HomeMy WebLinkAbout20194068.tiffRECEIVED
a
COLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
August 22, 2019
Dear Sir or Madam:
AUG 3 0 2019
WELD COUNTY
COMMISSIONERS
On August 29, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Frico T3N-R65W-515 L02. 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 &t 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
Polo 1 ie Rv iew
Opt/(Co/(9
ccPLCTP), PGCsm), 2.11cL(c),
A J(SwIfER!Cf-I/CK)
0'1/ ralc9
2019-4068
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Frico T3N-R65W-S15 L02 - Weld County
Notice Period Begins: August 29, 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: Frico T3N-R65W-S15 L02
Oil and gas well production facility
SWSW Sec 15, T3N, R65W
Weld County
The proposed project or activity is as follows: Applicant is proposing to vent production gas from tow
pressure separators and a vapor recovery tower (VRT) to an enclosed flare.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0377 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:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
nmpartment of Pubua
1 I Health BOEnvironment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Bradley Fades
Package #: 395712
Received Date: 4/5/2019
Review Start Date: 7/29/2019
Section 01- Facility Information
Company Name: Noble Energy Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
SWSW
15
3N
65
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
3256
Frico T3N-R65W-S15 L02
SWSW quadrant of Section 15, Township 3N, Range 65W
Weld County
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?
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 4
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
010
Separator Venting
LP Separators
Yes
19WE0377
1
Yes
Permit Initial
Issuance
011
Separator Venting
VRT
Yes
19WE0377
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Applicant is requesting a construction permit for venting of gas from low-pressure separators and a vapor recovery tower to enclosed combustors. This is an existing facility,
however, noble indicates that it plans to remove engines and associated compressors that are used to recycle gas from these equipment. As a result, gas routed to the
combustor is increased and is now above reporting and permitting thresholds.
The vapor recovery tower was previously reported as part of the tank vapor control system but Noble is requesting to assign a separate emissions point with this issuance,
specifically for the VRT The Division agrees with the requested point allocation and a vapor recovery tower should not be aggregated with a storage tank point.
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)
No
Yes
SO2
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
CO VOC PM2.5 PM10 TSP HAPs
No
NOx CO VOC
PM2.5 PM10 TSP
HAPs
Separator Venting Emissions Inventory
010 Separator Venting
Facility AIRs ID:
123
County
3256
Plant
010
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Venting of gas from two (2) low pressure separators.
Enclosed combustor
w
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 =
6.91 MMscf per year
95
Requested Permit Limit Throughput =
6.91 MMscf per year
Requested Monthly Throughput =
0.6
MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU: No
Is VRU process equipment.
6.91 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
2573 Btu/scf
scf/b b I
Applicant modeled emissions using HYSYS and a pressurized liquid sample taken from the liquid discharge of the LP separator (12/8/11 Frico 2-15HZ Pad). Applicant used HYSYS to simulate the low-pressure gas in equilibrium
with the sampled liquid and recombined (re -saturated) the low pressure liquid with the low pressure gas at the operating conditions of the high pressure separator to generate a representative composition of the high pressure
liquid that is discharged into the low pressure separator. The model subsequently models flash gas from LP separators and VRT. The following represents the modeled composition of the LP gas stream. Operating conditions in
the simulation are as follows:
LP Separator: 120 F, 30 psig
VRT: 101 F, 4 psig
MW
46.02
Weight %
Helium
CO2
1.46
N2
0.00
methane
2.61
ethane
17.37
propane
30.91
isobutane
7.79
n -butane
15.71
isopentane
4.55
n -pentane
4.12
cyclopentane
0.45
n -Hexane
3.34
cyclohexane
0.66
Other hexanes
6.77
heptanes
1.75
methylcyclohexane
0.58
224-TMP
0.06
Benzene
0.42
Toluene
0.47
Ethylbenzene
0.01
Xylenes
0.16
C8+ Heavies
0.84
Total
VOC Wt %
100.0
78.6
lb/lb-mol
Displacement Equation
Ex = Q * MW * Xx / C
2 of 9 K:\PA\2019\19WE0377.CP1.xlsm
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(Ib/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
95432.5455
4771.6273
�,�
���� HYSYS
Benzene
513.2771
25.6639
•sTh F "/.' HYSYS
Toluene
573.7359
28.6868
HYSYS
Ethylbenzene
14.5406
0.7270
HYSYS
HYSYS
HYSYS
HYSYS
Xylene
194.3204
9.7160
n -Hexane
4049.9187
202.4959
224 TMP
74.8370
3.7418
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
19.171
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PIY110/PM.2.5)
AP -42 Table 1.4-2. (SOx)
PM2.5
0.0075
19.171
SOx
0.0006
1.514
NOx
0.0680
174.964
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
CO
0.3100
797.630
Section 05 - Emissions Inventory
Emission Factors Proposed by Applicant
Pollutant
lb/1011,18cl
NOx
t 77.& V
CO
799.8464
VOC
95.432.6'3 19
S02
0 0t `,S
PM2_ E.
C 2007
Benzene
C13.245y
Dschlorobenzene
0.0000
Formaldehv'de
0.0020
Hexane
4.0.9.719E
Toluene
573.7010
E -Benzene
14.5397
X . tenes
194.3086
:=--Mpentare
74.8324
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
0.07
0.07
0.07
0.07
0.07
11
0.07
0.07
0.07
0.07
0.07
11
0.01
0.01
0.01
0.01
0.01
1
NOx
0.60
0.60
0.60
0.60
0.60
103
VOC
329.72
329.72
16.49
329.72
16.49
2800
CO
2.76
2.76
2.76
2.76
2.76
468
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
3547
3547
177
3547
177
Toluene
3965
3965
198
3965
198
Ethylbenzene
100
100
5
100
5
Xylene
1343
1343
67
1343
67
n -Hexane
27985
27985
1399
27985
1399
224 TMP
517
517
26
517
26
Section 06 - Regulatory Summary Analysis
uncontrolled
95432.6619
513.2459
4049.7195
573.701
14.5397
194.3086
74.8324
Controlled (lb/MMscf)
4771.6331 VOC
25.6623 benzene
202.4860 n -hexane
28.6851 toluene
0.7270 ethylbenzene
9.7154 xylenes
3.7416 224-TMP
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
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
3 of 9 K:\PA\2019\19WE0377.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
*The low pressure separators permitted with this point are the low pressure portion of an HLP separator (i.e. a single vessel consisting of a high pressure segment and low pressure segment with respective liquid -gas separation). As a result,
the operator is unable to obtain a pressurized liquid sample directly from the high pressure portion of the separator and used HYSYS to "back -blend" the known liquid composition to obtain an estimated upstream composition prior to
discharge to the low pressure segment. Since (i) there is no reason to contest the assumptions used in the simulation, (ii) the resulting compositions of LP (79% VOC) and VRT (93% VOC) are typical, (iii) the gas volume will be metered for
actual compliance demonstration, and (iv) the requested facility -wide controlled emission rates are not approaching major source thresholds, I will approve the emission factors for use with the Initial Approval permit and will require an
initial extended gas analysis of this stream be submitted with self -certification to verify the emission factors.
*Applicant provided comments on the draft permit indicating that they request that the emission factors reflected in their calculations be included in the "notes to permit holder" instead of the values calculated by the Division (i.e. in the
analysis above). I agree to include the emission factors as caclulated by applicant and displayed next to those calculated by the Division in the analysis above on the basis that the differences are minor and attributable to rounding. Also, the
assigned limits in the permit do not change when using the proposed emission factors x process limit from what I've calculated above.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
010
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 19.17 0 Ib/MMSCF
PM2.5 19.17 0 Ib/MMSCF
SOx 1.51 0 lb/MMSCF
NOx 174.96 0 lb/MMSCF
VOC 95432.55 95 Ib/MMSCF
CO 797.63 0 Ib/MMSCF
Benzene 513.28 95 lb/MMSCF
Toluene 573.74 95 lb/MMSCF
Ethylbenzene 14.54 95 Ib/MMSCF
Xylene 194.32 95 lb/MMSCF
n -Hexane 4049.92 95 Ib/MMSCF
224 MAP 74.84 95 Ib/MMSCF
4 of 9 K:\PA\2019\19WE0377.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Are..
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)?
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. 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
Scurce 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
Scurce is not subject to Regulation 7, Section XVII.B.2, G
Section XV11.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 documen• 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
011 Separator Venting
Facility AIRs ID:
123
County
3256
Plant
011
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Venting of gas from one (1) Vapor Recovery Tower (VRT).
Enclosed combustor
Emission Control Device Descr ption:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Natural Gas Vente
Yes, meter is currently installed and operational
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
3.99 MMscf per year
95
Requested Permit Limit Throughput =
3.99 MMscf per year
Requested Monthly Throughput =
(i
MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped s,ith a VRU: s
Is VRU process equipment:
3.99 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
3090 Btu/scf
scf/bbl
Applicant modeled emissions using HYSYS and a pressurized liquid sample taken from the liquid discharge of the LP separator (12/8/11 Frico 2-15HZ Pad). Applicant used HYSYS to simulate the low-pressure gas in equilibrium
with the sampled liquid and recombined (re -saturated) the low pressure liquid with the low pressure gas at the operating conditions of the high pressure separator to generate a representative composition of the high pressure
liquid that is discharged into tie low pressure separator. The model subsequently models flash gas from LP separators and VRT. The following represents the modeled composition of the VRT stream. Operating conditions in
the simulation are as follows:
LP Separator: 120 F, 30 psig
VRT: 101 F, 4 psig
MW
55.26
Weight %
Helium
CO2
0.32
N2
0.00
methane
0.26
ethane
6.87
propane
25.61
isobutane
9.49
n -butane
20.69
isopentane
6.76
n -pentane
6.18
cyclopentane
0.68
n -Hexane
5.00
cyclohexane
1.00
Other hexanes
0.84
heptanes
2.51
methylcyclohexane
11.10
224-TMP
0.09
Benzene
0.63
Toluene
0.67
Ethylbenzene
0.02
Xylenes
0.21
C8+ Heavies
1.09
Total
100.02
VOC Wt %
92.57
Ib/Ib-mol Displacement Equation
Ex = Q * MW * Xx / C
6 of 9 K:\PA\2019\19WE0377.CP1.xlsm
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
Emission Factor Source
(Ib/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
134978.6466
6748.9323
HYSYS
Benzene
925.3985
46.2699
HYSYS
Toluene
980.5053
49.0253
HYSYS
Ethylbenzene
23.4917
1.1746
HYSYS
Xylene
306.7098
15.3355
HYSYS
HYSYS
HYSYS
n -Hexane
7284.8511
364.2426
224 TMP
131.2243
6.5612
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
23.024
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)
PM2.5
0.0075
23.024
SOx
0.0006
1.818
NOx
0.0680
210.120
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 industrial Flares (CO)
CO
0.3100
957.900
Section 05 - Emissions Inventory
Emission Factors Proposed by Applicant
Pollutant
IbIMhlscf
NOx
.-' µ.NS}E.Q
CO
?51 7430
VOO
135.011_5274
SO2
0.0275
PM PM 10.
PM2 5
0.3477
Benzene-
_=25.56CG
Die hlcroberze<n -
0.0061
Formaldehyde
0.0034
Hexane
7.286.7821
Tc!uere
930.7501
E -Benzene
23.4197
Xy lenes
306.7031
224-Mpentane
130.0680
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.05
0.05
0.05
0.05
0.05
8
0.05
0.05
0.05
0.05
U.05
8
0.00
0.00
0.00
0.00
0.00
1
0.42
0.42
0.42
0.42
0.42
71
269.28
269.28
13.46
269.28
13.46
2287
1.91
1.91
1.91
1.91
1.91
325
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
3692
3692
185
3692
185
Toluene
3912
3912
196
3912
196
Ethylbenzene
94
94
5
94
5
Xylene
1224
1224
61
1224
61
n -Hexane
29067
29067
1453
29067
1453
224 TMP
524
524
26
524
26
Section 06 - Regulatory Summary Analysis
uncontrolled
135011.5274
925.56
7286.7821
930.7561
23.4197
306.7031
130.068
Controlled (lb/MMscf)
6750.5764 VOC
46.2780 benzene
364.3391 n -hexane
49.0378 toluene
1.1710 ethylbenzene
15.3352 xylenes
6.5034 224-TMP
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
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? No
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Ye—)
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
7 of 9 K:\PA\2019\19WE0377.CP1.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
'The low pressure separators permitted with this point are the low pressure portion of an HLP separator (i.e. a single vessel consisting of a high pressure segment and low pressure segment with respective liquid -gas separation). As a result,
the operator is unable to obtain a pressurized liquid sample directly from the high pressure portion of the separator and used HYSYS to "back -blend" the known liquid composition to obta n an estimated upstream composition prior to
discharge to the low pressure segment. Since (i) there is no reason to contest the assumptions used in the simulation, (ii) the resulting compositions of LP (79% VOC) and VRT (93% VOC) are typical, (iii) the gas volume will be metered for
actual compliance demonstration, and (iv) the requested facility -wide controlled emission rates are not approaching major source thresholds, I will approve the emission factors for use wi'h the Initial Approval permit and will require an
initial extended gas analysis of this stream be submitted with self -certification to verify the emission factors.
*Applicant provided comments on the draft permit indicating that they request that the emission factors reflected in their calculations be included in the "notes to permit holder" instead of the values calculated by the Division (i.e. in the
analysis above). I agree to include the emission factors as caclulated by applicant and displayed next to those calculated by the Division in the analysis above on the basis that the differences are minor and attributable to rounding. Also, the
assigned limits in the permit do not change when using the proposed emission factors x process limit from what I've calculated above.
AIRS Point #
011
Process # SCC Code
01 3-10-001-60 Flares
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 23.02 0 Ib/MMSCF
PM2.5 23.02 0 Ib/MMSCF
SOx 1.82 0 Ib/MMSCF
NOx 210.12 0 lb/MMSCF
VOC 134978.65 95 Ib/MMSCF
CO 957.90 0 lb/MMSCF
Benzene 925.40 95 Ib/MMSCF
Toluene 980.51 95 Ib/MMSCF
Ethylbenzene 23.49 95 Ib/MMSCF
Xylene 306.71 95 lb/MMSCF
n -Hexane 7284.85 95 Ib/MMSCF
224 TMP 131.22 95 lb/MMSCF
8 of 9 K:\PA\2019\19WE0377.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)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. 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
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 (Le., not the primary control device) that is not enclosed?
Na
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
COLORADO
Air Pollution Control Division
Department of Public Heath b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0377 Issuance: 1
Noble Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Frico T3N-R65W-S15 L02
123/3256
SWSW, Section 15, T3N, R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LP
Separators
010
Venting of gas from two (2) low-pressure
separators.
Enclosed combustor
VRT
011
Venting of gas from one (1) vapor recovery
tower (VRT)
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, 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 -
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The 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
Part B, Section II.A.4.)
Annual Limits:
not exceed the following limitations. (Regulation N
umber 3,
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
LP Separators
010
---
---
16.5
2.8
Point
VRT
011
---
---
13.5
2.0
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.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
7. Point 010, 011: 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 combustor
VOC and HAP
VRT
011
Emissions from the VRT
enclosed combustor
are routed to an
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
LP Separator Gas Venting
6.91 MMSCF
VRT
011
VRT Gas Venting
3.99 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. Point 010: The owner or operator must continuously monitor and record the volumetric flow
rate of natural gas vented from the low-pressure separator(s) using the flow meter. The
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
11. Point 011: The owner or operator must continuously monitor and record the volumetric flow
rate of natural gas vented from the vapor recovery tower (VRT) using the flow meter. The
owner or operator must use monthly throughput records to demonstrate compliance with the
process limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. Point 010, 011: 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)
13. Point 010, 011: 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.)
14. Point 010, 011: This source is subject to the odor requirements of Regulation Number 2.
(State only enforceable)
OPERATING Et MAINTENANCE RE
UIREMENTS
15. Point 010, 011: Upon startup of these points, the owner or operator must follow the most
recent operat ng and maintenance (0&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements of
this permit. Revisions to the 0&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
16. Point 010, 011: The owner/operator must 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 must 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 must 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
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
operator must submit to the Division within 60 days, or in a timeframe as agreed to by the
Division, a request for permit modification to address these inaccuracies.
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) 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 (NOr) 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
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) 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
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
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 M.G. Final
authorizationcannot 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. Itis 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.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
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
Page 6 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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:
Bradley Eades
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
Page 7 of 11
COLORADO
Air Pollution Control Division
Deo rtrnent of Public 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-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 sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
LP Separator
010
Benzene
71432
3,547
177
Toluene
108883
3,965
198
Ethylbenzene
100414
100
5
Xylenes
1330207
1,343
67
n -Hexane
110543
27,985
1,400
2,2,4-
Trimethylpentane
540841
517
26
VRT
011
Benzene
71432
3,692
185
Toluene
108883
3,912
196
Ethylbenzene
100414
93
5
Xylenes
1330207
1,223
61
n -Hexane
110543
29,067
1,454
2,2,4-
Trimethylpentane
540841
519
26
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health &Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
5) The emission levels contained in this permit are based on the following emission factors:
Point 010 (LP Separators):
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
NOx
177.6049
177.6049
AP -42
CO
799.8484
799.8484
AP -42
VOC
95,432.6619
4,771.6331'
HYSYS
71432
Benzene
513.2459
25.6623
108883
Toluene
573.7010
28.6851
100414
Ethylbenzene
14.5397
0.7270
1330207
Xylene
194.3086
9.7154
110543
n -Hexane
4,049.7195
202.4860
540841
2'2'4
Trimethylpentane
74.8324
3.7416
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The emission factors listed above are based on the following low-pressure separator gas composition,
as modeled using HYSYS:
Molecular Weight:
46.01 lb/lbmol
VOC (Weight %)
78.56%
Benzene (Weight %)
0.42%
Toluene (Weight %)
0.47%
Ethylbenzene (Weight %)
0.01%
Xylene (Weight %)
0.16%
n -Hexane (Weight %)
3.33%
2,2,4-TMP (Weight %)
0.06%
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environmerrt
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 011 (VRT):
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(lb/MMscf)
Source
NOx
214.6950
214.6950
HYSYS/AP-42
Chapter 13.5
CO
961.7430
961.7430
VOC
135011.5274
6750.5764
HYSYS
71432
Benzene
925.5600
46.2780
108883
Toluene
980.7561
49.0378
100414
Ethylbenzene
23.4179
1.1710
1330207
Xylene
306.7031
15.3352
110543
n -Hexane
7,286.7821
364.3391
540841
2,2,4-130.0680
Trimethylpentane
6.5034
Mote: The controlled emissions factors for this point are based on a control efficiency of 95%.
The emission factors listed above are based on the following VRT gas composition, as modeled using
HYSYS:
Molecular Weight:
55.25 lb/lbmol
VOC (Weight %)
92.55%
Benzene (Weight %)
0.63%
Toluene (Weight %) ;
0.67%
Ethylbenzene (Weight %)
0.02%
Xylene (Weight %)
0.21%
n -Hexane (Weight %)
5.00%
2,2,4-TMP (Weight %)
0.09%
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, HAP
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PSD/NANSR
Synthetic Minor Source of: VOC, NOx
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
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
Subpart NNNNN - Subpart XXXXXX
MACT
63.8980 -End
Page 11 of 11
APR - 5 2019
Gas Venting APEN - Form APCD-21r,
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: P tAle3 '77 AIRS ID Number: 123 /3256 / O1O
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Noble Energy, Inc.
FRICO T3N-R65W-S15 L02
SWSW SEC15 T3N R65W
Mailing Address: 1625 Broadway,Suite 220
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@nblenergy.com
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.
355709
Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I A
COLORADO
tWa :o< mb Huat�?� rvN ni
Permit Number: AIRS ID Number:
123 /3256/
[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)
O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
D Change permit limit ❑ Transfer of ownership' ❑ 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: Natural gas venting from low pressure
separators (low pressure leg of two high/low pressure separators)
Company equipment Identification No. (optional): LP Separators
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
TBD
® Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
Yes
Yes
Yes
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I
No
No
No
COLORADO
fitiiT ent of "'c
Permit Number: AIRS ID Number:
123 /3256/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
O 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?
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ Yes 0 No
Vent Gas
Heating Value:
2573
BTU/SCF
Requested:
MMSCF/year
Actual:
6.91
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
46.0132
VOC (Weight %)
78.56
Benzene (Weight %)
0.42
Toluene (Weight %)
0.47
Ethylbenzene (Weight
oz i
0.01
Xylene (Weight %)
0.16
n -Hexane (Weight %)
3.33
2,2,4-Trimethylpentane
(Weight %)
o 06
Additional Required Information:
O Attach a representative gas analysis (including BTEX ft 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 APEN - Revision 7/2018
3I A
of
COLORADO
-H M. 6 EoO1r PtterA
Permit Number:
AIRS ID Number:
123 / 3256 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.2197, -104.6554
Operator
-'--- =---
Discharge Height
Above Ground Level
-- Temp.
Flow Rate
r Velocity
—
Stack ID No.
('F)
(ACFM)
(ft/set)
(Feet)
Leed Gen 1
Variable
Variable
Variable
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
O Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
0 Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
%
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
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: J, Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
AVLVLVKAVV
Permit Number:
AIRS ID Number:
123 / 3256
[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
rail (or combined) control efficiency (% ceduction):
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
Source
Uncontrolled
Controlled
! Uncontrolled ,
Controlled
Emissions
(tons/year)
Emissions 6
(tons year) -
Emissions
ear
y J
Emissions
__( tons/ ear
Uncontrolled
--
Basis
-- -----
Units
2
(413-42,
,-_ ,
M etc.)
_f9��torts/
PM
7.6
lb/mmscf
AP -42
0.00
0.00
SOx
0.6
Ib/mmscf
AP -42
0.00
0.00
NO.
0.068, 100
Ib/mscf
AP -42
0.61
0.61
CO
0.31, 84
lb/mscf
AP -42
2.76
2.76
VOC
95.4325, 5.5
lb/Mscf, Ib/MMscf
HYSYS/AP-42
329.74
16.49
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
_ ( )
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Units
Source
(AP -42,
Uncontrolled
Controlled
Emissions
(pounds/year)
Emissions6
(Pounds/year)
Basis
Mfg., etc.)
Benzene
71432
D.5132
lb/Mscf
HYSYS/AP-42
3547
177
Toluene
108883
D.5737
lb/Mscf
HYSYS/AP-42
3965
198
Ethylbenzene
100414
0.0145
lb/Mscf
HYSYS/AP-42
100
5
Xylene
1330207
0.1943
lb/Mscf
HYSYS/AP-42
1343
67
n -Hexane
110543
4.0496
lb/Mscf
HYSYS/AP-42
27985
1400
2,2,4-
Trimethylpentane
540841
Q0748
lb/Mscf
HYSYS/AP-42
517
26
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
5 j _1
COLORADO
befoorfroon: of Public
Poo.,=Eniitnnmmf
Permit Number: AIRS ID Number:
1 23 / 3256 /
[Leave blank unless APCD has already assigned a permit II 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.
04/03/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Allison Satterfield
Environmental Scientist
Name (please print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
j Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.Rov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I Al
COLORADO
De:
Heald.: E'r renmanl
APR
Gas Venting APEN - Form APCD-211 ° ?°',4
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.Qov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
/p77 AIRS ID Number: 123 / 3256 / O i l
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: FRICO T3N-R65W-S15 L02
Site Location: SWSW SEC15 T3N R65W
Mailing Address: 1625 Broadway,Suite 220
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Allison Satterfield
Phone Number: 303-228-4137
E -Mail Address2: a.satterfield@nblenergy.com
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.
'355710
Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I
COLORADO
e-p,nn- atww.dc
Nu.,01 EllUil, ,rd
Permit Number: AIRS ID Number:
123 /3256/
[Leave blank unless APCD has already assigned a permit #I 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 ownership' ❑ 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:. Natural gas venting from VRT
Company equipment Identification No. (optional): VRT
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
1St Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
hours/day
Will this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
❑✓ Yes 0 No
O Yes ❑✓ No
❑ Yes ❑✓ No
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I
I COLORADO
uv=*.-r'r [Public
Permit Number: AIRS ID Number:
123 /3256/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
O Pneumatic Pump
Make: Model:
o 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? O Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑✓ No
VentValue:
Heating Valuue::
3090
BTU/SCF
Requested:
MMSCF/year
Actual:
3,99
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
55.256
VOC (Weight %)
92.55
Benzene (Weight %)
0.63
Toluene (Weight %)
0.67
Ethylbenzene (Weight
0.02
Xylene (Weight %)
0.21
n -Hexane (Weight %)
5.00
2,2,4-Trimethylpentane
(Weight %)
0 09
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)
a
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
3IAil
�
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
Department of Poetic
H+ai1M r. invifoolnoni
Permit Number:
AIRS ID Number:
123 / 3256 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.2197, -104.6554
- - — —
Operator;
Stack ID No
Discharge Height
-
Above-
Temp.
Flow Rate
Velocity
(ft/sec)
(ACFM)
(•F)
Comm 200 48"
Variable
Variable
Variable
Indicate the direction of the stack outlet (check one)
EI Upward
O Horizontal
0 Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
Section 6 - Control Device Information
O 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, 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
4IAY
V V L VV
Dtrarmtns
IA E Env!e�»imc��l
Permit Number:
AIRS ID Number:
123 /3256/
[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 Methods)
Overall Requested
Control Efficiency
(% reduction in emissions) !:
PM
SOx
NO.
CO
VOC
VOC Burner
95% '
HAPs
VOC Burner
95%
Other:
Fran 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)
--
Uncontrolled
-- —
Basis
Units
--- -
Source
(4P-42,
M etc.
.,_!pc.)
)
Uncontrolled ;
Controlled
_
Uncontrolled
Controlled
Emissions
(tons/year)
Emissions.
----
(tons/year)_
Emissions i
(tons/year) !
Emissions e
(tons/year)
n
_Mfg_
PM
7.6
lb/mmscf
AP -42
0.00
0.00
SOx
0.6
Ib/mmscf
AP -42
0.00
0.00
NO.
0.068, 100
Ib/mscf
AP -42
0.43
0.43
CO
0.31, 84
Ib/mscf
AP -42
1.93
1.93
VOC
5.5, 135.011
Ib/MMsd, lb/Mscr
AP-42/HYSYS
269.28
13.46
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
_._ (--CAS
(
Emission Factor
Actual Annual Emissions
—
Uncontrolled
Uncontrolled
Basis
--
Units
Source
,
SAP -42,
Mfg., etc.)(pounds/year)
-_ —
Uncontrolled
Emissions
Controlled
s6
Emissions6
(Pounds/year)
Benzene
71432
0.9255
lb/Mscf
HYSYS/AP-42
3692
185
Toluene
108883
0.9807
lb/Mscf
HYSYS/AP-42
3912
196
Ethylbenzene
100414
0.0234
lb/Mscf
HYSYS/AP-42
93
5
Xylene
1330207
0.3067
lb/Mscf
HYSYS/AP-42
1223
61
n -Hexane
110543
7.2866
lb/Mscf
HYSYS/AP-42
29067
1454
2,2,4-
Trimethylpentane
540841
0.1300
Ib/Mscf
HYSYS/AP-42
519
26
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
°:wn n: of
n
Permit Number: AIRS ID Number:
123 /3256/
[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.
04/03/2019
Signature of Legally Authorized Person (not a vendor or consultant)
Allison Satterfield
Date
Environmental Scientist
Name (please print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
Q Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
0
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.gov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
61
COLORADO
Public
HwFtin E Enmirewnc,.1
Hello