HomeMy WebLinkAbout20192108.tiffPL.b\ C (;)6u0.0
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COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
May 30, 2019
Dear Sir or Madam:
RECEIVED
JUN 0 4 2019
WELD COUNTY
COMMISSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc - Boulter State G21-69HN, G16-75HN. 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 a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
(JM (ER 1thK .V-)
2019-2108
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc - Boulter State G21-69HN, G16-75HN - Weld County
Notice Period Begins: June 6, 2019
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Noble Energy, Inc
Facility: Boulter State G21-69HN, G16-75HN
Tank Battery, Oil Et Natural Gas Production Et Processing
SESW Quadrant of Section 16, Township 4N, Range 65W
Weld County
The proposed project or activity is as follows: Noble Energy Inc. currently operates the Boulter State G21-
69HN, G16-75HN tank battery located in Weld County. This permit application seeks authorization to send
low pressure gas to a combustor and remove the vapor recovery unit on -site that has been capturing this
gas.
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 18WE1007.CP1 have
been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
James Ricci
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
Deparentezt
;COLORADO
m vaxate
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE 1007
XX
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Noble Energy, Inc.
Boulter State G21-69HN, G16-75HN
123/9825
SESW Quadrant of Section 16, Township 4N, Range 65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control
Description
008
Venting of low pressure separator gas
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq),
to this specific general terms and conditions included in this document and the following
specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days of the latter of commencement of operation or issuance of this permit,
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the
permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, compliance with the conditions contained in this permit shall
be demonstrated to the Division. It is the owner or operator's responsibility to self -
certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. A self certification form and guidance on
COLORADO
Air Pollution Control Division
Department of Rine Health & Environment
Page 1 of 9
as requthis perm
.colora'; •ov/ • - -permit-s ' ation.
be obtaine
on Numbe
nline at
Part B,
3._ . _a,..it shall the : •. =r Herat.. 4 �. ,wa = or which t r"';_ `it was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen months or more; (iii) does not complete construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. Within one hundred and eighty days (180) after issuance of this permit, the operator
shall install a flow meter to monitor and record volumetric flow rate of natural gas
vented from each separator covered by this permit. Until the flow meter is installed,
the operator shall monitor and record condensate/crude produced through the
separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel
(bbl) of 634 scf/bbl of loadout estimated in the permit application.
5. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
008
--
0.7
30.2
3.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall
be determined on a rolling twelve (12) month total. By the end of each month a new
twelve month total is calculated based on the previous twelve months' data. The permit
COLORADO
Air Pollution Control Division
Department of Public Neeitn E+ Environment
Page 2 of 9
cula ~ FTii '= -missions nth and • $ omplianc -cord on
l fie k • ; ith site r r .; f 'ty for Di : ion -view.
8. a emus point the le b- w shall :;, opera and maintain with the
control rder' • �oi • c - ohs to les `°• equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
AIRS
Point
Control Device
Pollutants
Controlled
008
All low pressure separator gas is routed to
an Enclosed Combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
AIRS
Point
Process Parameter
Annual Limit
008
Natural Gas Venting
8.24 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve-month total is calculated
based on the previous twelve months' data. The permit holder shall calculate
throughput each month and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor
and record the volumetric flow rate of natural gas vented from the separator(s) using
the flow meter. The owner or operator shall use monthly throughput records to
demonstrate compliance with the process limits contained in this permit and to
calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g.
123/4567/001) shall be marked on the subject equipment for ease of identification.
(Regulation Number 3, Part B, Section III.E.) (State only enforceable)
12. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.5.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
COPH
COLORADO
Air Pollution Control Division
1 Department of Public Health & Environment
Page 3 of 9
OPERA '_ G it MAI NAN<., ° MENTS
14. > on startu } r ry.f th = s po ; , , the o d er or erator 11 f low the a, t recent
main ance x • M) • n and r . d kee g format appro R• by the
�•t�:. i - - ments
fn order � ��= �nstr. � � +-� .nce o �`�������g•� is with th-
of this permit. Revisions to the O&M plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner/operator shall complete an initial site specific extended gas analysis
("Analysis") within one hundred and eighty days (180) after commencement of operation
or issuance of this permit, whichever comes later, of the natural gas vented from this
emissions unit in order to verify the VOC content (weight fraction) of this emission
stream. Results of the Analysis shall be used to calculate site -specific emission factors
for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using
Division approved methods. Results of the Analysis shall be submitted to the Division as
part of the self -certification and must demonstrate the emissions factors established
through the Analysis are less than or equal to, the emissions factors submitted with the
permit application and established herein in the "Notes to Permit Holder" for this
emissions point. If any site specific emissions factor developed through this Analysis is
greater than the emissions factors submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division
within 60 days, or in a timeframe as agreed to by the Division, a request for permit
modification to address this/these inaccuracy(ies).
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare
for one continuous hour. (Regulation Number 1, Section II.A.5)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part
A, II.C.)
CDPHE
li
• 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 NO. 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
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 4 of 9
0 tons pe
s per ye
sub
in actual
less, abov
ssions of
he level
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the
applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and
D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this
construction permit does not provide "final" authority for this activity or operation of
this source. Final authorization of the permit must be secured from the APCD in writing
in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation
Number 3, Part B, Section III.G. Final authorization cannot be granted until the
operation or activity commences and has been verified by the APCD as conforming in all
respects with the conditions of the permit. Once self -certification of all points has been
reviewed and approved by the Division, it will provide written documentation of such
final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this
information and with representations made by the owner or operator or owner or
operator's agents. It is valid only for the equipment and operations or activity
specifically identified on the permit.
23. 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.
COLORADO
Air Pollution Control Division
Department of pub&c Neahh 6 Ettvironrr ent.
Page 5 of 9
24. hand ev ` con t . • • �_, 9 " is permit erial par j «e3 and is no verable.
a condition all cons a to . ejection •qty e entire
ce, th"permit ==ll be d ed denied ab io. This
e re :;- an ` '_� , x to se . nd final a ^ .ion by
the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or
the Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual
fee billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
James Ricci
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc. Low pressure
separator gas venting at an E&tP facility in the
non -attainment area.
COPHE
COLORADO
Air Pollution Control Division
Department of albite Health & Environment
Page 6 of 9
this perm ce:
s re • edz'ay fees f e p -ssing ti :'aid for his permit "''n invoice
l be i ed a the • mit is is d Th ' ermit holder s pay the
i . in 30 day • eip . t oice. he invoic ult in
revocation of this permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit
are based on the consumption rates requested in the permit application. These limits may
be revised upon request of the owner or operator providing there is no exceedance of any
specific emission control regulation or any ambient air quality standard. A revised air
pollution emission notice (APEN) and complete application form must be submitted with a
request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall
notify the Division of any malfunction condition which causes a violation of any emission
limit or limits stated in this permit as soon as possible, but no later than noon of the next
working day, followed by written notice to the Division addressing all of the criteria set
forth in Part II.E.1 of the Common Provisions Regulation. See:
https: //www.colorado.gov/ pacific /cd phe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of
the Division's analysis of the specific compounds emitted if the source(s) operate at the
permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
008
Benzene
71432
7135
357
Toluene
108883
8416
421
Xylenes
1330207
2078
104
n -Hexane
110543
46106
2305
2,2,4-Trimethylpentane
540841
1118
56
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission
rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees
based on the most recent Air Pollution Emission Notice.
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 7 of 9
ed on the •, g emissio ctors:
CAS #
Controlled
Emission
Factors
(lb/MMSCF)
Source
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
NOx
1.62 x 10Z
AP -42 (Flares)
CO
7.39 x 10
VOC
1.47 x 105
7.34 x 103
Vented gas
composition
from an
estimated HP
Inlet Stream in
HYSYS + Buffer
71432
Benzene
8.66 x 102
4.33 x 101
108883
Toluene
1.02 x 103
5.11 x 101
1330207
Xylene
2.52 x 102
1.26 x 10'
110543
n -Hexane
5.60 x 103
2.80 x 102
540841
2,2,4-Trimethylpentane
1.36 x 102
6.79 x 10°
Note: The controlled emissions factors for this point are based on the enclosed combustor
control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 120 °F
and separator pressure of 42.2 psia.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)
associated with this permit is valid for a term of five years from the date it was received
by the Division. A revised APEN shall be submitted no later than 30 days before the five-
year term expires. Please refer to the most recent annual fee invoice to determine the
APEN expiration date for each emissions point associated with this permit. For any
questions regarding a specific expiration date call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane, Total HAPS
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60,
Appendixes
Appendix A - Appendix I
COLORADO
Air Pollution Control Division
Departrmnt of Publ c Health b EnNxonmeni
Page 8 of 9
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
ous Air . s for Sou
63.59 . ubpar. A - Subp. Z
63.600-6"`.
- Su
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Hea;in E Erntronment
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details 4
Review Engineer
Package #
Received Date
Review Start Date
(James Rica x�"
387347 ~>�
9/6/2018 Qa
,V2019 ,. , f
,V
Section 01- Facility Information
Company Name yry�N��oble Energytlnc,
y;A,,,,, c�f1Y T^C
County AIRS ID ''123 (�, ,<''
KF
Plant AIRS ID9B25� ice, 4 _1Facility Name 'BoulteG,State'`G21 6911N, G16� N 2 17,7
Location SESW Quadrant of Section 16 Township 4N, Range 65W
County Weld County
Type of Facility Explorefion & Production well pad>' ,
What industry segment?LOil &/Natur ( as,Pfodruction & ocessing '-i, '
Is this facility located in a NAAQS non attainment area? L `- -' Yes J..i`
If yes for what pollutant? El Carton Monoxide (CO) Q Particulate Matter (PM)
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
a'SESW
''1",;; 1fiN P
't4 4N'. `a,
Omne (NOx &50C)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
y'l
Y ca '�
x A008
<
_ ._ -- ,,
r Separator Venting
P ne. , i r
' .,,, f ,
,`�LP3Venting 7
K r„, r
_ ,
„,,
_ _
Yes
';`,1"--,P, - .
a 18E1007 CPI
a 4 Pk,'p
�,,' �',wr
t er .l x
, x^
..
- Yes
4,
Permit Initial
` Issuance ,
`
� y�
ii
S"
., ,..e '5 _
'
4 PZ-,—. s",xc
-"
ff v;.� 5'�fn; s
>° .e+
—
Section 03 - Description of Project
Neptp 5 < H.,n' '',,4,,,,,,r Ton, , nn. ,, , n;,,,,,,,,,4-. ,s -s' ,„ �`,f,,n T`,£#,? vim t " d -,.*x ,3,-.�`„ ,n14, "" ,1, 1,-,,, 'z+ — ,
oble Energy Inc currently operates the Boulter State G21-69HN, G16-95HN tank battery located in eld County This permit "application seeks authorization tasend low pressure gas to a>
.combustor'and remove thewapor recovery unit on site that has been capturing this gas
Section 04 - Public Comment Requirements
Is Public Comment Required? ( Yes ,.�
x
If yes, why? �Requestng5ynthet�cMmor,P�rmitn �,1',+`,^+,
Section 05 - Ambient Air Impact Analysis Requiremmnts
Was a quantitative modeling analysis required? i No
If yes, for what pollutants? ,� a
If yes, attach a copy of Technical Services Unit modeling results summary
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non Attainment New Source Review (NANSR)
,No
502 NOx CO VOC PM2 5 PM10 TSP HAPs
B
e
J
Is this stationary source a major source? & ".T-�i' •-No ,
rq
If yes, explain what programs and which pollutants here 502 Nov CO VOC
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non Attainment New Source Review (NANSR)
B
99n
PM2 5 PM10 TSP HAPs
8 ADD
Separator Venting Emissions Inventory
008 Separator Venting
Facility AIRs ID:
123
County
9B25
Plant
008
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %: 95
Combustion of Low Pressure Seperator Gas
Enclosed Combustor, 95% Manufacturer Guaranteed Control Efficiency
Limited Process Parameter
Gas meter
Natural Gas Vented
Yes, meter will be installed within 180 days
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
8.2
8.2
MMscf per year
MMscf per year
8.2 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
2384
634
Description
Btu/scf
scf/b b l
Requested Monthly Throughput =
1 MMscf per month
HHV of Low Pressure Stream (903000 Btu/lb-mol)
Based on 35.6 bbl/day of loadout modeled in HYSYS and the equivalen 0.9404 MSCFH of
LP Flash Gas also modeled in HYSYS
The current VRU will be removed from this facility and LP gas will be sent to a combustor. A liquid sample was taken from the Boulter State G21-69HN facility in 1/31/2013 and analyzed by Empact Analytical Systems on 2/7/13.
The applicant used this liquid sample to recreate and estimate an HP inlet stream to the separator. HYSYS was used to model the HP stream at 252.2 psia and 120 deg F. The LP Liquid and LP Vented Gas were modeled at 42.2psia
and 120 deg F. The LP Flash Gas stream in HYSYS was used to estimate the vented gas composition. The applicant used Mole% as the basis for their calculations. Since more sig figs could be carried in their calculations page vs
read off a HYSYS report, the below Weight% were rounded to match the applicants calculations. There are nearly identical the the Weight% read from the HYSYS report.
MW
46
Weight %
Helium
0.00
CO2
1.08
N2
0.22
methane
3.12
ethane
15.27
propane
30.62
isobutane
8.47
n -butane
17.55
isopentane
4.78
n -pentane
4.42
cyclopentane
0.37
n -Hexane
3.06
cyclohexane
0.68
m -Pentane
5.67
heptanes
1.94
methylcyclohexane
0.61
224-TMP
0.07
Benzene
0.47
Toluene
0.56
Fthylbenzene
0.00
Xylenes
0.14
n -Octane
0.61
n-Nonane
0.18
n-Decane
0.09
Total
100
VOC Wt Rio
80
Ib/Ib-rnol Displacement Equation
Ex = Q • MW * Xx / C
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(Ib/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
1.47E+05
7.34E+03
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Extended gas analysis
Benzene
8.66E+02
4.33E+01
Toluene
1.02E+03
5.11E+01
Ethylbenzene
0.00E+00
0.00E+00
Xylene
2.52E+02
1.26E+01
n -Hexane
5.60E+03
2.80E+02
224 TMP
1.36E+02
6.79E+00
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
17.763
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.S)
AP -42 Table 1.4-2 (SOx)
PM2.5
0.0075
17.763
SOx
0.0006
1.402
2.of6
K:\PA\2018\18WE1007.CP1.xlsm
Separator Venting Emissions Inventory
NOx CO I 0.0680 162.110 AP 42 Chapter 13.5 Industrial Flares (NOx)
0.3100 I 739.031 AP -42 Chapter 13.5 Industrial Flares (CO)
3 of 6 K:\PA\2018\18WE1007.CP1.xlsm
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Note: NOx and CO includes 0.02 tpy of estimated emissions from the pilot light
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.07
0.07
0.07
0.07
0.07
12
0.07
0.07
0.07
0.07
0.07
12
0.01
0.01
0.01
0.01
0.01
1
0.67
0.67
0.67
0.67
0.69
117
604.44
604.44
30.22
604.4
30.2
5134
3.04
3.04
3.04
3.04
3.06
520
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
7135
7135
357
7135
357
Toluene
8416
8416
421
8416
421
Ethylbenzene
0
0
0
0
0
Xylene
2078
2078
104
2078
104
n -Hexane
46106
46106
2305
46106
2305
224 TMP
1118
1118
56
1118
56
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 XVlI.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas, sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific 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? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
4 of 6 K:\PA\2018\18WE1007.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
HYSYS v10 was used to model a HP Separator Stream and the respective LP Gas Stream that will be vented. Due to estimations required to recreate an HP Separator stream from the liquid sample taken in 2013, the applicant added 50%
buffers to the emission factors. The applicant will be required in the permit to show initial compliance with the emissions factors by taking a site specific gas sample. Because of the buffers and initial compliance required, these emission
factors were accepted.
The applicant confirmed that none of the wells at this facility have been fractured or recompleted since August 1, 2014. They also confirmed that a gas meter will be installed after a permit is issued, prior to removal of the compressor.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
008
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 17.76 0 lb/MMSCF
PM2.5 17.76 0 lb/MMSCF
SOx 1.40 0 lb/MMSCF
NOx 162.11 0 lb/MMSCF
VOC 146745.63 95 lb/MMSCF
CO 739.03 0 lb/MMSCF
Benzene 866.08 95 lb/MMSCF
Toluene 1021.66 95 lb/MMSCF
Ethylbenzene 0.00 95 Ib/MMSCF
Xylene 252.25 95 lb/MMSCF
n -Hexane 5596.82 95 Ib/MMSCF
224 TMP 135.71 95 Ib/MMSCF
5 of 6 K:\PA\2018\18WE1007.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the l' on -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 S 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?
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?
No
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
Source Req
Source Req
Source is ni
The contro
SEP
6 ?Oig
St CD
sour
s
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
casing, pneumatic pumps, blowdown events, among other events.
category, there may be a more specific APFN fnr - ---
loading,
loading, condensate storage tanks, et(
specialty APEN options will not satisfy
Air Pollution Control Division (APCD) w
This emission notice is valid for five (5
of the five-year term, or when a repor
new equipment, change in fuel type, e
Permit Number:
rck
emissions from gas/liquid separators, well head
If your emission unit does not fall into this
weetening unit, hydrocarbon liquid
)rm APCD-200) is available if the
lilable APEN forms can be found on the
Lpd
I
is required 30 days prior to expiration
ssions increase, increase production,
C. for revised APEN requirements.
O02#
e 0 O— AIRS ID Number: 123 / 9B25
[Leive'lank unless APC has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
LAX
.
Mailing Address:
(Include Zip Code)
Noble Energy, Inc.
Boulter State G21-69HN, G16-75HN
SESW SEC2•1 T4N R65W
Se.16
1625 Broadway, Suite 2200
Denver, CO 80202
Site Location Weld
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.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
387345
!COLORADO
Fia,th tmgP '
Permit Number: AIRS ID Number: 123 I 9B25 / TBD
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 2 - Requested Action
0 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 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: Combustion of LP Gas
Company equipment Identification No. (optional):
For. existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
['Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
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?
Form APCD-211 - Gas Venting APEN - Revision 7/2018
days/week weeks/year
❑✓ Yes
❑ Yes
Yes
❑ No
❑✓ No
gi No
J
2 I AVCOLORADO
R =
Permit Number: AIRS ID Number: 123 / 9625 / TBD
[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 #: 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 O No
Vent Gas
Heating Value:
2383.97
BTU/SCF
Requested:
8.2379
MMSCF/year
Actual:
NA
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
46.1588
VOC (Weight %)
80.30
Benzene (Weight %)
0.47
Toluene (Weight %)
0��7 () . S
Ethylbenzene (Weight %)
0.00
' Xylene (Weight %)
0.14
n -Hexane (Weight %)
3.06
2,2,4-Trimethylpentane (Weight %)
0.07
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
CI
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
3I�!COLORADO
►V; HtiTragt-t::,
Permit Number:
AIRS ID Number: 123 / 9B25 / TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.3078, -104.6683
Operator
P
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:
❑Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type:
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: E Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
I cep .-..eoD,thIsc
. Fiv.(U±= �zvizaymnc�
Permit Number:
AIRS ID Number:
123 / 9B25 / TBD
[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 comoinea)
CURIA Ul eI I IL. lelR.y va t ruu,,,,,v•
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
Pollutant
PM
SOx
NOx
CO
VOC
Enclosed Combustor
95
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
Pollutant;
PM
Uncontrolled:,
Basis
AP -42
Criteria Pollutant Emissions Inventory
Source:.
(AP -42
Actual: Annual- Emissions
Uncontrolled .
Emmssions?.
(tons/year):
Controlled
Emissions6_
(tons/year) '
Requested; Annual Permit
Emission Limits)
Uncontrolled
Emissions:
(tons/year)
Controlled
Emissions .
(tons/year)
SOX
NOx
CO
100, 0.068
IbIMMSCF, Ib/MMBtu
0.69
0.69
84, 0.31
lb/MMSCF, Ib/MMBtu
AP -42
3.06
3.06
VOC
5.5, 146.7676
Ib/MMSCF, Ib/mscf
AP-42/HYSYS
30.23
Non -Criteria
Chemical
Abstract
Service : (CAS)
Number
Reportable Pollutant Emissions Inventory
Emission Factor .
Actual Annual Emissions
Chemical Name
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
0 loo 1
Ib/MSCF
HYSYS/AP42
7134.72
356.74
.'
Ib/MSCF
HYSYS/AP42
8416.32
420.82
Toluene
108883
\ . 0�\ r
Ethylbenzene
100414
Ib/MSCF
HYSYS/AP42
0
0
Ib/MSCF
HYSYS/AP42
2078.01
103.90
Xylene
1330207
0,2 c2,2
n -Hexane
110543
5..c 9 6l.
Ib/MSCF
HYSYS/AP42
46106.04
2305.93
2,2,4-540841
Trimethylpentane
O .13S-71
Ib/MSCF
HYSYS/AP42
1117.95
55.90
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.
COLORADO
se
Form APCD-211 - Gas Venting APEN - Revision 7/2018
51
Ccv-: of P1Lc
Permit Number: AIRS ID Number:
123 / 9B25 / TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
08/31/2018
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:
O 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-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.pov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
6 IVCOLORADO
,‘„Env„,,,„,„
5/17/2019
State.co.us Executive Branch Mail - APEN Review: LP Venting, Boulter State G21-69HN, G16-75HN, 123/9B25/008
COLORADO
Air Pollution Control Division
Department of Public Health & Encronment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
[Quoted text hidden]
Allison Satterfield <Allison.Satterfield@nblenergy.com>
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Hi James,
Wed, Feb 20, 2019 at 2:44 PM
Please see my responses below and attached. Let me know if you have any additional questions. Thank you,
Allison Satterfield
Environmental Scientist
Air Quality Group - EHSR
Direct: 303.228.4137 I Cell: 303.518.0879
a.satterfield cunblenergy.com I www.nobleenergyinc.com
noble
energy
1. Is there an O&M plan for the combustor? See attached.
2. Do you have any more details on the combustor? It is an enclosed combustor, right? Yes, enclosed combustor.
3. Is there a gas meter already installed that can directly measure the LP gas sent from the separator to the
combustor? A gas meter will be installed after a permit is issued, prior to removal of the compressor.
4. Can you please send the full HYSYS report that includes the inputs and flow diagram? If you have it in excel, even
better! See attached.
0 The liquid sample looks like it was taken at 107 deg F and 35 (psia?).Are these the conditions the separator
was modeled at in HYSYS? The LP Separator is modelled at 120 F and 42.2 psia.
5. Is there a process diagram for this facility that you can share? Something that shows number of separators, flow
paths, tanks, etc. See flow diagram attached.
6. The APEN emission values differ from the calculation sheet. It looks like a 50% buffer was taken on the VOC
controlled emissions? The same 50% buffer was also added to the Uncontrolled HAPs? I wanted to confirm this
was correct. The 150% conservative factor was added for VOC and HAP controlled and uncontrolled emission
calculations.
7. Is the heating value of 2383.971816 Btu/scf from HYSYS? Yes, it is the heat value of the LP Flash Gas.
[Quoted text hidden]
3 attachments
O LP O&M - Boulter St.docx
139K
.o _no ..Dion. ocoaaoovo,rgvlaA g/1F•1RcirnnL—men_no/3Ar_P7319d(1
2I
5/17/2019 State.co.us Executive Branch Mail - APEN Review: LP Venting, Boulter State G21-69HN, G16-75HN, 123/9825/008
HYSYS-PFD.pdf
9K
HYSYS-Streams.pdf
290K
Ricci - CDPHE, James <james.ricci@state.co.us> Mon, Mar 4, 2019 at 9:14 AM
To: Allison Satterfield <Allison.Satterfield@nblenergy.com>
Hi Allison,
Thank you for the additional info. I have a couple quick follow-up questions:
• Can you please briefly walk me through how the HP Stream was estimated in HYSYS? Was the 2013 liquid
sample input into HYSYS and the HP Stream back calculated some how? The LP stream doesn't quite equal the
composition from the lab analysis, is the because pressure and temperate are different?
• Section 7: I am calculating the following values, please let me know if you agree and if I can redline the APEN:
o VOC Uncontrolled: Change from 403.02 tpy to 604.4 tpy (I think the buffer was only applied to the controlled
emissions)
o Benzene Emission Factor: Change from 0.5774 lb/MMSCF to 0.8661 lb/MMSCF (Matches Calculation
Sheet)
O Toluene Emission Factor : Change from 0.6811 lb/MMSCF to 1.0217 lb/MMSCF (Matches Calculation
Sheet)
o Xylene Emission Factor : Change from 0.1682 lb/MMSCF to 0.2522 lb/MMSCF (Matches Calculation
Sheet)
o n -Hexane Emission Factor : Change from 3.7312 lb/MMSCF to 5.5968 lb/MMSCF (Matches Calculation
Sheet)
O 224-TMP Emission Factor : Change from 0.0905 lb/MMSCF to 0.1357 lb/MMSCF (Matches Calculation
Sheet)
• I saw on the APEN that the separator will be subject to Reg 7 Section VXII.G. Is this because the well
was hydraulically fractured, or recompleted on or after August 1, 2014
Thanks,
James Ricci
Permit Engineer
COLORADO
Air Pollution Control Division
Department of Pubis Health & Environment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
[Quoted text hidden]
Allison Satterfield <Allison.Satterfield@nblenergy.com> Thu, Mar 7, 2019 at 1:44 PM
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Hi James,
I have responded to your questions below. Please let me know if you need any additional information. Thank you,
Allison Satterfield
Environmental Scientist
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5/17/2019 State.co.us Executive Branch Mail - APEN Review: LP Venting, Bpulter State G21-69HN, G16-75HN, 123/9825/008
Air Quality Group - EHSR
Direct: 303.228.4137 I Cell: 303.518.0879
a. satterfield anblenergy.com I www.nobleenergyinc.com
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From: Ricci - CDPHE, James <james.ricci@state.co.us>
Sent: Monday, March 4, 2019 9:14 AM
To: Allison Satterfield <Allison.Satterfield@nblenergy.com>
Subject: EXTERNAL: Re: APEN Review: LP Venting, Boulter State G21-69HN, G16-75HN, 12319825/008
Hi Allison,
Thank you for the additional info. I have a couple quick follow-up questions:
• Can you please briefly walk me through how the HP Stream was estimated in HYSYS? Was the 2013 liquid
sample input into HYSYS and the HP Stream back calculated some how? The LP stream doesn't quite equal the
composition from the lab analysis, is the because pressure and temperate are different? I took the LP liquids
sample and pressurized it to recreate the HP stream. Yes, the LP stream reflects a more lower pressure from the
lab analysis.
• Section 7: I am calculating the following values, please let me know if you agree and if I can redline the APEN:
Agreed on all of these. The corrected redline EF will account for the buffer.
o VOC Uncontrolled: Change from 403.02 tpy to 604.4 tpy (I think the buffer was only applied to the controlled
emissions)
o Benzene Emission Factor: Change from 0.5774 lb/MMSCF to 0.8661 lb/MMSCF (Matches Calculation
Sheet)
o Toluene Emission Factor : Change from 0.6811 lb/MMSCF to 1.0217 lb/MMSCF (Matches Calculation
Sheet)
o Xylene Emission Factor : Change from 0.1682 lb/MMSCF to 0.2522 lb/MMSCF (Matches Calculation
Sheet)
o n -Hexane Emission Factor : Change from 3.7312 lb/MMSCF to 5.5968 lb/MMSCF (Matches Calculation
Sheet)
o 224 -IMP Emission Factor : Change from 0.0905 Ib/MMSCF to 0.1357 lb/MMSCF (Matches Calculation
Sheet)
• I saw on the APEN that the separator will be subject to Reg 7 Section VXII.G. Is this because the well
was hydraulically fractured, or recompleted on or after August 1, 2014. Can you please recline the APEN to not
subject to Reg 7 Section VXII.G? None of the wells at this facility have been fractured or recompleted since August
1, 2014.
[Quoted text hidden]
[Quoted text hidden]
Ricci - CDPHE, James <james.ricci@state.co.us> Tue, Apr 16, 2019 at 2:51 PM
To: Allison Satterfield <Allison.Satterfield@nblenergy.com>
Hi Allison,
I have attached the draft permit for your review before sending it to public comment. I also need permission to redline
Section 4 of the APEN. Toluene Weight % is listed at 0.47%. Based on the emissions and HYSYS report, I believe it
should be 0.56%
Thanks,
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5/17/2019
State.co.us Executive Branch Mail - APEN Review: LP Venting, Boulter State G21-69HN, G16-75HN, 123/9625/008
James Ricci
Permit Engineer
COLORADO
Air Pollution Control Division
Department of Public Health E Environment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
• [Quoted text hidden]
2 attachments
18WE1007.CP1 - DRAFT.pdf
458K
18WE1007.CP1 PA - DRAFT.pdf
139K
Allison Satterfield <Allison.Satterfield@nblenergy.com>
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Hi James,
Yes, I agree, the APEN should be redlined to 0.56% for toluene. Thank you,
[Quoted text hidden]
Tue, Apr 16, 2019 at 2:55 PM
Allison Satterfield <Allison.Satterfield@nblenergy.com> Mon, Apr 22, 2019 at 9:47 AM
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Hi James,
Are you going to send me a new draft with the corrected toluene % or will that be reflected on the final permit? Thanks!
[Quoted text hidden]
Ricci - CDPHE, James <james.ricci@state.co.us>
To: Allison Satterfield <Allison.Satterfield@nblenergy.com>
Mon, Apr 22, 2019 at 9:53 AM
Hi Allison,
The calculations were based off of 0.56% so that permit draft is still OK to review. I think it was just a typo on the APEN.
Thanks,
James Ricci
Permit Engineer
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
[Quoted text hidden]
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