HomeMy WebLinkAbout20193077.tiffa
COLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
July 2, 2019
Dear Sir or Madam:
RECEIVED
JUL 082019
WELD TY
COMMISSIONERS
N
On July 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - Hurley H26 -11-A 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
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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CG PL(TP), H!_(TT), OG(' yrr ),
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i
2019-3077
a
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Hurley H26 -11-A Econode - Weld County
Notice Period Begins: July 4, 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: Hurley H26 -11-A Econode
Oil and gas well production facility
NESW SEC 26 T3N R65W
Weld County
The proposed project or activity is as follows: Applicant proposes to flare gas from four (4) low pressure
separators and one (1) vapor recovery tower at an existing well production facility.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0394 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:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
me
(COLORADO
1 , He6 Emrlronc
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Christopher Kester
Package #: 395542
Received Date: 4/2/2019
Review Start Date: 5/30/2019
Section 01 - Facility Information
Company Name: Noble Energy Inc
County AIRS ID: 123
Quadrant
Section
Township
Range
.- L
_ v
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
A03 E
HURLEY H26 -11-A
NESW quadrant of Section 26, Township 3N, Range 65W
Weld County
Exploration & Production Weil Pad
If yes, for what pollutant?
Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit ti
Issuance if
Self Cert
Required?
Action
Engineering
Remarks
(:
Condensate Tank
COND
Yes
19WE0087
I
Yes
3ermit Initial
Issuance
002
Produced Water Tank
PW
Yes
19WE0088
Yes
003
Liquid Loading
WAD
Yes
19WE0089
Yes
004
Fugitive Component Leaks
FUG
Yes
19WE0090
Yes
005
Separator Venting
SEP
Yes
19WE0091
Section 03 - Description of Project
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.: .. . :::.:
.7777. o.<.<.<:......... a ..:............
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.. < .1ri1 i... < :. nn.< 7•777 .7777
•
R
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r .
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•
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)
SO2
NOx
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE SO2 NOx
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
i
4
CO
VOC PM2.5 PM10 TSP HAPs
11
CO VOC PM2.5 PM10 TSP HAPs
•
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
!Facility AIRs ID:
123
County
A03E
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Three (3) 5.00 bbl fixed roof condensate storage tanks
Enclosed Combustor
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput = 287,000 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
287,000 Barrels (bbl) per year
Requested Permit Limit Throughput = 287,000 Barrels (bbl) per year
Requested Monthly Throughput =
24375 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
287,000 Barrels (bbl) per year
2799
Btu/scf
scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Yes
937 MMBTU per year
937 MMBTU per year
937 MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0.1332
0.00666
Si•:4. ipecific ES. (Includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
cite Specific E.F. (includes flash)
•e Specific E.F. (Includes flash)
.e Specific E.F. (includes flash)
.e Specific E.F. (Includes flash)
Benzene
0.0007
0.000035
Toluene
0.0013
0.000065
Ethylbenzene
0.00002
0.000001
Xylene
0.00003
0.0000015
n -Hexane
0.00525
0.0002625
224 TMP
0.00004
0.000002
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
0.0000
AP -42 Table 1.4-2 (PMW/Pl1t1.23)
AP -42. Table 1,42 (PM10/PM.2.5)
AP -112 Chapter 13.5 industrial Flares (NCJx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
0.0000
NOx
0.0680
0.0000
CO
0.3100
0.0000
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)
VOC
PM10
PM2.5
NOx
CO
I
19.1
19.1
1.0
19.11
0.96
162
0.0
0.0
0.0
0.0
0.0
1
0.0
0.0
0.0
0.0
0.0
1
0.0
0.0
0.0
0.032
0.032
5
0.1
0.1
0.1
0.145
0.145
25
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
201
201
10
201
10
373
373
19
373
19
6
6
0
6
0
9
9
0
9
0
n -Hexane
224 TMP
1507
1507
75
1507
75
11
11
1
11
1
Section 06 - Reeulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
tank is subject to Regulation 7, Section XII.C-F
'Storage
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
3 of 17
K:\PA\2019\19W E0394.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? ir4ti
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
Yes
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
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 Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process # SCC Code
01
4-04-003-11 Fixed Roof Tank, CondensAte, working breathing+fias.hing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.01 0 lb/1,000 gallons condensate throughput
VOC 3.2 95 lb/1,000 gallons condensate throughput
CO 0.02 0 lb/1,000 gallons condensate throughput
Benzene 0.02 95 Ib/1,000 gallons condensate throughput
Toluene 0.03 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.00 95 Ib/1,000 gallons condensate throughput
n -Hexane 0.13 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 lb/1,000 gallons condensate throughput
4 of 17 K:\PA\2019\19WE0394.CP1
Condensate Tank Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Nom 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. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
You have indicated that source is in the Non -Attainment Area
Yes
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. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
No
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
Storage tank is subject to Regulation 7. Section XII.C F
Yes
Yes
Yes
Section XII.C-1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage
Section XII.C2 — Emission Estimation Procedures
Section XII.D — Emissions Control Requirements
Section XII.E — Monitoring
Section XII.F — Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank is not subject to Regulation 7, Section XII.G
Section XII.G2 - Emissions Control Requirements
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tanks located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank is subject to Regulation 7, Section XVII, 8, CA & C.
Yes
Yes
No
N.,
Yes
Yes
Section XVII.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic. meters (m1) (-472 BBLsi?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m' ("10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] and without emissions to the atmosphere (60.11ob(d)(2))?; or
b. The design capacity is greater than or equal to 151 m' ('950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M' ['472 BBL] but less than 151 m3 (`950 BBL) and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
Yes
P.
Source Req
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Storage Tank is not subject to NSPS Kb
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b • Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
7. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage Tank is not subject to NSPS 0000
Yes
Nr
Subpart A, General Provisions per §60.5425 Table 3
460.5395 - Emissions Control Standards for VOC
460.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
560.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
(Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even
If potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel" in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitonng
§63.774 • Recordkeeping
§63.775 - Reporting
Nc
RACT Review
RACT review is required if Regulation / does not apply AND if the tank is in the non attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law.
regulation, or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations. the language of the statute or regulation will control The use of non -mandatory language such as "recommend," -may,"'should, " and "can." is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as -must" and 'required' are intended to describe controlling requirements under the terms of the Clean Air Act
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
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Storage Tar
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Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
002 Produced Water Tank
'Facility AIRs ID:
123
County
A03E
Plant
002
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Four (4) 500 bbl fixed roof produced water storage tanks
Enclosed Combustor
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput = 1,461,000.0 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating = 1,461,000
Requested Permit Limit Throughput = 1,461,000.0 Barrels (bbl) per year
Requested Monthly Throughput = 124085 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput =
1,461,000 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 1496 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced = scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
78,840 MMBTU per year
78,840 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 78,840 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Produced Water Tank
Emission Factor Source
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Pollutant
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
0.262
0.01310
Produced Water State E.F. (include,
Produced Water State E.F. (Includes flash) - Front
Produced Water State E.F. (Includes flash) - Front
Produced Water State E.F. (includes flash) - Front
Produced Water State E.F. (includes flash) - Fror-
Benzene
0.007
0.00035
Toluene
0.00000
Ethylbenzene
0.00000
Xylene
0.00000
n -Hexane
0.022
0.00110
Produced Water State E.F. (includes flash) - From
224 TMP
0.00000
Produced Water State ES. (includes flash) - Free:
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
PM10
0.0075
0.0000
AP -42 Table 1.4-2 (PM10/PM.2..5)
PM2.5
0.0075
0.0000
AP -42 Table 1.ii•-2 (PM;10; PM.2.5)
NOx
0.0680
0.0000
AP -42 Chapter 1.3.5 Industrial Flares (NOx)
CO
0.3100
0.0000
AP -42 Chapter 133 mdpstrl$ Flares
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)
VOC
PM10
PM2.5
NOx
CO
191.4
191.4
9.6
191.4
9.6
1626
0.3
0.3
0.3
0.3
0.3
50
0.3
0.3
0.3
0.3
0.3
50
2.7
2.7
2.7
2.7
2.7
455
12.2
12.2
12.2
12.2
12.2
2076
Hazardous Air Pollutants
I
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
10227
10227
511
10227
511
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
32142
32142
1607
32142
1607
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart OOOO
Storage Tank is not subject to NSPS OOOO
(See regulatory applicability worksheet for detailed analysis)
6 of 17
K:\PA\2.019\19W E0394.CP1
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and 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 Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
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
NO..,
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
002
1 .O4;e11.11..:2;xr .x I
.:1•••• 1•\l. r-• 7-:Y X4'41,
d 1 1 14
I(
if rI 111'.11*i .::
Process # SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.01 0 lb/1,000 gallons liquid throughput
PM2.5 0.01 0 lb/1,000 gallons liquid throughput
NOx 0.09 0 lb/1,000 gallons liquid throughput
VOC 6.2 95 lb/1,000 gallons liquid throughput
CO 0.40 0 lb/1,000 gallons liquid throughput
Benzene 0.17 95 lb/1,000 gallons liquid throughput
Toluene 0.00 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.52 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 17 K:\PA\2019\19WE0394.CP1
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
Yes
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. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
No
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility, natural gas compressor station' or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC?
Yes
No
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Record keeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
No
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions? from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430?
Storage Tank is not subject to NSPS OOOO
Yes
No
No
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Record keeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year!
RACT Review
RAG review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RAG requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend," "may,'
'should,- and "can," is intended to descnbe APCD interpretations and recommendations Mandatory terminology such as "must and "required- are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
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Source Req
Continue - •
Continue -
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Source is st
Source is st
Continue -
Storage Tar
Storage Tar
Hydrocarbon Loadout Emissions Inventory
005 Liquid Loading
'Facility AIRs ID:
123
County
A03E
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Condensate loading into trucks
Enclosed Combustion Device
Yes
100.0
95
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
287,000 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
287,000
Requested Permit Limit Throughput =
287,000 Barrels (bbl) per year Requested Monthly Throughput =
24375 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
287,000 Barrels (bbl) per year
Loading Loss Equation
L= 12.46*S*P*M/T
2799 Btu/scf
509339 scf/year
1,647 MMBTU per year
1,647 MMBTU per year
1,647 MMBTU per year
Barrels (bbl) per year
The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
' ;r '
:;itbmergec "donna? Service (S=O.6)
P
True Vapor Pressure
7.6324
psia
M
Molecular Weight of Vapors
68
Ib/Ib-mol
T
Liquid Temperature
511.7925
Rankine
L
Loading Losses
7.581330174
lb/1000 gallons
0.318415867 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.004396766
0.0014
lb/bbl
Toluene
0.008479477
0.0027
lb/bbl
Ethylbenzene
0.000125622
0.00004
Ib/bbl
Xylene
0.002198383
0.0007
lb/bbl
n -Hexane
0.033917908
0.0108
lb/bbl
224 TMP
0.000125622
0.00004
Ib/bbl
Emission Factors
Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
0.318416
0.015921
cite Specific - AP -42: Chapter 5.2, Equation 1
Benzene
0.001400
0.000070
Site Specific - AP -42: Chapter 5.2, Equation 2
Toluene
0.002700
0.000135
Site Specific- AP -42: Chapter 5.2, Equation 3
Ethylbenzene
0.000040
0.000002
Site Specific- AP -42: Chapter 5.2, Equation 4
Xylene
0.000700
0.000035
Site Specific - AP -4L Chapter 5.2, Equation 5
Site Specific - AP -42: Chapter 5.2, Equation 6
n -Hexane
0.010800
0.000540
224 TMP
0.000040
0.000002
Site Specific - AP -42: Chapter 5.2, Equation 7
Control Device
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) (Ib/bbl)
Emission Factor Source
(waste heat combusted)
(Volume
Loaded)
PM 10
0.0075
3.70E-05
AP -42 Table 1.4-2 (PM2O/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (50x)
AP -42 Chapter 13.5 Industrial Flares (NCb
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
3.70E -0S
SOx
0.0006
2.92E-06
NOx
0.0680
3.38E-04
CO
0.3100
1.54E-03
9 of 17
K:\PA\2019\19WE0394.CP1
Hydrocarbon Loadout 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)
PM 10
0.01
0.01
0.01
0.01
0.01
1
PM2.5
0.01
0.01
0.01
0.01
0.01
1
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
0.06
0.06
0.06
0.06
0.06
10
VOC
45.69
45.69
2.28
45.69
2.28
388
CO
0.26
0.26
0.26
0.26
0.26
43
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
402
402
20
402
20
Toluene
775
775
39
775
39
Ethylbenzene
11
11
1
11
1
Xylene
201
201
10
201
10
n -Hexane
3100
3100
155
3100
155
224 TMP
11
11
1
11
1
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT - Regulation 3, Part B, Section III.D.2.a
The loadout must be operated with submerged fill to satisfy RAG.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
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
Section 08 - Technical Analysis Notes
1'nrwltlll Frsr:
x .
id
E.
;- t
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
003
Process It
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 Ib/1,000 gallons transferred
5Ox 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 7.6 95 lb/1,000 gallons transferred
CO 0.04 0 lb/1,000 gallons transferred
Benzene 0.03 95 lb/1,000 gallons transferred
Toluene 0.06 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.02 95 lb/1,000 gallons transferred
n -Hexane 0.26 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
10 of 17 K:\PA\2019\19WE0394.CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source i
s in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
yes
yes
no
no
no
yes
Source requires a permit
7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a
The loadout must be operated with submerged fill to satisfy RACT.
Disclaimer
I?
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations. the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend, "may," "should," and "can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
no
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The loadou
The loadou
004 Fugitive equipment leaks
Regulation 7 Information
Operating Hours:
8760 hours/year
Emission Factor Source Screening EFs - EPA -453/R-95-017 Table 2-8
Control Efficiency Source:
Calculations
Service
Component Type
Count
Emission Factor (kglhr-
source)
Table 2-4 Table 2-8
Control (%)
Pollutant
Mass Fraction
Emissions
(tpy)
Reg. 3
Connectors
4068
2.00E-04
1.00E-05
0.0%
VOC
0.32
0.4414964
Flanges
558
3.90E-04
5.70E-06
0.0%
Benzene
0.0007
0.0009658
Open -Ended Lines
11
2.00E-03
1.50E-05
0.0%
Toluene
0.0002
0.0002759
Gas
Pump Seals
0
2.40E-03
3.50E-04
0.0%
Ethylbenzene
0
0
Valves
1727
4.50E-03
2.50E-05
0.0%
Xylenes
0.0001
0.000138
Other
464
8.80E-03
1.20E-04
0.0%
n -Hexane
0.0045
0.0062085
Connectors
353
7.50E-06
7.50E-06
0.0%
VOC
1
0.0351358
Flanges
0
3.90E-07
3.90E-07
0.0%
Benzene
0.0029
0.0001019
Heavy Oil
Open -Ended Lines
0
1.40E-04
7.20E-06
0.0%
Toluene
0.0008
2.811E-05
Pump Seals
Valves
0
118
0.00E+00
8.40E-06
0.00E+00
8.40E-06
0.0%
0.0%
Ethylbenzene
Xylenes
0
0.0005
0
1.757E-05
Other
0
3.20E-05
3.20E-05
0.0%
n -Hexane
0.0188
0.0006606
Connectors
1310
2.10E-04
9.70E-06
0.0%
VOC
1
0.4898371
Flanges
305
1.10E-04
2.40E-06
0.0%
Benzene
0.0029
0.0014205
Light Oil
Open -Ended Lines
0
1.40E-03
1.40E-05
0.0%
Toluene
0.0008
0.0003919
Pump Seals
Valves
3
1361
1.30E-02
2.50E-03
5.10E-04
1.90E-05
0.0%
0.0%
Ethylbenzene
Xylenes
0
0.0005
0
0.0002449
Other
90
7.50E-03
1.10E-04
0.0%
n -Hexane
0.0188
0.0092089
Connectors
692
1.10E-04
1.00E-05
0.0%
VOC
1
0.1394454
Flanges
21
2.90E-06
2.90E-06
0.0%
Benzene
0.0029
0.0004044
Water/Oil
Open -Ended Lines
0
2.50E-04
3.50E-06
0.0%
Toluene
0.0008
0.0001116
Pump Seals
Valves
0
246
2.40E-05
9.80E-05
2.40E-05
9.70E-06
0.0%
0.0%
Ethylbenzene
Xylenes
0
0.0005
0
6.972E-05
Other
86
1.40E-02
5.90E-05
0.0%
n -Hexane
0.0188
0.0026216
None
Emissions Summary Table
Pollutant
Uncontrolled Emissions
Controlled Emissions
Source
VOC
1.11
tpy
1.11
tpy
Screenin E
Benzene
5.79
lb/yr
5.79
lb/yr
Screenin E
Toluene
1.81
lb/yr
1.61
lb/yr
Screenin E
Ethylbenzene
0.00
lb/yr
0.00
lb/yr
Screenin E
Xylenes
0.94
lb/yr
0.94
lb/yr
Screenin E
n -Hexane
37.40
lb/yr
37.40
lb/yr
Screenin E
s - EPA -453/R-95-017 Table 2-8
s - EPA -453/R-95-017 Table 2-8
s - EPA -453/R-95-017 Table 2-8
s - EPA -453/R-95-017 Table 2-8
s - EPA -453/R-95-017 Table 2-8
s - EPA -453/R-95-017 Table 2-8
Separator Venting Emissions Inventory
003 Separator Venting
Facility AIRs ID:
123
County
A03E
Plant
005
Point
Section 02 - Equipment Description Details
Low pressure heater treater and surge drum vapor streams
Detailed Emissions Unit Description:
Enclosed Combustor
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vented
Yes, Meter is currently installed and operational
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
11.70 MMscf per year
95
Requested Permit Limit Throughput =
11.70 MMscf per year
Requested Monthly Throughput =
1
MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
11.7C MMscf per year
Yes
Yes
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)
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
2902 Btu/scf
cf/bbl
Description
Using the more conservative surge drum (basically a VRT) gas stream composition to estimate the combined emissions from the surge drum and heater treater. These have different emission profiles, however using the more
conservative of the two.
MW
51.921
Weight %
Helium
0.0000
CO2
1.0000
N2
0.0100
methane
2.0100
ethane
9.0800
propane
22.7000
isobutane
8.2100
n -butane
213400
isopentane
8.8800
n -pentane
10.3000
cyclopentane
n -Hexane
3.8750
cyclohexane
Other hexanes
5.1700
heptanes
3.4000
methylcyclohexane
224-TMP
0-0^^0
Benzene
0.5:.'
Toluene
1.0100
Ethylbenzene
0.0200
Xylenes
01700
C8+ Heavies
1.8000
Total
VOC Wt %
99.9750
°7.8750
Ib/Ib-mol
Displacement Equation
Ex = Q MW * Xx / C
120,456
701.1
1,386.50
28
364.3
5,323.70
6022.8
35.1
69.3
1.4
18.2
266.2
Emission Factors
Separator Venting
Emission Factor Source
Uncontrolled Controlled
Pollutant
(Ib/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
120384.1128
6019.2056
_ ... _ ., _ : gas analysi..
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
gas analysis
Benzene
684.9736
34.2487
Toluene
1383.6467
69.1823
Ethylbenzene
27.3989
1.3699
Xylene
369.8858
18.4943
n -Hexane
5308.5455
265.4273
224 TMP
0.0000
0.0000
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
21.623
AP -42 Table 1.4-2 (PMi0/PM.2.5)
AP -42 Table 1.4•-2 (PM1O/PM.2.5)
AP -42 Table 1.4-2 (5Ox)
AP -42 Chapter .13.5 industrial Flares (ttO1:)
PM2.5
0.0075
21.623
SOx
0.0006
1.707
NOx
0.0680
197.336
13 of 17
K:\PA\2019\ 19 W E0394. CP 1
Separator Venting Emissions Inventory
CO
I
0.3100
I
899.620 1 AP -42 Chapter 13.S Industrial Flares (CO)
14 of 17 K:\PA\2019\19WE0394.CP1
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
SOx
NOx
VOC
0.13
0.13
0.13
0.13
0.13
21
0.13
0.13
0.13
0.13
0.13
21
0.01
0.01
0.01
0.01
0.01
2
1.15
1.15
1.15
1.15
1.15
196
704.25
704.25
35.21
704.25
35.21
5981
CO
5.26
5.26
5.26
5.26
5.26
894
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
8014
8014
401
8014
401
Toluene
16189
16189
809
16189
809
Ethylbenzene
321
321
16
321
16
Xylene
4328
4328
216
4328
216
n -Hexane
62110
62110
3105
62110
3105
224 TM P
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
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.
aCieVACOnsh3;kds_:
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
- An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
- A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
Yes
15 of 17 K:\PA\2019\19WE0394.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
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.2
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Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
005
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 21.62 0 lb/MMSCF
PM2.5 21.62 0 lb/MMSCF
SOx 1.71 0 lb/MMSCF
NOx 197.34 0 Ib/MMSCF
VOC 120384.11 95 lb/MMSCF
CO 899.62 0 lb/MMSCF
Benzene 684.97 95 Ib/MMSCF
Toluene 1383.65 95 Ib/MMSCF
Ethylbenzene 27.40 95 Ib/MMSCF
Xylene 369.89 95 lb/MMSCF
n -Hexane 5308.55 95 Ib/MMSCF
224 TMP 0.00 95 Ib/MMSCF
16 of 17
K: \PA\2019\ 19 W E0394. C P 1
Separator Venting Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II D.3)?
Not enough information
Ye..
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 S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Yes
Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e - Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. in the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing
regulations, and Air Quality Control Commission regulations. the language of the statute or regulation well 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 descnbe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Source Req
Source Req
Source is st
The contro
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0394
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
Noble Energy Inc.
HURLEY H26 -11-A ECONODE
123/A03E
NESW SEC 26 T3N R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
COND
001
Three (3) 500 bbl fixed roof condensate
storage tanks
Enclosed Combustor
PW
002
Four (4) 500 bbl fixed roof produced water
storage tanks
Enclosed Combustor
LOAD
003
Condensate loading into trucks by
submerged fill
Enclosed Combustor
FUG
004
Fugitive component leak emissions
None
SEP
005
Low pressure heater treater and surge
drum
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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
Page 1 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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, 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 must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit self -certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Divisionmay grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. Point 005: Upon issuance of this permit, the operator must install a flow meter to monitor and
record volumetric flow rate of natural gas routed to the combustors from all separators and
surge vessels covered by this permit.
5. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
6. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
Page 2 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
COND
001
---
---
1.0
---
Point
PW
002
---
2.7
9.6
12.2
Point
LOAD
003
---
---
2.3
---
Point
FUG
004
---
---
1.2
--'-
Fugitive
SEP
005
-
1.2
35.1
5.3
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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
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 owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 3 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
9. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
COND
001
Enclosed Combustor
VOC and HAP
PW
002
Enclosed Combustor
VOC and HAP
LOAD
003
Enclosed Combustor
VOC and HAP
SEP
005
Enclosed Combustor
VOC and HAP
10. Point 004: The operator shall calculate actual emissions from this emissions point based on
representative component counts for the facility with the most recent gas and liquids analyses,
as required in the Compliance Testing and Sampling section of this permit. The operator shall
maintain records of the results of component counts and sampling events used to calculate
actual emissions and the dates, that these counts and events were completed. These records
shall be provided to the Division upon request.
PROCESS LIMITATIONS AND RECORDS
11. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
COND
001
Condensate throughput
287,000 barrels
PW
002
Produced water throughput
1,461,000 barrels
LOAD
003
Condensate loaded
287,000 barrels
SEP
005
Natural gas routed to combustor
11.7 MMscf
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
Page 4 of 14
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
12. Point 005: Upon issuance of this permit, the owner or operator must continuously monitor
and record the volumetric flow rate of natural gas vented from the separator(s) using the flow
meter. The owner or operator must use monthly throughput records to demonstrate
compliance with the process limits contained in this permit and to calculate emissions as
described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
14. Point 003: No owner or operator of a smokeless flare or other flare for the combustion of waste
gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess
of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
15. This source is .subject to the odor requirements of Regulation Number 2. !, (State only
enforceable)
16. Point 003: This source is located in an ozone non -attainment or attainment -maintenance area
and is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted
by submerged fill and emissions must be controlled by a flare.'' (Reference: Regulation 3, Part
B, III.D.2)
17. Point 003 All hydrocarbon liquid loading operations, regardless of size, must be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
18. Point 003: The owner or operator must follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
a. The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loading and unloading. The inspections must occur at least monthly.
Each inspection must be documented in a log available to the Division on request.
b. All compartment hatches at the facility (including thief hatches) must be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers must be weighted and properly seated.
Page 5 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs must be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
19. Point 003: For this controlled loading operation, the owner or operator must follow loading
procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to
(Reference: Regulation 3, Part B, III.D.2):
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c.
Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
20. Point 001: This source is subject to Regulation Number 7, Section XII. The operator must
comply with all applicable requirements of Section XII and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (State only enforceable)
21. Points 001, 002 Et 005: 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 must be enclosed; have no visible emissions during normal operations, as defined
under Regulation Number 7, XVII.A.16; 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, 2014, 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.
22. Points 001 £t 002: The storage tank covered by this permit is subject to the emission control
requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and
operate air pollution control equipment that achieves an average hydrocarbon control
Page 6 of 14
COLORADO
Air Pollution Control Division
Department of Pubiic Health It Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency
of at least 98% for hydrocarbons except where the combustion device has been authorized by
permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation
Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years,
made available to the Division upon request. This control requirement must be met within 90
days of the date that the storage tank commences operation.
23. Points 001 £t 002: The storage tanks covered by this permit are subject to the venting and
Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7,
Section XVII.C.2.
24. Point 005: 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.
25. Point 004: Fugitive component leaks at this well production facility are subject to the Leak
Detection and Repair (LDAR) program requirements, including but not limited to: monitoring,
repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F.
In addition, the operator shall comply with the General Provisions contained in Regulation 7,
Section XVII.B.1.
OPERATING Et MAINTENANCE REQUIREMENTS
26. Points 001, 002, 003 £t 005: Upon startup of these points, the owner or operator must follow
the most recent operating and maintenance (O8M) 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.)
27. Point 004: This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
28. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
29. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
30. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
Page 7 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
GENERAL TERMS AND CONDITIONS
31. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
32. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
33. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
Page 8 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
34. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
35. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action
36. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
37. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
Page 9 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set, forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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)
001
Toluene
108883
374
19
n -Hexane
110543
1,508
75
002
Benzene
71432
10,227
511
n -Hexane
110543
32,142
1,607
003
Benzene
71432
411
21
Toluene
108883
468
38
n -Hexane
110543
3,098
155
005
Benzene
71432
8,157
408
Toluene
108883
16,132
807
Ethylbenzene
100414
326
16
Xylenes
1330207
4,239
212
n -Hexane
110543
61,940
3,098
Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 10 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
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 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
VOC
0.1332
0.0067
108883
Toluene
0.0013
0.00007
110543
n -Hexane
0.00525
0.00026
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
NOx
0.068 lb/MMBtu
0.068 lb/MMBtu
CO
0.31 lb/MMBtu
0.31 lb/MMBtu
VOC
0.262
0.0131
71432
Benzene
0.007
0.00035
110543
n -Hexane
0.022
0.0011 '.
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
VOC
0.3184
0.01592
71432
Benzene
0.0014
0.00007
108883
Toluene
0.0027
0.00014
110543
n -Hexane
0.0108
0.00054
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 7.6324 psia
M (vapor molecular weight) = 68 lb/lb-mol
T (temperature of liquid loaded) = 511.79 °R
Page 11 of 14
COLORADO
Air Pollution Control Division
Department of Public Health &Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 004:
Component
Gas Service
Heavy Oil
Light Oil
SWater/Oil
ervi
Service
Connectors
4068
353
1310
692
Flanges
558
0
305
21
Open-ended Lines
11
0
0
0
Pump Seals
0
0
3
0
Valves
1727
118
1361
246
Other*
464
0
90
86
VOC Content (wt.
fraction)
0.32
1
1
1
Benzene Content (wt.
fraction)
0.0007
0.0029
0.0029
0.0029
Toluene Content (wt.
fraction)
0.0002
0.0008
0.0008 ::
0.0008
Ethylbenzene (wt.0
fraction)
0
0
0
Xylenes Content (wt.
fraction)
0.0001
0.0005
0.0005
0.0005
n -hexane Content
(wt. fraction)
0.0045
0.0188 '
0.0188 ...
0.0188
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
1.00E-05
7.50E-06
9.70E-06
1.00E-05
Flanges
5.70E-06
3.90E-07
2.40E-06
2.90E-06
Open-ended Lines
1.50E-05
7.20E-06
1.40E-05
3.50E-06
Pump Seals
3.50E-04
0.00E+00
5.10E-04
2.40E-05
Valves
2.50E-05
8.40E-06
1.90E-05
9.70E-06
Other
1.20E-04
3.20E-05
1.10E-04
5.90E-05
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC
content from the most recent gas and liquids analyses.
Page 12 of 14
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 005:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf )
Controlled
Emission
Factors
(lb/MMscf)
NOx
0.068 lb/MMBtu
0.068 lb/MMBtu
CO
0.31 lb/MMBtu
0.31 lb/MMBtu
VOC
120;456
6,022.8
71432
Benzene
701.1
35.1
108883
Toluene
1,386.5
69.3
100414
Ethylbenzene
28.0
1.4
1330207
Xylene
364.3
18.2
110543
n -Hexane
5,323.7
266.2
Note: The controlled emissions factors for this point are based on a control' efficiency of 95%.'
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the
five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC a HAP
PSD
True Minor Source
NANSR
Synthetic Minor Source of: VOC
Page 13 of 14
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
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 14 of 14
Condensate Storage Tank(s) APEN
Form APCD-205
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 be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.cotorado.gov/pacific/cdphe/air-permits.
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:
AIRS ID Number: 12.. 3E/ 00k
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: HURLEY H26 -11-A ECONODE T3N-R65W-S26 L01
Site Location: NESW SEC26 T3N R65W
Mailing Address:
(Include Zip Code)
1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@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.
395538
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 I (p
COLORADO
( LepuLiencct Pubik
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
El Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name3
❑ Change permit limit O Transfer of ownership' ❑ Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Condensate Tanks (Off Spec Tanks)
01/02/2019
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
El Exploration & Production (EEtP) site
weeks/year
O Midstream or Downstream (non EftP) site
Will this equipment be operated in any NAAQS nonattainment area?
MI
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
■
Yes
MI
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
■
Yes
O
No
If "yes", identify the stock tank gas -to -oil ratio:
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
I
MI
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIII
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
2iAY
COLORADO
%..,N frEM�mrtm#.f
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit #, and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bbl/year)
Condensate Throughputs
N/A
287,000
From what year is the actual annual amount?
N/A
Average API gravity of sales oil: 59.51 degrees
Tank design:
El Fixed roof O Internal floating roof
RVP of sales oil:
7.9 (Ran tanks at 8)
❑ External floating roof
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
^- Date of First
Production
(month/year)
Storage
Tank' ID
3
1500
1/2019
Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites On
y)
API Number
Name of Well
Newly Reported Well
- -
SEE ATTACHED
■
- -
■
- -
U
- -
■
- -
■
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EitP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1946, -104.6321
Operator Stack!
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
El Upward 0 Downward
❑ Horizontal
0 Other (describe):
Indicate the stack opening and size: (check one)
9 Circular
❑ Square/rectangle
❑ Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3
COLORADO
i awaracracd axtc
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
• Vapor
❑ Recovery
Unit (VRU):
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
%
❑ Combustion
8
Device:
Pollutants Controlled:
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: El Yes 0 No Pilot Burner Rating:
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 2 psig
Describe the separation process between the well and the storage tanks: Liquids go from well to HP
separators, then to LP separators (heater treaters), then to a surge drum, then to a LACT. These tanks
only take off -spec oil rejected from the LACT. The pilot emissions from burners associated
with tanks and load -out are accounted for in heater treater and surge tank calculations (shared burners).
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I Ay I`tpa'°°rt"Pettit
HiultlSF.Nrcxuranl
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8- 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)
VOC
Enclosed Burner
95%
NOx
CO
HAPs
Enclosed Burner
95%
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factory
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
8
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
on_
Emissions •
(Tons/year)
VOC
0.1332
lb/bbl
HYSYS/ranks4.0.9d
19.11 -
0.96
NOx
0.068
MMBTU/hr
AP -42
0.00
0.03
CO
0.31
MMBTU/hr
AP -42
0.00
0.15
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
( )
Number
Emission Factor?
Actual Annual Emissions
Uncontrolled'
Basis
Units•
Source
(AP -42,
Mfg. etc)
g
Uncontrolled
Emissions
(Pounds/year)
( y )
Controlled
Emissions g
, (Pounds/year)
Benzene
71432
0.00070
Ib/bbl
HYSYS/Tanks4.0.9d
200
10
Toluene
108883
0.00130
lb/bbl
HYSYS/Tanks4.0.9d
374
19
Ethylbenzene
100414
0.00002
lb/bbl
HYSYS/Tanks4.0.9d
4
0
Xylene
1330207
0.00003
lb/bbl
HYSYSRanka4.0.9d
93
5
n -Hexane
110543
0.00525
lb/bbl
HYSYS/Tanks4.0.9d
1508 -
75
2,2,4-
Trimethylpentane
540841
0.0000
lb/bbl
HYSYSrranks4.0.94
0.00
0.00
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5
COLORADO
r g$O%aE v1.cMrn Ai
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in fulE\compliance with each condition of the applicable General Permit.
04/01/2019
Signs ure of Legally Authorizerson (not a vendor or consultant)
Allison Satterfield
Date
Environmental Scientist
Name (print) Title
Check the appropriate box to request a copy of the:
ID Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
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:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
6I AY
COLORADO
Departmenrot
Nmv`Ip bEmm:rcnnimf
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
Noble Energy, Inc.
Source Name:
HURLEY 1126-11-A ECONODE T3N-R65W-S26 L01
Emissions Source AIRS ID2:
123 /ACE 001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 46770
HURLEY H26-712
,I
05 -123 - 46765
HURLEY 1126-717
►./
05 -123 - 46769
HURLEY 1326-724
r
05 -123 - 46763
HURLEY H26-730
0
05 -123 - 46762
HURLEY 1126-736
►.1
05 -123 - 46761
HURLEY H26-743
►�1
05 =123 - 46768
HURLEY 1326-750
►�I
05 -123 - 46772
HURLEY 1126-756
r
05 -123 - 46767
HURLEY 1326-762
.1
05 -123 - 46766
HURLEY 1326-768
/ 1
05 -123 - 46771
HURLEY 1126-776
05 -123 - 46764
HURLEY H26-783
►�I
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
APEN-Addendum Tank Battery 1
Produced Water Storage Tank(s) APR - MR
APEN - Form APCD-207
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 be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Qov/pacific/cdphe/air-permits.
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:
Numbe
CkW Ci� AIRS ID 025 7 2�
��
1 r:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: HURLEY H26 -11-A ECONODE T3N-R65W-S26 L01
Site Location: NESW SEC26 T3N R65W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@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.
355537
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1
;COLORADO
i Hee. SEnC.envwn:
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
O Request coverage under a General Permit
O GP05 O GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
- OR
❑ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment O Change company name3
❑ Change permit limit O Transfer of ownership' ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Produced Water Storage
1/2/2019
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7
Storage tank(s) located at: Q Exploration Et Production (EEtP) site
days/week
52
weeks/year
❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
p
Yes
❑
No
Are Flash Emissions anticipated from these storage tanks?
✓
Yes
❑
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
❑
Yes
No
✓
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
❑
Yes
✓
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)•
805 series rules? If so, submit Form APCD-105.
Yes
No
✓
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
❑
No
✓
:COLORADO
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2 I =
❑✓ Upward
❑ Horizontal
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount '
(bbl /year)
Requested AnnualPermit Limits
(bbl/year)
Produced Water Throughput:
1,461,000
From what year is the actual annual amount?
Tank design:
❑✓ Fixed roof
N/A
O Internal floating roof
0 External floating roof
'Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
4
2000
1/2019
Wells Serviced by this Storage Tank or Tank Battery(' (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
-
SEE ATTACHED
❑
_
❑
_
❑
- -
❑
5 Requested values will become permit limitations. Requested lirnit(s) should consider future growth.
6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1946, -104.6321
Operator -Stack''
ID No.
''Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
['Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
O Other (describe):
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3
L.ep sire rW.FaEtfe
RsvLk fr P :uiMMvnnntr!
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
O Recovery
Unit (VRIJ):
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Burner Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: 0 Yes O No Pilot Burner Rating:
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? — 300, 25, 2 psig
Describe the separation process between the well and the storage tanks: Liquids from wells go to
HP separators, LP separators (heater treaters), and surge drums and all feed into the produced
water storage tanks. The pilot emissions from burners associated with condensate and water tanks
and load -out are accounted for in heater treater and surge drum (shared burners).
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4
COLORADO
➢culmmcotvettic
1.1.2RSEnv.',.monl
Permit Number:
AIRS ID Number:
[Leave blank unless APED has already assigned a permit # and AIRS ID]
Section 8 - 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)
VOC
Enclosed Burner
95%
NOx
CO
HAPs
Enclosed Burner
95%
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
0.2620
lb/bbl
CDPHE
191.39 —
9.57 ,
NOx
0.068
Ib/MMBTU
AP -42
0.00
2.68 -
CO
0.31
Ib/MMBTU
AP -42
0.00
12.20 —
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
(CAS
( )
)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
$
Uncontrolled
- -
Emissions
(pounds/year)
y )
Controlled
Emissions8
(pounds/year)
Benzene
71432
0.007
lb/bbl
CDPHE
10227.00 -
S i 1 .,5.401*"
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.022
lb/bbl
CDPHE
32142.00--
K9o'
2,2,4
Trimethylpentane
540841
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
5I
COLORADO
ame,.toeaunk
senor ..m
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
4/1/2019
Signature of Legally AuthorizePerson (not a vendor or consultant) Date
Allison Satterfield Environmental Scientist
Name (print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
E✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
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 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
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:
https://www.colorado.Rov/cdphe/apcd
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
COLORADO
61 • «�
viEcvytir
Hydrocarbon Liquid Loading APEN
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
Apga2Q19
rk NT'
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for hydrocarbon liquid loading only. 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, glycol dehydration unit,
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.Qov/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: Ck4 G 0 Z3
3a� AIRS ID Number: '
[Leave blank unless A CD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: HURLEY H26 -11-A ECONODE T3N-R65W-S26 L01
Site Location: NESW SEC26 T3N R65W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@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.
395535
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1
COLORADO
Na:lb k EnaBnnrrtv:
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
El Request coverage under construction permit
0 Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: The pilot emissions from burners associated
with tanks and load -out are accounted for in heater treater and surge tank calculations (shared burners).
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: Truck load -out of condensate
Company equipment Identification No. (optional):
For existing sources, operation began on:
1/2/2019
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
MI
Yes
I
No
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
a
p
Does this source load gasoline into transport vehicles?
Yes
No
■
(9
Is this source located at an oil and gas exploration and production site?
Yes
No
MI
•
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
MI
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
MI
■
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
No
■
MI
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
21 AY
MAIM IT ElVer.lit.!
COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate 0 Crude Oil 0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
287,000
bbl/year
This product is loaded from tanks at this facility into:
(e.g. "rail tank cars" or "tank trucks")
Actual Volume Loaded:
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:Average
0.6
temperature of
bulk liquid loading:
51.7925
°F
True Vapor Pressure:
7.6324
Psia @ 60 °F
Molecular weight of
displaced vapors:
GQ
DO
lb/lb-mot
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
3' AY
COLORADO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1946, -104.6321
0 erator
r-
'Discharge Height Above
Ground .eyes
?feet)
e'er �
•
l+o a
ft/ Velocity
!
Indicate the direction of the stack outlet: (check one)
O Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
Circular
❑ 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.
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency:
❑ Combustion
Device:
Used for control of: VOC and HAPs
Rating: MMBtu/hr
hr
Type: Enclosed Burner Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature: °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4
COl.of2a DO
HRa:tnfr FnY cnreti4
Permit Number:
AIRS ID Number:
[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 Burner
95%
HAPs
Enclosed Burner
95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tonslyear)
Controlled
Emissions6
, (tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NO.
0.068
Ib/MMBTU
AP -42
0.00
0.06
CO
0.310
Ib/MMBTU
AP -42
0.00
0.26
VOC
0.3184
lb/bbl
AP -42
45.69 --
2.28 —
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
(CAS)
( )
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
(P y )
Controlled
Emissions6
(pounds/year)
Benzene
71432
0.0014
lb/bbl
AP -42
411 —
21 -
Toluene
108883
0.0027
lb/bbl
AP -42
768 -
38 -
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0108
lb/bbl
AP -42
3098
155 -
2,2,4-
Trimethylpentane
540841
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-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5
COLORADO
bcpastaacgt of Public
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ft 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. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
4/1/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Allison Satterfield Environmental Scientist
Name (print) Title
Check the appropriate box to request a copy of the:
❑� Draft permit prior to issuance
▪ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
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:
https://www.colorado.gov/cdphe/apcd
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 A
COLORADO
Devatxs.o: Public
Hea'NS>iv_ronmam
Fugitive Component Leak Emissions APEN
Form APCD-203
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 be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
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:
AIRS ID Number: 123 /foi/QOu
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Noble Energy Inc.
Site Name: HURLEY H26 -11-A ECONODE T3N-R65W-S26 L01
Site Location: NESW SEC26 T3N R65W
Mailing
p i g Address: 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location WeIA
ld
County:
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@nblenergy.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
395546
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 1
COLORADO
Ham wra c
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
Ei NEW permit OR newly -reported emission source (check one below)
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change process or equipment 0 Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 ❑ Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
Company equipment Identification No. (optional): Fugitives
For existing sources, operation began on: 1/2/2019
For new 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:
Facility Type:
❑✓ Well Production Facility5
❑ Natural Gas Compressor Stations
0 Natural Gas Processing Plants
❑ Other (describe):
hours/day
days/week weeks/year
5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 2
COLORADO
teyu.tment Pulaic
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Regulatory Information
What is the date that the equipment commenced construction? 1/2/2019
Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes ❑ No
Will this equipment be located at a stationary source that is considered a ❑ Yes ❑✓ No
Major Source of Hazardous Air Pollutant (HAP) emissions?
Are there wet seal centrifugal compressors or reciprocating compressors ' Yes ❑ No
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? 0 Yes ❑✓ No
Is this equipment subject to 40 CFR Part 60, Subpart 0000? 0 Yes ❑✓ No
Is this equipment subject to 40 CFR Part 60, Subpart 0000a? ❑✓ Yes 0 No
Is this equipment subject to 40 CFR Part 63, Subpart HH? 0 Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? 0 Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑✓ Yes ❑ No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑✓ Yes ❑ No
Section 5 - Stream Constituents
❑✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight % content of each applicable stream.
VOC
(wt %)
Benzene
(wt %)
Toluene
Stream Tnme(ylpp
(wt %) '
Ethylbenzene
(wt V
Xylene
(wt %)
n -Hexane '
(wt %)
2,2,4
ntane
w
Gas
32.00
0.07
0.02
0.00
0.01
0.45
0.00
Oil
(or HeavyHeavy Liquid)
100
0.29
0.08
0.00
0.05
1.88
0.00
i
(or LightLight LiqOluid)
100
0.29
0.08
0.00
0.05
1.88
0.00
Water/Oil
100
0.29
0.08
0.00
0.05
1.88
0.00
Section 6 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1946, -104.6321
Attach a topographic site map showing location
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 3
COLORADO
0cyt'.ment a4 PO:2k
ftsa!ehREnsYermrnna:
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
❑ LDAR per 40 CFR Part 60, Subpart KKK
0 Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump
0 Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump
❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa
0 Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81%
connectors
❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F
❑ Other6:
❑ No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 4
;COLORADO
1 bcpirtwattat Pu*b'
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
❑ Table 2-4 was used to estimate emissions.
❑✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions.
Use the following table to report the component count used to calculate emissions. The component counts listed
in the following table are representative of:
❑✓ Estimated Component Count
❑ Actual Component Count conducted on the following date:
Service
Equipment Type
Connectors
Flanges
Open -Ended
Lines
Pump Seals
Valves
Other9
Gas
Counts
4068
558
11
0
1727
464
Emission Factor
1.00E-5
5.70E-6
1.5E-5
2.50E-5
1.20E-4
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
Heavy Oil (or Heavy Liquid)
Counts
353
0
0
0
118
0
Emission Factor
7.50E-6
8.40E-6
Units
kg/hr/source
kg/hr/source
Light Oil (or Light Liquid)
Counts
131O
305
0
3
1361
90
Emission Factor
9.70E-6
2.4E-6
5.10E-4
1.90E-5
1.10E-4
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
Water/Oil
Counts
692
21
0
0
246
86
Emission Factor
1.00E-5
2.90E-6
9.70E-6
5.90E-5
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual
Calendar Year Emissions" below.
9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump
seals, or valves.
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 5 &IdT�96E."1'
Huttiriv:meuna,!
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source:
Use the data reported in Section 8 to calculate these emissions.
Chemical Name
CAS
Number
Actual Annual Emissions
mt ) Permit Emission
Requested Annual Limit(s)11
( ti
Uncontrolled
(tons/year)
Controlled io
(tons/year)
Uncontrolled
(tons/year)
Controlled
(tons/year)
voc
1.11 .-'
1.11
Does the emissions source have any actual emissions of non -criteria pollutants
(e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
El Yes No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
CAS
Number
Actual Annual Emissions
Limit(s)11 Requested Annual Permit Emission
Uncontrolled
(Ibslyear)
Controlled io
(lbs/year)
Uncontrolled
(Ibs/year)
Controlled
Ohs/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2,2,4
Trimethylpentane
540841
Other:
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
ii Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count
variability, and gas composition variability.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 6 I
COLORADO
Dc,rtmcns a: Public
Haiith Fr Env:myat>.
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
l
4-1-2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Allison Satterfield
Environmental Scientist
Name (print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
E✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
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-B1
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:
https: //www.colorado.Rov/cdphe/apcd
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
!COLORADO
7 I LEW Ilt=roM ,
Gas Venting APEN - Form APCIY-212919
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 be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for 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.Rov/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: , `k.WCO3 Ci AIRS ID Number: 12.3 Avr33 a- 6 O
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: HURLEY H26 -11-A ECONODE T3N-R65W-S26 L01
Site Location: NESW SEC26 T3N R65W
Mailing Address: 1625 Broadway, Suite 2200
(Include Zip Code) y
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver, CO 80202 Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@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.
3B5536
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit tt and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
O Change permit limit ❑ Transfer of ownership4 ❑ 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 Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
streams
Heater treater (LP) and surge drum gas
Company equipment Identification No. (optional):
For existing sources, operation began on:
1/2/2019
For new, modified, or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
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
❑ Yes
El Yes
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2.1
No
No
No
COLORADO
tr .w.L t ip
KW' h4EF.ra4¢nn.¢rrt
Permit Number. AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID;
Section 4 - Process Equipment Information
El Gas/Liquid Separator
❑ Well Head Casing
O 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?
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ Yes ❑ No
Vent Gas
Heating Value:
2902
BTU/SCF
Requested:
11.70
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
51.921
VOC (Weight %)
87.88%
Benzene (Weight %)
0.51 %
Toluene (Weight %)
1.01%
Ethylbenzene (Weight %)
0.02%
Xylene (Weight %)
0.27%
n -Hexane (Weight %)
3.88%
2,2,4-Trimethylpentane (Weight %)
0.00%
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX is n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
O
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
i
r
Geographical Coordinates.
(Latitude/Longitude or UTM)
40.1946, -104.6321
.._
Operator
t)p
_a. e I
Stack ID No.
Discharge Height
�.. _
, Above Ground Level t
(Feet)
_� Temp.
l'F) `
fio�nr Rate
_a_�
(ACPA —
__.
Velocity
w n
(ftiaec),
Zeeco
30
Variable
Variable
Variable
Indicate the direction of the stack outlet: (check one)
▪ Upward
O Horizontal
0 Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter. (inches):
O 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.
0 VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control -Efficiency:
VRU Downtime or Bypassed:
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
hr
Type: VOC Burner Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 4
ftAmer.ot Public
Permit Number:
AIRS ID Number:
[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
VOC Burner
95%
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
7.6
Ib/MMscf
AP -42
0.00
0.00
SOx
0.6
Ib/MMscf
AP -42
0.00
0.00
NO.
0.068, 0.1
Ib/MMBTU,Ib/Mscf
AP -42
1.17
1.17
CO
0.310, 0.084
Ib/MMBTU, lb/Mscf
AP -42
5.25
5.25
VOC
120.4568, 0.0055
lb/Mscf
HYSYS, AP -42
700.74 -
35.04 —
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical
Emission Factor
Actual Annual Emissions
Chemical Name
Abstract
Uncontrolled
Source
Uncontrolled
Controlled
Service (CAS)
Number
Basis
Units
(AP -42,
Mfg., etc.)
Emissions
(pounds/year)
Emissions6
(pounds/year)
Benzene
71432
0.7011
lb/Mscf
HYSYS/AP-42
8157 —
408
Toluene
108883
1.3865
lb/Mscf
HYSYS/AP-42
16132 -
807
Ethylbenzene
100414
0.0280
lb/Mscf
HYSYS/AP-42
326.
16
Xylene
1330207
0.3643
lb/Mscf
HYSYS/AP-42
4239 "
212
n -Hexane
110543
5.3237
lb/Mscf
HYSYS/AP-42
61940 -
3098
2,2,4-
Trimethylpentane
540841
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
COLORADO
beiartmeneoe Pavan
Health 5EnW.lc-Tut .
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit tt 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.
4/1/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Allison Satterfield
Environmental Scientist
Name (please print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
Q 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-B1
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:
https://www.colorado.Rov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018 6
COLORADO
Hw `�Senntof P.1t
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