HomeMy WebLinkAbout20191472.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
April 10, 2019
Dear Sir or Madam:
RECEIVED
APR 1 5 2019
WELD COUNTY
COMMISSIONERS
On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy Inc. - Hullabaloo Y16 -28-A Econode T2N R64W S16 L01. 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
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
POdokic 9Ne3re.,103
4122/101
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2019-1472
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy Inc. - Hullabaloo Y16 -28-A Econode T2N R64W 516 L01 - Weld County
Notice Period Begins: April 11, 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: Hullabaloo Y16 -28-A Econode T2N R64W S16 L01
Exploration &t Production Well Pad
NENW quadrant of Section 16, Township 2N, Range 64W
Weld County
The proposed project or activity is as follows: Initial application for a new E&tP Wellsite
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 18WE0996 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:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
1 I ACOLORADO
n ul, me
ADO
n Contro
lic Heal
CONSTRUCTION PERMIT
Permit number: 18WE0996 Issuance: 1
Date issued:
Issued to: Noble Energy Inc.
Facility Name: Hullabaloo Y16 -28-A Econode T2N R64W S16 L01
Plant AIRS ID: 123/9FF0
Physical Location: NENW SEC 16 T2N R64W
County: Weld County
General
Description: Econode Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LP and
Surge
Drums
001
Venting of Gas from heater treaters and
surge drums during vapor recovery unit
downtime.
Enclosed combustor
Oil Tanks
002
Two (2) 500 barrel fixed roof storage
vessels used to store condensate
Enclosed combustor
TLO
003
Truck loadout of condensate by
submerged fill
Enclosed combustor
Produced
Water
004
Four (4) 500 barrel fixed roof storage
vessels used to store produced water
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
COLORADO
Air Pollution Control Division
0-zmartrriern of Public Hee rn E Era.aronnient
Page 1 of 13
1.°.' U MUST s fy t tion Con r . r sion (the ) no late an fifteen
tter enceme ation o ssu.: ce of thi�F'ermit, by
otic Sta ` ,k• form the Di ° ,' •n for equipment co ' ed by this
e ��_ - o �_ �-, for •ownload-. 'ne at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the
permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, compliance with the conditions contained in this permit shall
be demonstrated to the Division. It is the owner or operator's responsibility to self -
certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. A self certification form and guidance on
how to self -certify compliance as required by this permit may be obtained online at
www.colorado.Rov/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
LP and Surge
Drums
001
---
1.2
36.7
5.5
Point
Oil Tanks
002
---
---
1.4
---
Point
TLO
003
---
---
1.7
---
Point
COLORADO
Air Pollution Control Division
U artmer of Ribhc Hean b E^.vrron rc ;t
Page 2 of 13
ote ,._ it info • sion fact • , ethods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall
be determinedon 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 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
LP and Surge
Drums
001
Emissions from the heater treater(s) and
surge drum(s) are routed to an enclosed
combustor during Vapor Recovery Unit
(VRU) downtime
VOC and HAP
Oil Tanks
002
Enclosed combustor
VOC and HAP
TLO
003
Enclosed combustor
VOC and HAP
Produced
Water
004
Enclosed combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. 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
LP and Surge
Drums
001
Natural Gas Venting to
enclosed combustor
12.5 MMSCF
COLORADO
Air Pollution Control Division
,.!Dartment of Pub,c t eStn t Entironmer+t
Page 3 of 13
Produced
Water
004
Conderfi_oughput 240,900 rels
ded 240,900 rels
Produced Water
Throughput
2,250,000 barrels
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.
9. Point 001: 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 meter
shall measure the total combined volumetric flow rate of gas from the heater treater(s)
and the surge drum(s) to the enclosed combustor. 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
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. Point 001: 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.
12. Point 002: This source is subject to Regulation Number 7, Section XII. The operator
shall comply with all applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank
be enclosed, have no visible emissions, and be designed so that an observer can,
by means of visual observation from the outside of the enclosed combustion
device, or by other means approved by the Division, determine whether it is
operating properly. (Regulation Number 7, Section XII.C.) (State only
enforceable)
13. Point 003: No owner or operator of a smokeless flare or other flare for the combustion
of waste gases shall allow or cause emissions into the atmosphere of any air pollutant
which is in excess of 30% opacity for a period or periods aggregating more than six
minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.)
14. Point 003: This source is located in an ozone non -attainment or attainment -
maintenance area and is subject to the Reasonably Available Control Technology (RACT)
requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck
COLORADO
Air Pollution Control Division
Page 4 of 13
bmerged emissionby a flare.
rt B, III.D
15.iquid ading egardless of s: shall be
opera - • . as kage of organic
compounds to the atmosphere to the maximum extent practicable.
16. Point 003: The owner or operator shall follow loading procedures that minimize the
leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation
3, Part B, III.D.2):
a. The owner or operator shall inspect onsite loading equipment to ensure that
hoses, couplings, and valves are maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading. The inspections shall
occur at least monthly. Each inspection shall be documented in a log available
to the Division on request.
b. All compartment hatches at the facility (including thief hatches) shall be closed
and latched at all times when loading operations are not active, except for
periods of maintenance, gauging, or safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief
hatch covers shall be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure flashing,
working and breathing losses are not vented through the PRD under normal
operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of
status, a description of any problems found, and their resolution.
17. Point 003: For this controlled loading operation, the owner or operator shall follow
loading procedures that minimize the leakage of VOCs to the atmosphere including, but
not limited to (Reference: Regulation 3, Part B, III.D.2):
a. Install and operate the vapor collection and return equipment to collect vapors
during loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back -pressure less than the
pressure relief valve setting of transport vehicles.
18. Points 002 and 004: The storage tank covered by this permit is subject to the emission
control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator
shall install and operate 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 except where the
combustion device has been authorized by permit prior to May 1, 2014. The source shall
follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and
maintain records of the inspections for a period of two years, made available to the
COLORADO
Air Pollution Control Division
Lae' 3':metit of Ptib!tC Haiti Environment
Page 5 of 13
19.
age Tan
Number 7, Section XVII.C.2.
20. Points 001, 002, and 004: 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)
21. Points 001, 002, and 004: 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 operations, as defined under Regulation Number 7, XVII.A.16; and be
designed so that an observer can, by means of visual observation from the outside of
the enclosed flare or combustion device, or by other convenient means approved by the
Division, determine whether it is operating properly. This flare must be equipped with
an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with
an operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion
device planned shutdown, whichever comes first.
OPERATING £t MAINTENANCE REQUIREMENTS
22. Points 001, 002, 003, and 004: Upon startup of these points, the owner or operator
shall follow the most recent operating and maintenance (O&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 OFtM 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
23. Point 001: The owner/operator shall complete an initial site specific extended gas
analysis ("Analysis") within one hundred and eighty days (180) after commencement of
operation or issuance of this permit, whichever comes later, of the natural gas vented
from the surge drum in order to verify the VOC content (weight fraction) of this emission
stream. Results of the Analysis shall be used to calculate site -specific emission factors
for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using
Division approved methods. Results of the Analysis shall be submitted to the Division as
part of the self -certification and must demonstrate the emissions factors established
through the Analysis are less than or equal to, the emissions factors submitted with the
permit application and established herein in the "Notes to Permit Holder" for this
emissions point. If any site specific emissions factor developed through this Analysis is
greater than the emissions factors submitted with the permit application and
established in the "Notes to Permit Holder" the operator shall submit to the Division
must behin 90 da f the date
COLORADO
Air Pollution Control Division
ihvoartment Of PUNIC it He an b EnWOrrnent
covered P.,this p it are subject t he venting
t Sys W -quiremen " ulation
Page 6 of 13
rame as
these ina
o by the
s).
a reque for permit
24. e�,�int 00._. e o r or �.�� ator all come sit ecific samplincluding a
ional an ;''� Ww the . press :;, „�. o e routed ' storage
tanks and, if necessary for emission factor development, a sales oil analysis to determine
RVP and API gravity. Testing shall be in accordance with the guidance contained in PS
Memo 05-01. Results of testing shall be used to determine site -specific emissions factors
for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -
specific sampling and analysis shall be submitted to the Division as part of the self -
certification and used to demonstrate compliance with the emissions factors chosen for
this emissions point.
25. Points 001, 002, and 004: 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 XII.C, XVII.B.2. and XVII.A.16)
26. Point 004: This source is not required to conduct initial testing, unless otherwise
directed by the Division or other state or federal requirement.
Periodic Testing Requirements
27. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
28. 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
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
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
COLORADO
Air Pollution Control Division
v'.er of Pubk Mean t Env:Tor meat
Page 7 of 13
equipme tailed, o " .°giver a diff nt type of
laces an r .r pe of c • rola• uipment;
ust be E 'r ified;
• No later than 30 days before the existing APEN expires.
29. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the
applicable Federal program threshold will require a full review of the source as though
construction had not yet commenced on the source. The source shall not exceed the
Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and
D).
GENERAL TERMS AND CONDITIONS
30. 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.
31. 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.
32. 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.
33. 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.
34. 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 shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall 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.
COLORADO
Air Pollution Control Division
s{?rei14 of Pk:no )-'n-`. ES Env:To!me^C
Page 8 of 13
35.
tion 25
fission No
ministra •
. require l sources • to file an r Pollution
pay an - to cov he osts of in ctions and
activitcontin , the owner m notify the
Upon noti,Q�: annual
36. 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:
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc.
COLORADO
Air Pollution Control Division
Oms:ment QT F':ftl!t' HeaS.h & F awon :e ,
Page 9 of 13
(A •f . ) ,
If a ura
ritin_ m
fee billing will terminate.
Notes t this per r mince:
1) Th is reay fees r t e •�_ essing - e f. this perm An invoice
for se fe �ll be ed a the -rmit is ed. T permit holder - ll pay the
i s in 30 day ` • -ceip :'.'. voice. . "tee e' s. the invoi `- esult 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)
LP and Surge
Drums
001
Benzene
71432
9,273
464
Toluene
108883
8,204
410
Ethylbenzene
100414
1,050
53
Xylenes
1330207
4,201
210
n -Hexane
110543
49,734
2,487
Oil Tanks
002
Benzene
71432
308
15
Toluene
108883
263
13
n -Hexane
110543
1,648
82
TLO
003
Benzene
71432
325
16
Toluene
108883
277
14
n -Hexane
110543
1,739
87
Produced
Water
004
Benzene
71432
15,750
788
n -Hexane
110543
49,500
2,475
',,`COLORADO
1 Air Pollution Control Division
a^,erem or P!0 HeairA 8'En:mo ment
Page 10 of 13
5)
pollutant table abs uncontrol i emission
(lb/yr) a le andult in ann emission fees
tion E r ssion N e.
Point 001:
owing em 5R = `' tors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
196.3
196.3
AP -42
CO
883.8
883.8
AP -42
VOC
117,636.5
5,881.8
HYSYS
71432
Benzene
742.4
37.1
HYSYS
108883
Toluene
656.8
32.8
HYSYS
100414
Ethylbenzene
84.1
4.2
HYSYS
1330207
Xylene
336.3
16.8
HYSYS
110543
n -Hexane
3,981.5
199.1
HYSYS
Note: The controlled emissions factors for this point are based on the ECD control
efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 120 °F
and separator pressure of 2 psig.
Point 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0004
0.0004
AP -42
CO
0.0018
0.0018
AP -42
VOC
0.2289
0.01145
HYSYS/Tanks
4.0.9d
71432
Benzene
0.0013
6.0E-5
HYSYS/Tanks
4.0.9d
108883
Toluene
0.0011
5.0E-5
HYSYS/Tanks
4.0.9d
110543
n -Hexane
0.0068
3.4E-4
HYSYS/Tanks
4.0.9d
Note: The controlled emissions factors for this point are based on the ECD control
efficiency of 95%.
Point 003:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors lb/bbl
Source
NOx
3.32E-4
3.32E-4
AP 42
CO
1.51E-3
1.51E-3
COLORADO
Air Pollution Control Division
l7me:mem of Hst11C Nralzn 6 Envuormenc
Page 11 of 13
AP-
42/HYSYS
Uncontr
Emis
Fac
Contro
Emiss
ctors bbl
V0C
0.281
0.0141
Benzene
71432
0.0013
6.7E-5
Toluene
108883
0.0012
5.8E-5
n -Hexane
110543
0.0072
3.6E-4
AP-
42/HYSYS
The uncontrolled V0C emission factor was calculated using AP -42, Chapter 5.2, Equation
1 (version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 7.6 psia
M (vapor molecular weight) = 60 lb/lb-mol
T (temperature of liquid loaded) = 511 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were
calculated by multiplying the mass fraction of each NCRP in the vapors by the V0C
emission factor.
Controlled emission factors are based on an ECD efficiency of 95% and a collection
efficiency of 100%.
Point 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
0.0037
0.0037
AP -42
CO
0.0167
0.0167
AP -42
V0C
0.2620
0.0131
CDPHE
71432
Benzene
0.0070
0.0004
CDPHE
110543
n -Hexane
0.0220
0.0011
CDPHE
Note: The controlled emissions factors for this point are based on the ECD control
efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)
associated with this permit is valid for a term of five years from the date it was received
by the Division. A revised APEN 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) Points 002 and 004: This permit fulfills the requirement to hold a valid permit reflecting
the storage tank and associated control device per the Colorado Oil and Gas Conservation
Commission rule 805b(2)(A) when applicable.
8) This facility is classified as follows:
COLORADO
Air Pollution Control Division
i nmen, of Pub c HK0.n & Er,, roriment
Page 12 of 13
g Permit
th urce
VOC, NOx, CO, Benzene, n -Hexane, Total HAPs
Synthetic Minor Source of:
VOC, NOx, CO
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
NANSR or PSD
MACT HH
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60,
Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
1COLORADO
Air Pollution Control Division
tk^,xarrrert at Rahi.r.. t±eaSn £+ E^v;rnnmenc
Page 13 of 13
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Ben Fischbach
Package #: 387376
Received Date: 9/6/2018
Review Start Date: 2/1/2019
Section 01- Facility Information
Company Name: Noble Energy, Inc
County AIRS ID: 123
Plant AIRS ID: 0PES
Facility Name: Hullabaloo 016-28-A Econode T2N R64W 516 LOS
Physical Address/Location: NENW quadrant of Section 06, Township 2P1, Range 64W
County:
Type of Facility: ;Exploration &'Production WWII Fad
What industry segment? Coil& Natural Gas Production & Processing
Is this facility located in a NAARS non -attainment area?
If yes, for what pollutant? ❑ Carbon Monoxide (Co)
'Weld County
Section 02 - Emissions Units In Permit Application
Quadrant
NENW
Partcsiate Matra (PM) O Ozone (Non & 000)
Section
6
Township I Range
2N 64'
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance#
Self Cert
Required?
Action
Engineering
Remarks
-
001
- "
Separator Venting
:
LP and Surge Drums
Yes
18WE0996
1
Yes
Permit initial
Issuance
Operators
requesting to
cover venting of
both LP
separator.and
surge drums
under same
emission point
as both are
routed to same
flare.
002
Condensate Tank
Oil Tanks
Yes
18WE0996
1
Yes
Permit Initial
Issuance
003
Liquid Loading
- TLOYes18WE0996
1 :
Yes
Permit Initial
Issuance
004
Produced Water Tank
Produced Water
Yes
-
18WE0996
-
1
Yes
Permit Initial
Issuance
005
Fugitive Component Leaks
Fugitives
No
18WE0996
1
Yes
Permit initial
Issuance
Cancelled
during service
(Fell below
thresholds
given actual
component
count). PA
worksheets
hidden.
Section 03 - Description of Project
All new Econode facility. - -
Per Noble caner letter "Noble would like to request thatthe issued permit combine the VOC emissions going to the burners from the heater treaters )LP separators) with the
VOC emissions from the surge drums to have a total annual limit of 367 tons per year (TPY). When running processsimulations to estimate emissions as conservatively as
possible, Noble recognized that there is give and take when Tuning the model conservatively for the heater treaters versus the surge drums, as such, Noble would prefer to run
the model in a way such that the combined emissions are most conservative and have a single emissions limn.
Section 04- Public Comment Requirements
Is Public Comment Required? '
If yes, why? _Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? -Na
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes.
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 (POD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs.
❑ ❑ ❑ ❑ 0 0
❑ 0 0 0 0 ❑ ❑ O
0 0
Colorado Air Permitting Project
Is this stationary source a major source?dt".
If yes, explain what programs and which pollutants here: S02 NOx
Prevention of Significant Deterioration (PS D) ❑ O
Title V Operating Permits (OP) O O
Non -Attainment New Source Review (NANSR) O
CO VOC PM2.5 PM10 TSP HAPs
0000
000000
Separator Venting Emissions Inventory
001 Separator Venting
'Facility Al Rs ID:
123
County
SEED
Plant
`001
Point
Section 02 -Equipment Description Details
Detailed Emissions Unit Description: 'Venting of gas from heater treater and surgettrum gas green's.'
Emission Control Device Description: Enclosed Flare
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Separator
Actual Throughput= ,„-
12,5 MMscf per year
95
Requested Permit LimitThraughput=
MMscf per year
Requested Monthly Throughput= 1 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU
Is VRU process equipment:
12 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 Fasters & Methodologies
2843 Btu/scf
MW
Weight %
Helium
CO2
N2
methane
ethane
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
CS+ Heavies
;.0.73
5,57
27,87
'76.82
23:10
6,70
0,00
2.71
4-D5
' ':000
0.06
:0,24
Total
VOCWt%
100.00
87.82
scf/bbl
eater tl.P); dream and flash stream from surge' drum. Demeter ran HFSVS simulation of process and found that of"the two streams, the "Surge Druin Vapors to
d was therefore used for both streams (After coroner isO:1 I agree that it is the more conservative stream composition); Grouping as a single point -gas flow meter
being placed after the mixing point of the two streams.
b/Ib-mol Displacement Equation
Ex = Q°MW*Xx/C
3 of 19 K:\PA\2018\18WE0996.CP1
Separator Venting Emissions Inventory
Calculated Emission Factors
Pollutant
Pollutant
Separator Venting
Uncontrolled
(lb/MMscf)
Controlled
(lb/MMscf)
117629.0979
736,6594
656.9662
84.3810
3964.5668
0.0000
5881.4549
4.2190
16.0726
0.0000
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
lb/MMscf
(Gas Throughput)
Emission Factor Source
Emission Factor Source
Operator GiVeh Emissidd?Fattgrs l ..'
Section 05 - Emissions Inventory
SAP k2 Cfiap#eri3.S rnirustrial E[ar
R,42 Chapter 13,5 illtit,trial Ha
Operator given/APEN listed
emission factors. Differences
due to rounding and inclusion
of pilot fuel, so will go with
operators EF's. (EF's in table
above (A65 -F84) correspond to
standard calculation methods.]
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
0.00
0.00
0.00
0.00
0.00
0
0,00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
1.23
1.23
1.23
1.23
1.23
208
734.72
734.72
36.74
734.72
36.74
6240
5.52
5.52
5.52
5.52
5.52
938
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
1165/year) (16s/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
9274
9274
464
9274
464
8204
8204
410
8204
410
1051
1051
53
1051
53
4201
4201
210
4201
210
49734
49734
2487
49734
2487
0
0
0
0
0
Section 06- Regulatory Summary Anal,/ is
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is subject to Regulation 7, Section XVII.B.2, G
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
4 of 19
K.\PA\2018\18WE0996.CP1
Separator Venting Emissions Inventory
Section 07 -Initial and PeriodicSampling 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 wider 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 colect a site-specificgas 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 operatorto 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% tor a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer.
Section 08 - Technical Analysis Notes
Venting of gas from heater treater and surge d urn gas stream.,. More conservative EFs from Surge Drum Stream used for both streams as they are commingled before being sent to the flare
Operator desires to permit separator venting tor both heater treater (LP) stream and flash stream from surge drum. Operator ran HYSYS simulation of process and found that of the two streams, the "Surge Drum Vapors. to VRU"
stream gave more conservative emission estimates, and was therefore used for both streams (After comparison, I agree that it is the more conservative stream composition) Permit limit is split /shared between the "Heater '..
Treater Veporsto VRU" and "Surge Drum Vapors to l'R:J"streams, with a gas flow meter being placed after the mixing point of the two streams.
Have already reached out to operator to confirm that a gas Flowmeter a currently installed and operational. Flowmeter is installed after the mixing -point of the two streams and will measure the total throughput to the flare.
Section 09- Inventory 5CC Coding and Emissions Factors
AIRS Point #
001
Process# 5CC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.00 0 lb/MMSCF
PM2.5 0.00 0 lb/MMSCF
SOx0.00 0 lb/MMSCF
NOx 193.32 0 lb/MMSCF
VOC 117629,10 95 lb/MMSCF
CO 881.33 0 lb/MMSCF
Benzene 736.66 95 lb/MMSCF
Toluene 656.97 95 Ib/MMSCF
Ethylbenzene 84.38 95 lb/MMSCF
Xylene 321.45 95 lb/MMSCF
n -Hexane 3964.57 95 lb/MMSCF
224 TMP 0.00 95 lb/MMSCF
5 of 19 S K:\PA\2018\18W E0996.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B- APEN and Permit Requlrenents
'Source Is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutantodrom this Individual source greater than 2TPY (Regulation 3, Part A,Section ll.D.1.a)?
2. Aretotal facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 1OTPY or CO emissions greater than 1OTPY (Regulation 3, Part 8, Section II D.3)?
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NO0 greater than 5 TPV or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0.2)7
(Source requires a permit
Colorado Regulation 7. Section XVII
1. Was the well newly constructed, hydraulically fractured, or remmpleted on or after August 1,2014?
(Source Is subject to Regulation 7, Section XVII.B.2, G
Section 00115.2 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e —Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
Implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," may,"
°should," and 'can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the
terms of the Clean Air Act and Air Quality Contaol Commission regulations, but this document does not establish legally binding requirements in and of itself.
Condensate Storage Tank(s) Emissions Inventory
092 Condensate Tank
(Facility AIRS ID:
123 9F10 002
County Plant Point
Section 02- Equipment Description Details
Detailed Emissions Unit Condensate Tanks -Two M750 bbl vessels.
Description:
Emission Control Device Enclosed Flare.
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95
Section 03 -Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Condensate Throughput =
(Requested Permit LimltThroughput =
Potential to Emit (PTE) Condensate
Throughput =
240,900 Barrels (bbl) per year
240,900 Barrels (bbl) per year Requested Monthly Throughput=
Actual Condensate Throughput While Emissions Controls Operating =
240,900 Barrels (bbl) per year
20460 Barrels (bbl) per month
289,080 Barrels (bbl) per year
- •r`. - '
,yI 2MassFrae
MW
Mass Flow
Volume Flow
C02
0.0084
44.0097
0.061500269
lb/hr
4643.180356
scf/yr
0.002236
lb/bbl
N2
0
28.013
0
lb/hr
0
scf/yr
0
lb/bbl
Methane
0.0233
16.0429
0.170590031
lb/hr
35331.14565
scf/yr
0.006203
lb/bbl
Eth
0.1085
30.0699
0.79437847
lb/hr
87777.34283
scf/yr
0.028886
lb/bbl
prop
0.2953
44.097
2.1620273
lb/hr
162906.7494
scf/yr
0.078619
lb/bbl
ibut
0.0688
58.124
0.503716486
lb/hr
28795.03559
scf/yr
0.018317
lb/bbl
nbut
0.2286
58.124
1.673685882
lb/hr
95676.52813
scf/yr
0.060861
lb/bbl
ipent
0.0638
72.151
0.467109183
lb/hr
21511.11884
scf/yr
0.016986
lb/bbl
npent
0.0849
72.151
0.621592001
lb/hr
28625.29764
scf/yr
0.022603
lb/bbl
cyclopent
0
70.1
0
lb/hr
0
scf/yr
0
lb/bbl
2mpent
0.0146
86.1779
0.106893324
lb/hr
4121.370179
scf/yr
0.003887
lb/bbl
3mpent
0.0093
86.1779
0.068089583
lb/hr
2625.256347
scf/yr
0.002476
lb/bbl
cyclohex
0.0108
84.16
0.079071774
lb/hr
3121.782949
scf/yr
0.002875
lb/bbl
nhept
0.033
100.205
0.241608198
lb/hr
8011.414885
scf/yr
0.008786
lb/bbl
pact
0.0109
114.232
0.07980392
lb/hr
2321.25789
scf/yr
0.002902
lb/bbl
noon
0.0029
128.259
0.021232236
lb/hr
550.0406972
scf/yr
0.000772
lb/bbl
ndec
0
142.285
0
lb/hr
0
scf/yr
0
lb/bbl
dec+
0.0001
221.1813
0.000732146
lb/hr
10.99857116
scf/yr
2.66E-05
lb/bbl
. 7$.12
0.035143011
Ib/hr
14841924554
scf1yr'
.r
0.051278
Ibibbl
Sal
0,0041
92.1408
0.0300179881b/hr
1082. 471708
scfjyr
0.001092
Ib/bbl
ethy)ban .
-
0.0045'
106,166
.
OA03S6f)73
16/hr
114.5605547
sc /yr
0000133
Ib/bbi ..
pxyl
0.0002
106.166
0.001464292
lb/hr
45.82782187
scf/yr
5.32E-05
Ib/bbl
oxyl
0.0006
106.166
0.004392876
lb/hr
137.4834656
scf/yr
000016
lb/bbl
rani
0.0011
106.166
0.008053607
lb/hr
252.0530203
scf/yr
0.000293
lb/bbl
Total Xylenes
0.0019
318.498
0.013910775
lb/hr
435.3643078
scf/yr
0
0.000506
lb/bbl
bhea .
m
-
0.0257.
.s
88.1779
0.7.88161535
Ilrlhr
7254.740558
scf/yr
0.008842
Ib/hbl
224TMP
0
86.1779
0
lb/hr
scf/yr
0
lb/bbl
Total VOf'.-
bbl/hr
0,8598
6.294991781 lb/hr
496845,955 scf/yr
0,228909 ]b/bbl
27.5
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Annual Oil Tank emissions=
2749.8 Btu/scf
496845.955 scf/yr
Volume of waste gas emitted per BBL of
liquids produced = 2.062457264 scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Annual oil tank emissions consist of W&B only (according to ProMax and Tanks sims, zero flash from these tanks). Calculated by
multiplying compositions of emissions (From HY5Y5) by annual emissions mass flowrate (from Tanks 4.0.9d). Equation used: [
Mass Flowrate (lb/hr)] = [ Mass. Fraction ] ' [Tank VOC Emissions (lb/yr) ] / [ 8760 hr/yr ] / [ Total VOC Mass Fraction ]
1,366 MMBTU per year
1,366 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 1,639 MMBTU per year
7 of 19 K:\PA\2018\18WE0996.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Pollutant
Uncontrolled
Controlled
(Ib/bbl)
(lb/bbl)
(Condensate
Throughput)
0,2289 `F
0.0013
0.0011
0,0001
0.0005
0:0068
0.0000
(Condensate
Throughput)
0.01145
0.00006
0.00005
0.00001
0,0000
0.00034
0.00000
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
(Ib/bbl) .
00680.:
0.3100
(Condensate
Throughput)
0.0000
0.0000
0.0004
0.0018
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx _
CO
33.1
27.6
1.4
27,6
1,4
234
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.1
0.0
0.0
0.046
0.046
8
0.3
0.7
0.2
0.212
0.212
36
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
Ethylbenzene
Xylene
n -Hexane
224 MAP
370
308
15
308
15
315
263
13
263
13
38
31
2
31
2
147
123
6
123
6
1977
1648
82
1648
82
0
0
0
0
0
Section 06 - Regulatory Summar/ Analysis
Regulation 3, Parts A, B
Source requires a pernit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section Xll.G
Regulation 7, Section XVII.B, Cl, C.3
Storage tank is subject to Regulation 7, Section XVII, 8, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart OH
Storage Tank is not subject to MACE OH
(See regulatory applicability worksheet for detailed analysis)
8 of 19 K:\PA\2018\18WE0996.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 07- Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? ("F•
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based one pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an oldernite-specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 -Technical Analysis Notes
"APEN: "Liquids go from well to HP separators, then told, separators (heater heaters), then to surge drum, then to [ACT. These tanks only take off -spec oil rejected from the LACT. The pilo
emissions from burrmrs associated with tank and load. out accv nted for in heater treater and surge drum ca Iculations (shared burners)."
I1YSY5 simulation shows no flash desnite hressrire d,op:,of2p iE, as liquids enter tank: Temperature simultaneously drops 20F which could explain lack of flash emissions, but may include initial'.
tekti rig requirFI,Enlili tovr_rfy FFs
• Given lack of -lash emissions and simulation methodologies, operator calculated NO, and CO emissions as follows:
Since me don- have any tank II nh rood sate tank' burners will only he burning gas from condensate working and breathing ((WAS) losses and truck loadout (TLO). Because AP42:Section!.
13.5 isicn factors for 500 and CO are given m IL/ NMMBtu we need to know the total volume of gas going to the burners from W8r8 loses and TLO
For WAS loses we know the total emissions in lb/yr from Tanks 4.0.94 and we know the composition (mass fraction) of that gas from 50505. With that we can get lb/yr of each of our components.
Using molecular weight and the ideal gas law conversion fctor (379.3 sef/ Ibmol) wean detei mine the volume of each component and get a total volume. Using the HEW modeled in 50575 (2750
Btu/scf)we get the total MMBiu associated with WAS loses and therr can multiply by our AP -42 emission factor and determine the emissions."
Equation used M lawn to (lb/hr) Mass Frt or * Tank VOC Emissions (Ib/yr) / 8760 hr/yr / Total VOC Mass Fraction
For example, with Methane: Mass Flovrrate (Ib/hr)=0.0233* 55,144 lb/yr / 8760 hr/yr / 0.86 = 0.17 ib/hr
Then, divided ,scf/yr by bbl/yr to arrive at GOR listed above.
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point#
002
Process# SCC Code
01
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.00 0 Ib/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.01 0 lb/1,000 gallons condensate throughput
VOC 5.5 95 lb/1,000 gallons condensate throughput
CO 0.04 0 lb/1,000 gallons condensate throughput
Benzene 0.03 95 lb/1,000 gallons condensate throughput
Toluene 0.03 95 Ib/1,000gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.01 95 lb/1,000 gallons condensate throughput
n -Hexane 0.16 95 lb/1,000 gallons condensate throughput
224TMP 0.00 95 lb/1,000 gallons condensate throughput
9 of 19 K:\PA\2018\18WE0996.CP1
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts Aand B -APEN and Permit nequlrements
'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 11.0.1.a)?
2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See P5 Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)?
3. Are.total facility uncontrolled VOC emissions greater than 5TPY, NOxgreater than lO TPY or CO emisiom greaterthan lO TPY (Regulation 3, Part B, Section ll.D.3)?
(You have indicated that source Is in the Non-Attainmentprea
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l WY (Regulation 3, Part A, Section ll.o.l.a)7
2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo OS -o1 Definitions 1.12 and1.14 and Section Zion additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5TPY or COembsions greaterthan lO TN (Regulation 3, Part B, Indian 0.0.2)?
(Source requires a permit
Colorado Regulation 7. Section X31.1 -F
1. Is this storage tank located In the 8 -hr ozone control area orany ozone non -attainment area or attainment/maintenance area?
a. Is this storage tank located at an oil and gas exploration and production operations, natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
ESI;riii h$
Yes
Yes
'Storage tank is subject to Regulation 7, Section XII.C-F
Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section XII.G3—Emission Estimation Procedures
Section%LLD— Emissions Control Requirements -
Section XII.E— Monitoring
Section XII.F—Recordkeeping and Reporting
Colorado Regulation 7. Section XII.0
1. Is this storage tank located in the ti -hr ozone control area or any ozonemon-attainment area or attalnmem/malntenance area?
2. Is this storage tank located at a natural gas processing plant?
3.' Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greaterthan or equal to Coons per year VOC?
'Storage Tank Is not subject to Regulation 7, Section *0.0
Section XII.G2 - Emissions Control Requirements
Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section XII.C2—Emission Estimation Procedures
Colorado Regulation 7, Section Mill
1. Is this tank located at a transmission/storage fadlity?
2. Is this condensate storage tank' looted at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this storage tank equal to or greaterthan 6 tons per year VOC?
Yes
No
UNA.
No
Yes
'Storage tank is subject to Regulation 7, Section XVII, B, t-.1 & 0.3
Section X011.9 —General Provisions for Air Pollution Control Equipment and Prevonrinn of Emissions
Section 0011.0.1- Emissions Control and Monitoring Provisions
Section XVII.G3-Recordkeeping Requirements
5. Does the condensate storage tank contain only"stabilized" liquids?
(storage tank Is sublect to Regulation 7, Section X111.0.2
Section XVII.G,- Capture and Monoodngfor Storage Tanks fined with Air Pollution Control Equipment
40 CFR, Part60. Subpart Ida, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greaterthan or equalto 75 rabic meters (m') I-472 BBlsl?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4(?
a. Does thevessel has a design capacity less than or equal to 1$89.874 m' ('-10,000 BBL( used forpetroleums or condensate stored, processed, ortreated prior to custody transfer' as defined in 6o.111b?
3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) afterlury 23, 1904?
4. Does the tankmeet the definition of"storage vessel' in 60.111b?
5. Does the storage vassal store a"volatile organic liquid (VOL)"s as defined in 60.1111?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate Imexcess of 204.9 kPa (^29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greaterthan or equal to 151 m° (`950 BBL( andstores a liquid with a maximum true vaporpressurea lea than 35 kPa (60110b(b))?; or
a The design capacity is greaterthan or equal to 75 M' (`472 Bell but less than 151 m5 ['-950 BBL] andsoores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))?
Storage Tank is natsubject to NIPS Kb
Subpartry General Provisions
§601121- Emissions Control Standards forVOC
§60.113b -Testing and Procedures
§60.1151- Reporting and Recordkeeping Requirements
§601161- Monitoring of Operations
40 CFR. Part 60, Subpart0000. Standards of Performance for Crude OR and Natural Gas Production. Transmission and Distribution
1. Is this condensate storage vessel located at a fadlity in the onshore oil oral natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry?
2. Wasthb condensate storage vessel mnstmcted,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3, Are potential VOC emissions' from the Individual storage vessel greaterthan or equal to 6 tons per year?
4. Does this condensatestorage vessel meet the definition of "storage vessel"a per 60.5430?
5. Is the storage vessel subject to and controlled In accordance with requirements forstorage vessels in 40 000 Part 60 Subpart Kb or40 CFR Part 63 Subpart HO?
(Storage Tank is notsublect to NIPS 0000
Subpart A. General Provisions per 4605425 Table
§60.5395 - Emissions Control Standards for VOC
§605413 -Testing and Procedures
460.5395(g) - Notification, Reporting and Recordkeeping Requirements
§6.5416(c) - cover and Closed Vent System Monitoring Requirements
4605417-Conttol Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per year VOC on the applicability determination date, It should remain subjectto NSPS 0000 per 60.3365(e](2) even It
parental VOL emissions drop below 6 tons per year]
40 CFO, Part 53, Subpart MAC' Hat 011 and Gan Production F0000i05
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. Afacility that processes, upgrades onstores hydrocarbon liquids' (63.76G(a((2)); OR
b. Afacility that processes, upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or Is delivered to a final end user' (63.7Bo(a)(3)l?
2. Is the tank located at a fadliry that Is major' for HAPs?
3. Does the tank meet the definition of .storage vesselp° in 63.761?
4. Does the tankmeetthedeflnition of"storage vessel with the patentlal fortlash emissions"' per 63.761?
5. Is the tanksubject to control requirements under40 CFA Part 60, Subpart Kb or Subpart 00007
(Storage Tank Is not subject. MACT HH
Subpart A, General provisions per 463.764 (a) Table 2
443.766 - Emissions Control Standards
X463.773 -Monitoring
463.774- Recordkeeping
§63.775 -Reporting
PACT Review
PACT review is required If Regulation 7 does not apply AND if the tank isln the non -attainment area. If the tank meets both cdteda, then review PACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This document is not
a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation,
or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations,
and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,' may,"should,' and 'can," is intended to
describeAPCD interpretations and recommendations. Mandatory terminology such as 'must- and 'required are intended to describe controlling requirements under the terns of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements in and of 11100.
Yes
IIon 7
AMM
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
'Facility AIRS ID:
123
County
9FF0
Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Loadout of condensate to trucks.
Enclosed Flafe.
Requested Overall VOC & HAP Control Efficiency %:
100.0
95
95.00
Section 03 -Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded=
(Requested Permit LimitThroughput= 240,900 Barrels (bbl) per year
Potential to Emit (PTE) Volume Loaded =
240,900 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
Requested Monthly Throughput =
.i40Vg90 Barrels (bbl) per year
20460 Barrels (bbl) per month
Secondary Emissions- Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
240900 Barrels (bbl) per year
2750 Btu/scf
428140 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L= 12.46*S*P*M/T
1,177 MMBTU per year
1,177 MMBTU per year
1,177 MMBTU per year
A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor.
*See technical analysis notes.
Factor
Meaning
Value
Units
Source
5
Saturation Factor
0.6
,07il
�w
er512Table 52-1 Submerged Loa ding; Dedicate
'.
gx4e jS�O.
P
True Vapor Pressure
7.6324
psia
_ Tanks 4.0.9d (oasis: Gasoline- RVP 15.0)
::
M
Molecular Weight of Vapors
60 -r ;_-t,
lb/Ib-mol
o-
• Tanks 4.0.9d (Basis: Gasoline-: RVP 15.0)
'1:0'
T
Liquid Temperature
511.4625 '
Rankine
Tanks 4.0.9d (Basis: Denver, CO)
L
Loading Losses
6.693725041
lb/1000 gallons
0.281136452 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
'-'0:0048
"-
0.0013494516/661
..
-"-, HYSYS
Toluene
0.0041.
0.00115266
lb/bbl
HYSYS.
Ethylbenzene
0.0005
0.00014057
lb/bbl
HYSYS
Xylene
. ' 0.0019
' .':'.
0.00053416
Ib/bbl
:-
— HYSYS
n -Hexane
!,::.-
, 0.0257
"-'"cr"'.
0.00722521
lb/bbl
-'s: -
)-` HYSYS
'
?'
224 TMP:"
0
0
lb/bbl
HYSYS
Pollutant
Pollutant
Hydrocarbon Loadout
Uncontrolled
Controlled
(Ib/bbl)
(Ib/bbl)
(Volume
Loaded)
(Volume Loaded)
0.0013
0.0012
0.0001
0.0005
0.0072
0.0000
Uncontrolled
Control Device
Uncontrolled
(Ib/MMBtu)
(Ib/bbl)
Volume
Loaded)
(waste heat combusted)
0:0680
0.3100
Emission Factor Source
Emission Factor Source
11 of 19
K:\PA\2018\18W E0996.CP1
Hydrocarbon Loadout Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
sox
NOx •
VOC
CO
000
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.04
0.04
0.04
0.04
0.04
7
33.86
33.86
1.69
33.86
1.69
288
0.18
0.18
0.18
0.18
0.18
31
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
Ethylhenzene
Xylene
n -Hexane
224TMP
325
325
16
325
16
278
278
14
278
14
34
34
2
34
2
129
129
6
129
6
1741
1741
87
1741
87
0
0
0
0
0
Section 86 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT-Regulation 3, Part B, Section III.D.2.a
(See regulatory applicability worksheet far detailed analysis)
Section 07 - Initial and PeriodicSampling and Testing Requirements
The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 -Technical Analysis Notes
Per APEN;" NOx and CO emissions are accounted ffor'condensate tank Llculation6 se there are shared borne
*Operator did not use site specdm sample, but are using most conservative : gasoline properties from AP -42, which should produce conservative liquid properties
AIRS Point N
Process n SCC Code
003 01 4-06-00132 Crude Oil: Submerged Loading Normal Service (5=0.6)
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 5.7 95 lb/1,000 gallons transferred
CO 0.04 0 lb/1,000 gallons transferred
Benzene 9.03 95 16/1,000 gallons transferred
Toluene 0.03 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.01 95 lb/1,000 gallons transferred
n -Hexane 0.17 95 lb/1,000 gallons transferred
224 TMP 0.00 95 16/1,000 gallons transferred
12 of 19 K:\PA\2018\18WE0996.CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Sec
'You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude•oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Par
'Source requires a permit
7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
'The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
Disclaimer
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.
Produced Water Storage Tank(s) Emissions Inventory
004 Produced WaterTank
'Facility AIRS ID:
123 3PEO 004
County Plant Point
Section 02- Equipment Description Details
Detailed Emissions Unit `Poor (4) storage tanks forthestorageofProduced Water,'All vessels are liquid man(fol
Description: .. . _
Emission Control Device Enclosed combustion device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
Requested Permit Limit Throughput= 2,250,000 Barrels (bbl) per year Requested Monthly Throughput= 391096 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput=
2,250,000 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating = 2250,500
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of
liquids produced = `"36 scffbbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2,250,000 Barrels (bbl) per year
Btu/scf
121,176 MMBTU per year
121,176 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 121,176 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Produced Water Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
..0.2620 _„
0.0131
PrPdlceU LR aterW :F (Nitludes hash)-Fres=
Benzene
?„ :..0.0070
0.0004
t>roduced Wa e, .F. (inc{'odes flash} -Fasts
Toluene
"'. .
0.000
Ethylbeozene
0.000
Xylene
'rt-x. -
0.000
�,€.lircludes
n -Hexane
' .:.0220-"
0.0011
Prexlu[Pd W,, n' fipi4i) fro
224 TMP
". .s'aa:<. ..
0.000
Control Device
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) (lb/bbl)
Emission Factor Source
(Produced
(waste heat
combusted)
Water
Throughput)
PM10
PM2.5
`
0.0000
NOx
,"' f 0 0680 r,
0.0037
CO
t"`"'.,o,. 03100.6 ...;:
0.0167
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tans/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
VOC
PM10
PM2.5
NOx
CO
294.8
294.8
14.7
294.8
14.7
2503
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
4.1
4.12
4.1
4.1
4.1
700
18.8
18.8
18.8
18.8
18.8
3190
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
15750
15750
788
15750
788
0
0
0
0
0
0
0
0
D
0
0
0
0
0
0
49500
49500
2475
49500
2475
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
14 of 19
K:\PA\2018\18WE0996.CP1
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Pei ARENT, 9iclu%dsfronswellsg0 [o14P separators, LP separators (heater treaters), and surge drums and ail feed into the produced water steragetanks?
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point S
004
Process S SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons liquid throughput
PM2.5 0.00 0 lb/1,000 gallons liquid throughput
NOx 0.09 0 lb/1,000 gallons liquid throughput
VOC 6.2 95 lb/1,000 gallons liquid throughput
CO 0.40 0 lb/1,000 gallons liquid throughput
Benzene 0.17 95 lb/1,000 gallons liquid throughput
Toluene 0.00 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.52 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
15 of 19 K:\PA\2018\18WE0996.CP1
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Regulation 3 Parts A and B- APEN and Permit Requirements
Source is in the Non.Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutantsirom this individual source greater than 2TPY (Regulation 3, Part A, Section lineal?
2. Isthe operator claiming less than'1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.O.1.M)
3. Are total facility uncontrolled VOC emissions greater Man 5 TPY, N0x greater than 10TPY or CO emissions greater than DOTPY (Regulation 3, Part B, Section 11.0.31?
'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 1TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the operator claiming Iess than 1% crude oil and is thetank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section 11.0.1.M)
3. Are total facility Uncontrolled VOC emissions greater than 2TPY, NOx greater than SIPS or CO emissions greater than 10TPY (Regulation 3, Perte, Sadler 11.0.21?
'Source requires a permit
Colorado Regulation 7, Section XVII
1. Is this tank located eta transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions°of the storage tank equal to or greater than 6 tons per year VOC?
Y -F..,...-,=
No
Yes
UMW
'Storage tank is subject to Regulation 7, Section XVII, e, C.1 & C.3
Section XVII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3- Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized' liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
90 CFR. Part 60. Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
• 1. Is this produced water storage vessel located ate facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see detriment 40 CFR, 60.2) between August 23, 2011 and September 10, 20157
3. Are potential VOCemissions'. from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel ',seethe definition of "storage vessel"' per 60.5430?
'Storage Tank is not subject to NSPS O0O0
Subpart?, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413- Testing and Procedures
§60.5355(g)- Notification, Reporting and Recordkeeping Requirements
§60.5416(51- Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subect to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remaieubject to NSPS 0000 per 60.5365(e)(2)
even if potential VOC emissions drop below 6tens per year]
RACT Review
RACT review is required if Regulation 7 does not applyAND 7 the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determieing applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This
document is note rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. Thioadocument does not change or
substitute for any law, regulation, or any otherlegally 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 orregulab'on will control. The use of men -mandatory language such as
"recommend,"may,"'should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'moor and "rerp fired"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.
Yes
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
rCompany Name
County AIRS ID
Plant AIRS ID
Facility Name
Noble Energy Inc.
123
9FF0
Hullabaloo Y16 -28-A Econode
History File Edit Date
3/25/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontro led (tons per year)
EMISSIONS With Controls (tons per year
POIN
T
AIRS
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
18WE0996
LP and Surge Drums
1.2
734.7
5.5
36.2
1.2
36.7
5.5
1.8
LP and Surge drums share common flare -
002
18WE0996
Oil Tanks
0.1
27.6
0.2
1.1
0.1
1.4
0.2
0.1
003
18WE0996
TLO
0.0
33.9
0.2
1.3
0.0
1.7
0.2
0.1
004
18WE0996
Produced Water
4.1
294.8
18.8
32.6
4.1
14.7
18.8
1.6
005' "
18WE0996-:C
Fugitives
','0 0
0:0
Cancellation received 2/21/2019)^.
006
GP02
GM 5.7L 4SRB RICE
0.1
0.1
12.4
0.6
9.8
0.1
0.1
0.1
0.9
0.6
1.8
0.1
SN: 10CHMM411120039
007
GP02
GM 5.7L 4SRB RICE
0.1
0.1
12.4
0.6
9.8
0.1
0.1
0.1
0.9
0.6
1.8
0.1
SN: 10CHMM503060019
008
GP02
GM 5.7L 4SRB RICE
0.1
0.1
12.4
0.6
9.8
0.1
0.1
0.1
0.9
0.6
1.8
0.1
SN: 10CHMM503090040
009
GP02
Waukesha F3524GSI 4SRB RI(
0.6
0.6
126.5
5.7
103.8
0.7
0.6
0.6
5.7
5.7
12.2
0.7
SN: 5283702923
010
GP02
Waukesha F3524GSI 4SRB RI(
0.6
0.6
126.5
5.7
103.8
0.7
0.6
0.6
5.7
5.7
12.2
0.7
SN: 5283702498
011
GP02
Cummins KTA19GC 4SRB RIC
0.3
0.3
47.0
3.40
22.4
0.5
0.3
0.3
2.6
2.60
7.3
0.5
SN: 37263943
012
GP02
Caterpillar G3306TA 4SRB RIC
0.2
0.2
32.5
1.40
32.5
0.6
0.2
0.2
2.0
1.4
3.9
0.6
SN: R6S01056
013
GP02
Caterpillar G3306TA 4SRB RIC
0.2
0.2
32.5
1.40
32.5
0.6
0.2
0.2
2.0
1.4
3.9
0.6
SN: G6X01675
014
GP02
Caterpillar G3516J 4SRB
0.5
0.5
13.3
9.3
32.4
6.6
0.5
0.5
13.3
9.3
20.0
6.6
SN: N6W00398
0.0
0.0
0.0
0.0
APEN Exempt/Insignificant Sources
0.0
0.0
XA
Heater Treaters (3)
0.2
0.2
2.0
0.10
1.7
0.0
0.2
0.2
2.0
0.10
1.7
0.0
0.0
0.0
FACILITY TOTAL
2.9
2.9
0.0
0.0
422.9
1,119.8
0.0
383.2
81.2
2.9
2.9
0.0
0.0
41.4
82.5
0.0
91.3
13.5
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (OP)
HAPS: Syn Minor B, n -Hex, & Total
HH: Minor + affected Area
ZZZZ: Minor
Permitted Facility Total
2.7
2.7
0.0
0.0
420.9
1,119.7
0.0
381.5
81.2
2.7
2.7
0.0
0.0
39.4
82.4
0.0
89.6
13.5
Excludes units exempt from
(L) Change in Permitted Emissions
2.7
2.7
0.0
0.0
39.4
82.4
0.0
89.6
Pubcom & modeling (not) required based
on (0 change in emissions)
Note 1
Total VOC Facility Emissions (point and fugitiv
�) Change in Total Permitted VOC emissions (point and fugitiv
82.5
Facility is eligible for GP02 because < 90
Project emissions less than 25/50 tpy
82.4
Facility permitted emissions for CO are nearly to 90 tpy, with several GPO2s on site.
Note 2
Page 17 of 19
Printed 4/9/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Noble Energy Inc.
123
9FF0
Hullabaloo Y16 -28-A Econode
Emissions - uncontrolled (Ibs er 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
18WE0996
LP and Surge Drums
9274
8204
1051
4201
49734
36.2
002
18WE0996
Oil Tanks
308
263
31
12
1648
1.1
003
18WE0996
TLO
325
278
34
129
1740
1.3
004
18WE0996
Produced Water
15750
49500
32.6
005
18WE0996.CN
Fugitives , ° _
-
��
....
.0.0
006
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
007
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
008
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
009
GP02
Waukesha F3524GSI 4SRB RICE
811
185
175
105
203
0.7
010
GP02
Waukesha F3524GSI 4SRB RICE
811
185
175
105
203
0.7
011
GP02
Cummins KTA19GC 4SRB RICE
614
84
79
47
92
0.5
012
GP02
Caterpillar G3306TA 4SRB RICE
980
45
42
25
49
0.6
013
GP02
Caterpillar G3306TA 4SRB RICE
980
45
42
25
49
0.6
014
GP02
Caterpillar G3516J 4SRB RICE
11460
834
513
44
250
6.6
0.0
0.0
APEN Exempt/Insignificant Sources
0.0'
XA
Heater Treaters (3)
0.0
0.0
TOTAL (tpy)
8.1
0.7
0.5
13.0
4.4
0.6
2.2
51.3
0.5
0.0
0.0
0.0
81.2
otal Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
18
Emissions with controls (lbs per year)
18WE0996.CP1
4/9/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Noble Energy Inc.
123
9FF0
Hullabaloo Y16 -28-A Econode
POIN1
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
18WE0996
LP and Surge Drums
464
410
53
210
2487
1.8
002
18WE0996
Oil Tanks
15
13
2
1
82
0.1
003
18WE0996
TLO
16
14
2
6
87
0.1
004
18WE0996
Produced Water
788
2475
1.6
005 :
18WE0996,CN
Fugitives
?
0.0
006
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
007
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
008
GP02
GM 5.7L 4SRB RICE
149
20
19
11
22
0.1
009
GP02
Waukesha F3524GSI 4SRB RICE
811
185
175
105
203
0.7
010
GP02
Waukesha F3524GSI 4SRB RICE
811
185
175
105
203
0.7
011
GP02
Cummins KTA19GC 4SRB RICE
614
84
79
47
92
0.5
012
GP02
Caterpillar G3306TA 4SRB RICE
980
45
42
25
49
0.6
013
GP02
Caterpillar G3306TA 4SRB RICE
980
45
42
25
49
0.6
014
GP02
Caterpillar G3516J 4SRB RICE
11460
834
513
44
250
6.6
0.0
0.0
APEN Exempt/Insignificant Sources
0.0
XA
Heater Treaters (3)
0.0
0.0
TOTAL (tpy)
8.1
0.7
0.5
0.8
0.2
0.0
0.1
2.6
0.5
0.0
0.0
0.0
13.5
19
18WE0996.CP1
4/9/2019
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
1‘6WE061clio
AIRS ID Number:
4—FO/on I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1: Noble Energy Inc.
Site Name: HULLABALOO Y16 -28-A ECONODE T2N R64W S16 L01
Site Location: NENW SEC16 T2N R64W
Mailing Address: Code) 1625 Broadway, Suite 2200
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E -Mail Address': janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
381361
Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I
I COLORADO
Department of Pb.
HUHhb E.wlnenmmt
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
- OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
Heater treater (LP) and surge drum gas
General description of equipment and purpose:
streams
Company equipment Identification No. (optional):
For existing sources, operation began on:
6/10/2018
For new, modified, or reconstructed sources, the projected start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
Form APCD-211 - Gas Venting APEN - Revision 7/2018
days/week weeks/year
O Yes
❑ Yes
• Yes
❑ No
O No
❑ No
2I AY
COLORADO
I�µourant of Pudic
fit.. b Envimom.M.
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
o Well Head Casing
O Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
- --_ —
---
Vent Gas
-
Heating Value:
2843-
BTU/SCF
Requested:
12.49
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
50.75
VOC (Weight %)
87.82%
Benzene (Weight %)
0.55%
Toluene (Weight %)
0.49%
Ethylbenzene (Weight %)
0.06%
Xylene (Weight %)
0.25%
n -Hexane (Weight %)
2.97%
2,2,4-Trimethylpentane (Weight %)
0.00%
_Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX 8 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
3 AV!COLORADO
AIRS ID Number:
Permit Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1445, -104.5568
Operator.
Stack ID NO.,-
Discharge Height
_
Above Ground Level
(Feet)
Temp.,_ ' : •:. ,
Ci)
Flow Rate
(ACFM)
,: Velocity
(ftlsec)'
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
® Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu / hr
Type: VOC Burner Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
41
a Pat.
CO LORAQO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested.
Control Efficiency
(% reduction in emissions)
PM
SOx
NO),
CO
VOC
VOC Burner
95%
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
::Criteria Pollutant Emissions Inventory
Pollutant .
Emission Factor
Actual Annual Emissions..
::: :
Requested Annual Permit :
.:,_
Emission L�
_ . _ _ . .._ ....
._.
: ;...._-'Uncontrolled..q:...
__- __ ...__.._.___
• •-
_
_..*_...
Urnts
Source
(AP -42,•.; =:
. Uncontrolled:-
Emisstons��-�
Controlled:_ -�-Uncontrolled.
=-" Emissionsb';
Em!sstons • �
Controlled -:-:
....:
--.•-Eintssions �
Basis: . : :..
_. ...
_.
_ Mfg , ete:)��
.. %tons/year):.:
- :-(torrslyedr).
:' :. (tons/year)
tons/year):`-..,
PM
7.6
lb/MMscf
AP -42
0.00
0.00
SOx
0.6
lb/MMscf
AP -42
0.00
0.00
NOx
0.1963, 0.1
lb/Mscf
HYSYS, AP -42
1.23
1.23
CO
0.8838, 0.084
lb/Mscf
HYSYS, AP -42
5.52
5.52
VOC
117.6365, 0.0055
lb/Mscf
HYSYS, AP -42
734.72
36.74
.Non -Criteria Reportable Pollutant Emissions Inventory.
Chemica l Name
Chemical
Abstract
Service CAS
•
Number
Emission Factor
. Actual Annual Emissions:.
Uncontrolled.
- Basis .:
, .
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
U
; Emissions :
(pounds/year)
Controlled.
6.... ,'..
....Emissions,,
. (pounds/year).
Benzene
71432
0.7424
lb/Mscf
HYSYS/AP-42
9,273
464
Toluene
108883
0.6568
lb/Mscf
HYSYS/AP-42
8,204
410
Ethylbenzene
100414
0.0841
lb/Mscf
HYSYS/AP-42
1,050
53
Xylene
1330207
0.3363
lb/Mscf
HYSYS/AP-42
4,201
210
n -Hexane
110543
3.981.5
lb/Mscf
HYSYS/AP-42
49,734
2,487
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, Leave
blank.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
5
j COLORADO
n.o,a..t
H.W, S Enelr�xunwl
Permit Number: AIRS ID Number:
[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.
oMW.e.
09/05/2018
Sin ure of Legally Authorized erson (not a vendor or consultant) Date
Sign g Y
Janessa Salgado Environmental Engineer
Name (please print)
Title
Check the appropriate box to request a copy of the:
�✓ Draft permit prior to issuance
E✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-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.Rov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
^ !COLORADO
6 I V I ==i
RECEIVED
SSEP-62018
APCD
c;al;onary j
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
f (J OR k0 AIRS ID Numberfl/ f 002.
_ [Leave blank unless APCD has already assigned a permit # and AIRS ID] _____ __ _—
Section 1 Administrative Information
Company Name1: Noble Energy Inc.
Site Name: HULLABALOO Y16 -28-A ECONODE T2N R64W S16 L01
Site Location: NENW SEC16 T2N R64W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E -Mail Address2: janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
387382
(COLOR ADO
1 I nmau, 5 cim,xm.rt
Permit Number: AIRS ID Number:
[Leave bLank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly -reported emission source
0 Request coverage under traditional construction permit
O Request coverage under a General Permit
0 GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info It Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Condensate Tanks (Off Spec Tanks)
06/10/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
hours/day 7 days/week
52
weeks/year
Storage tank(s) located at: ❑✓ Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
•
Yes
l7
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
•
Yes-
SI
No
If "yes", identify the stock tank gas -to -oil ratio:
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
SI
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
0
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
21
'COLORADO
, Depararsot of Puttee
HWih5 Emsratwasa
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested, Annual Permit Limits
(bbl/year)
Condensate Throughput:
From what year is the actual annual amount?
Average API gravity of sales oil: 61.12 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
240,900
RVP of sales oil: 7.79 (Ran tanks at 15)
❑ External floating roof
Storage.
:• Tank ID.
# of Liquid Manifold Storage
Vessels in Storage Tank. ' .
Total Volume of.
Storage Tank
(bbl)
':Installation Date of • Most .
Recent Storage Vessel m
: Storage Tank•(monthlyeor).
'. Date of First= •
' Production
(monthlyear)
2
1500
6/2018
�- •---•: -• -v•:--Wells•Serviced-by-this StorageTankorTank-Batte sX(: Eili:Sites On
) =t-•-• -n •-
,Y.. ,:.:.. API' Nuinlier—'.•.
.........:!.......:. .. Name of`Wel1M,: e,,.m:a�.:A..m,,:�.�..�:;.'� : ":;.:-
s .. ...:. "
Re
NeW Y. .Ported Well'
- -
SEE ATTACHED
■
_
■
- -
■
-
■
- -
■
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates -E- ..:
'."(Latitpde/L:ongitacie. or UTM)-,i:..; .
40.1445, -104.5568
Operator Stack-
::._ : ID. Na:..::_:::..
-Discharge HeightAbove
w .....Gr'oun'd Level (feet) '
Temp.
... .... (°F)
' •.Flow Rate
.....:..: (ACFM)',
, . .Velocity :.
_ (ft/sec) '
Indicate the direction of the stack outlet: (check one)
❑� Upward D Downward
❑ Horizontal
❑ Other (describe):
Indicate the stack opening and size: (check one)
O Circular
❑ Square/ rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I
1coiORADC,
Hrzit
ih E Em. h^.vaent
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
0 Other:
Pollutants Controlled:
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
1
iA
Manufacturer Guaranteed Control Efficiency: 95 % IJ 7
Waste Gas Heat Content: )` }5® Btu/scf \ ' `\
ti‘h\
MMBtu/hr
Minimum Temperature:
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
Description of the closed loop system:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (EaP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 2 psig
Describe the separation process between the well and the storage tanks: Liquids go from well to HP
separators, then to LP separators (heater treaters), then to surge drum, then to LACT. These
tanks only take off -spec oil rejected from the LACT. The pilot emissions from burners associated with
tank and load -out are accounted for in heater treater and surge drum calculations (shared burners).
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
I COLOR ADO
4 I m�I
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction ):
Pollutant .
Description of Control Method(s) .
Overall Requested Control -
.Efficiency :.(% reduction in emissions)
VOC
Enclosed Burner
95%
NOx
CO
HAPs
Enclosed Burner
95%
Other:
From what year is the following reported actual annual emissions data?
:........ .:, .-.,, :..:..: Criteria Pollutant Emivions Inventory
—..,..—,...;._,......—_.__,_..
' Pollutant
:.,::. ,' ..-
..
_.—...Emission:Factor7_.._ _.._:: .L.
.......
_......_
...Actual Annual: Emisssions_—..._,.-,._
_.:.r. -p•°::';:.:._ ._.
... e''vested..Annval:.Permit..,:_
WE "iss'on1"�
_.:. _ .:. !n J .... rmif s
Uncontrolled
Basis..
:_
Units
Urce:
. (AP -42; '•
`. . Mfg. etc)
g' .
:. .... ....:...
: Uncontrolled
' •. Emissions .
; • (Tons/year)
. Controlled .
8 ..
' Emissions ,
(Tons/year) :�
Uncontrolled
...
• Emissions
(TOnsJyear)
Controlled
- Emissions' ..
/ . ..
(Tons/year) -
VOC
0.22891
lb/bbl
HYSYSrranks4.0.9d
'1
27.57
1.38
NOx D.06$
: tai p.
la/l
-GDP I }
e44 -0 -of
0.11 0.01
0.0837
CO 0.310 0.0094
4bllb- ties•
0490,1•1
-633 0. 1.1
1
esPf tE
I�/MM13fu Af N2
_._._..N n C .Y:,., Reporx b( P ll ta. t.E issi:o 1...__ t
�.:rta:<,.�.:-.<.e�_,,�..:..r.....,v_..__...- on. -:r eria epo..a e o u an:..missions.:nv
.._�..»... _.:.
� •�•- •.- �. - -
Chemical Name
- . :
-. ............:
..w ....._:...'
:. .Chemical .......
Abstract`
Service (CAS)
Number -:...........,..,Bas
f-7_: itii§ti n- a-...- 7, --:_ '..-7_-:
- Em�sstorr.Factor.. ... ;...
• : ttial. ..:..:_:::
Actual:7annual
s
s_ n —•:
Emissions..
Uncontrolled:
is :...,...,
.
_ Units ..
.. - -
Source
(AP. -42;
- Mf :.etc)
ncontrolle
uEmissions:d..
(Pounds% ear - • -
Controlled •
8
Emissions,. •
: (pounds:/year)
Benzene
71432
0.00128
lb/bbl
HYSYSrranks4.0.9d
308
15
Toluene
108883
0.00109
lb/bbl
HYSYSrranks4.0.9d
263
13
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.00684
lb/bbl
HYSYSITanks4.0.9d
1648
82
2,2,4-
Trimethylpentane
540841
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I
COLORA@O
c
Fwahb Js1
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Siq ature of Legally Authorized Person (not a vendor or consultant) Date
0(0146 S
09/05/2018
Janessa Salgado Environmental Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
O Draft permit prior to issuance
❑� Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-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-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
;COLORADO
6 �' n:at
Hwuh6F usamen[
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Noble Energy, Inc.
Source Name:
HULLABALOO Y16 -28-A ECONODE T2N R64W S16 L01
Emissions Source AIRS ID2:
et /41RO/O51,,
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 45232
HULLABALOO STATE Y21-716
O
05 -123 - 45234
HULLABALOO STATE Y21-726
0
05 -123 - 45233
HULLABALOO STATE Y21-736
0
05 -123 - 45235
HULLABALOO STATE Y21-746
0
05 -123 - 45240
HULLABALOO STATE Y21-756
O
05 -123 - 45236
HULLABALOO STATE Y21-763
gi
05 -123 -45237
HULLABALOO STATE Y21-769
O
05 -123 -45241
HULLABALOO STATE Y21-775
O
05 -123 - 45239
HULLABALOO STATE Y21-781
ri
05 -123 - 45238
HULLABALOO STATE Y21-787
Ei
- -
❑
- -
❑
- -
❑
- -
❑
- __
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014
RECGNED
se 6 200
Hydrocarbon Liquid Loading APEN
Form APCD-208
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 hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.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: ` LEORCt(j AIRS ID Number: 122 /CIFF0 /ad 3
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: HULLABALOO Y16 -28-A ECONODE T2N R64W S16 L01
Site Location: NENW SEC16 T2N R64W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: • 1311
Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E -Mail Address2: janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
387363
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1445, -104.5568
Operator
Stack ID No
Discharge Height Above
Ground Level
(feet)
Temp.
(°F)
Flow Rate
(ACPM)
Velocity
(it/sec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
0 Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
O Other (describe):
0 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.
O Loading occurs using a vapor balance system:
Requested Control Efficiency:
® Combustion
Device:
Used for control of: VOC and HAPs
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature: °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr
O Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
4 AiLY ea2111,,ETir=mc-rtt
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency reduction):
Pollutant
•
Description of Control Method(s)
Overall .Requested,,
Control Efficiency •
(% reduction in emissions)
PM
SOX
NOX
CO
VOC
Enclosed Burner
95%
HAPs
Enclosed Burner
95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
= - -.w._._._.Criteria...Pollutant�Emissions-.lnventoryL: == _Y.. —
"Pollutant•
_ :W _.
Emission. Factor
v, ActualAnnual EmtssionsP.
Requeste nnua
Em�ss�onlim� t;(s)5
Uncontrolled"
_. _. _ -
Basis__
Source
Uncontrolled
------Emissions:-.':-.':
(tons/year):
Controlled,_ -
Uncontrolled;
.: EmIsslons,. -.
(tons/year).
Controlle` d ,_;
- Ecom.pns_.:-
(tons/year) -
"—
. - -,Units,„,--, nits -,
-i....(AP 42,
Mfg., etc.
e
.-Emissionsw - '
(tons/year)
PM
SOx
NO
0.06g
IV/A(04,,
A -e -q-1
0.(jq
0.0tl
CO
o•3Io
1LcAmOu
A -Q iz
o.I8
0. I
VOC
0.2810
lb/bbl
AP -42
33.84
1.69
Non -Criteria Reportable Pollutant Emissions Inventory
- --
Chemical Name
Chemical
' . Abstract:. •
Service (CAS)
Number
' .Emission Factor -
ActuaPAnnual Emissions ..-
.....
Uncontrolled
Basis
Units
s ource
(AP -42, .
Mfg:, etc.)
ncoritrolle
U d `
Emissions •
(pounds/year)
Controlled ,
.
Emissions'.
(pounds/year) .
Benzene
71432
0.0013
lb/bbl
AP -42
325
16
Toluene
108883
0.0012
lb/bbl
AP -42
277
14
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0072
lb/bbl
AP -42
1,739
87
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
5I ,
COLORADO
IF «uc
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under construction permit
O Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
O 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: NOx and CO emissions are accounted for in condensate tank
calculation because there are shared burners.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Truck load -out of condensate
Company equipment Identification No. (optional):
For existing sources, operation began on:
6/10/2018
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
12
Yes
■
No
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
p
Does this source load gasoline into transport vehicles?
■
Yes
12
No
Is this source located at an oil and gas exploration and production site?
Yes
No
12
•
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
O
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
p
■
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
No
■
12
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
2 I AV"'- `s«
� HWfh n O+vUa�nsn�
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
240,900
bbl/year
This product is loaded from tanks at this facility into:
(e.g. "rail tank cars" or "tank trucks")
Actual Volume Loaded:
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:51.7925
0.6
Average temperature of
bulk liquid loading:
°F
True Vapor Pressure:
7.6324
Psia ® 60 °F
Molecular weight of
displaced vapors:
60
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year_
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I
'COLORADO
camnetuoe a�.t
I koatN9 Ervasvrmt
•
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ti and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
nmWd,cn S
09/05/2018
Si nature of Legally Authorized Person (not a vendor or consultant) Date
Janessa Salgado
Environmental Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
6 I AV. 4�
F:be%Hhv EmLannfrM
Produced Water Storage Tank(s)
APEN - Form APCD-207
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number: B Z3
KnFf0/061 !{`
`� �-
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Noble Energy Inc.
Site Name: HULLABALOO Y16 -28-A ECONODE T2N R64W S16 L01
Site Location: NENW SEC16 T2N R64W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Janessa Salgado
Phone Number: 303-228-4196
E -Mail Address2: janessa.salgado@nblenergy.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018
387364
COLORADO
1I AT
=
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP05 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR -
• MODIFICATION to existing permit (check each box below that applies)
O Change in equipment O Change company name3
o Change permit limit 0 Transfer of ownership4 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Produced Water Storage
6/10/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
weeks/year
0 Exploration & Production (E&P) site 0 Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
✓
Yes
❑
No
Are Flash Emissions anticipated from these storage tanks?
✓
Yes
❑
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
❑
Yes
No
✓
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
❑
Yes
✓
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
❑
Yes
No
✓
Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions a 6 ton/yr (per storage tank)?
Yes
❑
No
✓
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
21
Departmant
COLORADO
of Public
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Produced Water Throughput:
Requested Annual Permit Limits
(bbl/year)
3 eeteee- Zl2 re'', bd 0
From what year is the actual annual amount?
Tank design:
❑✓ Fixed roof
N/A
O Internal floating roof
P -61.4+-cte) ekai I
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in'Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year) .
Date of First._,
Production:`:
(month/year) •'
4
2000
6/2018
-47--
AA200- -
E3 , 2/ZO/l `)
-6/20-4=8®-
ells.Serviced by this. Storage:.Tank.orTank_Batteryb (E&P-Sites On yy::..
API Number"
Name of Welt:.
Newly.Reported Well.
SEE ATTACHED
s Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates--
(Latitude/Longitude or UTM)
40.1445, -104.5568
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches):
❑ Square/ rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 I
ICOLORAOO
,*,
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
%
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
0 Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? - 300, 25, 2 psig
Describe the separation process between the well and the storage tanks: Liquids from wells go to
HP separators, LP separators (heater treaters), and surge drums and all feed into the produced
water storage tanks.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
COLORADO
4i =.,
Nub'. ti E EnvLnnnlenl
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
- Efficiency .
(% reduction in emissions). •
VOC
Enclosed Burner
95%
NOx
Co
HAPs
Enclosed Burner
95%
Other:
From what year is the following reported actual annual emissions data?
:......... :. Criteria .Pollutant.Emissions.lnventory_.......
Pollutant
Emission Factor
__ :....:............_. ..
al Annual Emissions
Actual
Requested : Annual:Permit""
Emission Ltmtt s
Uncontrolled
Basis
Units
Source
. (AP -42,
Mfg., etc.)
g
Uncontrolled-
Emissions
(tons/year)
.. Controlled-
Emissions8
(tonsl ear
(tons/year)
Uncontrolled
Emissions-
(tons/year)
. Controlled-
Emissions
(tons/year)
VOC
0.2620
lb/bbl
CDPHE
303.0E i`i.g
4Q5 -I'{.
NOx &
DS, 0.0037
CDPHE
6 i{. Q .)
4.I i
CO 0.1@ 0:9494
lbhIb. V6C
CDPHE
..f 1g.8
�0 Pk.
0b��4E�I�v 2 IV!
Non -Criteria -Reportable
-Pollutant
-Emissions Inventory. ,--.,-•---,- ---_---•-w ---•••---
Chemical Name
Chemical .
Abstract
Service. (CAS)
NumberMfg.,
Emission Factor?
Actual Annual Emissions
Uncontrolled
Basis ..
Units
. Source,
(AP -42,
etc.)
Uncontrolled.
Emissions
(pounds%year).
Controlled
Emissions8
(pounds/year)
Benzene
71432
0.007
lb/bbl
CDPHE
21,001t
40E9-
Toluene
108883
l ° - t)
aQ o
Ethylbenzene
100414
Xylene
1330207
n-l-lexane
110543
0.022
lb/bbl
CDPHE
66;99&
-3-89&
2,2,4
Trimethylpentane
540841
`i%,Voo
. ,,ilr
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 5 I
COLDR ADO
LF...,..d�:4rR�u�
I FuaVry5 F;1,-..vvu
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Si nature of Legally Authorized Person (not a vendor or consultant) Date
mew, S
09/05/2018
Janessa Salgado Environmental Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
ID Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
COLORADO
M orasrc
6 I AYHCW 5E �.o[
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