HomeMy WebLinkAbout20192107.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 O St
PO Box 758
Greeley, CO 80632
May 29, 2019
Dear Sir or Madam:
RECEIVED
JUN 0 4 2010
WELD COUNTY
COMMISSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy Inc - Y11 Waste Management ECONODE. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
Public Pepe
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
cc. Pi - C113), NL(.011,
Pi K kICY
2019-2107
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy Inc - Y11 Waste Management ECONODE - Weld County
Notice Period Begins: June 6, 2019
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Noble Energy Inc
Facility: Y11 Waste Management ECONODE
Well Production Facility
NENW SEC 11 T2N R64W
Weld County
The proposed project or activity is as follows: The operator is requesting permit coverage for twenty-two
(22) condensate storage vessels and ten (10) produced water storage vessels at a new synthetic minor oil
and gas well production facility located in the ozone non -attainment area.
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 18WE1277 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:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
�.. e o..mm w.new.
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Christopher fester
Package If: 390715
Received Date: 12/3/2018
Review Start Date: 3/26/2018
Section 01- Facility Information
Company Name: Noble Energy Inc
County AIRS ID: 123
Quadrant
Section
Township
Range
NENW
11
2N
64
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
A01S
Y11 Waste Management Production facility
NENW quadrant of Section 11, Township 2N, Range 64W
(Weld County
Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Condensate Tank
18WE1277
Permit Initial
Issuance
Produced Water Tank
18WE1277
Permit Initial
Issuance
Liquid Loading
18WE1277
Permit Initial
Issuance
Fugitive Component Leaks
Permit Initial
Issuance
Separator Venting
18WE1277
Permit Initial
Issuance
Section 03 - Description of Project
New synthetic minor exploration and production facility.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
Section 05 - Ambient Air Impact Analysis Requirement:
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
.1
J
CO
J
VOC PM2.5 PM10 TSP HAPs
1.1
J
Colorado Air Permitting Project
Is this stationary source a major source?
If yes, explain what programs and which pollutants herE SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
H
NOx
CO
VOC
PM2.5 PM10 TSP HAPs
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Two (2) 750 bbl condensate storage tanks
Enclosed Combustion Device
9S
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
272,290 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
272,290 Barrels (bbl) per year
Requested Permit Limit Throughput = 272,290 Barrels (bbl) per year
Requested Monthly Throughput =
23126 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
272,290 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2814.85 Btu/scf
scf/bbl
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
The surge vessel just upstream operates at atmospheric pressure and therefore there should be no additional pressure drop into the tank
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0.090660
0.004533
'.e Specific VS. (inchtcle6 #last°'
Benzene
Toluene
Ethylbenzene
Xylene
°• £ icsttia:;;,6is ,
n -Hexane
0.002520
0.000126
224 TMP
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
0.0000
;p ': cpdu3t.s>itt&5r t
PM2.5
0.0075
0.0000
NOx
0.0680
0.0000
CO
0.3100
0.0000
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
12.3
12.3
0.6
12.3
0.6
105
PM10
0.0
0.0
0.0
0.0
0.0
0
PM2.5
0.0
0.0
0.0
0.0
0.0
0
NOx
0.0
0.0
0.0
0.0
0.0
0
CO
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (gm/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
0
0
0
0
0
Toluene
0
0
0
0
0
Ethylbenzene
0
0
0
0
0
Xylene
0
0
0
0
0
n -Hexane
686
686
34
686
34
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage Tank is not subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
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, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
3 of 16
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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?
ISM
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 on a 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 older site -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
There is not any flashing emissions associated with this tank as the upstream surge vessel drops the pressurized fluid to atmopsheric pressure before it enters the tanks. The lack of additional pressure
drop gives no additional flashing
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process # SCC Code
01
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.00 0 lb/1,000 gallons condensate throughput
VOC 2.2 95 lb/1,000 gallons condensate throughput
CO 0.00 0 lb/1,000 gallons condensate throughput
Benzene 0.00 95 lb/1,000 gallons condensate throughput
Toluene 0.00 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.00 95 lb/1,000 gallons condensate throughput
n -Hexane 0.06 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 lb/1,000 gallons condensate throughput
4 of 16 K:\PA\2018\18WE1277.CP1
Condensate Tank 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 construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 WY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Scour -e requires a permit
Yes
No
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
Storage Tank is not subject to Regulation 7, Section XII.C-F
Yes
Yes
Yes
Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C2 - Emission Estimation Procedures
Section XII.D - Emissions Control Requirements
Section XII.E - Monitoring
Section XILF - Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance 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 greater than or equal to 2 tons per year VOC?
Storage Tank is not subject to Regulation 7, Section XII.G
No
Yes
No
Section XII.G.2 - 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 XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3 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 greater than 6 tons per year VOC?
Storage tank Is subject to Regulation 7, Section XVII, 0, C.1 & C.3
No
Yes
Yes
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
S. Does the condensate storage tank contain only "stabilized" liquids?
Storage tank is subject to Regulation 7. Section XVII.C.2
Yes
Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) [-472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ['10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer as defined in 60.11 lb?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"3 as defined in 60.111°?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 [-950 BBL} and stores a liquid with a maximum true vapor pressure° less than 35 kPa (60.11ob(b))?; or
c. The design capacity is greater than or equal to 75 M3 (-472 BBL) but less than 151 m3 (`950 BBL) and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11ob(b))?
rio
Yes
Source Req
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Source is sr.
Source is sr.
Storage Tar
Storage Tank is not subject to NSPS Kb
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a 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 condensate storage vessel constructed, 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 greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel'' per 60.5430?
5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
Storage Tank is not subject to NSPS 0000
Yes
No
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even
if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH, OII and Gas Production Facilities
1. Is the storage tanx located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids2 (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end users (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"° in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to NIACF HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
NO
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT 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." "may. " "should," and "can,' is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
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Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
002 Produced Water Tank
Facility AIRS ID:
123 A015 002
County
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Four (4) 500 bbl produced water storage tanks
Emission Control Device
Enclosed Combustion Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
1,500,000 Barrels (bbl) per year
Actual Produced Water Throughput While Emissions Controls Operating = 1,500,000
Requested Permit Limit Throughput =
1,500,000 Barrels (bbl) per year Requested Monthly Throughput =
127397 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput=
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
1,500,000 Barrels (bbl) per year
Btu/scf
scf/bbl
80,774 MMBTU per year
80,774 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 80,774 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Produced Water Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
0.262
0.01
Produced Water State El. (includes flash) - Front
Benzene
0.007
0.000
Produced Water State E.F. (includes flash) - Front
duced Water State E.F. (includes flash) - front
Toluene
0.000
Ethylbenzene
0.000
Xylene
0.000
n -Hexane
0.001
224 TMP
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
PM10
0.0075
0.0000
AP -42 Table 1.4-2 (PM10/Pl4M.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Chapter 13.5 industrial Flares (NOx)
AP742 Chapte ..13,4 f flrial flares (CO)
PM2.5
0.0075
0.0000
NOx
0.0680
0.0000
CO
0.3100
0.0000
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
196.5
196.5
9.8
196.5
9.8
1669
PM10
0.3
0.3
0.3
0.3
0.3
51
PM2.5
0.3
0.3
0.3
0.3
0.3
51
NOx
2.7
2.7
2.7
2.7
2.7
466
CO
12.5
12.5
12.5
12.5
12.5
2127
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
10500
10500
525
10500
525
Toluene
0
0
0
0
0
Ethylbenzene
0
0
0
0
0
Xylene
0
0
0
0
0
n -Hexane
33000
33000
1650
33000
1650
224 TMP
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, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
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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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
002
Process #
01
SCC Code
4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.01
0.01
0.09
6.2
0.40
0.17
0.00
0.00
0.00
0.52
0.00
Control %
0
0
0
95
0
95
95
95
95
95
95
Units
Ib/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
Ib/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
lb/1,000 gallons liquid throughput
Ib/1,000 gallons liquid throughput
7 of 16 K:\PA\2018\18WE1277.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 Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the 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.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Ycu 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 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.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Scurce requires a permit
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tanks located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC?
No
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XVII, B, 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 - Record keeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
No
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
40 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 at a 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 definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"1 per 60.5430?
Yes
No
Storage Tank is not subject to NSPS OOOO
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
(Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RAG 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 describe APCD interpretations and recommendations Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
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Source Req
Continue -
Continue -
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Source is st
Source is st
Continue -'
Storage Tar
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
Facility AIRs ID:
123
County
A015
Plant
(103
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Truck loadout of Condensate
Enclosed Combustion Device
Yes
100.0
95
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
272,290 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
272,290 Barrels (bbl) per year
Requested Permit Limit Throughput =
272,290 Barrels (bbl) per year Requested Monthly Throughput =
23126 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device
272,290 Barrels (bbl) per year
Btu/scf
205116 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
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
Yes The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
% j'� � ,"
P
True Vapor Pressure
3.2376
psia
M
Molecular Weight of Vapors
68
Ib/Ib-mol
T
Liquid Temperature
511.4625
Rankine
L
Loading Losses
3.218011559
lb/1000 gallons
0.135156435 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.0043
0.000581173
lb/bbl
Toluene
0.0046
0.00062172
lb/bbl
Ethylbenzene
0.0003
4.05469E -OS
lb/bbl
Xylene
0.0017
0.000229766
lb/bbl
n -Hexane
0.0246
0.00332485
lb/bbl
224 TMP
0
0
lb/bbl
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
1.35E-01
6.76E-03
;: &ific - AP -42: Chapter 5.2, Equation 1.
Benzene
5.81E-04
2.91E-05
Site Specific - AP -42: Chapter 5.2, Equation 2
Toluene
6.22E-04
3.11E-05
Site Specific - AP -42: Chapter 5.2, Equation 3
Site Specific- AP -42: Chapter 5.2, Equation 4
Site Specific - AP -42: Chapter 5.2, Equation 5
site Specific- AP -42: Chapter 5.2, Equation 6
Site Specific - AP -42: Chapter 5.2, €quati-on 7
Ethylbenzene
4.05E-05
2.03E-06
Xylene
2.30E-04
1.15E-05
n -Hexane
3.32E-03
1.66E-04
224 TMP
0.00E+00
0.00E+00
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM 10
0.0075
0.00E+00
AP -42 Table 1.42 (PM10/PM.2.5)
AP -42 Table 1.42 (PM1O/PM.2.5)
AP -42 Table 1.4-2 (SOx)
P-42 Chapter 13,5 Industrial Flares (NOx,
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
0.00E+00
SOx
0.0006
0.00E+00
NOx
0.0680
0.00E+00
CO
0.3100
0.00E+00
9 of 16
K:\PA\2018\18WE1277.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
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
0.00
0.00
0.00
0.00
0.00
0
VOC
18.40
18.40
0.92
18.40
0.92
156
CO
0.00
0.00
0.00
0.00
0.00
0
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
158
158
8
158
8
Toluene
169
169
8
169
8
Ethylbenzene
11
11
1
11
1
Xylene
63
63
3
63
3
n -Hexane
905
905
45
905
45
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT - Regulation 3, Part B, Section III.D.2.a
The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
\�;
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
003
Process#
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 Ib/1,000 gallons transferred
PM2.5 0.00 0 Ib/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.00 0 lb/1,000 gallons transferred
VOC 3.2 95 lb/1,000 gallons transferred
CO 0.00 0 lb/1,000 gallons transferred
Benzene 0.01 95 lb/1,000 gallons transferred
Toluene 0.01 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 0.08 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
10 of 16 K:\PA\2018\18WE1277.CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
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 S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
Yes
No
No
No
Yes
Source requires a permit
7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
Yes
The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT.
Disclaimer
This document assists operators with determining applicability of certain requirements of tie Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as "recommend." -may." "should," and "can. " is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations. but this document does not establish legally binding requirements in and of itself
Go to next
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The loadou
The loadou
004 Fugitive equipment leaks
Regulation 7 Information
Operating Hours
Emission Factor Source
Control Efficiency Source
Calculations
8760 hours/year
Screening EFs EPA 453/R 95 017 Table 2 8
None
r
Service
1
Component Type
Count
Emission Factor (kglhr
source)
Table 2-4 Table 2 8
Control (%)
Pollutant
Mass Fraction
Emissions
(tpy)
Reg 3
Connectors
3844
2 00E 04
1 00E 05
0 0%
VOC
0 4
0 5603718
Flanges
638
3 90E 04
5 70E-06
0 0%
Benzene
0 001
0 0014009
Gas
Open Ended Lines
9
2 00E 03
1 50E 05
0 0%
Toluene
0 0005
0 0007005
Pump Seals
0
2 40E 03
3 50E-04
0 0%
Ethylbenzene
0 0005
0 0007005
Valves
1878
4 50E 03
2 50E 05
0 0%
Xylenes
0 0005
0 0007005
Other
466
8 80E 03
1 20E 04
0 0%
n Hexane
0 002
0 0028019
Connectors
353
7 50E 06
7 S0E 06
0 0%
VOC
1
0 0351358
Flanges
0
3 90E 07
3 90E-07
0 0%
Benzene
0 0025
8 784E 05
Heavy Oil
Open Ended Lines
0
1 40E 04
7 20E-06
0 0%
Toluene
0 0013
4 568E 05
Pump Seals
0
0 00E+O0
0 00E+00
0 0%
Ethylbenzene
0 0013
4 568E 05
Valves
118
8 40E 06
8 40E-06
0 0%
Xylenes
0 0013
4 568E 05
Other
0
3 20E-05
3 20E 05
0 0%
n Hexane
0 005
0 0001757
Connectors
1234
2 10E 04
9 70E 06
0 0%
VOC
1
0 5501397
Flanges
443
1 10E 04
2 40E 06
0 0%
Benzene
0 0025
0 0013753
Light Oil
Open Ended Lines
0
140E 03
140E 05
0 0%
Toluene
0 0013
0 0007152
Pump Seals
3
1 30E 02
5 10E 01
0 0%
Ethylbenzene
0 0013
0 0007152
Valves
1630
2 50E 03
1 90E 05
0 0%
Xylenes
0 0013
0 0007152
Other
104
7 50E 03
1 10E 04
0 0%
n Hexane
0 005
0 0027507
Connectors
479
1 10E 04
1 OOE 05
00%
VOC
1
01002472
Flanges
14
2 90E 06
2 90E 06
0 0%
Benzene
0 0025
0 0002506
Water/Oil
Open Ended Lines
0
2 50E 04
3 50E 06
0 0%
Toluene
0 0013
0 0001303
Pump Seals
0
2 40E 05
2 40E 05
0 0%
Ethylbenzene
0 0013
0 0001303
Valves
183
9 80E 05
9 70E 06
0 0%
Xylenes
0 0013
0 0001303
Other
64
1 40E 02
5 90E 05
0 0%
n Hexane
0 005
0 0005012
(
Emissions Summary Table
Pollutant
Uncontrolled Emissions
Controlled Emissions
Source
VOC
1 25
tpy
1 25
tpy
Screening E
Benzene
6 23
lb/yr
6 23
lb/yr
Screening E
Toluene
3 18
lb/yr
3 18
lb/yr
Screening E
Ethylbenzene
318
lb/yr
3 18
lb/yr
Screening E
Screening E
Xylenes
3 18
lb/yr
3 18
lb/yr
n Hexane
12 46
lb/yr
12 46
lb/yr
Screening E
1
1
s EPA 453/R 95-017 Table 2 8
s EPA 453/R 95 017 Table 2 8
s EPA 453/R 95 017 Table 2 8
s EPA 453/R 95 017 Table 2 8
s EPA -453/R 95 017 Table 2 8
s EPA 453/R 95 017 Table 2 8--
Separator Venting Emissions Inventory
005 Separator Venting
Facility AIRs ID:
County
Plant
005
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
..'• x .YK Y:vv x.r � y, .Rx:<-x=, >?4 :=wz- .r ;.;r
Heater Treater (Low Presitit8) asld surge drum gas Streams •
J�-J4r:UCl L1; 1A�:Jla. .. ,r .. r.'G ✓v. v -✓'r
•.,........ J.,L: CI 4t
{FA..F':• sac
14.•
Enclosed Combustion Device
Emission Control Device Description:
Requested Overall VOC & HA? Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
11.6 MMscf per year
Requested Permit Limit Throughput =
11.6 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:
11.6 MMscf per year
Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
2899 Btu/scf
scf/bbl
Low pressure heater treater separator and surge drum operate to separate and recover natural gas as well as to lower the stream to atmospheric pressure. The further downstream surge drum stream composition is used to
estimate these emissions as it is the most conservative.
MW
51.71
Weight %
Helium
0,00
CO2
0.55
N2
0.01
methane
1.44
ethane
8.15
propane
. )
isobutane
7.06
n -butane
isopentane
7.16
n -pentane
-7)
cyclopentane
n -Hexane
"83
cyclohexane
Other hexanes
3.76
heptanes
3.37
methylcyclohexane
224-TMP
0.00
Benzene
0.48
Toluene
0.55
Ethylbenzene
0.04
Xylenes
0.21
C8+ Heavies
1.50
Total
99.98
VOC Wt %
89.83
Ib/Ib-mol Displacement Equation
Ex = Q * MW * Xx / C
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
Emission Factor Source
(Gas Throughput)
(Gas Throughput)
VOC
122562.2507
6128.1125
. _ ..
Benzene
654.9024
32.7451
HYSYS
Toluene
750.4090
37.5204
HYSYS
Ethylbenzene
54.5752
2.7288
HYSY5
Xylene
286.5198
14.3260
HYSYS
n -Hexane
3861.1953
193.0598
HYSYS
224 TMP
0.0000
0.0000
pv =`vc.
Primary Control Device
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) lb/MMscf
Emission Factor Source
(Waste Heat
Combusted)
(Gas Throughput)
PM10
21.600
AP -42 T.abi 1,4-:r (P 1O„IPM.2;.';
AP -42 Tabhe 1..4✓2,(PNI10/Pryl, J, ,"
:°,P-42 `≥~sb;r• t4,.2 fir,;'".
AP -42 Chapter 13..51ntiustr r? F...nris ,NO •
PM2.5
. . _
21.600
SOx
0.0006
1.705
NOx
0.0680
197.132
CO
0.3100
898.690
13 of 16
K:\PA\2018\18WE1277.CP1
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.12
0.12
0.12
0.12
0.12
21
0.12
0.12
0.12
0.12
0.12
21
0.01
0.01
0.01
0.01
0.01
2
1.14
1.14
1.14
1.14
1.14
194
708.41
708.41
35.42
708.41
35.42
6017
5.19
5.19
5.19
5.19
5.19
882
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
7571
7571
379
7571
379
Toluene
8675
8675
434
8675
434
Ethylbenzene
631
631
32
631
32
Xylene
3312
3312
166
3312
166
n -Hexane
44635
44635
2232
44635
2232
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
'yes >,
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
- An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
No
- A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? Yes
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parameter is natural gas vented. The following questions do not re • uire an answer.
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41/1/../1-
14 of 16 K:\PA\2018\18WE1277.CP1
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
005
Process #
O1
SCC Code
3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor
PM10 21.60
PM2.5 21.60
SOx 1.71
NOx 197.13
VOC 122562.25
CO 898.69
Benzene 654.90
Toluene 750.41
Ethylbenzene 54.58
Xylene 286.52
n -Hexane 3861.20
224 TMP 0.00
Control %
0
0
0
0
95
0
95
95
95
95
95
95
Units
Ib/MMSCF
Ib/MMSCF
Ib/MMSCF
Ib/MMSCF
lb/MMSCF
Ib/MMSCF
Ib/MMSCF
lb/MMSCF
Ib/MMSCF
Ib/MMSCF
Ib/MMSCF
Ib/MMSCF
it
15 of 16 K:\PA\2018\18WE1277.CP1
Separator Venting Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
Yes
Yes
Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
Na
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is
intended to describe APCD interpretations and recommendations Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Source Req
Source Req
Source is si
The contro
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE 1277 Issuance: 1
Noble Energy Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Y11 Waste Management Econode
123/A015
NENW SEC 11 T2N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
AIRS
Point
Equipment Description
Emissions Control ;Description
001
Two (2) 750 barrel fixed roof condensate
storage tanks
Enclosed Burner
002
Four (4) 500 barrel fixed roof produced
water storage tanks
Enclosed Burner
003
Truck loadout of condensate
Enclosed Burner
004
Fugitive equipment leak emissions
None
005
Heater treater (low pressure) and surge
drum gas emissions
Enclosed Burner
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 the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
Page 1 of 13
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(1) 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. Point 005: Upon issuance of this permit, the operator shall install a flow meter to monitor and
record total volumetric flow rate of natural gas vented from the separators covered by this
permit.
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 I I .A.4. )
Annual Limits:
AIRS
Point
Tons per Year
Emission Type
PM2.5
NOX
VOC
CO
001
---
---
0.7
---
Point
002
---
2.8
9.9
12.6
Point
003
---
---
1.0
---
Point
004
---
---
1.3
---
Fugitive
005
---
1.3
35.5
5.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Page 2 of 13
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit 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.),
AIRS
Point
Control Device
Pollutants
Controlled
001
Enclosed Burner
VOC and HAP
002
Enclosed Burner
VOC and HAP
003
Enclosed Burner
VOC and HAP
005
Enclosed Burner
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
AIRS
Point
Process Parameter
Annual Limit
001
Condensate
throughput
272,290 bbl/yr
002
Produced Water
throughput
1,500,000 bbl/yr
003
Condensate Loaded
272,290 bbl/yr
005
Natural Gas routed
to flare
11.56 MMscf/yr
The owner or operator shall monitor monthly process rates based on the calendar month.
Page 3 of 13
COLORADO
Air Pollution Control Division
Department of Pubhc Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 005: Upon issuance of this permit, the owner or operator shall continuously monitor and
record the volumetric flow rate of natural gas vented from the separator(s) using the flow
meter. The owner or operator shall use monthly throughput records to demonstrate compliance
with the process limits contained in this permit and to calculate emissions as described in this
permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. 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)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. Point 001: 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. Points 001, 002, and 005: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.
Page 4 of 13
c.
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
14. Points 001 and 002: 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 Division upon request. This control requirement must be met within 90
days of the date that the storage tank commences operation.
15. Points 001 and 002: The storage tanks covered by this permit are subject to the venting and
Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7,
Section XVII.C.2.
16. 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 tanks shall be conducted
by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part
B, III.D.2)
17. 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 toss 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.
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.
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.
18. 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.
Page 5 of 13
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
19. Point 004: Fugitive component leaks at this well production facility are subject to the Leak
Detection and Repair (LDAR) program requirements, including but not limited to: monitoring,
repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F.
In addition, the operator shall comply with the General Provisions contained in Regulation 7,
Section XVII.B.1.
20. Point 005: The separator covered by this permit is subject to Regulation 7, Section XVII.G.
(State Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well,
must either be routed to a gas gathering line or controlled from the date of first production by
air pollution control equipment that achieves an average hydrocarbon `control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING a MAINTENANCE REQUIREMENTS
21. Points 001, 002, 003, and 005: 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 O&M plan are subject to Division approval prior
to implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
22. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
23. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
24. 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
Page 6 of 13
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
25. 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 11.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
26. 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.
27. 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.
28. 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.
Page 7 of 13
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
29. 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.
30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
31. 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.
Bv:
Christopher Kester
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc.
Page 8 of 13
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator 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-reps
4) The following emissions of non -criteria reportable air, pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(ib/yr)
Controlled
Emissions
(lb/yr)
001
n -Hexane
110543
687
34
002
Benzene
71432
10,500
525
n -Hexane
110543
33,000
1,650
003
n -Hexane
110543
905
45
005
Benzene
71432
7,629
381
Toluene
108883
8,719
436
Ethylbenzene
100414
648
32
Xylenes
1330207
3,565
166
n -Hexane
110543
44,722
2,240
5) The emission levels contained in this permit are based on the following emission factors:
Page 9 of 13
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 001:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
VOC
0.09066
0.004533
110543
n -Hexane
0.00252
0.000126
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 002:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
NOx
0.068 lb/MMBTU
0.068 lb/MMBTU
CO
0.31 lb/MMBTU
0.31 lb/MMBTU
VOC
0.262
0.0131
71432
Benzene
0.007
0.00035
110543
n -Hexane
0.022
0.00110
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
VOC
0.1351
0.00676
110543
n -Hexane
0.00333
0.00017
The uncontrolled VOC 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) = 3.24 psia
M (vapor molecular weight) = 68 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 VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
Page 10 of 13
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 004:
Component
Gas Service
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
3844
353
1264
479
Flanges
638
0
443
14
Open-ended Lines
9
0
0
0
Pump Seals
0
0
3
0
Valves
1878
118
1630
183
Other*
466
0
104
64
VOC Content (wt.
fraction)
0.4
1
1
1
Benzene Content (wt.
fraction)
0.001
0.0025
0.0025 .
0.0025
Toluene Content (wt.
fraction)
0.0005
0.0013
0.0013
0.0013
Ethylbenzene (wt.
fraction)
0.0005
0.0013
0.0013
0.0013
Xylenes Content (wt.
fraction)
0.0005
0.0013
0.0013
0.0013
n -hexane Content
(wt. fraction)
0.0020
0.005
0.005
0.005
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
SWater/Oil
ervi
Service
Connectors
1.00E-05
7.50E-06
9.70E-06
1.00E-05
Flanges
5.70E-06
3.90E-07
2.40E-06
2.90E-06
Open-ended Lines
1.50E-05
7.20E-06
1.40E-05
3.50E-06
Pump Seals
3.50E-04
0.00E+00
5.10E-04
2.40E-05
Valves
2.50E-05
8.40E-06
1.90E-05
9.70E-06
Other
1.20E-04
3.20E-05
1.10E-04
5.90E-05
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC
content from the most recent gas and liquids analyses.
Page 11 of 13
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Point 005:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
NOx
0.068 lb/MMBTU
0.068 lb/MMBTU
CO
0.31 lb/MMBTU
0.31 lb/MMBTU
VOC
122649.4
6132.47
71432
Benzene
659.9
33.00
108883
Toluene
754.1
37.71
100414
Ethylbenzene
56.1
2.81
1330207
Xylene
308.3
15.42
110543
n -Hexane
386.81
19.34
Note: The controlled emissions factors for this point are based on a control efficiency of 95%
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This 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:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
NOx, CO, VOC, and HAP
NANSR
Synthetic Minor Source of:
NOx and VOC
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
Page 12 of 13
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 63: National Emission Standards for HazardousAir 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
Page 13 of 13
v Y�
Condensate Storage Tank(s) APENE� 3"'
\ 0 A4C�7'Cy
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:
lsVV 211 AIRS ID Number: 123 iftOL6 /COI
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1: Noble Energy Inc.
Site Name: Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 L01
Site Location' NENW SEC11 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.
390701
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
COLORADO
1 I n.weme�, o�ruMx
Nvn4A b 4nvitolu,w.nl
VflCe
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
El Request coverage under traditional construction permit
0 Request coverage under a General Permit
❑ GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of S312.50 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 0 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 £t 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: Condensate Tanks (Off Spec Tanks)
Company equipment Identification No. (optional):
For existing sources, operation began on: 09/05/2018
For new or reconstructed -sources, the projected start-up date is:
Normal Hours of Source Operation: 24
hours/day 7 days/week
Storage tank(s) located at: ❑✓ Exploration Et Production (EEtP) site
52
weeks/year
0 Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
O
•
Are Flash Emissions anticipated from these storage tanks?
Yes
No
•
ig
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
p
•
If "yes", identify the stock tank gas -to -oil ratio:
0
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
SI
•
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
NfrCOLORADO
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: 40.68 degrees
O Internal floating roof
Tank design: El Fixed roof
272,290
RVP of sales oil:
6.030 (Ran Tanks at 7(
❑ 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)
2
1500
09/2018
Wells Serviced by this Storage Tank or Tank Battery6 (ECtP Sites On
y)
API Number
Name of Well
Newly Reported Well
- -
SEE ATTACHED
■
- -
U
- -
■
- -
■
- -
■
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
(Latitude/Longitude or UTM)
40.158, -104.52
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)
i Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
I] 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
!COLORADO
3 1 =Itatn,
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit tt 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.
Vapor
❑ Recovery
Unit (VRU):.
Pollutants Controlled:
Size:
Requested Control Efficiency:
Make/Model:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (E8tP 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, PW 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
COLORADO
4 I A.' ' Uearc�n:n�o1 P_bic
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 Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions8
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.09066 -'
lb/bbl
HYSYS/Tanks4.0.9d
12.34 -
0.62 -
NOx
0.0037
lb/lb VOC
CDPHE
0.11
0.11
CO
0.0094
lb/lb VOC
CDPHE
0.29
0.29
Non -Criteria Reportable Pollutant Emissions Inventory
• Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissionse
(Pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.00252 '
lb/bbl
HVSYS/Tanks4.o.9d
687 -'
34
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 wilt 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
®y COLORADO
5 o;puMic
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.
ovnilith S 12/03/2018
Sign lure 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:
0✓ 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.aov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 I A
COLORADO
Dep.:mnn ofPcb
He�4AbEnWitan...nl
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
Noble Energy, Inc.
Source Name:
Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 L01
Emissions Source AIRS ID2:
123 /f0I6 / Od 1
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 44840
WASTE MANAGEMENT Y23-712
❑
05
- 123
- 44844
WASTE MANAGEMENT Y23-728
❑
05
- 123
- 44841
WASTE MANAGEMENT Y23-736
❑
05
- 123
- 44843
WASTE MANAGEMENT Y23-744
❑
05
- 123
- 44846
WASTE MANAGEMENT Y23-752
❑
05
- 123
- 44838
WASTE MANAGEMENT Y23-760
❑
05
- 123
- 44845
WASTE MANAGEMENT Y23-768
❑
05
- 123
- 44847
WASTE MANAGEMENT Y23-776
❑
05
- 123
- 44839
WASTE MANAGEMENT Y23-784
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
-
-
❑
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
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 alt
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Rov/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:
pQ
AIRS ID
ISW iZfl Number: {Z3 A-0 002.
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 L01
Site Location: NENW SEC11 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.
390703
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
COLORADO
1 Ay; DcµrtLent of PnGAc
F,"t;NJR.. Fm..rurv,nt
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ft 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 ❑ Change company name3
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
1=1 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
09/05/2018
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
❑✓ Exploration & Production (EEtP) site
52
weeks/year
0 Midstream or Downstream (non E&P) 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 ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
❑
No
✓
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
p COLORADO
2 I '. K Fru, a" r,
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)
Produced Water Throughput:
...1.,80070130—"
From what year is the actual annual amount?
Tank design: ❑✓ Fixed roof
N/A
O Internal floating roof
11SVOlcooc
0 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)
Tanks
4
2000
09/2018
Wells Serviced by this Storage Tank or Tank Battery(' (MP Sites Only)
API Number
Name of Well
Newly Reported Well
-
SEE ATTACHED
❑
_
❑
- -
❑
_
❑
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EftP 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)
40.158, -104.52
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):
0 Upward with obstructing raincap
Indicate the stack opening and size: (check one)
D 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 A
.COLORADO
L•c^..uxmen: of PU,Ic
F?eal�1+Fr Fmim:o +n,.
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit 11 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
O Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Burner Make/Model:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
95
98
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:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (EEP 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. Note, pilot emissions are in the heater treater/surge drum APEN because
they are shared burners.
COLORADO
Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
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)
V0C
Enclosed Burner
95%
NOx
CO
HAPs
Enclosed Burner
95%
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
0.2620 -
lb/bbl
CDPHE
%S,?3S'BS —
9.1 1,1 .9',
NOx
0,...D937"'
lb/lb VOC
CDPHE
Vior Aar --2,15%,(1.10"
CO 0'31 0.0094;'
lb/lb VOC
CDPHE
t2.5't.1
rt.ft
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions8
(pounds/year)
Benzene
71432
0.007 -
lb/bbl
CDPHE
V
639
Toluene
108883
Idiom
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.022 /
lb/bbl
CDPHE
u J
1
2,2,4-
Trimethylpentane
540841
33,`00
I ��
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 Lia'
COLORADO
! t)e,arMr_m of Halm
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.
arvMn S uatde, 12/03/2018
Signature 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:
✓❑ 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-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018
(COLORADO
.
6 I ADr471rtalPubtk
Kcaunaenr,.onnr,a
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.Qov/cdphe/aocd.
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: tigVVE 2-11 AIRS ID Number: 12, 3 /p.016/ 00 3
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': Noble Energy Inc.
Site Name: Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 L01
Site Location: NENW SEC11 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.
390702
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
1 I AY
COLORADO
of Public
H n1Ab Cnvl.aninent
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
❑✓ Request coverage under construction permit
D 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)
O Change fuel or equipment O Change company name3
O Change permit limit O Transfer of ownership4 O Other (describe below)
- OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: NOx and CO emissions are accounted for in condensate tank calculation
because there are shared burners. Pilot emissions are accounted for in HT and surge calculations.
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:
09/05/2018
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
p
•
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
(51
Does this source load gasoline into transport vehicles?
Yes
No
•
p
Is this source located at an oil and gas exploration and production site?
Yes
No
0
•
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
0
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
■
PI
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
2 I T Vittne• n
�Health kFnvi��n.nenl
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # 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:
272,290
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:
0.6
Average temperature of
bulk liquid loading:
51.7925
°F
True Vapor Pressure:
3.2376
Psia ® 60 °F
Molecular weight of
displaced vapors:
Q
68
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 1 A
:COLORADO
LY{armenc °I Pualc
ttv.VU: E Enrite.,11•Vai
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)
40.158, -104.52
Operator
Stack ID No.
Discharge Height Above
Ground Level
(f)
Temp.
(•F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
❑ Horizontal
O Downward
O 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:
Manufacturer Guaranteed Control Efficiency: 98
Used for control of: VOC and HAPs
Rating:
Type: Enclosed Burner
MMBtu/hr
Make/Model:
Requested 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
®vricOLORADO
4 I Ityr .K°f PIA.
Kwr. a E.u;.°.r..nl
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
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?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NOx
CO
VOC
0.1351 -.
lb/bbl
AP -42
18.39 -
0.92
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year) (P Y )
Controlled
Emissions6
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0033 -
lb/bbl
AP -42
905 /
45
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.
COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I A.V '=:;:an"",
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. 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.
12/03/2018
Signature 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:
❑✓ 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.Rov/cdphe/apcd
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 I A
I COLORADO
Public
MAIM bEnulronnenl
Fugitive Component Leak Emissions APEN
Form APCD-203
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 fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.Qov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
AIRS ID Number:
123 in -0 (6/ 0 04
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Noble Energy Inc.
Site Name: Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 L01
Site Location: NENW SEC11 T2N R64W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver, CO 80202
Site Location WeIA
ld
County:
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2: janessa.salgado@nblenergy.com
Janessa Salgado
303-228-4196
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.
390704
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
COLORADO
1 Ay I DaWrtnrnt ul Pattie
Neg.& Envllavvnl
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 (check one below)
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change process or equipment O Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 O 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 a Notes:
3 For company name change, a completed Company Name Change Certification Fomi (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
Company equipment Identification No. (optional): Fugitives
For existing sources, operation began on: 09/05/2018
For new or reconstructed sources, the projected start-up date is:
El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Facility Type:
D Well Production Facility5
❑ Natural Gas Compressor Stations
O Natural Gas Processing Plants
❑ Other (describe):
hours/day
days/week weeks/year
5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
'COLORADO
2 I Ay
i Nva�4n a CY Cnvironnwnl
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Regulatory Information
What is the date that the equipment commenced construction? 09/05/2018
Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes ❑ No
Will this equipment be located at a stationary source that is considered a ❑ Yes ❑✓ No
Major Source of Hazardous Air Pollutant (HAP) emissions?
Are there wet seal centrifugal compressors or reciprocating compressors ❑✓ Yes ❑ No
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? 0 Yes ❑✓ No
Is this equipment subject to 40 CFR Part 60, Subpart 0000? 0 Yes ❑✓ No
Is this equipment subject to 40 CFR Part 60, Subpart 0000a? ✓❑ Yes ❑ No
Is this equipment subject to 40 CFR Part 63, Subpart HH? 0 Yes p No
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? 0 Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑✓ Yes 0 No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑✓ Yes 0 No
Section 5 - Stream Constituents
❑ The required representative gas and liquid extended analysis (including BTEX) to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight % content of each applicable stream.
Stream
V0C
(wt %)
Benzene
(wt %)
Toluene
(wt %)
Ethylbenzene
(wt %)
Xylene
(wt %)
n -Hexane
(wt %)
2,2,4
Trime(ntane
%)
(wt %)
Gas
40.00
0.10
0.05
0.05
0.05
0.20
0.05
Heavy
(or Heavy Liq0iluid)
100
0.25
0.13
0.13
0.13
0.50
0.13
Light Oil
(or Light Liquid)
100
0.25
0.13
0.13
0.13
0.50
0.13
Water/Oil
100
0.25
0.13
0.13
0.13
0.50
0.13
Section 6 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.158, -104.52
Attach a topographic site map showing location
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
a !COLORADO
3 I A�' �_�
HeatlT. b EnvO�xuneni
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
D LDAR per 40 CFR Part 60, Subpart KKK
o Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump
o Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump
❑✓ LDAR per 40 CFR Part 60, Subpart 0000/0000a
o Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81%
connectors
❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F
O Other6:
O No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
COLORADO
4 I A� nr Pb<tc
H u16P.nvironrtu'nl
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
0 Table 2-4 was used to estimate emissions7.
0 Table 2-8 (< 10,000ppmv) was used to estimate emissions7.
Use the following table to report the component count used to calculate emissions. The component counts listed
in the following table are representative of:
❑✓ Estimated Component Count
0 Actual Component Count conducted on the following date:
Service
Equipment Type
Connectors
Flanges
Open -Ended
Lines
Pump Seals
Valves
Other y
Gas
Counts
3844
638
9
1878
466
Emission Factor
1.00E-5
5.70E-6
1.5E-5
2.50E-5
1.20E-4
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
Heavy Oil (or Heavy Liquid)
Counts
353
0
0
0
118
0
Emission Factor
7,50E-6
8.40E-6
Units
kg/hr/source
kg/hr/source
Light Oil (or Light Liquid)
Count8
1264
443
0
3
1630
104
Emission Factor
9,70E-6
2.4E-6
5.10E-4
1.90E-5
1.10E-4
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
Water/Oil
Count8
479
14
0
0
183
64
Emission Factor
1.00E-5
2.90E-6
9.70E-6
5.90E-5
Units
kg/hr/source
kg/hr/source
kg/hr/source
kg/hr/source
7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual
Calendar Year Emissions" below.
9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump
seals, or valves.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
COLORADO
5 I A. viP.bt.
eoos.ont:w i
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data?
Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source:
Use the data reported in Section 8 to calculate these emissions.
Chemical Name
CAS
Number
Actual Annual Emissions
Requested Annual
Limit(s)11Permit Emission
Uncontrolled
(tons/year)
Controlled �o
(tons/year)
Uncontrolled
(tons/year)
Controlled
(tons/year)
voC
1.25
1.25 —
Does the emissions source have any actual emissions of non -criteria pollutants
(e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
Ei Yes ✓❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
CAS
Number
Actual Annual Emissions
Requested Annual
Limit(s)11Permit Emission
Uncontrolled
(lbs/year)
Controlled �o
(lbs/year)
Uncontrolled
(lbs/year)
Controlled
(lbs/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
2,2,4
Trimethylpentane
540841
Other:
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count
variability, and gas composition variability.
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
!COLORADO
6 I ! itill1 v 2:',.
Permit Number:
AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
rfime.tha 5
12/03/2018
Si ature 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:
❑✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.Rov/cdphe/apcd
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018
71
'COLORADO
Lkpastrissne. Pub.
Pub
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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.Rov/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.
.CjEIVF`:a_
NEC 3 2018
APCD
Stationary
Sources
Permit Number: ISNE 1177 AIRS ID Number: 1 23 1A-016 /005
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Site Location:
Noble Energy Inc.
Y11 WASTE MANAGEMENT ECONODE T2N-R64W-S11 LO1
NENW SEC11 T2N R64W
Mailing Address: 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 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.
390700
Form APCD-211 - Gas Venting APEN - Revision 7/2018
AV
iCOLOR ADO
1 I AV I oipt
Viea4le 6 Crvvieo:i:�eet
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
O Change permit limit ❑ Transfer of ownership4 O 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 £t 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:
streams
Heater treater (LP) and surge drum gas
Company equipment Identification No. (optional):
For existing sources, operation began on:
09/05/2018
For new, modified, or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
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?
O
days/week weeks/year
Yes
Yes
Yes
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I A.`
No
No
No
(COLORADO
1H tab Eire, nflL
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
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
Heating Value:
2899
BTU/SCF
Requested:
11.56
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
51.71
VOC (Weight %)
89.85%
Benzene (Weight %)
0.48%
Toluene (Weight %)
0.55%
Ethylbenzene (Weight %)
0.04%
Xylene (Weight %)
0.23%
n -Hexane (Weight %)
2.83%
2,2,4-Trimethylpentane (Weight %)
0.01%
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-211 - Gas Venting APEN - Revision 7/2018
;COLORADO
Hog.5 Gw f Puh4c
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
GeographicalCoordinates
(Latitude/Longitude or UTM)
40.158, -104.52
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
en(ACpM)
Flow Rate
Velocity.
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
❑ Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
O VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed:
%
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
Type: VOC Burner Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes 0 No Pilot burner Rating: MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 - Gas Venting APEN - Revision 7/2018
}A
/lak�� iCOO ADO
ei1�1R
4 I � y��+11t� ENYGUn�:mnL
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 Limit(s)5
Uncontrolled
Source
-42,
Uncontrolled
Controlled
Uncontrolled
Controlled
Basis
Units
(AP
Mfg., etc.)
Emissions
(tons/year)
Emissions6
(tons/year)
Emissions
(tons/year)
Emissions
(tons/year)
PM
7.6
Ib/MMscf
AP -42
0.01
0.01
SOx
0.6
Ib/MMscf
AP -42
0.00
0.00
NO.
0.068, 100
Ib/Mscf
AP -42
1.27 -
1.27 --
CO
0.31, 84
Ib/Mscf
AP -42
5.30 -
5.30
VOC
122.6494, 0.0055
Ib/Mscf
HYSYS, AP -42
709.02 —
35.46
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(Ap-42, etc.)
Mfg.,
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions 6
(pounds/year)
Benzene
71432
0.6599
Ib/Mscf
HYSYS/AP-42
7,629 --
381 '
Toluene
108883
0.7541
Ib/Mscf
HYSYS/AP-42
8,719
436 /
Ethylbenzene
100414
0.0561
Ib/Mscf
HYSYS/AP-42
648 '
32 -
Xylene
1330207
0.3083
Ib/Mscf
HYSYS/AP-42
3,565 /
178
n -Hexane
110543
3.8681
lb/Mscf
HYSYS/AP-42
44,722 '
2,240
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
51 AY
COLORADO
fitrUh t,tof Pt
kerUhb EIW flcwst
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.
Si�ature of Legally Author(not a vendor or consultant Date
gv )
w+tw.ot S
12/03/2018
Janessa Salgado Environmental Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
0✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-211 - Gas Venting APEN - Revision 7/2018
COLORADO
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