF)
Source
Pollutant
NOx
150.15
AP -42
(Flares)
CO
684.50
VOC
128625.69
6431.28
Low
Pressure
Liquid
sample
modeled in
HYSYS
71432
Benzene
814.78
40.74
108883
Toluene
759.31
37.97
100414
Ethylbenzene
37.35
1.87
1330207
Xylene
230.18
11.51
110543
n -Hexane
4531.90
226.59
540841
2,2,4-Trimethylpentane
207.11
10.36
Note: The controlled emissions factors for this point are based on the enclosed combustor
control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 120 °F
and separator pressure of 42.2 psia.
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, n -Hexane
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.Qov/
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
COLORADO
Air Pollution Control Division
Deuartovnt of Public Head't b Environment
Page 8 of 9
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
ous Air s for Sou
63.59 ubpary.-A - Subp Z
63.600-6
A - Su
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
COLORADO
Air Pollution Control Division
Depart 'it of Publtt Health & Environment
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: James Ricci
Package #: 387244
Received Date: 9/4/2018
Review Start Date: 1/25/2019
Section 01 - Facility Information
Company Name: Noble Energy, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
13
6N
63
Plant AIRS ID:
Facility Name:
Location:
County:
Type of Facility:
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? !I Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
9964
Wells Ranch USX AA 13-67
NWNW Quadrant of Section 13, Township 6N, Range 63W
Weld County
Exploration & Production Well Pad
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point t#
Emissions Source Type
Equipment Name
Emissions
Control?
Permit tt
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
008
Separator Venting
Yes
18WE0989.CP1
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Noble Energy is requesting to remove the existing VRU at the Wells Ranch USX AA 13-67 facility and instead send low pressure gas from the separator to a combustor.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Yes
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?
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)
No
Yes
SO2 NOx
Is this stationary source a major source? No
If yes, explain what programs and which pollutants her€ SO2 NOx
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
CO VOC PM2.5 PM10 TSP HAPs
i
•
CO VOC PM2.5 PM10 TSP HAPs
i _
J
Separator Venting Emissions Inventory
008 Separator Venting
Facility AIRs ID:
123
County
9964 008
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Low Pressure gas from one well is sent from the seperator to the enclosed combustor
Limited Process Parameter
Gas meter
Enclosed Combustor, 95% Manufacturer Guaranteed Control Efficiency (Make/Model TBD)
Natural Gas Vented
Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
IRequested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
6.40678
6.40678
6.40678
MMscf per year
MMscf per year Requested Monthly Throughput =
1 MMscf per month
MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Pilot Light Combustion
Section 04 - Emissions Factors & Methodologies
2208
0
0.5
Description
Btu/scf
scf/bbl
Mscf/day
The LP liquid stream was input into HYSYS and the corresponding vapors in equilibrium were pulled out as a separate stream. These vapors were then added to the LP stream at a higher pressure (representative of HP pressure)
until saturation. This stream was then used as the surrogate HP stream. The LP stream at this location is at a slightly different T&P to the stream where the sample was pulled, as such the LP does not match exactly.
The applicant converted from mole % to mass flow; however, the HYSYS report only includes z. significant figures for the mass % and the spreadsheet directly consumes the mole % from HYSYS with 15 significant figures and then
is converted directly to mass flow using the appropriate scientific/engineering calculations.
Since this well is currently shut in, this methodology was accepted. The applicant added a 50% buffer onto the emissions to account for any variation. Part of initial permit compliance will include taking a gas sample from the well
at this facility and validating the emission factors.
MW
43.31
Ib/Ib-mol
Displacement Equation
Ex=Q*MW*Xx/C
Weight %
(From HYSYS)
Ib/Ib-mol
Molecular Weight
Mole % (From
HYSYS)
Helium
0.00
0.00
4.00
0.000
CO2
1.93
0.84
44.01
1.900
N2
0.92
0.39
28.01
1.410
methane
4.62
2.00
16.04
12.470
ethane
17.50
7.58
30.06
25.200
propane
33.45
14.48
44.09
32.850
isobutane
5.08
2.20
58.12
3.780
n -butane
15.28
6.61
58.12
11.380
isopentane
2.74
1.19
72.11
1.650
n -pentane
3.19
1.38
72.11
1.920
cyclopentane
0.96
0.41
70.13
0.590
n -Hexane
2.64
1.15
86.18
1.330
cyclohexane
0.94
0.41
84.16
0.490
2-Mpentane
5.65
2.45
86.18
2.840
heptanes
1.88
0.81
100.21
0.810
methylcyclohexane
0.96
0.41
98.19
0.420
224 -IMP
0.12
0.06
114.23
0.050
Benzene
0.48
0.20
78.12
0.260
Toluene
0.44
0.19
92.15
0.210
Ethylbenzene
0.02
0.01
106.17
0.010
Xylenes
0.13
0.05
106.17
0.050
n -Octane
0.67
0.30
114.23
0.260
n-Nonane
n-Decane
0.24
0.10
128.25
0.080
0.16
0.07
142.29
0.050
Total
100.01
43.31
VOCWt%
75.04
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/MMscf) (la/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
128625.6941
6431.2847
HYSYS + 50% Buffer
HYSYS + 50% Buffer
HYSYS + 50% Buffer
HYSYS + 50% Buffer
HYSYS + 50% Buffer
HYSYS + 50% Buffer
HYSYS + 50% Buffer
Benzene
814.7829
40.7391
Toluene
759.3087
37.9654
Ethylbenzene
37.3498
1.8675
Xylene
230.1765
11.5088
n -Hexane
4531.8975
226.5949
224 TMP
207.1127
10.3556
Primary Control Device
Uncontrolled Uncontrolled
2ot5
K:\PA\2018\18WE0989.CP1.xlsm
Separator Venting Emissions Inventory
Pollutant
(Ib/MMBtu) lb/MMscf
Emission Factor Source
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
16.452
AP -42 Table 1.4-2 (PM10/PM.2.5)
PM2.5
0.0075
16.452
AP -42 Table 1.4-2 (PM10/PM.2.5)
SOx
0.0006
1.299
AP -42 Table 1.4-2 (SOx)
NOx
0.0680
150.149
AP -42 Chapter 13.5 Industrial Flares (NOx)
CO
0.3100
684.504
AP -42 Chapter 13.5 Industrial Flares (CO)
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
NOx
100.000
AP -42 Table 1.4-1 (NOx)
AP -42 Table 1.4-1 (CO)
CO
84.000
Criteria Pollutants
Potential to 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
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.05
0.05
0.05
0.05
0.05
9
0.05
0.05
0.05
0.05
0.05
9
0.00
0.00
0.00
0.00
0.00
1
0.50
0.50
0.50
0.50
0.50
85
412.04
412.04
20.60
412.0
20.6
3500
2.21
2.21
2.21
2.21
2.21
375
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
5220
5220
261
5220
261
4865
4865
243
4865
243
239
239
12
239
12
1475
1475
74
1475
74
29035
29035
1452
29035
1452
224 TM P
1327
1327
66
1327
66
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 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
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.
No
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific 2,21 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 :ons per year? No
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 :his 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?
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 monitored process parameter is natural gas vented. The fol owing questions do not require an answer.
3 of 5
K:\PA\2018\18W E0989.CP_.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Noble Energy submitted a liquid sample taken from the Wells Ranch AE 18-62-1HN and Wells Ranch AE 18-62-1HN taken on May 1st 2013. This sample was analyzed by Empact Analytical Systems Inc on May 3rd 2013. The sample was
taken from a well approximately 1.25 miles away from the facility requesting to be permitted. The applicant will have 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 applicat on.
HYSYS was used to estimate the gas stream being vented. Since the gas is being vented directly from the separator, an upstream liquid sample was unable to be taken A high pressure surrogate stream was estimated based on this liquid
sample. The gas stream could them be estimated from this surrogate stream in HYSYS. Since the well is currently shut in, this method of estimation was accepted. The applicant has added a 50% buffer to the emissions factors to account
for this approach. The site -specific gas sample will confirm the emission factors once the well is put back online.
The HYSYS report only includes 4 significant figures for the mass % but the applicant's spreadsheet directly consumes the mole % from HYSYS with 15 significant figures and then is converted directly to mass flow using the appropriate
scientific/engineering calculations. Because of this, the applicant's mass % were accepted as they carried many more significant figures than the Division could calculate with a HYSYS report.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
008
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 16.45 0 lb/MMSCF
PM2.5 16.45 0 lb/MMSCF
SOx 1.30 0 lb/MMSCF
NOx 150.15 0 lb/MMSCF
VOC 128625.69 95 lb/MMSCF
CO 684.50 0 lb/MMSCF
Benzene 814.78 95 lb/MMSCF
Toluene 759.31 95 Ib/MMS _F
Ethylbenzene 37.35 95 lb/MMSCF
Xylene 230.18 95 lb/MMSCF
n -Hexane 4531.90 95 lb/MMSCF
224 TMP 207.11 95 lb/MMSCF
4 of 5 K:\PA\2018\18WE0989.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Nor -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 S TPY, NOx greater than 10 TPY or CO emissions greater than 10 WY (Regulation 3, Part B, Section II.D.3)?
Not enough information
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)?
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 8, Section II.D.2)?
Source requires a permit
Yes
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Source is not subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Preventior 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?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Yes
Section XVII.B.2.e - Alternative emissions control equipment
Disclaimer
This document assists operators with determinirg 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 ooes not establish legally binding requirements in and of itself.
No
Source Req
Source Req
Source is nu
The contro
,^`120..18
May 20, 2013
Rev 0
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and applic .
updates. An application with missin
longer application processing times
incorrectly or is missing informatio
This APEN is to be used for gas vent
casing, pneumatic pumps, blowdow
category, there may be a more spe(
loading, condensate storage tanks,
specialty APEN options will not sati; -
Air Pollution Control Division (APCD) vveuwie ai..
o`, n'i . 0
ce,x\Ki20
and existing facilities, including APEN
mplete and may be returned or result in
DEN fee if the APEN is filled out
s from gas/liquid separators, well head
emission unit does not fall into this
sweetening unit, hydrocarbon liquid
Form APCD-200) is available if the
-- • • • . l'vailable APEN forms can be found on the
vvww.Luiui auu.uvi Luplie/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: /'WEO9 q AIRS ID Number: 123 /9964 / G'€✓5
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: Wells Ranch USX AA 13-67
Site Location:
NWNW S13 T6N R63W
Mailing Address: 1625 Broadway, Suite 2200
(Include Zip Code)
Denver, CO 80202
Site Location Weld
County:
NAICS or SIC Code: 1311
Contact Person: Shaun Higgins
Phone Number: 720-587-2459
E -Mail Address2: shaun.higgins@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.
387242
Form APCD-211 - Gas Venting APEN - Revision 7/2018
;COLORADO
1 I 6j . :nf��f
A. I 1b3n Mhb P.mNmmmrt.fl
Page 6 of 20
May 20, 2013
Rev 0
Permit Number: AIRS ID Number:
123 /9964/
[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 O Change company name3 O Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 O 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: Combustion of LP Gas
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
❑✓ Yes
O Yes
Yes
❑ No
❑✓ No
$'No
16\ Ott trot
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
2 I A.. liaahl�. ii Envimmml
Page 7 of 20
May 20, 2013
Rev 0
Permit Number: AIRS ID Number: 123 / 9964 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
O Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
2208 08
BTU/SCF
Heating Value:
Requested:
6.40678
MMSCF/year
Actual:
NA
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
43.3433
VOC (Weight %)
75.05
Benzene (Weight %)
0.48
Toluene (Weight %)
0.44
Ethylbenzene (Weight %)
0.02
Xylene (Weight %)
0.13
n -Hexane (Weight %)
2.64
2,2,4-Trimethylpentane (Weight %)
0.12
Additional Required Information:
O Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
El
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
Av COLORADO
E,
Page 8 of 20
May 20, 2013
Rev 0
Permit Number:
AIRS ID Number: 123 / 9964 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitudellongitude or UTM)
40.4906, -104.3931
Operator'
Discharge,Height :.t
Velocity
(fe/sec)
-
-`..
Temp.
r
-
Flow Rate
�t)
WEA)
Above Ground Level
(Ft.... t...:.
ee-
Stack ID No� � .:.
the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
0 Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
MMBtu/hr
Make/Model:
95
95
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: O Yes O No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
4I
(COLORADO
SAMI^_n:it smolt
Page 9 of 20
May 20, 2013
Rev 0
Permit Number:
AIRS ID Number: 123 / 9964 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction ):
Pollutant
Description of Control Method(s) ...___•; : ,
Overall Requested
; Control Efficiency_- ,
(%reduction in emissions )
PM
SOX
NO.
CO
VOC
Enclosed Combustor
95
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
—_ ' '_ : {ritena_PolGutant= Emission- nYentgry_.:.:._..._::.._.... __..._.:.. : __ .._... _r.
Pollutant:..
=`'
. : -...
:: ,' Emission Factor- • : "
=---• qe .e
Emission
" . Actual Annual Emissions __ .
•
.. ..
........... . .
'- Source -
Uncontrolled=
.:_ Emissiohs _
Controlled,..
'
,.: Emissions.:. -
•_...__
> Uncont olled
1 Controlled- I
Uncontrolled!'
.r .
Bassist.
..
., < Units .
___—..__
.,_ . {AP 42,_..I _
S MN etc.);
fg:,-
.- . Emissions:, :
_ . _..._ ..
tons! ear ,
( Y.. )
] :_ Emissions.
: (ions/ ear
Y )
{tons/ ear
- -- ----.-Y )
._ _.
(tons/ ear
y )
PM
I
SOx
I
NO.
100, 0.068
Ib/MMSCF,Ib/MMBIu
AP -42
0.50
0.50
CO
84, 0.31
Ib/MMSCF,Ib/MMBIu
,112
2.21
2.21
VOC
5.5, 128.7202
IbMMSCF, Ib/mscr
AP-42/HYSYS
412.3`f
20.62
• Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name I
_ _.__._..._ _ . _u
Chemical
Abstract
,Service (CAS.
- ( }
Number ;
._____ ___.—
_Emission Factor..... - .
•
Actual Annual Emissions .. i
—
iUncontrolled :
_._. _ ..
Basis
:.-......_..sis
. _...,..
Units :
source
. P 2,
(AP -42, )
M etc.
fg•,._
Uncontrolled
-..-.-- Uncontrolled_
_ Emissions
- �
ounds/ear
(P . Y. )
Controlled
-_.... Controlled
Emissions
— -- —....I
- ----- - --
(Pounds/year)
Benzene
71432
0.8148
Ib/MSCF
HYSYS/AP42
5 4'-0
26
Toluene
108883
0.7593
Ib/MSCF
HYSYS/AP42
U t 11oS
141
Ethylbenzene
100414
0.0373
Ib/MSCF
HYSYS/AP42
',lil 9
II
Xylene
1330207
0.2302
Ib/MSCF
HYSYS/AP42
1, 9les
'i-
n -Hexane
110543
4.5319
Ib/MSCF
HYSYS/AP42
11 01 S
\LISel-
2,2,4-
Trimethylpentane
540841
0.2071
Ib/MSCF
HYSYS/AP42
13•1-4..
V1/4.
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
5 I A
COLORADO
L•c«rtv 7;v7 :E.bc
Page 10 of 20
May 20, 2013
Rev 0
Permit Number: AIRS ID Number:
123 /9964/
[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.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Shaun Higgins Air Permitting Supervisor
Name (please print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
o 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:
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
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
or visit the APCD website at:
httos://www.colorado.Rov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
6 I AVCOLOR&DO
_ ,.'a'"` li. 1."v E� '
Page 11 of 20
5/17/2019 State.co.us Executive Branch Mail - Gas Venting APEN - Wells Ranch USX AA 13-67, AIRS ID 123/9964
1. Do you have the full HYSYS report that includes the input stream? Sorry if I missed it, I couldn't find the
inputs it at first glance. I've attached it to this email, let me know if you have any questions! I would
anticipate you might as the inlet for this facility was created by proxy from a nearby facility. The reason for
this is that the facility has been shut in for quite some time and won't be re -started until after this permitting
action is completed. As such we pulled a sample from a nearby facility and saturated it to the current HP
line pressure at this location to generate conservative estimates of flash emissions. We have used this
approach several times before; however, understandably there are often questions along the way.
2. Section 7: I am calculating 13.7 tons of VOC, controlled. If the 20.62 tpy of VOC is a typo on the APEN,
I will redline the APEN to show 13.7 tpy with your permission. The 20.62 intentionally included a 50%
conservative factor from calculated emissions; This is reflected in the lb/MSCF factors on the APEN as well.
The reason we took this approach is that historically permits have required us to sample these streams and
revise APENs if lb/MSCF factors calculated based on the sample pulled exceed what is reported on the
APEN. We added this 50% conservative factor in an effort to avoid future APEN revisions.
3. Section 7: The HAPs seem to be missing from the table. I calculated the following using weight
percentages directly from HYSYS. I think you may have used mole percentages and converted to weights
which may be why my numbers slightly differ than the calculation sheet? If you approve, I will redline the
APEN with these values
Actual Emissions
Hazardous Air Pollutants
Uncontrolled Controlled
(I ls/yea r) Cabs/}year)
Benzene
3514
176
Toluene
3221
161
Ethylbenzene
146
7
Xylene
952
48
n -Hexane
19328
466
224 TRIP
879
44
I think you're likely correct that the reason for the difference in your calculated emissions and ours is due
to rounding error; however, if you are amenable I would prefer we use the values reported on the
calculation sheet. You are correct that we converted from mole % to mass flow; however, the HYSYS
report only includes 4 significant figures for the mass % and the spreadsheet directly consumes the mole
% from HYSYS with 15 significant figures and then is converted directly to mass flow using the
appropriate scientific/engineering calculations. I would prefer to avoid reporting any lower numbers than
appear on our calculation sheet if at all possible.
4. Do you have an O&M Plan for the combustor? Any update on Make/Model/Size since the time of APEN
submittal? I have attached an O&M plan for your review. With respect to the Make/Model/Size of the
combustor, this is information that we have available; however, it has been our practice historically with
other permits to avoid listing a specific make/model/size in the case that the combustor needed to be
replaced for some reason we would to re -permit the burner and be unable to operate our facility when there
is not a material difference in the emissions from the separator if the burner were to be replaced. I do know
that it is a 48" combustor, not sure if this helps. Let me know what you think.
5. Is there a simple process diagram or description available for this facility? I want to make sure I
understand the process as much as possible. The VRT still exists? There is not and has never been a VRT
at this location. This location is similarly named to an econode, which does have a VRT if that is a potential
source of confusion.
6. Is the gas being vented coming from any wells constructed, hydraulically fractured, or recompleted on
or after August 1, 2014? (Reg 7 XVII.G. Applicability) No, there is only one well on location and if was last
completed in May 2012.
Thanks Again!
James Ricci
„ - _., t.. i., ca4774A kons.., ts.acarrh=aIIRnarmthid=thraad-a%3Ar1690708148876516661&simpl=msg-a%3Ar-84191886... 4/9
5/17/2019
Permit Engineer
State.co.us Executive Branch Mail - Gas Venting APEN - Wells Ranch USX AA 13-67, AIRS ID 123/9964
COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/ap-cd
[Quoted text hidden]
2 attachments
HYSYS-Inlet Stream.pdf
35K
LP Flare O&M.docx
24K
Ricci - CDPHE, James <james.ricci@state.co.us> Fri, Feb 8, 2019 at 11:26 AM
To: Shaun Higgins <Shaun.Higgins@nblenergy.com>
Thank you Shaun. A couple follow-up comments:
1. Regarding the way HYSYS is modeling, I think I understand. I assume the LP Liquid stream matches the lab
analysis provided in terms of Mole% and the HP Liquid was back calculated based on that temp/pressure input?
2. I hate to be a pain but the Division has become strict on using the most updated O&M Plan templates. I attached
the separator one here, below is the link to all of them for use in the future. Can you please fill this one out and
return it to me?
https://www.colorado.gov/Pacific/cdPhe/aidoil-and-gas-index
3. It seems like only the 50% buffer was applied to the controlled VOC emissions which caused the confusion. With
your permission, I would like to redline the APEN as follows. We can use the numbers on the calculation sheet:
Change FROM
Change TO
VOC Uncontrolled Requested
274.89 tpy
412.34 tpy
Benzene Uncontrolled Actual
Blank
5220 lb/yr
Benzene Controlled Actual
Blank
261 lb/yr
Toluene Uncontrolled Actual
Blank
4865 lb/yr
Toluene Controlled Actual
Blank
243 lb/yr
Ethylbenzene Uncontrolled Actual
Blank
239 lb/yr
Ethylbenzene Controlled Actual
Blank
12 lb/yr
Xylene Uncontrolled Actual
Blank
1475 lb/yr
Xylene Controlled Actual
Blank
74 lb/yr
n -Hexane Uncontrolled Actual
Blank
29035 lb/yr
n -Hexane Controlled Actual
Blank
1452 lb/yr
224-TMP Uncontrolled Actual
Blank
1327 lb/yr
224-TMP Controlled Actual
Blank
66 lb/yr
hi+nc•//mniI nnnnIp nnm/mail/u/02ik=5517734b80&view=pt&search=all&permthid=thread-a%3Ar1690708148876516661 &simpl=msg-a%3Ar-84191886... 5/9
5/17/2019 State.co.us Executive Branch Mail - Gas Venting APEN - Wells Ranch USX AA 13-67, AIRS ID 123/9964
Thanks, have a good weekend!
James Ricci
Permit Engineer
COLORADO
Air Pollution Control Division
Department of Public Health a Environment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/aped
[Quoted text hidden]
OG SEP OM PLN TMPL.DOCX
130K
Shaun Higgins <Shaun.Higgins@nblenergy.com> Tue, Feb 12, 2019 at 4:51 PM
To: "Ricci - CDPHE, James" <james.ricci@state:co.us>
Hey James,
See my responses below, thank you for your work!
Shaun Higgins
1625 Broadway, Suite 2200
Denver, CO 80202
Office: 720.587.2459 I Cell: 303.898.2897
shaun.higgins@nblenergy.com I www.nobleenergyinc.com
noble
i energy
From: Ricci - CDPHE, James <james.ricci@state.co.us>
Sent: Friday, February 8, 2019 11:27 AM
To: Shaun Higgins <Shaun.Higgins@nblenergy.com>
Subject: EXTERNAL: Re: Gas Venting APEN - Wells Ranch USX AA 13-67, AIRS ID 123/9964
Thank you Shaun. A couple follow-up comments:
1. Regarding the way HYSYS is modeling, I think I understand. I assume the LP Liquid stream matches the lab
analysis provided in terms of Mole% and the HP Liquid was back calculated based on that temp/pressure
input? This is close. The LP liquid stream was input into HYSYS and the corresponding vapors in equilibrium were
pulled out as a separate stream. These vapors were then added to the LP stream at a higher pressure
(representative of HP pressure) until saturation. This stream was then used as the surrogate HP stream. The LP
stream at this location is at a slightly different T&P to the stream where the sample was pulled, as such the LP
does not match exactly; however, it would be our expectation that it would be very close.
2. I hate to be a pain but the Division has become strict on using the most updated O&M Plan templates. I attached
the separator one here, below is the link to all of them for use in the future. Can you please fill this one out and
return it to me? Not being a pain at all, I've attached the updated O&M plan.
httnc•//mail nnnnla rnm/mail/u/0?ik=5517734b80&view=ot&search=all&oermthid=thread-a%3Ar1690708148876516661 &simpl=msg-a%3Ar-84191886... 6/9
5/17/2019 State.co.us Executive Branch Mail - Gas Venting APEN - Wells Ranch USX AA 13-67, AIRS ID 123/9964
https://www.colorado.gov/pacific/cdphetair/oil-and-gas-index
3. It seems like only the 50% buffer was applied to the controlled VOC emissions which caused the confusion. With
your permission, I would like to redline the APEN as follows. We can use the numbers on the calculation sheet:
Sorry for the confusion, works for me.
[Quoted text hidden]
[Quoted text hidden]
Shaun Higgins <Shaun.Higgins@nblenergy.com> Tue, Feb 12, 2019 at 4:52 PM
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Would have been good to include the attachment.
Shaun Higgins
1625 Broadway, Suite 2200
Denver, CO 80202
Office: 720.587.2459 I Cell: 303.898.2897
shaun.higgins@nblenergy.com I www.nobleenergyinc.com
" , noble
i energy
[Quoted text hidden]
OG SEP OM PLN TMPL.DOCX
138K
Ricci - CDPHE, James <james.ricci@state.co.us> Tue, Apr 16, 2019 at 2:39 PM
To: Shaun Higgins <shaun.higgins@nblenergy.com>
Hi Shaun,
I attached a draft of the permit for your review before public comment. Also, I need permission to redline Section 3 of the
APEN. You noted earlier this seperator is not subject to Reg 7 XVII.G. so wanted to correct the APEN since the "yes"
mark is checked for this regulation.
Thanks,
James Ricci
Permit Engineer
COLORADO
Air Pollution Control Division
Department of Public Health & Enveonment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
On Mon, Jan 28, 2019 at 9:08 AM Ricci - CDPHE, James <james.ricci@state.co.us> wrote:
[Quoted text hidden]
2 attachments
18WE0989.CP1 PA - DRAFT.pdf
httnc.//mail nnnnla rnm/mail/u/n?ik=F517734hR0&view=nt&search=all&oermthid=thread-a%3Ar16907081.48876516661&simol=msa-a%3Ar-84191886... 7/9
Hello