HomeMy WebLinkAbout20192300.tiffCOLORADO
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
June 11, 2019
Dear Sir or Madam:
RECEIVED
WELD COUNTY
COMMISSIONERS
On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - Wells Ranch BB11 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
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
OCn ( SY-1 / 19
Cc PLC -VP), T),
Pw(£RICH/Z3 r)iCK)
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2019-2300
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Wells Ranch BB11 Econode - Weld County
Notice Period Begins: June 13, 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 BB11 Econode
Exploration Et Production Well Pad
SWNW S11 T5N R63W
Weld County
The proposed project or activity is as follows: This project was to install and operate 3 natural gas RICE
engines (point 001 was permitted through the general permit 02 process) and permit the venting of flash gas
from the knock out scrubber, which is controlled by an enclosed combustion device. One of the engines was
cancelled prior to the issuance of this permit and is not included in the permit and permit analysis.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0830 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:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
iE3
1 i
COLORADO
Air Pollution Control Division
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0830
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Noble Energy Inc.
WELLS RANCH BB11 ECONODE
123/9FE1
SWNW SEC 11 T5N R63W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
ENG-
EEPOG301907*
002
One (1) Doosan (PSI), Model D8.1L, Serial
Number EEPOG301907, natural gas -fired,
naturally aspirated, 4SRB reciprocating
internal combustion engine, site rated at
236 horsepower. This emission unit is
used for power generation.
Air -fuel ratio
control/Non-
selective catalytic
reduction system
Enclosed
Burner
004
Flash Gas from 2 -Phase Separator known
as Condensate Knock out Scrubber
Enclosed Combustion
Device
*This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Doosan (PSI) D8.1L engine in accordance with the permanent
replacement provision of the Alternate Operating Scenario (AOS), included in this permit as
Attachment A.
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.
Page 1 of 16
COLORADO
Air Pollution Control Division
£t F .ni•,,nc
Dedicated to protecting and improving the health and environment of the people of Colorado
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
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, by 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 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit 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. Point 002: The following information shall be provided to the Division within fifteen (15) days
of the latter of commencement of operation or issuance of this permit.
• manufacture date
• construction date
• order date
• date of relocation into Colorado
• manufacturer
• model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
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.
Page 2 of 16
COLORADO
Mr Pollution Control Division
]3T'Tl [ Cr I. ",C_ 1-frafth
Dedicated to protecting and improving the health and environment of the people of Colorado
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:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
ENG-
EEPOG301907
002
---
2.3
1.6
4.6
Point
Enclosed
Burner
004
---
---
14.8
2.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits for criteria 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 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.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in th's permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
ENG-
EEPOG3019
07
002
Air-fuel ratio control/Non-selective
catalytic reduction system
NOx and CO
Enclosed
Burner
004
Flash gas from the condensate knock -out
scrubber is routed to an Enclosed
Combustion Device
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.)
Page 3 of 16
COLORADO
Air Pollution Control Division
i- ,,Tal-m r of 1,-1.1,!'.c Health E r nir^}e:•
Dedicated to protecting and improving the health and environment of the people of Colorado
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
ENG-
EEPOG301907
002
Consumption of natural
gas as fuel*
18.61 MMscf/year
Enclosed
Burner
004
Natural Gas Throughput
6.57 MMSCF
*Point 002: Fuel consumption shall be measured by one of the following methods: individual
engine fuel meter; facility -wide fuel meter attributed to fuel consumption rating and hours of
operation; or manufacturer -provided fuel consumption rate.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. Point 004: 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. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. Point 002: Visible emissions shall not exceed twenty percent (20%) opacity during normal
operation of the source. During periods of startup, process modification, or adjustment of
control equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections
XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section
II.A.1. . A.1. Et 4.)
14. Point 002: This equipment is subject to the control requirements for natural gas -fired
reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only
enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion
engine that is either constructed or relocated to the state of Colorado from another state after
the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life
of the engine so that it achieves the emission standards required in the table below:
Page 4 of 16
COLORADO
Air Pollution Control Division
Dedicated to protecting and improving the health and environment of the people of Colorado
Maximum' Engine
HP
Construction or
Relocation Date
Emission Standard in g/hp-hr
NOx
CO
VOC
<100HP
Any
N/A
N/A
N/A
≥100HP and
<500HP
January 1, 2008
January 1, 2011
2.0
1.0
4.0
2.0
1.0
0.7
≥500HP
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
deration.
15. Point 004: The combustion device covered by this permit is subject to Regulation Number 7,
Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section XVII,
it shall be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2O14, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
16. Point 004: The separator covered by this permit is subject to Regulation 7, Section XVII.G.
(State Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well,
must either be routed to a gas gathering line or controlled from the date of first production by
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING £t MAINTENANCE REQUIREMENTS
17. 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 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
18. Point 004: 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
Page 5 of 16
COLORADO
Air Pollution Control Division
.:na,^:� cr 7I..177. Hnalth
Dedicated to protecting and improving the health and environment of the people of Colorado
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.17)
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. 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.
• 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.
21. 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).
Page 6 of 16
COLORADO
Air Pollution Control Division
i"..na n - of ri„2*(- H afh 8 c r .nrn,P.n-r
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
22. 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.
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
Page 7 of 16
By:
COLORADO
Air Pollution Control Division
'".1"
Dedicated Dedicated to protecting and improving the health and environment of the people of Colorado
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc.
Page 8 of 16
COLORADO
Air Pollution Control Division
Fr;iamn rr TM'r ~~(=11¢h ?: Fn'7nnr;"e3„.�
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator 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)
ENG-
EEPOG301907
002
Formaldehyde
50000
381
381
Enclosed
Burner
004
Benzene
71432
3,714
186
Toluene
108883
3,026
151
Ethylbenzene
100414
2,173
109
Xylenes
133 020
1,372
69
n -Hexane
110543
19,822
992
2,2,4-
Trimethylpentane
540841
2,115
106
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.
Page 9 of 16
COLORADO
Air Pollution Control Division
r'ratrh
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
CAS #
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission Factors
Controlled
lb/MMBtu
-
g/bhp-hr
NOx
2.2100
9.02
0.2450
1.00
CO
3.7200
15.20
0.4899
2.00
VOC
0.1715
0.70
0.1715
0.70
50000
Formaldehyde
0.0205
0.08
0.0205
0.08
Emission factors are based on a Brake-Speclic Fuel Consumption Factor of 9000 Btu/hp-hr, a
site -rated horsepower value of 236, and a fuel heat value of 1000 Btu/scf.
Emission Factor Sources:
CAS #
Pollutant
Uncontrolled EF Source
Controlled EF Source
NOx
AP -42; Table 3.2-3
(7/2000); Natural Gas
AFRC/NSCR
CO
AP -42; Table 3.2-3
(7/2000); Natural Gas
AFRC/NSCR
VOC
Manufacturer
Specification/NSPS JJJJ
No Control
50000
Formaldehyde
AP -42; Table 3.2-3
(7/2000); Natural Gas
No Control
Point 004:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
173.52
173.52
AP -42,
Chapter 13.5
CO
767.12
767.12
VOC
90,231
4,511.55
HYSYS model based
on a pressurized
gas sample taken
from the HP
separator taken
6/8/2018
71432
Benzene
565.3
28.265
108883
Toluene
460.5
23.025
100414
Ethylbenzene
330.7
16.535
1330207
Xylene
208.8
10.44
110543
n -Hexane
3,017.3
150.865
540841
2'2'4-321.9
Trimethylpentane
16.095
Note: The controlled emissions factors for this point are based on the enclosed combustion
device 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
Page 10 of 16
COLORADO
Air Pollution Control Division
f4F.pa:^r . of : t.h' c HenIth r sar •�zr�,
Dedicated to protecting and improving the health and environment of the people of Colorado
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) Point 002: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register
posting - effective March 18, 2008). This rule has not yet been incorporated into Colorado Air
Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on
the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf
8) Point 002: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards
for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18,
2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to
include requirements for area sources and engines < 500 hp located at major sources have not yet
been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the
complete subpart is available on the EPA website
at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf
Additional information regarding area source standards can be found on the EPA website
at: http://www.epa.govittn/atw/area/arearules.html
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
PSD or NANSR
Synthetic Minor Source of: VOC
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: //www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 11 of 16
COLORADO
Air Pollution Control Division
o,alm,F
Dedicated to protecting and improving the health and environment of the people of Colorado
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas
fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3,
Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural
requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement
performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
2.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine
maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent
replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month
period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The
90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that
day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic
monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required
by this permit.
All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit
(including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within
30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with
NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the
engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and
serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all
Applicability Reports required under section 2.1.2 and make them available to the Division upon request.
2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set
forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different
manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary
replacement engine complies with all permit limitations and other requirements applicable to the existing engine.
Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2.
Page 12 of 16
'COLORADO
Air Pollution Control Division
^?ar;�n rnf 7.�-''.c 1-_�2I�h. E r rv•�•�*
Dedicated to protecting and improving the health and environment of the people of Colorado
2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same
manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement
engine complies with all permit limitations and other requirements applicable to the existing engine as well as any
new applicable requirements for the replacement engine. Measurement of emissions from the permanent
replacement engine and compliance with the applicable emission limitations shall be made as set forth in section
2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and
horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be
accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising
an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant
Applicability Reports for the replacement engine. Example Applicability Reports can be found at
www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible
Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and
information included in the submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an
engine that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information
submitted to the Division in regard to any permanent engine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified
by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test
conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for
another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust
from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing
operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer
Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
www.colorado.00v/cdphe/portable-analyzer-monitorinq-protocol
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall
be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever
applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
Page 13 of 16
'COLORADO
Air Pollution Control Division
-
r'nr<.,�—,1.
Dedicated to protecting and improving the health and environment of the people of Colorado
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration
based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to,
the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable
Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence
of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and
CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable
analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be
considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates
compliance with both the NOX and CO emission limitations or until the engine is taken offline.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as attainment/maintenance or
nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area
is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall
be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or
nonattainment, except as follows:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions
and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal
combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0
grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -Only
conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the
applicable control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst
and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to
reduce emissions.
Page 14 of 16
!COLORADO
Air Pollution Control Division
aa,Trn 1- :alth °; c r nrF uttY
Dedicated to protecting and improving the health and environment of the people of Colorado
The above emission control equipment shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
Emission Standards: Section XVII. E — State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the
date listed in the table below shall operate and maintain each engine according to the manufacturer's written
instructions or procedures to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards
required in the table below:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
January 1, 2008
2.0
4.0
1.0
100<Hp<500
January 1, 2011
1.0
2.0
0.7
July 1, 2007
2.0
4.0
1.0
500≤Hp
July 1, 2010
1.0
2.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25
hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean
burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater
than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ.
An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine
replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by
the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can
serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that
such test is conducted within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of
the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture
date for purposes of determining the applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine
subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an
additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B
(which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado
is considered to be a new source, subject to the requirements of NSPS JJJJ.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR
Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the
Page 15 of 16
COLORADO
Air Pollution Control Division
‘it Pnalth
Dedicated to protecting and improving the health and environment of the people of Colorado
permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any
testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the
MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 2.2.
2.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new
emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced
construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that
is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing
onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation.
Page 16 of 16
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Lauraleigh Lakocy
Package N: 385539
Received Date: 7/24/2018
Review Start Date: 1/22/2019
Section 01- Facility Information
Company Name: Noble Energy Inc.
County AIRS ID: 123
Plant AIRS ID: 9FE1
Facility Name: Wells Ranch 8511 Econode
Physical Address/Location: swrnA/ quadrant of Section 11, Township 5N, Range 63W
County: I
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil &Natural Gas Production :$ Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) ❑✓ Ozone (NOx & VOC)
Quadrant
Section
Township
Range
SWNW
11
5N
63
Section 02 - Emissions Units In Permit Application
AIRs Point N
Emissions Source Type
Equipment Name
Emissions
Control?
Permit S
Issuance 4
Self Cert
Required?
Action
Engineering
Remarks
002
Natural Gas RICE ''
ENG-EEPOG3o1407
Yes
18WE0830
1
Yes ?
Permit Initial
Issuance
003
NaturalGan RICE
ENG-EEPOG402720
No
Cancelled prior to
issuance
No
Cancdiation -,
Cancelled prior to
issuance
004
Separator Venting;,
Enclosed Burner
Yes
1$WE0830
1
Yes. <.
Permit Initial
Issuance
Section 03 - Description of Project
This project was to install and operate 3 natural gas RICE engines (point 001 was permitted through the general permit 02 process) and permit the venting of flash gas from the knock out
scrubber, which is controlled by an enclosed combustion device. Points 002 and point 003 were originally requested to be permit exempt engines; however, upon further evaluation of their
emissions, it was determined that they were permit required. Point 003 was cancelled prior to the issuance of this permit, though.
This is a new well -production facility operating in the ozone non -attainment area and it is synthetic minor for VOC only. All of her pollutants are at a true minor designation.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Ye:
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
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
Yes
502 NOx CO VOC PM2.5 PM10 TSP HAPs
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
O El
Summary of Preliminary Analysis - NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Noble Energy Inc.
WELLS RANCH BB11 ECONODE
SWNW SEC11 T5N R63W
ENG-EEPOG301907
Permit No.
AIRS
Review Date
Permit Engineer
18WE0830
123/9FE1/002
/002
04/01/2019
Lauraleigh Lakocy
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Doosan (PSI), Model D8.1 L, Serial Number EEPOG301907, natural gas -fired, naturally aspirated, 4SRB
reciprocating internal combustion engine, site rated at 236 horsepower. This engine shall be equipped with a non -selective
catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for power generation.
Natural Gas Consumption
Requested (mmscf/yr)
18.61
Requested (mmscf/m)
1.58
Fuel Heat Value (btu/scf)
1000
BSCF (Btu/hp-hr)
9000
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
AP -42; Table 3.2-3 (7/2000); Natural Gas
AFRC/NSCR
VOC
Manufacturer Specification/NSPS JJJJ
No Control
CO
AP -42; Table 3.2-3 (7/2000); Natural Gas
AFRC/NSCR
Formaldehyde
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
SOX
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
Point Summary of Criteria Emissions (t
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
20.6
2.3
20.6
88.9%
VOC
1.6
1.6
1.6
0.0%
CO
34.6
4.6
34.6
86.8%
SOx
0.0
0.0
0.0
0.0%
TSP
0.2
0.2
0.2
0.0%
PM10
0.2
0.2
0.2
0.0%
PM2.5
0.2
0.2
0.2
0.0%
Total HAPs*
0.2
0.2
0.3
0.0%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants Ib/yr)
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
381
381
381
0.0%
Methanol
*
57
0.0%
Acetaldehyde
*
*
52
0.0%
Acrolein
*
*
49
0.0%
Benzene
*
*
29
0.0%
1,3 -Butadiene
*
*
12
0.0%
Toluene
*
*
10
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines.
Public Comment
Public Comment Required for facility -wide permit based on synthetic minor limits & project VOC
emissions
MACT 777Z
New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT ZZZZ (area source)
Is this engine subject to MACT ZZZZ area
source requirements?
Yes
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requriements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
0
Natural Gas -Fired Reciprocating Internal Combustion Engines
002 Emission Factors - 4SRB
1
Uncontrolled
Uncontrolled
Controlled
Controlled
AP -42
Value Used
Value Used - comments
Value Used
Value used - comments
Table 3.2-3 (7/2000)
(lb/MMBtu)
(Ib/MMBtu)
Natural Gas
Pollutant
CAS
BIN
Ib/MMBtu
NOx
2.21
AP -42; Table 3.2-3 (7/2000);
0.244957729
AFRC/NSCR
2.21
CO
3.72
AP -42; Table 3.2-3 (7/2000);
0.489915458
AFRC/NSCR
3.72
VOC
0.17
Manufacturer Specification/N
0.17147041
No Control
2.96E-02
Formaldehyde
50000
A
0.02
AP -42; Table 3.2-3 (7/2000);
0.0205
No Control
2.05E-02
SO2
0.000588
AP -42; Table 3.2-3 (7/2000);
0.000588
No Control
5.88E-04
PM10
0.01941
AP -42; Table 3.2-3 (7/2000);
0.01941
No Control
0.01941
PM2.5
0.01941
AP -42; Table 3.2-3 (7/2000);
0.01941
No Control
0.01941
TSP
0.01941
AP -42; Table 3.2-3 (7/2000);
0.01941
No Control
0.01941
1,1,2,2-Tetrachloroethane
79345
A
0.0000253
AP -42; Table 3.2-3 (7/2000);
0.0000253
No Control
2.53E-05
1,1,2-Trichloroethane
79005
A
0.0000153
AP -42; Table 3.2-3 (7/2000);
0.0000153
No Control
1.53E-05
1,1-Dichloroethane
75343
B
0.0000113
AP -42; Table 3.2-3 (7/2000);
0.0000113
No Control
1.13E-05
1,3 -Butadiene
106990
A
0.000663
AP -42; Table 3.2-3 (7/2000);
0.000663
No Control
6.63E-04
1,3-Dichloropropene
542756
A
0.0000127
AP -42; Table 3.2-3 (7/2000);
0.0000127
No Control
1.27E-05
2-Methylnaphthalene
91576
AP -42; Table 3.2-3 (7/2000);
0
No Control
2,2,4-Trimethylpentane
540841
C
AP -42; Table 3.2-3 (7/2000);
0
No Control
Acenaphthene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Acenaphthylene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Acetaldehyde
75070
A
2.79E-03
AP -42; Table 3.2-3 (7/2000);
0.00279
No Control
2.79E-03
Acrolein
107028
A
0.00263
AP -42; Table 3.2-3 (7/2000);
0.00263
No Control
2.63E-03
Anthracene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benz(a)anthracene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benzene
71432
A
1.58E-03
AP -42; Table 3.2-3 (7/2000);
0.00158
No Control
1.58E-03
Benzo(a)pyrene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benzo(b)fluoranthene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benzo(e)pyrene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benzo(g,h,i)perylene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Benzo(k)fluoranthene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Biphenyl
92524
C
AP -42; Table 3.2-3 (7/2000);
0
No Control
Carbon Tetrachloride
56235
A
0.0000177
AP -42; Table 3.2-3 (7/2000);
0.0000177
No Control
1.77E-05
Chlorobenzene
108907
A
0.0000129
AP -42; Table 3.2-3 (7/2000);
0.0000129
No Control
1.29E-05
Chloroform
67663
A
0.0000137
AP -42; Table 3.2-3 (7/2000);
0.0000137
No Control
1.37E-05
Chrysene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Ethylbenzene
100414
C
0.0000248
AP -42; Table 3.2-3 (7/2000);
0.0000248
No Control
2.48E-05
Ethylene Dibromide
106934
A
0.0000213
AP -42; Table 3.2-3 (7/2000);
0.0000213
No Control
2.13E-05
Fluoranthene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Page 4 of 15
Printed 4/26/2019
Natural Gas -Fired Reciprocating Internal Combustion Engines
002 Emission Factors - 4SRB
1
Uncontrolled
Uncontrolled
Controlled
Controlled
AP -42
Value Used
Value Used - comments
Value Used
Value used - comments
Table 3.2-3 (7/2000)
(lb/MMBtu)
(lb/MMBtu)
Natural Gas
Pollutant
CAS
BIN
lb/MMBtu
Fluorene
7782414
C
AP -42; Table 3.2-3 (7/2000);
0
No Control
Indeno(1,2,3-c,d)pyrene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Methanol
67561
C
0.00306
AP -42; Table 3.2-3 (7/2000);
0.00306
No Control
3.06E-03
Methylene Chloride
75092
A
0.0000412
AP -42; Table 3.2-3 (7/2000);
0.0000412
No Control
4.12E-05
n -Hexane
110543
C
AP -42; Table 3.2-3 (7/2000);
0
No Control
Naphthalene
91203
B
0.0000971
AP -42; Table 3.2-3 (7/2000);
0.0000971
No Control
9.71 E-05
PAH
0.000141
AP -42; Table 3.2-3 (7/2000);
0.000141
No Control
1.41 E-04
Phenanthrene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Phenol
108952
C
AP -42; Table 3.2-3 (7/2000);
0
No Control
Pyrene
AP -42; Table 3.2-3 (7/2000);
0
No Control
Styrene
100425
C
0.0000119
AP -42; Table 3.2-3 (7/2000);
0.0000119
No Control
1.19E-05
Tetrachloroethane
79345
A
AP -42; Table 3.2-3 (7/2000);
0
No Control
Toluene
108883
C
0.000558
AP -42; Table 3.2-3 (7/2000);
0.000558
No Control
5.58E-04
Vinyl Chloride
75014
A
0.00000718
AP -42; Table 3.2-3 (7/2000);
0.00000718
No Control
7.18E-06
Xylene
1330207
C
0.000195
AP -42; Table 3.2-3 (7/2000);
0.000195
No Control
1.95E-04
Page 5 of 15
Printed 4/26/2019
Natural Gas -Fired Reciprocating Internal Combustion Engines
002 Emission Factors - 4SRB
2
3
4
5
GRI HAPCalc 3.0
GRI HAPCalc 3.0
GRI HAPCalc 3.0
GRI HAPCalc 3.0
Literature
Literature
Test Data
Test Data
Natural Gas
Field Gas
Natural Gas
Field Gas
Pollutant
CAS
BIN
g/bhp-hr
g/bhp-hr
g/bhp-hr
g/bhp-hr
NOx
18.3
7.53
CO
14.5
9.08
VOC
0.264
Formaldehyde
50000
A
0.0623
0.0381
0.0994
0.0418
SO2
PM10
PM2.5
TSP
1,1,2,2-Tetrachloroethane
79345
A
1,1,2-Trichloroethane
79005
A
1,1-Dichloroethane
75343
B
1,3 -Butadiene
106990
A
1,3-Dichloropropene
542756
A
2-Methylnaphthalene
91576
5.05E-05
2,2,4-Trimethylpentane
540841
C
Acenaphthene
1.09E-05
Acenaphthylene
1.89E-05
Acetaldehyde
75070
A
0.0039
Acrolein
107028
A
0.0034
Anthracene
4.00E-06
Benz(a)anthracene
1.80E-06
Benzene
71432
A
0.0046
0.0221
0.0221
Benzo(a)pyrene
4.00E-07
Benzo(b)fluoranthene
2.20E-06
Benzo(e)pyrene
Benzo(g,h,i)perylene
7.00E-07
Benzo(k)fluoranthene
2.20E-06
Biphenyl
92524
C
Carbon Tetrachloride
56235
A
Chlorobenzene
108907
A
Chloroform
67663
A
Chrysene
2.20E-06
Ethylbenzene
100414
C
Ethylene Dibromide
106934
A
Fluoranthene
1.26E-05
Page 6 of 15 Printed 4/26/2019
Natural Gas -Fired Reciprocating Internal Combustion Engines
002 Emission Factors - 4SRB
2
3
4
5
GRI HAPCaIc 3.0
GRI HAPCaIc 3.0
GRI HAPCaIc 3.0
GRI HAPCalc 3.0
Literature
Literature.
Test Data
Test Data
Natural Gas
Field Gas
Natural Gas
Field Gas
Pollutant
CAS
BIN
g/bhp-hr
g/bhp-hr
g/bhp-hr
g/bhp-hr
Fluorene
7782414
C
1.72E-05
Indeno(1,2,3-c,d)pyrene
5.00E-07
Methanol
67561
C
0.02
0.00667
Methylene Chloride
75092
A
n -Hexane
110543
C
Naphthalene
91203
B
2.75E-04
PAH
Phenanthrene
3.21 E-05
Phenol
108952
C
Pyrene
8.60E-06
Styrene
100425
C
Tetrachloroethane
79345
A
Toluene
108883
C
0.002
0.007
7.10E-03
Vinyl Chloride
75014
A
Xylene
1330207
C
0.0014
0.0017
1.70E-03
Page 7 of 15 Printed 4/26/2019
Separator Venting Emissions Inventory
004 Separator Venting
Facility AIRS ID:
L 123
County
9FE1
Plant
004:''
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description: LEnclosed Combustion Device •
Requested Coverall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
rNaturaltas'=Vented V
Pes irrieter s currehtly:iii talled,and-"operationaF')= " ">t.,-1
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =1 ---7
0.01 MMscf per year
95
k -out scrubber
Requested Permit Limit Throughput =I , 6.6) MMscf per year
Requested Monthly Throughput = MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
7 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:
Section 04 - Emissions Factors & Methodologies
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
--..._..._.m-7�.., 2461tj Btu/scf
Description •
Using a pressurized gas sample analysis from the HP separator, taken 6/8/2018 at 140,F and 320 PSIG, this sample was inputted into a HYSYS model which modelled the separation units (knock -out scrubber). Using thevapor stream from the knock -out,.
scrubber ("Mist Vap to Bruner 2"), the emission factors were determined based on the standard gas flow calculated in the HYSYS model. .
scf/bbl
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
90231.0000
4511.5500
a _' •HYSYS
Benzene
565.3000
28.2650
s;;'- ` �°HYSYS , }
i rirsys74,
Toluene
460.5000
23.0250
Ethylbenzene
330.7000
16.5350
F v HYSYS
Xylene
208.8000
10.4400
HYSYS
3 z c
n -Hexane
3017.3000
150.8650
HYSYS
224 TMP
321.9000
Primary.Control
16.0950
�'s�.-. 3�L'1'°v�HYSYSm�
Device
Uncontrolled
Emission Factor Source
Pollutant
Uncontrolled
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM30
7.600
„F.` .:cOttier=Explain
Bof15
K:\PA\2018\18W E0830.CP1
Separator Venting Emissions Inventory
PM2.5
..
7.600
Otherp)aln,4
5Ox
0.600
Other Explain
NOx
0.0680
167.348
' AP -41 Cha ter 13.5 Industrial Flares (NOx) .4 r
•
CO
0.3100
762.910
, 6s P3,x .131 v ,I3n1s ) d
g� �ffq,AP;42 Chapter 13.5 Industrial Flares,)CO
9 0115
K: \PA\2018\ 18 W E 0830. C P 1
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
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
SOz
NOx
VOC
CO
0.02
0.00
0.00
0.02
0.02
4
0.02
0.00
0.00
0.02
0.02
4
0.00
0.00
0.00
0.00
0.00
0
0.55
0.00
0.00
0.55
0.55
93
296.41
0.00,
0.00
296.41
14.82
2517
2.51
0.00
0.00
2.51
2.51.
426
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year( (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
3714
0
0
3714
186
3025
0
0
3025
151
2173
0
0
2173
109
1372
0
0
1372
69
19824
0
0
19824
991
2115
0
0
2115
106
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, 8
Source requires a permit
Regulation 7, Section XVII.B, G
Source is 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.
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 gai 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.throughputusing.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
10 of 15
K:\PA\2018\18 W E0830. C P1
Separator Venting Emissions Inventory
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an
sl Uquid rough Mb It'OCC
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11 of 15 K:\PA\2018\18WE0830.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
The emission factorsfor particulate matter and SOx came from'AP-42 Table 1..4.2 ((missions factors for:crlteria pollutants and. greenhouse•gases from natural gascombustion); which are given in It?/10^6 scf. The source elected to use the emission factor for PM
(Total) to represent thin PMl0 and PM2.5 emissions: ••-
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point II
004
Process M 5CC Code
01 3-10-001-60 Flares
Uncontrolled
Pollutant Emissions Factor Control % Units
PM10 7.60 0 Ib/MMSCF
PM2.5 7.60 0 lb/MMSCF
SOx 0.60 0 lb/MMSCF
NOx 167.35 0 lb/MMSCF
VOC 90231.00 9S Ib/MMSCF
CO 762.91 0 Ib/MMSCF
Benzene 565.30 95 lb/MMSCF
Toluene 460.50 95 lb/MMSCF
Ethylbenzene - 330.70 95' lb/MMSCF
Xylene 208.80 95 lb/MMSCF
n -Hexane 3017.30 95 lb/MMSCF
224 TMP 321.90 95 lb/MMSCF
12 of 15 K:\PA\2018\18WE0830.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Regule Ion 3 Parts A and B - OPEN and Permit Requirements
Source is In the NuroAtialnment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Indvidual source greater than 2 TPY (Regulation 3, Pan A, Section II.O.t.a)2
2. Are total facility uncontrolled VOC emissions greater than S TPY. NOa greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section II.D.3)7
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this itdlvidual source greater than 1 TPY (Regulation 3, Pan A, Section II.D.1.a)7
2. Ara total facility uncontrolled VOC emissions from the greater than 2 TPY, NOe greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires s permit
Colorado Reerktlon 7. Section kill
1. Was the wed newly constructed. hydraudcaay fractured, or «completed on or after August 1. 20147
'Source Is subject to Regulation 7, Section kVil.0.2, G
Section OVII.0.2 - General Provision lea Ai Pollution Control Equipment and Prevention of Emissuna
Section >VII.0 - Emissions Control
Alternative Emissions Control (Optional Sectlun)
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 1511.8.2.e
Section CVIl,B.2.e - Misuse)u. erriabte control egtipmsnt
Disclaimer
This document assists operators with determining applicability of cettein requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation,
end the analysis it contains may not apply toe particular situation based upon the individual lads and circumstances. This document does not change or substitute for any law, regulation, or any other logaly 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. end Air Quality Control Commission regulations, the language
of the statute or regulation will control. The use of non -mandatory language such es -recommend,- rney,- -should,- and -can,- is intended to describe APCD interpretations and recommendations. Mandatory terminology such as
must" and 'required- ere 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 legagy binding requirements in and
of hoed. '
Yes (Source Requ
Yes Source Requ
INb> ., .:'The control
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
Noble Energy Inc
County AIRS ID
123
Plant AIRS ID
9FE1
Facility Name
Wells Ranch BB11 Econode
History File Edit Date
Ozone Status
4/1/2019
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.6
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.6
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
GP02
Caterpillar 1380HP RICE 4SLB
6.7
20.0
32.4
6.4
6.7
9.3
20.0
6.4
New GP02 Request
002
18WE0830
Doosan PSI DB.1L 236 HP
0.2
0.2
20.6
1.6
34.6
0.2
0.2
0.2
2.3
1.6
4.6
0.2
New emission point
003
181NE0831:CN
Doosan PSI O8.14 236 HP
"
0.0
0.0
Engine cancelled poor to perm fling (Cancellation
004
18WE0830
Natural Gas Venting
0.0
0.0
0.6
296.4
2.5
15.1
0.0
0.0
0.6
14.8
2.5
0.8
New emission point
0.0
0.0
0.0
0.0
APEN Exempt/Insignificant Sources
0.0
0.0
Separator Heators (4)
0.5
0.0
0.4
0.0
0.5
0.0
0.4
0.0
From Form APCD-102
Fugitives
0.5
0.0
0.5
0.0
From Form APCD-102
0.0
0.0
0.0
0.0
0.0
0.0
FACILITY TOTAL
0.2
0.2
0.0
0.0
28.4
'
318.0
0.5
69.9
•
21.7
0.2
0.2
0.0
0.0
10.1
25.7
0.5
27.6
7.4
VOC: Syn Minor (NANSR and OP)
NOx: True Minor (NANSR and OP)
CO: True Minor (PSD and OP)
HAPS: True Minor
Permitted Facility Total
0.2
0.2
0.0
0.0
28.4
318.0
0.5
69.9
21.7
0.2
0.2
0.0
0.0
10.1
25.7
0.5
27.5
7.4
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.2
0.2
0.0
0.0
10.1
25.7
0.5
27.5
Pubcom required because new syn limit,
modeling not required b/c division guidelines
Note 1
Total VOC Facility Emissions (point and fugit
(A) Change in Total Permitted VOC emissions (point and fugitive)
ve)
26.2
Facility is eligible for GP02 because < 90 ipy
Project emissions less than 25 1py for NoxNOC
26.2
Point 002 & point 003 were originally submitted as XP requests. Due to emissions, they were not eligible for XP status. Point 002 was added to the facility -wide request and point 003 was cancelled prior to permit issuance.
Note 2
Page 14 of 15
Printed 4/26/2019
H
z
W
2
Z
O
cc
Z
W N
o a
z < <
• Z
O
Q (nQ
Z
m O Z
MHO
W J (n ,,a2
Z W
w CC
• Q
H J
r
Q <
a u_
O
O
O
O
J
O
O
w
u.,
rn
Wells Ranch BB11 Econode
TOTAL
ttPY)
O
O
V
(O
N
O
O
O
`-
0
O
0
O
0
O
0
O
0
O
0
O
21.7
o
O
co
(q
N
_
O
O
O
a
2
F-
N
N
0
LO
N
N
r
McOH
O
O
O
n -Hexane
O
17822
coo
T
a0
N
CD
C
a)
T
X
O
CV
N.
CO
N
n
O
Ethylbenzene
o
co
r-
N
N
A-
{
a)
N
-0-
H
O
CO
NO
M
N
1.5
Benzene
O
M
to
C)
A-
Acrolein
O
O
0
M
O
T
L
-a
T.°
U
Q
0
01
.k -
O
0.4
)
a
2
N
E
o
LL
0
11460
03
M
01
10
Description
Previous FACILITY TOTAL
Caterpillar 1380HP RICE 4SLB
IDoosan PSI D8.1L 236 HP
IDoosan PSI D8.1L. 236 HP
Natural Gas Venting
IAPEN Exempt/Insignificant Sources
Separator Heators (4)
Fugitives I
PERMIT
IGP02
o
co
co
o
>
co
U
r
a'Y
co
co
3
W
o
co
co
co
a)
QO
(TOTAL (tpy)
H
Z
CL
00
NCI
00
0
V
0
Q)
To
Ln
C
2
a)
-o
A
m
C
0
N
N
2
a)
a m
=
E
'c
o E
U N
C
• V
N
t
>
to co
G
=
c)
u a
a)
O
( O
O
Q
X
OL
o)H
o a
R
d
C
N
co
O
4-
C
O
U
3
Cu'
O
N
N
E
w
TOTAL
(IPY)
O
O
V'
(O
(N
O
A
O
co
0
O
0
O
0
0
0
0
0
0
0
0
O
0
O
V
N-
O
o
O
U)
N
=
O
O
O
a
I-
N
N
O
0
N
O
=
Q
a)
O
O
O
n -Hexane
o
a)
co
(o
O
Xylenes
O
O
CO
N
O
O
Ethylbenzene
O
m
O
N
C
Toluene
O
N
G
Benzene
O
<..
a0
0
to
Acrolein
0
CO
O
(C)
M
O
-8o
T
-o
v
a
O
O
a)
o
Formaldehyde
0
11460
CO
M
I 5.9
Description
'Previous FACILITY TOTAL
Caterpillar 1380HP RICE 4SLB
IDoosan PSI D8.1L 236 HP
I Doosan"PSI D8. IL 236 HP
(Natural Gas Venting
IAPEN Exempt/Insignificant Sources
Separator Heators (4)
(Fugitives
PERMIT
IGP02
0
M
03
O
11.1
a)
18WE0831, CN
0
M
CO
O
LLI
a)
r
ITOTAL (tpy) I
H
Z
a
0
N
0
M
0
0
0
O)
O
N
CO
N
18WE0830.CP1
LO
LU
Spark Ignition Engine APEN
Form APCD-201
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
AR sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal wilt require
payment for a new filing fee.
This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your
engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE
category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations,
asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty
APEN options do not meet 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/aocd.
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:
LsJ Ei O o AIRS ID Number: 123 / 9FE1 / 002
[Leave btarik unless APCD hoes already ossis'n d a Dermit and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: Wells Ranch BB11 Econode
Site Location: SWNW SEC11 T5N R63W
Mailing Address:
(include Zip Code) 1625 Broadway, Suite 2200
Portable Source
Home Base:
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Shaun Higgins
Phone Number: 720-587-2459
E -Mail Addressz• shaun.higgins@nblenergy.com
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
APCD-20 So k ft,'n
I_.ian 1/2019 1 I
C•LC'?.'. DO
Permit Number:
AIRS ID Number: 123 /9FE1 / 002
[Leave blank unless .A.PCD has aiready a i.,i _d , rmil and AIRS IG
Section 4 - Engine Information
Engine Function:
0 Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑ Compression
O Pump Jack ❑ Water Pump O Other:
What is the maximum number of hours this engine wilt be used for emergency back-up power? hours/year
Engine Make: Doosan (PSi) Engine Model: D8.1 L Serial Number': EEPOG301907
What is the maximum designed horsepower rating? 236 hp
What is the maximum manufacturer's site -rating? 236 hp kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 9000 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑ Lean Burn 0 Rich Burn
Aspiration: Q Natural ❑ Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? O Yes ❑ No
If yes, what type of AFRC is in use? 0 O2 Sensor (mV) ❑NOx Sensor (ppm) [] Other:
Is this engine equipped with a Low-NOx design? ❑ Yes ❑ No
Engine Dates: -
What is the manufactured date of this engine? 12/5/2013
What date was this engine ordered?
What is the date this engine was first located to Colorado?
What is the date this engine was first placed in service/operation?
What is the date this engine commenced construction?
What is the date this engine was last reconstructed or modified?
Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
7 The serial number must be submitted if coverage under GP02 is requested.
Farm APCD-'J1 • Spark Enginetngine 1,,PEN - 312019
Permit Number:
AIRS ID Number: 123 i9FE11 002
[ - btarth APCD h t..s. - ass1;-,,,:,,J perm - FS IDf
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
-.._...........
Primary Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
TSP (PM)
PM10
PM2.5
SOx
NOx
AFRC/NSCR
38.92
VOC
CO
ArRCINSCR
88.83
Other:
Use the following tables to report criteria and non -criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory -
Pollutant
Emission Factor
•
Actual Annual Emissions10
Requested Annual Permit
Emission Limit(s)8
• Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
• Uncontrolled
Emissions
(tons/year}
Controlled
Emissions
(tons/year)
• Uncontrolled
Emissions ,
(tons/year} .
Controlled
Emissions
(ions/year)
TSP (PM)
0.01941
Ib/mmbtu
AP -42
0.18
0,13
PM10
0,01941
Ib/mmbtu
AP -42
D.18
0.15
PM2.5
0,01941
lb/mmblu
AP -42
0.18
0.18
SOx
0,000588
Ibfmmbtu
AP -42
0.01
0.01
NOx
2.21
Ibfmmbtu
AP -42
20.55
2.28
VOC
0.7
0lhp-9r
JJJJ
1.59
1.59
CO
3.72
Ib/mmbtu
AP -42
34.51
4.55
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 El Yes ❑ No
lbs/year?
If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source:
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions1a
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
-
Emissions
(pounds/year)
Controlled
Emissions
(pounds/year)
Formaldehyde
50000
0,0205
ib/mmbtu
AP -42
385
381
Acetaldehyde
75070
Acrolein
107028
Benzene
71432
Other:
8 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form 151CP-20 I APEN - PevIsin 3/2019
51
_ CRb. o0
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN {Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website 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: 18WE0830
AIRS ID Number: 123 /9FE1 /004
[Leave Clans+. unless AKD has already assigned a permit and AIRS IDj
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Noble Energy, inc.
Wells Ranch BB11 Econode
SWNW S11 T5N R63W
Mailing Address: 1625 Broadway, Suite 2200
(Include Zip Code) y
) +
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@nbleneraycorn
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 wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form
G s Venbn -N - Re is._n 7/2..14 1 I
RAQu
Permit Number: 18WE0830
AIRS ID Number:
123 /9FE1/004
L t.ve btaNs unless APCD ii a1 +; asyigned a peril -1r AIRS ICS]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
Serial #:
# of Pistons:
Capacity:
Leak Rate:
gallmin
Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
❑✓ Other
Description: Control device for flash gas from knock out scrubber
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
[] No
Vent Gas
Heating Value:
2461
BTU/SCF
Requested:
6.57
MMSCF/year
Actual:
MMSCF/yeas
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
43.87
VOC (Weight %)
77.9
Benzene (Weight %)
0.49
Toluene (Weight %)
0.40
Ethylbenzene (Weight %)
0.29
Xylene (Weight %}
0.18
n -Hexane (Weight %)
2.60
2,2,4-Trimethylpentane (Weight %)
0.28
Additional Required Information:
❑✓ 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)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 Gas !'on ino APEll - Revtiori 7/2018
31
c6i.6 Rica
Permit Number: 1 8WE0830
AIRS ID Number:
123 19FE1 1004
[ v_ blank ual.:es ,e C.D has .readyy- assipned a permit and A R3 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
verall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOX
NOX
CO
VOC
VOC Burner
95%
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual onnuoi emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
._..__ ...-....... __..._ .. .
Actual Annual Emissions
-
Requested Annual Permit
Emission Limit(s)
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)-!
Uncontrolled :
Emissions
(tons/year)
Controlled
Emissions 6
(tonslyear)
Uncontrolled
Emissions
(tons/year)
Controlled
--
Emissions
(tanslyear)
PM
- 7.6 — -
lb/MMscf
- AP -42
-..
0.00
0.00 ---
SOX
0.60
lb/MMscf
AP -42
0.00
0.00
NOX
0.068
lb/MMBtu
AP -42
0.57
0.57
CO
0.310
lb/MMBtu
AP -42
2.52
2.52
VOC ✓
90.231
Ib/mscf
HYSYS
296.41
14.82
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical
Emission Factor
Actual Annual Emissions
Chemical Name
Abstract
Service (CAS)
Number
Uncontrolled
Basis
Units
Source
{AP 42,
c.._
Mfg., etc.)
Uncontrolled
Emissions
(poundslyear)
Controlled
Emissions6
(pounds/year)
Benzene
71432
0.5653 ,'
lb/mscf
HYSYS
3714.01
185.70
Toluene
108883
0.4605 i
lb/mscf
HYSYS
3025.53
151.28
Ethylbenzene
100414
0.3307 -,
Ib/mscf
HYSYS
2172.62
108.63
Xylene
1330207
0.2088 -/
Ib/mscf
HYSYS
1371.89
68.59
n -Hexane
110543
3.0173 -'
lb/mscf
HYSYS
19822.12
991.73
2,2,4-
Trimethylpentane
540841
0.3219 ,./
lblmscf
HYSYS
2114.56
105.73
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.
Fdrm _D-711 PEN Pa' itwa /7(r1S
5]
COLORADO
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