HomeMy WebLinkAbout20192224.tiffCOLORADO
Department of Public
Health Et 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
June 3, 2019
Dear Sir or Madam:
RECEIVED
IN 102. n
lr'aJ
WELD COUNTY
C>MUSSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - WELLS RANCH STATE AF08 ECONODE. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor
Pu b\; c Re,3V_,3
C..o/II/tcl
Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
Cc/. PL ‘.‘LC. ST,
(,)1•A I R lc k icw)
Lola tic)
2019-2224
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - WELLS RANCH STATE AF08 ECONODE - 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: WELLS RANCH STATE AF08 ECONODE
Exploration and Production Well Pad Facility
SENE Sec 08 T5N R62W
Weld County
The proposed project or activity is as follows: Noble Energy has submitted permit applications for the
emission points at this new tank -less facility, which began operation on March 18, 2018. The facility consists
of four natural gas driven compressors and two generators on site, which have requested coverage under the
GP02. This permit is for the enclosed combustor that receives gas from various process units throughout the
site, including but not limited to: knockout tanks and scrubber.
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 18WE0716 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
1 I A_ r. lImpanvan Palls
n ryna Enmmmwm.
ADO
n Contro
is Hea
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0716 Issuance: 1
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Noble Energy, Inc.
WELLS RANCH STATE AF08 ECONODE
123/9FD0
SENE SEC 08 T5N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Enclosed
Burner
001
Gas venting for flash gas from knock out
tanks, scrubber and other miscellaneous
equipment on site
Enclosed Combustion
Device
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, y
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
COLORADO
Air Pollution Control Division
Departtrn of Public Heath & Env n r ent
Page 1 of 9
on. It is er or op responsibi to self-
nce h ° � onditions demo ate , ompliancethin 180
t in • cati h f the • rmit. A f certi tion form and • ance on
certi... Tian ..,, ed by be obta ne at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B,
Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen months or more; (iii) does not complete construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. 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.)
5. 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
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
Enclosed
Burner
001
---
---
14.8
2.5
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Compliance with the annual limits, for criteria air pollutants, shall be determined on a
rolling twelve (12) month total. By the end of each month a new twelve month total is
calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
7. The owner or operator shall track emissions from all insignificant activities at the facility
on an annual basis to demonstrate compliance with the facility potential emission
limitations as seen below. An inventory of each insignificant activity and associated
emission calculations shall be made available to the Division for inspection upon request.
For the purposes of this condition, insignificant activities are defined as any activity or
equipment, which emits any amount but does not require an Air Pollution Emission
Notice (APEN) or is permit exempt.
COLORADO
Air Pollution Control Division
Department of Pubir hMa[th & Environment.
Page 2 of 9
em .. m the fa cluding
it fr a gnificant shall be
ns per
8. The emission points in the table below shall be operated and maintained with the
emissions control equipment as listed in order to reduce emissions to less than or equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Enclosed
Burner
001
Emissions from the knock out, scrubber,
and other miscellaneous equipment are
routed to an Enclosed Combustion Device
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Enclosed
Burner
001
Natural Gas Venting
6.57 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. The owner or operator shall continuously monitor and record the volumetric flow rate
of natural gas vented from the separator(s) using the flow meter. The owner or operator
shall use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g.
123/4567/001) shall be marked on the subject equipment for ease of identification.
(Regulation Number 3, Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The combustion device covered by this permit is subject to Regulation Number 7,
Section XVII.B.2. General Provisions (State only enforceable). If a flare or other
combustion device is used to control emissions of volatile organic compounds to comply
with Section XVII, it shall be enclosed; have no visible emissions during normal
CDPHE
dY�Y
COLORADO
Air Pollution Control Division
Department of Pubhc Health & Envvonment
Page 3 of 9
egulation 7, XVII. d be desig
visual obit . rom the of the en
other onveni : means pproved by th
het op .perly. 1. - t be equi
operational auto -igniter according to the following schedule:
so that
sed flare
Division,
'th an
• All combustion devices installed on or after May 1, 2014, must be equipped with
an operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion
device planned shutdown, whichever comes first.
14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State
Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and
gas well, must either be routed to a gas gathering line or controlled from the date of
first production by air pollution control equipment that achieves an average
hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a
design destruction efficiency of at least 98% for hydrocarbons.
OPERATING a MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (OEM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the O&M plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any
period or periods of duration greater than or equal to one minute in any fifteen minute
period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
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.)
• 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
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 4 of 9
pounds ( . nitrogen ources (N " in ozone
emitting 1 100 ton V�� or NOx 'q year, a
in an :l act :-emissi•� of one :: ton pe -ar or more or fi percent,
ever - ; er, -vet r, • • • st APEN;
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this
construction permit does not provide "final" authority for this activity or operation of
this source. Final authorization of the permit must be secured from the APCD in writing
in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation
Number 3, Part B, Section III.G. Final authorization cannot be granted until the
operation or activity commences and has been verified by the APCD as conforming in all
respects with the conditions of the permit. Once self -certification of all points has been
reviewed and approved by the Division, it will provide written documentation of such
final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this
information and with representations made by the owner or operator or owner or
operator's agents. It is valid only for the equipment and operations or activity
specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in
this permit have been determined by the APCD to be necessary to assure compliance
with the provisions of Section 25-7-114.5(7)(a), C.R.S.
COLORADO
Air Pollution Control Division
Department of Public Health & F. aliment
Page 5 of 9
23. h and ev:��� conf�� • � r is permit erial par and is no ..,-verable.
a conditioall cons ejection . ri e entire
on suce, th f°permitll be d ed denied ab io. This
e re to se i • N.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.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual
fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
COLORADO
Air Pollution Control Division
Department of Public Health b cnvviMmere
Page 6 of 9
Notes tthis perm . t .rice:
1) Th ay fees f e p -ssing ti for his permit, `n invoice
for � =-se fe- �� I be i � , � ed a the • e mit is is -d. Th: ermit holder s pay the
i - n 30 daeip ""voice. ° . • • . 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 /cdphe/ aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of
the Division's analysis of the specific compounds emitted if the source(s) operate at the
permitted limitations.
Facility
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Enclosed
Burner
001
Benzene
71432
3720
186
Toluene
108883
3020
151
Ethylbenzene
100414
2180
109
Xylenes
1330207
1380
69
n -Hexane
110543
19,820
991
2,2,4-
Trimethylpentane
540841
2120
106
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission
rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees
based on the most recent Air Pollution Emission Notice.
COLORADO
Mr Pollution Control Division
Department of Rota:: Health & Environment
Page 7 of 9
5) Th - 3, ission le
Poi 001:
is permi
CAS #
Pollutant
Ted
Emission
Factors
(lb/MMSCF)
-�
Emission
Factors
(lb/MMSCF)
Source
NOx
173.5
173.5
AP -42
Chapter 13.5
CO
767.1
767.1
VOC
90,231.0
4,511.55
HYSYS Modeling
based on a
pressurized liquid
sample s
06/007/207/2018
71432
Benzene
565.3
28.265
108883
Toluene
460.5
23.025
100414
Ethylbenzene
330.7
16.535
1330207
Xylene
208.8
10.44
110543
n -Hexane
3,017.3
150.865
540841321.9
2,2,4 -taken
Trimethylpentane
16.095
Note: The controlled emissions factors for this point are based on the enclosed
combustion device control efficiency of 95%. The combustion emission factors
were calculated based on a gas heating value of 2461 BTU/scf.
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: NOx, VOC, and CO
NANSR
Synthetic Minor Source of: NOx and VOC
PSD
Synthetic Minor Source of: CO
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://www.ecfr.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
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health b .Environment
Page 8 of 9
63: Nati 1 E . • . '..
• egories
dards for a +ous Air • . = s for Sou
T
6 <' 63.59 r:
ubpar s A- Subp. : Z
63.600-6 .
ti. e. .`.A., -Sue... .1.
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Department of Pubic Hear & Fnvfronment
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Lauraleigh Lakocy
Package #: 384267
Received Date: 6/15/2018
Review Start Date: 1/3/2019
Section 01 - Facility Information
Company Name: Noble Energy, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
SENE
03
5N
62
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
9FD0
WELLS RANCH STATE AF08 ECONODE
SENE quadrant of Section 08, Township 5N, Range 62W
Weld County
Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit tt
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Separator Venting
Enclosed Burner
18WE0716
Permit Initial
Issuance
Section 03 - Description of Project
Noble Energy is submitting APENs and permit applications for the associated emission points at the new tank -less facility known as the WELLS RANCH STATE AF08 ECUNODE.,
which began operation on March 18, 2018. The facility consists of four natural gas driven compressors and two generators on site, which have requested coverage under the
GP02. This permit analysis is for the enclosed combustor that receives gas from various process units throughout the site, including but not limited to: knockout tanks and
scrubber.
Based on the submitted documentation, this source is a synthetic minor facility located in the ozone non -attainment region. Because the total reported CO emissions
exceeded 90 tpy and the permitted CO limits were 89.0, the source is required to track emissions from all insignificant activities at the facility on an annual basis to
demonstrate compliance with the Title V program.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Yep
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
J
CO VCC PM2.5 PM10 TSP HAPs
NOx CO VOC PM2.5 PM10 TSP HAPs
i _
HI
Separator Venting Emissions Inventory
001 Separator Venting
Facility AIRs ID:
123
County
9FD0
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Control device for flash gas from knock out, scrutber and other miscellanous equipment at tank -less facility
Enclosed Combustion Device
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
6.6 MMscf per year
95
Requested Permit Limit Throughput =1 6.6
MMscf per year Requested Monthly Throughput =
1 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU: No
Is VRU process equipment:
7 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
2461 Btu/scf
scf/bbl
At this tankless facility, gas is routed to an enclosed combustion device from knock out tanks, scrubbers and other miscellaneous equipment on site. Noble obtained pressurized liquid samples of the facility inlet and modeled
and calculated emissions for this 'flash' gas as a hypothetical VRT stream in HYSYS.
Emission Factors
Separator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/MMscf)
(lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
90231.0
4511.5500
HYSYS
HYSYS
HYSYS
HYSYS
HYSYS
HYSYS
HYSYS
,
Benzene
565.3
28.2650
Toluene
460.5
23.0250
Ethylbenzene
330.7
16.5350
Xylene
208.8
10.4400
n -Hexane
3017.3
150.8650
224 TMP
321.9
16.0950
Pollutant
Primary Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu)
lb/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
0.0075
18.337
AP -42 Table 1.4-2 (PM1.0/PM.2.S)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 133 Industrial Flares
ustrial Flares
(Nox)
(CO)
PM2.5
0.0075
18.337
SOx
0.0006
1.448
NOx
0.0680
167.348
CO
0.3100
762.910
: of 7 K:\PA\2018\18WE0716.CP1
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.06
0.06
0.06
0.06
0.06
10
0.06
0.06
0.06
0.06
0.06
10
0.00
0.00
0.00
0.00
0.00
1
0.55
0.55
0.55
0.55
0.55
93
296.41
296.41
14.82
296.41
14.82
2517
2.51
2.51
2.51
2.51
2.51
426
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
3714
3714
186
3714
186
3025
3025
151
3025
151
Ethylbenzene
2173
2173
109
2173
109
Xylene
1372
1372
69
1372
69
n -Hexane
19824
19824
991
19824
991
224 TM P
2115
2115
106
2115
106
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulat on 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 equ pment 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.
No
-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 cn 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? No
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 followmg questions do not re wire an answer.
3 of 7 K:\PA\2018\18WE0716.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes - -
On the HYSYS model, the values for mole fraction inputted for the model matched the pressurized sample analysis. The weight fraction and liquid volume fraction had slight discrepancies from the pressurized sample analysis results and
could have resulted from the source directly calculating those values. This will not have a significant difference on the cat.ulation of emissions.
The emissions listed above in the analysis slightly differ from the requested annual permit values, likely due to some slightrounding differences. The permit will reflect the source -requested values.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point It
001
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 18.34 0 lb/MMSCF
PM2.5 18.34 0 Ib/MNSCF
SOx 1.45 0 lb/MMSCF
NOx 167.35 0 Ib/MNSCF
VOC 90231.00 95 lb/MNSCF
CO 762.91 0 lb/MMSCF
Benzene 565.30 95 Ib/MMSCF
Toluene 460.50 95 lb/MMSCF
Ethylbenzene 330.70 95 Ib/MMSCF
Xylene 208.80 95 lb/MMSCF
n -Hexane 3017.30 95 lb/MMSCF
224 TMP 321.90 95 lb/MMSCF
4 of 7 K:\PA\2018\18WE0716.CP1
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 8, Section II.D.3)?
Not enough information
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)?
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 subject to Regulation 7, Section XVII.B.2
G
Section XVII.B.2 — General Provisions for Air Pollution Contro Equipment and Preventicn of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e.. not the primary control device) that is not enclosed?
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e -- Alternative emissions control equipment
Yes
Yts
Disclaimer
This document assists operators with determiring applicability of certa,n 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. Mardatory 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 si
The contro
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
Noble Enemy, Inc.
County AIRS ID
123
Plant AIRS ID
9FD0
Facility Name
WELLS SITE STATE AF08 ECONOD
E
History File Edit Date
2/22/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons oer year
EMISSIONS With Controls (tons er year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous
Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
18WE0716
Enclosed Burner
0.6
296.4
2.5
16.1
0.6
14.8
2.5
0.8
New emission point
002
GP02
Doosan 236 HP 4SRB RICE
0.2
0.2
20.6
1.6
34.6
0.3
0.2
0.2
2.3
1.6
4.6
0.3
New GP02 Request
003
GP02
Doosan 236 HP 4SRB RICE
0.2
0.2
20.6
1.6
34.6
0.3
0.2
0.2
2.3
1.6
4.6
0.3
New GP02 Request
004
GP02
Caterpillar 601 HP 4SRB RICE
0.4
0.4
67.6
4.1
67.6
0.6
0.4
0.4
4.1
1.1
8.7
0.6
New GP02 Request 0
005
GP02
Caterpillar 1380 HP 4SLB RICE
0.6
0.6
6.7
13.7
60.0
4.4
0 6
0.6
6.7
9.3
20.0
4.4
New GP02 Request
006
GP02
Waukesha 1680 HP I1SRB RICE
1.3
1.3
215.8
11.4
186.6
1.4
1.3
1.3
8.1
11.4
24.3
1.4
New GP02 Request- see note 1
007
GP02
Waukesha 1680 HP 4SRB RICE
1.3
1.3
215.8
11.4
186.6
1.4
1.3
1.3
8.1
11.4
24.3
1.4
New GP02 Request- see note 1
0.0
0.0
APEN Exempt/Insignificant
0.0
0.0
Separator Heaters (12)
0.1
0.1
1.4
0.10
1.1
0.0
0.1
0.1
1.4
0.1
1.1
0.0
From APCD Form 102 Submitted 7/30/18
Funitives
0.8
0.0
0.8
0.0
From APCD Form 102 Submitted 7/30/18
n n
0.0
FACILITY TOTAL
4.1
4.1
0.0
0.0
549.0
340.3
0.8
573.6
24.4
4.1
4.1
0.0
0.0
33.6
51.3
0.8
90.1
9.1
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (PSD and OP)
HAPS: Minor
Permitted Facility Total
4.0
4.0
0.0
0.0
547.7
340.2
0.0
572.5
24.4
4.0
4.01 0.01 0.0
32.2
51.2
0.0
89.0
9.1
Excludes units exempt from permits/APENs
(A) Change
in Permitted Emissions
4.0
4.0 0.0 0.0
322
51.2
0 0
89.0
Pubcom required b/c synthetic minor limit.
Modelling not required based on a emissions &
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
52.1
_
Facility is eligible for GP02 because < 90 tpy
Project emissions not less than 25 tpy
51.2 _
Note 1
The GP02 requests were received 7/30/2018; however, due to the proximity in the requests being made and the project association, they are being added to this history tab for consideration under
the same
_
project.
Note 2
Project emissions are not less than 25 tpy; however, most of those emissions are a result of GP02 applications
which have gone through public comment & the individual permit requires
public comment separately.
Page 6 of 7
Printed 4/3/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Noble Energy, Inc.
County AIRS ID 123
Plant AIRS ID 9FD0
Facility Name WELLS SITE STATE AF08 ECONODE
Emissions - uncontrolled
(lbs
per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tpy)
(Previous FACILITY
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
18WE0716
Enclosed
Burner
.
3720
3020
2180
1380
19820
2120
16.1
002
GP02
Doosan 236 HP
4SRB RICE
381
52
49
29
57
0.3
003
GP02
Doosan 236
HP
4SRB RICE
381
52
49
29
57
I
0.3
004
GP02
Caterpillar
601
HP
4SRB
RICE
696
124
117
70
136
0.6
005
GP02
Caterpillar
1380
HP
4SLB
RICE
6930
970
597
51
I
290
4.4
006
GP02
Waukesha
1680
HP
4SRB
RICE
1622
360
339
394
1.4
007
GP02
Waukesha
1680
HP
4SRB RICE
1622
360
339
304
1.4
0.0
APEN
Exempt/Insignificant
0.0
Separator
Heaters
(12)
0.0
Fugitives
0.0
0.0
TOTAL (tpy)
5.8
1.0
0.7
2.0
1.5
1.1
0.7
9.9
0.7
1.1
0.0
0.0
24.4
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with
controls
(lbs
per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
0
0
0
0
0
0
0
0
0
0
0
0
0.0
!Previous FACILITY
TOTAL
001
18WE0716
Enclosed
Burner
186
151
109
69
991
106
0.8
002
GP02
Doosan 236
HP
4SRB
RICE
381
29
57
0.3
003
GP02
Doosan 236
HP 4SRB
RICE
381
29
57
0.3
004
GP02
Caterpillar
601
HP
4SRB
RICE
696
70
136
0.6
005
GP02
Caterpillar
1380
HP
4SLB
RICE
6930
970
597
51
i
290
4.4
006
GP02
Waukesha
1680
HP
4SRB RICE
1622
360
339
394
1.4
007
GP02
Waukesha
1680
HP
4SRB RICE
1622
360
339
394
1.4
0.0
APEN
E
0.0
Separator
Heaters
(12)
0.0
Fugitives
0.0
0.0
TOTAL
(tpy)
5.8
1.0
0.7
0.2
0.1
0.1
0.0
0.5
0.7
0.1
0.0
0.0
9.1
7
"18WE0716.CP1
4/3/2019
RECEIVED ,\
FEB 21 2019
APCD
n li Oilary
Natural 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 Natural Gas Venting only. Natural 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. 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: 18 WE0716
AIRS ID Number: 123 i 9FD0/ 001
[Leave blank unless APCD has already assigned a permit n and AIRS ID]
Company equipment Identification: Enclosed Burner
[Provide Facility -Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Namer: Noble Energy,Inc.
Site Name: WELLS RANCH STATE AF08 ECONODE
Site Location: SENE SEC08 T5N R62W
Mailing Address:
(Include. Zip Code) 1625 Broadway, Suite 2200
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver CO 80202 Permit Contact: Shaun Higgins
E -Mail Address': shaun.higgins@nblenergy.com
Phone Number: 720-587245.9
'Please 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 APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN; - Rev 03/2Q17
co Lc r,O
Permit Number: 18WE0716
AIRS ID Number: 123 / 9FD0/ 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.4136, -104_3388
t7perat®r''''.711,:6,:r6.:°.::'...—....'
Stack ID No
I ischarge Height
Above Ground Level
.
Tempiow
f F�
Rate
lACFbt)
Velocity
(ftlsec)
Indicate the direction of thestack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
O Upward with obstructing raincap
Section 6 - Control Device information
❑ VRU:
Pollutants Controlled
Size: Make /Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane
Rating:
Type: VOC Burner Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
95%
Waste Gas Heat Content
Constant Pilot Light: ❑ Yes O No Pilot burner Rating
Btu/scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-205 -Natural Gas Venting APEN Rev 03/2017
4I
Permit Number: 181NE0716
AIRS ID Number: 123 r 9FD0t 001
[Leave blank unless APCD has already assigned a permit # and AIRS. !DI
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations -and emission factor docurnentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes O No
If yes, please describe the control. equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO5
NOx
VOC
VOC Burner
95%
CO
HAPs
VOC- Burner
95%
Other.:
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and d to calculate these emissions.)
ed hip pei% pip -.42
xlct led emaU
:c.ieueot 21 tsVico
Luatco c* t
Pollutant
Uncontrolled
Emission
- Factor
Emission
: Factor
Units
Emission
Factor
Source
(AP42#
Mfg. etc)
Requested At►nual Permit
Emisston.Iimit�sJ5-
Actual Annual Emissions '
Uncontrolled
year)
(Toyear)
(Tons/
Controlled',
' (Tons/year)
Uncontrolled
(Tonsiyear) :
Controlled
(Tonslyear)?
PM
7.60
Ib/mmscf
HYSYS/AP42
0.00
0.00
SOK
0.60
Ibtmmscf
HYSYS/AP42
0.00
0.00
NO5
0.068
Ib!MMeV
HYSYS/AP42
0.57
D.57
VOC
90.231
Ib/mscf
HYSYSIAP42
296.41
14.82
CO
0.310
lb/Mh/l.sW
HYSYSIAP42
2.52
2.52
Benzene
0.5653
lb/rnscf
HYSYS/AP42
1.86
0.09
Toluene
0.4605
ib/mscf
HYSYS/AP42
1.51
0.08
Ethytbenzene
0.3307
lb/mscf
HYSYS/AP42
1.09
0.05
Xytenes
0.2088
lb/mscf
HYSYS/AP42
-
0.69
0.03
n -Hexane
3,0173
lb/mscf
HYSYS/AP42
9.91
0.50
2'x'4
Trimethylpentane
0.3219
Ib/mscf
HYSYS/AP42
1.06
0.05
Other:
5 Requested valueswillbecome permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based onactualcontrolled emissions reported. If source has not yet started operating, leave blank.
Forrn APCD-Z0541aturai Gas Venting APEN - Re;' 03/2017
i. jotw
cold Da
5h. ...,
(:),2a - VA.aau rTF EN
Odd&t,d th-\ recAeoed erat 1ao�q -
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
JUN 1 5 2018
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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, btowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. 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:
I ' W E O7I6 AIRS ID Number:
123 /cfFtc/ &o/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: Enclosed Burner
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: WELLS RANCH STATE AF08 ECONODE
Site Location
Site Location:
SENE SECO8 T5N R62W County: Weld
Mailing Address:
p Code1625 Broadway, Suite 2200
(Include Zip Code) i,
Denver CO 80202
E -Mail Address2: gabriela.vega@nblenergy.com
NAICS or SIC Code: 1311
Permit Contact: Gabriela Vega
Phone Number: 303-228-4475
'Please 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 APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017
COLORADO
ktzll" b E roonnent
Permit Number: AIRS ID Number:
123 / /TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
(] NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Please 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 ft Notes:
3 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:
Enclosed Burner
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
03 / 18 / 2018
/ /
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation:
24 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
7
days/week
52
weeks/year
Yes 0 No
0 Yes El No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I A
etment of P..
COLORADO
fl h6 Er.Nrrmmsat
Permit Number:
AIRS ID Number: 123 / / TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
O Well Head Casing
❑ Pneumatic Pump
Make: Model:
Serial #:
Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: # of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
# of Events/year: Volume per event: MMscf/event
D Other
Description: Control device for flash gas from knock out, scrubber and other misc. equipment
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
D No
Maximum Vent
Rate:
219
SCF/hr _ _
Vent Gas
Heating Value:
2461
BTU/SCF
Requested:
1.916
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
58.99
VOC (Weight %)
77.9
Benzene (mole %)
0.27
Benzene (Weight %)
0.49
Toluene (mole %)
0.19
Toluene (Weight %)
0.40
Ethylbenzene (mole %)
0.12
Ethylbenzene (Weight %)
0.29
Xylene (mole %)
0.07
Xylene (Weight %)
0.18
n -Hexane (mole %)
1.33
n -Hexane (Weight %)
2.60
2,2,4-Trimethylpentane
(mole %)
0.
2,2,4-Trimethylpentane
(Weight %)
0 28
Additional Required Information:
▪ 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)
O
Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017
3I A
COLORADO
DecemmntM Nb c
Heet0EFa cnmeM
❑ Upward
❑ Horizontal
Permit Number:
AIRS ID Number: 123 /
/TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.4136, -104.3388
Discharge Height
- Above Ground Level `
Temp. .:
Flow, Rate
Velocity
(it/sec).
Operator,
- -- -
Stack ID No.
('F)
(ACFht
(Feet)
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Other (describe):
Interior stack diameter (inches):
0 Upward with obstructing raincap
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency %
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane
Rating: MMBtu/hr
Type: VOC Burner Make/Model:
95% %
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
%
Waste Gas Heat Content
Constant Pilot Light: 0 Yes 0 No Pilot burner Rating
Btu/scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
4I A
COLORADO
PUM,c
Hee. b En•MCTmn»t
Permit Number:
AIRS ID Number: 123 i i TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes O No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO.
VOC
VOC Burner
95%
CO
HAPs
VOC Burner
95%
Other:
taint v,E4
2 1 lu 1 2 Ott
LC d �" L
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant .:
Uncontrolled
Emission
Requested` Annual.Pe
Emission Limit
.mom
sas
Emission
Factor `
Units 3;
Factor
Source
7 (AP -42, :
-Mfg.:etc)r
Actual nnual Emissions
Emission ,
Factor
-
-~^ _MM
ate"
:Uncontrolled
Controlledb
(•Tons/year).
Uncontrolled °
(Tons/year);
'Controlled,
(Tons/year)
s (Tons/year)
PM
7.60
ib/mmscf
I-YSYS/AP42
0.00
0.00
SOX
0.60
Ib/mCC^"i scf
HYSYS/AP42
0.00
0.00
NO.
0.068
lb/ NI sHYSYS/AP42
0.18
0.18
VOC
90.231
Ib/mscf
HYSYS/AP42
86.45
4.32
Co
0.310
FRN64
lb/MMscf
HYSYS/AP42
0.75
0.75
Benzene
0.5653
Ib/mscf
HYSYS/AP42
0.54
0.03
Toluene
0.4605
Ib/mscf
HYSYS/AP42
0.44
0.02
Ethylbenzene
0.3307
Ib/mscf
HYSYS/AP42
0.32
0.02
Xylenes
0.2088
Ib/mscf
HYSYS/AP42
0.20
0.01
n -Hexane
3.0173
Ib/mscf
HYSYS/AP42
2.89
0.14
2'2'4
Trimethylpentane
0.3219
lb/mscf
HYSYS/AP42
0.31
0.02
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I A.
COLORADO
PaMlc
% Rh 0 EMIIM.nrtv
Permit Number:
AIRS ID Number: 123 / / 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 corral.
06/15/2018
Sigp(ature of Legally Authorized'Person (not a vendor or consultant)
Date
Gabriela Vega -J Environmental Engineer
Name (please print)
Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 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
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6 I A
COLORADO
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