HomeMy WebLinkAbout20193073.tiffCOLORADO
Department of Public
Health & Environment
Janessa Salgado
Janessa.salgado@nblenergy.com
July 2, 2019
Ref: Permit No: 19WE0437 and 19WE0438
SUBJECT: Draft Permit and Related Public Notice
Dear Janessa Salgado :
RECEIVED
JUL 0 9 2019
WELD COUNTY
COMMISSIONERS
The Air Pollution Control Division has prepared a public comment package for the Noble Energy, Inc.
- JOHNSON ROBERTSON REIS UPRR PAN AM. The thirty (30) day public notice period will begin on July
4, 2019. This public notice period is being provided in accordance with the Colorado Air Pollution
Prevention and Control Act and Regulation No. 3, Part B, Section III.C.
For thirty (30) days from the beginning of the notice period, copies will be available for public
inspection at the respective county clerk's office(s). During the thirty -day period, please review
your permit and call your permit engineer with any questions or concerns you may have.
This application is complete and in proper form. It meets the requirements of the Colorado Air
Quality Control Commission's Regulation No. 3, Part B, Section III.B.
Sincerely,
Bradley Eades
Stationary Sources
Air Pollution Control Division
Enclosures
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
(/JL Rwiew
O7(oaLtIlei
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2019-3073
atls�fN
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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:
On July 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - JOHNSON ROBERTSON REIS UPRR PAN AM. 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
a
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - JOHNSON ROBERTSON REIS UPRR PAN AM - 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: JOHNSON ROBERTSON REIS UPRR PAN AM
Oil and gas well production facility
NWNE Sec. 19, T2N, R64W
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):
• 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 drafts of Construction Permit 19WE0437 and 19WE0438
have been filed with the Weld County Clerk's office. Copies of the draft permits 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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
11
rit
COLORADO
Department of Public
Health ft Environment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Bradley Eades
Package #: 396891
Received Date: 4/23/2019
Review Start Date: 6/14/2019
Section 01 - Facility Information
Company Name: Noble Energy, Inc
County AIRS ID: 123
Quadrant
Section
Township
Range
NENW
11
2N
64W
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
8757
Johnson Robertson REIS UPRR PAN AM
NENW quadrant of Section 11, Township 2N, Range 64WW
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? n Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
007
Liquid Loading
Loadout
Yes
12WE2752
2
No
Permit
Modification
010
Separator Venting
LP
Yes
19WE0437
1
Yes
Permit Initial
Issuance
011
Separator Venting
VRT
Yes
19WE0438
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Noble is reporting two (2) new emission points at an existing well production facility. This plant was previously owned and operate d by KMG and an ownership transfer was
processed in 2014. With this permitting action, Noble is requesting construction permits to author ze flaring of gas from the low pressure (LP) Separators (i.e. 3 -phase section
of HLP separators) and VRT. In addition, Noble is updating throughput for truck loadout. Emission control for loadout vapors is being permitted.
Applicant indicates that the VRT was previously reported as part of the tank vapor capture system. However, with this request, the VRT will be reported separately from the
tank and assigned its own emission point. Upon review of records, I agree that this is the case and the request in this permitting action (to separately report the VRT) is
preferred by the Division. The previous permit engineer had assigned two (2) separate operating scenarios at the tank, one of which includes vapors from VRT during VRU
downtime. The VRT is identified as a constant -level , flow -through knockout vessel. This aligns with equipment identified by the Division as a VRT. In this issuance, I will permit
the VRT as an individual emission point.
Gas from the LP separator was previously routed to sales gas line or used on -site as fuel. With this modification, Noble is requesting to route all gas to the VRT.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
No
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
No
If yes, explain what programs and which pollutants herE SO2 NOx CO
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
VOC
J
PM2.5 PM10 TSP HAPs
n
Hydrocarbon Loadout Emissions Inventory
007 Liquid Loading
Facility AIRs ID:
123
County
8757
Plant
007
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Loadout of condensate to tank trucks using submerged fill
Enclosed combustor
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 =
17,272 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
17,272 Barrels (bbl) per year
Requested Permit Limit Throughput =
50,000
Barrels (bbl) per year
Requested Monthly Throughput =
4217 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 =
50,000 Barrels (bbl) per year
2255 Btu/scf
51546 scf/year
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?
Loading Loss Equation
L = 12.46*S*P*M/T
40 MMBTU per year
116 MMBTU per year
116 MMBTU per year
The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
-
AP -42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Normal Service (S=0.6)
P
True Vapor Pressure
4.6
psia
Approved in issuance 1
M
Molecular Weight of Vapors
41
Ib/Ib-mol
Approved in issuance 1
T
Liquid Temperature
531
Rankine
Approved in issuance 1
L
Loading Losses
2.655317514
lb/1000 gallons
Approved in issuance 1
0.111523336 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.003407359
0.00038
lb/bbl
Approved in issuance 1
Toluene
0
Ib/bbl
Approved in issuance 1
Ethylbenzene
0
Ib/bbl
Approved in issuance 1
Xylene
0
lb/bbl
Approved in issuance 1
n -Hexane
0.02116149
0.00236
lb/bbl
Approved in issuance 1
224 TMP
0
lb/bbl
Approved in issuance 1
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
1.12E-01
5.58E-03
Site Specific - AP -42: Chapter 5.2, Equation 1
Benzene
3.80E-04
1.90E-05
Site Specific - AP -42: Chapter 5.2, Equation 1
Toluene
0.00E+00
0.00E+00
Site Specific- AP -42: Chapter 5.2, Equation 1
Ethylbenzene
0.00E+00
0.00E+00
Site Specific - AP -42: Chapter 5.2, Equation 1
Xylene
0.00E+00
0.00E+00
Site Specific - AP -42: Chapter 5.2, Equation 1
Site Specific - AP -42: Chapter 5.2, Equation 1
Site Specific- AP -42: Chapter 5.2, Equation 1
n -Hexane
2.36E-03
1.18E-04
224 TMP
0.00E+00
0.00E+00
Control Device
Uncontrolled Uncontrolled
Emission Factor Source
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0.0075
1.73E-05
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
1.73E-05
SOx
0.0006
1.37E-06
NOx
0.0680
1.58E-04
CO
0.3100
7.21E-04
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Hydrocarbon LoadoLt 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
0.00
0.00
0.00
0.00
0.00
0
PM2.5
0.00
0.00
0.00
0.00
0.00
0
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
0.00
0.00
0.00
0.00
0.00
1
VOC
2.79
0.96
0.05
2.79
0.14
24
CO
0.02
0.01
0.01
0.02
0.02
3
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
19
7
0
19
1
Toluene
0
0
0
0
0
Ethylbenzene
0
0
0
0
0
Xylene
0
0
0
0
0
n -Hexane
118
41
2
118
6
224 TMP
0
0
0
0
0
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 RACT.
(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
The applicant is not requesting any changes to the SSEF's that were approved with issuance 1. Applicant is only requesting reduction in throughput and emission limits and addition of control equipment.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
007
Process #
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Pollutant
PM10
PM2.5
SOx
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.00
0.00
2.7
0.02
0.01
0.00
0.00
0.00
0.06
0.00
Control %
0
0
0
0
95
0
95
95
95
95
95
95
Units
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
lb/1,000 gallons
Ib/1,000 gallons
Ib/1,000 gallons
lb/1,000 gallons
transferred
transferred
transferred
transferred
transferred
transferred
transferred
transferred
transferred
transferred
transferred
transferred
3 of 12 K:\PA\2019\19WE0437.CP1.xlsm
Hydrocarbon Loadout 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. 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 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 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
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)?
No
The loadout must be operated with submerged fill to satisfy RACT.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,"'may,"'should,"and "can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Separator Venting Emissions Inventory
010 Separator Venting
Facility AIRS ID:
123
County
8757 010
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Flaring of low-pressure gas from the low pressure section of four (4) high/low pressure separators (HIP Separators).
enclosed combustor
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
5.49 MMscf per year
95
Requested Permit Limit Throughput = 5.49 MMscf per year Requested Monthly Throughput =
0 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
5.49 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
2191
MIS
Description
Btu/scf
scf/bbl
A pressurized liquid sample was pulled from the outlet of the LP separator associated with the Robertson 15C-19HZ well. Applicant used pressurized liquid sample composition to model emissions from the LP separator and
VRT. Applicant applied a buffer of 50% to resulting emission factors to account for gas variability. The LP separator operates at '"40 psig.
MW
39.24826
Weight %
Helium
0.00
CO2
1.76
N2
1.04
methane
4.05
ethane
25.63
propane
43.28
isobutane
5.28
n -butane
12.09
isopentane
1.68
n -pentane
1.45
cyclopentane
0.32
n -Hexane
0.86
cyclohexane
1.17
Other hexanes
0.00
heptanes
0.51
methylcyclohexane
0.28
224 -IMP
0.03
Benzene
0.12
Toluene
0.11
Ethylbenzene
0.01
Xylenes
0.05
C8+ Heavies
0.31
Total
100.03
VOC Wt %
67.55
Ib/Ib-mol Displacement Equation
Ex=Q•MW•Xx/C
5 of 12 K:\PA\2019\19WE0437.CP1.xlsm
Separator Venting Emissions Inventory
:mission Factors
separator Venting (harecf cm modeled stre''-
Pollutant
Uncontrolled Controlled
Emission Factor Source
(Ib/MMscff (Ib/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
69953.0333
3497.6517
inillillir HYSYS V
HYSYS
Benzene
124.2689
6.2134
Toluene
113.9132
5.6957
HYSYS
HYSYS
HYSYS
HYSYS
HYSYS
Ethylbenzene
10.3557
0.5178
Xylenc-
X1.7787
2.5889
n -Hexane
890.5938
44.5297
224 IMP
31.0672
1.5534
EMISSION FACTORS PROPOSED BY APPLICANT
mission I ,ic tc I Soiir c c
Pollutantf
Uncontrolled Controlled
lb/MMscf lb/MMscf
(Gas Throughput)
(Gas Throughput)
VOC
104922.3000
5246.1150
HYSYS + 50% Buffer
Benzene
185.6237
9.2812
HYSYS + 50% Buffer
Toluene
182.5270
9.1263
HYSYS + 50% Buffer
Ethylbenzene
0.0000
0.0000
HYSYS + 50% Buffer
Xylene
84.1591
4.2080
HYSYS + 50% Buffer
n -Hexane
1331.0624
66.5531
HYSYS + 50% Buffer
224 TMP
45.1763
2.2588
HYSYS + 50% Buffer
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
16.325
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
16.325
SOx
0.0006
1.289
NOx
0.0680
148.988
CO
0.3100
679.210
Section 05 - Emissions Inventory
BASED ON MODELED COMPOSITION
(Emission factors in this table have buffer applied)
Criteria Pollutants
Er.
uncontrolled
Actual
Uncontrolled Controlled
is/year)
! Incontroiled Controller
'ar:
Controlled
ith)
PM 10
- PM2.5
SOx
NOx
VOC
CO
0.04
0.04
0.04
0.04
0.04
3
0.04
0.04
0.04
0.04
0.04
8
0.00
0.00
0.00
0.00
0.00
1
0.41
0.41
0.41
0.41
0.4 I
59
192.01
192.01
9.60
_92.01
9.60
1531
1 .86
1.86
1.86
1.86
1.86
317
Hazardous Air Pollutan'
P . _ :,al to uric
Uncontrolled
"., 3r)
7, <<.;.:I Lin :,;;uns
uncontrolled Controlled
`swear) (lbs/year'
Requested Permit Limits
Uncontrolled Controlled
ios,'. e-, ',s/year'
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
682
34
682
34
625
625
31
625
31
57
57
3
57
284
14
284
14
.1889
244
4889
244
:
171
9
_ 171
9 _
AS
CALCULATED BY APPLICANT
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Fequested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
0.04
0.04
8
0.04
0.04
8
SOx
0.00
0.00
1
NOx
0.41
0.41
69
VOC
287.99
14.40
2446
CO
1.86
1.86
317
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
1019.00
50.95
Toluene
1002.00
50.10
Ethylbenzene
0.00
_
0.00
Xylene
462.00
23.10
n -Hexane
7307.00
365.35
224 TMP
248.00
12.40
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
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Separator Venting Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to coiled 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
'See technical analysis notes
Section 08 - Technical Analysis Notes
*I will allow use of the buffered factors proposed by the applicant. The HYSYS simulation used to model emissions required the use of back -blending the pressurized liquid sample to simulate liquid composition upstream of the low
pressure separator. The methods used produce a LP gas composition as represented in the analysis above. The operator alsc proivded a 50% buffer to all hydrcarbon emission factors .
*Although the source did not have a site -specific gas sample, I will not require one be submitted with self -certification since the emissions factors with the 50% buffer result in emission profile that is much more conservative than what I
have generally seen from similar equipment at similar operating conditions, and the source is not close to Major Source thresholds. Therefore, an initial site -specific sample will not be required.
*Appplicant confirmed that no wells at the site have been constructed, hydrolically fractured, nor recompleted since August 1, 2014.
Section 09 - Inventory SCC CodinR and Emissions Factors
AIRS Point #
010
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
NOx 148.99 0 Ib/MMSCF
VOC 104922.30 95 Ib/MMSCF
CO 679.21 0 Ib/MMSCF
Benzene 185.62 95 Ib/MMSCF
Toluene 182.53 95 lb/MMSCF
Ethylbenzene 0.00 95 Ib/MMSCF
Xylene 84.16 95 Ib/MMSCF
n -Hexane 1331.06 95 Ib/MMSCF
224 TMP 45.18 95 Ib/MMSCF
7 of 12 K:\PA\2019\19WE0437.CP1.xIsm
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
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
Yes
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?
Source is not subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
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
No
r
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 A PCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Av
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Separator Venting Emissions Inventory
010 Separator Venting
Facility AIRs ID:
123
County
8757
Plant
011
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Flaring of gas from one (1) Vapor Recovery Tower (VRT)
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 =
5.01 MMscf per year
95
Requested Permit Limit Throughput =
5.01
MMscf per year
Requested Monthly Throughput =
0.43 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
5.01 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
2609 Btu/scf
scf/bbl
A pressurized liquid sample was pulled from the outlet of the LP separator associated with the Robertson 15C -19H1 well. Applicant used pressurized liquid sample composition to model emissions from the LP separator and
VRT. Applicant applied a buffer of 50% to resulting emission factors to account for gas variability. The LP separator operates at "40 psig.
MW
46.1903
Weight %
Helium
0.00
CO2
0.49
N2
0.04
methane
0.4S
ethane
13.00
propane
48.19
isobutane
7.88
n -butane
19.04
isopentane
2.80
n -pentane
2.39
cyclopentane
0.53
n -Hexane
1.35
cyclohexane
1.83
Other hexanes
0.00
heptanes
0.74
methylcyclohexane
0.42
224-TMP
0.05
Benzene
0.19
Toluene
0.15
Ethylbenzene
0.02
Xylenes
0.06
C8+ Heavies
0.38
Total
100.Uu
VOC Wt %
86.02
Ib/Ib-mol
Displacement Equation
Ex=QMW • Xx / C
9 of 12 K:\PA\2019\19WE0437.CP1.xlsm
Separator Venting Emissions Inventory
separator Venting (based on modeled stream)
Pollutant
Uncontrolled Controlled
(Ib/MMscf) (Ib/MMscf)
Emission Factor Source
Gas Throughput)
(Gas Throughput)
VOC
104336.1374
5241.8069
Benzene
231.5609
:1.5780
Toluene
182.8112
9.1406
Ethylbenzene
24.3748
1.2187
Xylene
73.1245
3.6562
,
n -Hexane
1645.3009
82.2650
?24 TMP
60.9371
.. _ ......
EMISSION FACTORS PROPOSED BY APPLICANT
Pollutant
Uncontrolled Controlled
lb/MMscf lb/MMscf
Emission Factor Source
(Gas Throughput)
(Gas Throughput)
VOC
157359.6000
7867.9800
Benzene
340.3194
17.0160
Toluene
291.8164
14.5908
Ethylbenzene
42.1158
2.1058
Xylene
126.1477
6.3074
n -Hexane
2457.0858
122.8543
224 TMP
90.4192
4.5210
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
19.440
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (Sax)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
19.440
SOx
0.0006
1.535
NOx
0.0680
177.412
CO
0.3100
808.790
Section 05 - Emissions Inventory
BASED ON MODELED COMPOSITION
(Emission factors in this table have buffer applied)
Criteria Pollutants
•
Uncontrolled
?tons/ye-!r`
Actual Emissions
Uncontrolled Controlled
r.ons/year) (tons/year)
E.:,..: ., .: Perrr.. ,..r,i,,
Uncontrolled Controlled
'.ins/year) (tons/year
-:equestc..:..:.::,:., ,..
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.05
0.05
0.05
0.05
0.05
8
0.05
0.05
0.05
0.05
0.05
8
0.00
0.00
0.00
0.00
0.00
1
0.44
0.44
0.44
0.44
0.44
75
262.61
'62.61
13.13
)62.61
13.13
2230
2.03
2.03
2.03
2.03
2.03
344
Hazardous Air Pollutants
'otential to Emit
Uncontrolled
• fissions
Uncontrolled Controlled
I incontralled Controlled
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
,,• -r• fin
1160
1160
58
1160
58
916
916
46
916
46
122
122
6
122
6
366
366
18
366
18
8243
8243
412
3243
112
Mi
AS CALCULATED
BY APPLICANT
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled
(tons/year)
Controlled
(tons/year)
Requested Permit
Uncontrolled
(tons/year)
Limits
Controlled
(tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
0.05
0.05
8
PM2.5
0.05
0.05
8
SOx
0.00
0.00
1
NOx
0.44
0.44
75
VOC
394.19
19.71
3348
CO
2.03
2.03
344
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
1705.00
85.25
Toluene
1462.00
73.10
Ethylbenzene
211.00
10.55
Xylene
632.00
31.60
n -Hexane
12310.00
615.50
224 TMP
453.00
22.65
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
ee regulatory applicability worksheet for detailed analysis
10 of 12
K:\PA\2019\19W E0437.CP1.xlsm
Separator Venting Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific 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
No
`See technical analysis notes
Section 08 - Technical Analysis Notes
`I will allow use of the buffered factors proposed by the applicant. The HYSYS model used to model emissions required the jse of back -blending the pressurized liquid sample to simulate liquid composition upstream of the low pressure
separator. The methods used produce a LP gas composition as represented in the analysis above. The operator also proivded a 50% buffer to all hydrcarbon emission factors . Although the source did not have a site -specific gas sample, I
will not require one be submitted with self -certification since the emissions factors with the 50% buffer result in emission Frcfile that is more conservative than what I have generally seen from similar equipment at similar operating
conditions and source is not nearing major source thresholds. Therefore, an initial site -specific sample will not be required.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
011
Process # SCC Code
01 3-10-001-60 Flares
Pollutant
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
177.41
157359.60
808.79
340.32
291.82
42.12
126.15
2457.09
90.42
Control % Units
0 Ib/MMSCF
95 Ib/MMSCF
0 lb/MMSCF
95 lb/MMSCF
95 lb/MMSCF
95 lb/MMSCF
95 Ib/MMSCF
95 Ib/MMSCF
95 Ib/MMSCF
11 of 12 K:\PA\2019\19WE0437.CP1.xlsm
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
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Sect on II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 1O 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?
No
Source is not subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a.
Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVIi.B.2.e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations. the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may." '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.
r
;COLORADO
I Air Pollution Control Division
Department: of Pub;ec Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0437 Issuance: 1
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Noble Energy, Inc.
JOHNSON ROBERTSON REIS UPRR PAN AM
123/8757
NENW, Sec. 11, T2N, R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LP
Separators
010
Flaring of gas from the low pressure
section of four (4) high/low pressure
separators (HLP Separators).
Enclosed Combustors
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, 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
Page 1 of 9
COLORADO
Air Pollution Control Division
Department. of Publ;c 1-feahh b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. 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.)
5. 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.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
LP Separators
010
---
---
14.4
1.9
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.
Page 2 of 9
(COLORADO
Air Pollution Control Division
Department of Pubitc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. 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.
8. 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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
LP
Separators
010
Emissions from the low pressure separators
are routed to an Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. 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
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
LP Separators
010
Natural Gas Venting to
enclosed combustor
5.49 MMSCF
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
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.
10. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the low-pressure separator(s) using a 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
11. 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)
Page 3 of 9
COLORADO
Air Pollution Control Division
Oei:artvmert of Pubtic -k- !th b E:nvironrnent
Dedicated to protecting and improving the health and environment of the people of Colorado
12. 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.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
OPERATING !t MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (0&tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one
continuous hour. (Regulation Number 1, Section II.A.5)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) 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
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
18. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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,
Page 5 of 9
(COLORADO
Air Pollution Control Division
Department of Pubic Flealfh b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
22. 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.
23. 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.
24. 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.
25. 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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
New synthetic minor permit.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of rubtsc Health b 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-reps
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 sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
LP
Separators
010
Benzene
71432
1,019
51
Toluene
108883
1,002
50
Ethylbenzene
100414
57
3
Xylenes
1330207
462
23
n -Hexane
110543
7,307
365
2,2,4-
Trimethylpentane
540841
248
12
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission 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 7 of 9
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Heath & 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:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
148.99
148.99
AP -42, Chapter
13.5
CO
679.21
679.21
VOC
104,922.30
5,246.12
Site -specific
sample and HYSYS
71432
Benzene
185.62
9.28
108883
Toluene
182.53
9.13
1330207
Xylene
84.16
4.21
110543
n -Hexane
1,331.06
66.55
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 facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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
Page 8 of 9
COLORADO
Air Pollution Control Division
Deoart r er t of Public e Er, ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 9 of 9
2019
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may 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.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:
19 E O ' — AIRS ID Number: 123 /8757 / 010
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1: Noble Energy, Inc.
Site Name: JOHNSON ROBERTSON REIS UPRR PAN AM T2N-R64W-S19 L01
Site Location: NWNE SEC19 T2N R64W
Mailing Address: 1625 Broadway,Suite 220
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E -Mail Address2: janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
396887
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
Permit Number: AIRS ID Number:
123 / 8757 /
[Leave blank. unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ 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 -
❑ 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:
HLP's
LP gas stream from the LP leg of four
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
21, Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
Yes
Yes
Yes
❑ No
❑✓ No
❑✓ No
COLORADO
\ L_iuti _n: of F_[u
Form r.PCD-211 Gas Venting APEN - Revision 7/2018 2 _ �
Permit Number: AIRS ID Number:
123 /8757/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #:
# of Pistons:
Volume per event:
Capacity: gal/min
Leak Rate: Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ No
Vent Gas
2191
BTU/SCF
Heating Value:
Requested:
55.49
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
39.25
VOC (Weight %)
67.51
Benzene (Weight %)
0.12
Toluene (Weight %)
0.12
Ethylbenzene (Weight
0.00
Xylene (Weight %)
0.05
n -Hexane (Weight %)
0.86
2,2,4-Trimethylpentane
(Weight %)
0 03
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
❑✓
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
pp coloenoo
Form ,APCD-211 - Gas Venting APEN - Revision 7/2018
Permit Number:
AIRS ID Number:
123 /8757/
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1308, -104.5901
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)
❑✓ 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.
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
0/0
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
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:
Form APCD-211 - Gas Venting AFRO - Revision 7/2013
IVLV KhUV
4 �c
cf-
Permit Number:
AIRS ID Number:
123 /8757/
[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
verall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
Sox
NOX
CO
VOC
VOC Burner
95%
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
N/A
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/ ear
( y )
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
tons/ ear
(tons/year) )
Controlled
Emissions
tons/ ear
(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, 100
lb/mscf
AP -42
0.42
0.42
CO
0.31, 84
lb/mscf
AP -42
1.87
1.87
VOC
1rn, 0.0055
lb/mscf
HYSYS/AP-42
288.01
14.40
1,09. 3,2
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.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
0.1856
lb/mscf
HYSYS/AP-42
1,019
51
Toluene
108883
0.1824
lb/mscf
HYSYS/AP-42
1,002
50
Ethylbenzene
100414
Xylene
1330207
0.0841
lb/mscf
HYSYS/AP-42
462
23
n -Hexane
110543
1.3310
lb/mscf
HYSYS/AP-42
7,307
366
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
5 I
Permit Number:
AIRS ID Number:
123 / 8757 /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
SignAMOO
turr e of Legally Authorized Person (not a vendor or consultant) Date
04/22/2019
Janessa Salgado Environmental Engineer
Name (please print)
Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
p 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.gov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I IfeNT
COLORADO
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may 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.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: icc Oct; g AIRS ID Number: 123 / 8757 / O t t
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: JOHNSON ROBERTSON REIS UPRR PAN AM T2N-R64W-S19 L01
Site Location: NWNE SEC19 T2N R64W
Mailing Address: 1625 Broadway, Suite 220
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Janessa Salgado
303-228-4196
janessa.salgado@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.
396388
Form APCD-211 - Gas Venting APEN - Revision 7/2018
per-
COLORADO
of
Permit Number: AIRS ID Number:
123 /8757/
[Leave blank unless APCD has already assigned a permit a 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
❑ 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: VRT gas stream from one VRT
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
❑✓ Yes ❑ No
❑ Yes ❑✓ No
❑ Yes ❑✓ No
Form .APCD-211 - Gas Venting APEN - Revision 7/2018 2 I
COLORADO
L.c..•ti_�. u(P�1 is
Permit Number: AIRS ID Number:
123 /8757/
[Leave blank unless APED has already assigned a permit d and AiRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #:
# of Pistons:
Volume per event:
Capacity: gal/min
Leak Rate: Scf/hr/pist
MMscf /event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ No
Vent Gas
Heating Value:
2609
BTU/SCF
Requested:
5.01
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
46.18
VOC (Weight %)
86.04
Benzene (Weight %)
0.19
Toluene (Weight %)
0.16
Ethylbenzene (Weight
0/1
0.02
Xylene (Weight %)
0.07
n -Hexane (Weight %)
1.34
2,2,4-Trimethylpentane
(Weight %)
0 05
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEPI - Revision 7/7018
3�
COLORADO
Permit Number:
AIRS ID Number:
123 /8757/
[Leave blank unless APCD has already assigned a permit g and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1308, -104.5901
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)
❑✓ 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.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled:
VOC, HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
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:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
4
AAICW
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Permit Number:
AIRS ID Number:
123 /8757 /
[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
SO.
NO.
CO
VOC
VOC Burner
95%
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
N/A
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Source
Uncontrolled
Controlled
Uncontrolled
Controlled
Basis
Units
(AP -42,
Mfg., etc.)
Emissions
(tons/year)
Emissions6
(tons/year)
Emissions
(tons/year)
Emissions
(tons/year)
PM
7.6
lb/mmscf
AP -42
0.00
0.00
SOx
0.6
lb/mmscf
AP -42
0.00
0.00
NO.
0.068, 100
Ib/mscf
AP -42
0.45
0.45
CO
0.31, 84
Ib/mscf
AP -42
2.03
2.03
VOC
1'55,74403, 0.0055
Ib/mscf
HYSYS/AP-42
394.17
19.71
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
M etc.)
Mfg.,
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
0.3402
Ib/mscf
HYSYS/AP-42
1,705
85
Toluene
108883
0.2919
Ib/mscf
HYSYS/AP-42
1,462
73
Ethylbenzene
100414
Xylene
1330207
0.1261
Ib/mscf
HYSYS/AP-42
632
32
n -Hexane
110543
2.4572
Ib/mscf
HYSYS/AP-42
12,310
616
2,2,4-
Trimethylpentane
540841
_
j,.
C?+ C�'l�
�/S C
rr %a
A.
Li C2
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
5I A.
COLORADO
L�urcr.-n. o(PuL1u:
Permit Number: AIRS ID Number:
123 /8757/
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
NA/1 SacpLo
Sig ature of Legally A thorized Person (not a vendor or consultant) Date
04/22/2019
Janessa Salgado Environmental Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
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
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2013
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