HomeMy WebLinkAbout20181255.tiffCOLORADO
Department of Public
Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
April 10, 2018
Dear Sir or Madam:
RECEIVED
APR 1 3 2018
WELD COUNTY
COMMISSIONERS
On April 12, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - Wells Ranch AF T5N-R6W-S8 L01. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
1 -C>bIIC. r`O.V;eW cc:PLCM(11/,-P), HLCTi.),
fk,oceR(CH/SM/cIc)
OL1 fa3/ t OL( ((cif(
2018-1255
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Wells Ranch AF T5N-R6W-S8 L01 - Weld County
Notice Period Begins: April 12, 2018
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Noble Energy, Inc.
Facility: Wells Ranch AF T5N-R6W-S8 L01
Oil and gas exploration and production facility
NWNW Sec 08 T5N R62W
Weld County
The proposed project or activity is as follows: Source proposes to operate an oil and gas exploration and
production facility and to route vapors to a flare.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 12WE2947 CP2 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. Any such comment must be submitted in writing to the following addressee:
Carissa Money
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORADO
1 _,.
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Carlssa Money
Package #: 370174
Received Date: 10/11/2017
Review Start Date: 1/23/2018
Section 01 - Facility Information
Company Name: Noble Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: 99A9
Facility Name: Wells Ranch AF T5N-R6W-58101
Physical Address/Locatio NWNW quadrant of Section 8, Township 5N, Range 62W, in Weld County, Colorado
Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? - Yes
If yes, for what pollutant?
Weld
Don Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
NWNW
8
5N
62
ERiculate Matter (PM) Eine (NO: & VOC)
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
Hydrocarbon Liquid Loading
Truck Load Out _
Yes .
12WE2947
2
No
Permit
Modification
Reducing
throughput
from 250,000
bbl/yr to
109,500 bbl/yr.
Adding control.
Update EF
011
Separator Venting
LP Burner
yes
12WE2947
2
Yes
Permit Initial
Issuance
Requesting to
permit new
equipment
012
- Separator Venting '
VRT Burner -
Yes.
12WE2947
2
Yes
Permit Initial
'Issuance
Requesting to
permit new
equipment
Section 03 - Description of Project
Noble is submitting this application for an existing low pressure (LP) separator and Vapor recovery -tower (VRT). Emissions from the LP separator and VRT-were routed to a vapor
recovery unit (VRU) and recycled. Noble would like to remove the engine associated with the VRU and thus route the LP separator and VRT emissions to flare instead of recycling.
Noble is also requesting to decrease the throughputfor the loadout which was the only point originally permitted under 12W12947. Noble is also adding a control device to the
loadout.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No ,-
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor? Yes
Colorado Air Permitting Project
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP) •
Non -Attainment New Source Review (NANSR)
SO2
Is this stationary source a major source?
If yes, explain what programs and which pollutants her€ SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NOx
NOx
CO VOC PM2.5 PM10 TSP HAPs
CO
VOC PM2.5
PM10
TSP
E ❑
HAPs
❑ ❑
Hydrocarbon Loadout Emissions Inventory
Section 01 - Administrative Information
Facility AIRs ID:
123
County
99A9
Plant
009
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Hydrocarbon foadout to tank trucks.
Description:
Emission Control Device Enclosed flare
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Requested Overall VOC & HAP Control Efficiency %:
100.0
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Volume Loaded =
95
95.00
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 =
Barrels (bbl) per year
109,500 Barrels (bbl) per year
109,500 Barrels (bbl) per year
2255 Btu/scf
172909 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?
Actual Volume Loaded While Emissions Controls Operating = Barrels (bbl) per year
0 MMBTU per year
390 MMBTU per year
390 MMBTU per year
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
A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
psia
,'i'abfRR.z''1_Stt§tbdrged I. d' .£iEdicatecffluzmol tiHlV tp;(S 0.6
P
True Vapor Pressure
--- 6.9
AP -42 Table 7.1-2 based on Gasoline RVP 13 at 60 deg F
M
Molecular Weight of Vapors
62
Ib/Ib-mol
a AP -42 Table 7.1-2 based on Gasoline RVP 13 at 60 deg F
T
Liquid Temperature
520
Rankine
- Assuming 60 deg F which is liquid temp in TANKS run
L
Loading Losses
6.150447692
lb/1000 gallons
0.258318803 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.00188
0.000485639
lb/bbl
Assumed HAP concentrations from Table 3-2 EPA -453/R-94.002a
Toluene
0:00129
0.000333231
lb/bbl
Assumed HAP concentrations from Table 3-2 EPA -453/A94 -002a
Ethylbenzene
0.00006
1.54991E-05
lb/bbl
Assumed HAP concentrations from Table 3-2 EPA -453/R-94-002a
Xylene
0.0003 -
7.74956E-05
lb/bbl
Assumed HAP concentrations front Table 3-2 EPA -453/0-94002a
n -Hexane
0.01044
0.002696848
lb/bbl
Assumed HAP concentrations from. Table 3-2 EPA -453/R -94002a
224 TMP
0.00074
0.000191156
lb/bbl
Assumed concentration to be similar to ES
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Volume Loaded)
(Volume
Loaded)
0.0129
0.0000
0.0000
0.0000
0.0000
0.0001
0.0000
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
2-58E-01
4.86E-04
3.33E-04
1.55E-05
7.75E-05
2.70E-03
1.91E-04
Emission Factor Source
Emission Factor Source
Pollutant
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
2.65E-05
2.65E-05
2.09E-06
2.42E-04
1.10E-03
PM10
PM2.5
0.0075
0.0075
0.0006
0.0680
0.3100
SOx
NOx
CO
3 of 13
K:\PA\2012\12 W E2947.CP2.xlsm
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)
PM10
PM2.5
sox
NOx
VOC
CO
0.00
0.00
0.00
0.0
0.0
0.00
0.00
0.00
0.0
0.0
0.00
0.00
0.00
0.0
0.0
0.01
0.00
0.00
0.0
0.0
14.14
0.00
0.00
14.1
11.7
0.06
0.00
0.00
0.1
0.1
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
53
0
0
53
3
36
0
0
36
2
2
0
0
2
0.1
8
0
0
8
0.4
295
0
0
295
15
21
0
0
21
1
Section 06 - Regulatory Summary Analysis _
Regulation 3, Parts A, B
Source requires a permit
RACT- Regulation 3, Part 8, Section III.D.2.a
(See regulatory applicability worksheet for detailed analysis)
The loadout must be operated with submerged fill to satisfy RACT.
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
Noble is requesting to reduce the permitted throughput from 295,000 bbl/yr to 109,500 bbl/yr. Also, the emission factor was previously based on using AP -42 default properties for Gasoline RVP 10. Now, Noble is
using the AP -42 properties for Gasoline RVP 13. Noble assumed the oil is 70% VOC in the application. I requested a site -specific sample to document this assumption or use 100% VOC. Noble agreed to use 100% VOC.
On 3/15/2018, Shaun Higgins with Noble emailed me stating the loadout would now be controlled. I requested a revised APEN, revised emission calculations and O&M Plan, which was emailed to me on 3/22/2018.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
009
Process #
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (0=0.61
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
5Ox 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 6.2 95 lb/1,000 gallons transferred
CO 0.03 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 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.06 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
4 of 13 K:\PA\2012\12WE2947.CP2.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
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 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. 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 5 TPY (Regulation 3, Part B, Section 11.0.2)?
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)?
IThe loadout must be operated with submerged fill to satisfy PACT.
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.
Yei
Yes:.;
No
No;:.......
No
Yes'
Go to next
Go to then
Go to next
Go to next
Go to next
The loadou
No - _....'' The loadou
Separator Venting Emissions Inventory
Section 01 - Administrative Information
Facility AIRs ID:
123
County
99A9
Plant
011
Point
Section 02 - Equipment Description Details
Two low pressure (LP) separators
Detailed Emissions Unit Description:
Enclosed flare
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
95
Yes nnefer se 5stdtfeil witbn 180,? t
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU: (Sq
Is VRU process equipment:
MMscf per year
10.28 MMscf per year
10 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
1756 Btu/scf
0.00009 scf/bbl
Description
Source used a HYSYS model based on a. site -specific sample collected at the HP separator oil port on 5/3/2007
Displacement Equation
Ex= Q' MW•So/C
MW
31.56
Weight %
Helium
CO2
4.63
N2
0.16
methane
20.80
ethane
22.46
propane
29.19
isobutane
3.65
n -butane
10.70
isopentane
2.10
n -pentane
2.55
ryclopentane
1.37
n -Hexane
0.87
cyclohexane
0.02
Other berates
heptanes
0.85
methylcyclohexa ne
224-TMP
0'.07
Benzene
0,15
Toluene
0.12
Ethytbenzene
0.01
Xylenes
0.02
C8+ Heavies
0.29
Total
VOC Wt %
100.01
51.96
b/lb-mol
6 of 13 K:\PA\2012\ 12WE2947.CP2.xlsm
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(Ib/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
Emission Factor Source
VOC
43268.0106
2163.4005
Benzene
Toluene
124.9077
99.9261
8.3272
16.6544
724.4644
58.2902
6.2454
4.9963
0.4164
0.8327
36.2232
2.9145
Ethylbenzene
Xylene
n -Hexane
224 TMP
Emission Factor Source
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) Ib/MMscf
(Waste Heat
Combusted)
(Gas Throughput)
PM10
PM2.5
5Ox
NOx
CO
Section OS - Emissions Inventory
0.0075
0.0075
0.0006
0.0680
0.3100
13.084
13.084
1.033
119.408
544.360
Since source's values are slightly different (due to using lb/hr values instead of mol %),
I've used the source's values in the permit.
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)
added in pilot light Based on lb/hr values in HYSYS
222.54 11.127
added in pilot light
PM10
PM2.5
SOx
NOx
VOC
CO
0.07
0.00
0.00
0.1
0.1
0.07
0.00
0.00
0.1
0.1
0.01
0.00
0.00
0.0
0.0
0.61
0.00
0.00
0.63
0.63
222.49
0.00
0.00
222.5
11.1
2.80
0.00
0.00
2.81
2.81
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Source's values
Uncontrolled
Controlled
Based on lb/hr
values in
Emission Factors (Ib/MMsd,
(Ibs/year)
(Ibs/year)
Incontrolle
Controlled
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1285
0
0
1285
64
1307
65
1307.0
127.09
6.3544
1028
0
0
1028
51
1003
50
1003.0
97.5279
4.8764
86
0
0
86
4
53
3
52.6
5.1535
0.2577
171
0
0
171
9
261
13
261.0
25.3786
1.2689
7451
0
0
7451
373
7490
375
7488.9
728.30
36.415
599
0
0
599
30
585
29
585.2
56.883
2.8442
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVILB, G
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
Source requires a permit
Source is not subject to Regulation 7, Section XVII.B.2,
The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? zeta _ Ewa
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the operator have a meter installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based
on inlet and outlet concentration sampling
You have indicated above that the monitored process parame
er is natural gas vented. The following que
ions do not require an answer.
7 of 13
K:\PA\2012\12 W E2947.CP2.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
I am using the source's values for VOC and HAPs. The source used the lb/hr values in HYSYS instead of converting the weight percent into lb/hr. This difference in methods leads to slight rounding differences. Shaun Higgins stated in an
email 2/14/2018 the last frac date for this site was 6/13/2012, sothe separator is not subject to Reg 7;Section XVII.G.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
011
Process # SCC Code
01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 13.08 0 Ib/MMSCF
PM2.5 13.08 0 Ib/MMSCF
SOx 1.03 0 Ib/MMSCF
NOx 172.96 0 lb/MMSCF
VOC 43277 95 Ib/MMSCF
CO 547.34 0 Ib/MMSCF
Benzene 127.09 95 Ib/MMSCF
Toluene 97.53 95 Ib/MMSCF
Ethylbenzene 5.154 95 Ib/MMSCF
Xylene 25.38 95 Ib/MMSCF
n -Hexane 728.30 95 Ib/MMSCF
224 TMP 56.38 95 Ib/MMSCF
8 of 13 K:\PA\2012\12WE2947.CP2.xlsm
Separator Venting 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. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
'You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
Yes ?,
Yes r'
'Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
'Source is not subject to -Regulation 7, Section XVh.B.2, 0
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?
Source Req
Source Req
No )Source is nr
'The control device for this separator is not subject to Regulation 7, Section XVILB.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
The control
Separator Venting Emissions Inventory
Section 01 - Administrative Information
acuity AIRs ID:
123
County
99A9
Plant
012
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
NEED TO UPDATE SHEET FOR VRT
One vapor recovery tower (DOT)
Enclosed flare
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
95
Liquid Throu$hpOE
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput =
Is VRU process equipment:
Barrels (bbl) per year
108;44115 Barrels (hbl) per year
108,442 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
2231 Btu/scf
18.87849 scf/bbl
Description
Source used a HYSYS model based on a site -specific sample collected at the HP separator oil port on 5/3/2017.
Displacement Equation
Ex= Q • MW • %x /C
MW 40.09
Weight %
Helium
CO2
N2
methane
ethane
2.97
0.02
6,24:
20.09
38.01
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
5-22
15.51
3.05
3-69
1,95
1.22
1.14
0-09
0;22
0:16
0-01
0.04
0,37
Total
VOC Wt %
100.00
70.68
b/Ib-mol
10 of 13 K:\PA\2012\12WE2947.CP2.xlsm
Separator Venting Emissions Inventory
Emission Factors
Pollutant
Separator Venting
Uncontrolled Controlled
(Ib/bbl) (lb/bbl)
(Liquid Throughput)
(Liquid Throughput)
Emission Factor Source
VOC
1.4114
0.0044
0.0032
0.0002
0.0008
0.0244
0.0018
0.0706
0.0002
0.0002
Benzene
Toluene
Ethylbenzene
0.0000
0.0000
0.0012
0.0001
Xylene
n -Hexane
224 TMP
Emission Factor Source
Pollutant
PM10
PM2.5
Primary Control Device
Uncontrolled Uncontrolled
(lb/MMBtu) lb/bbl
(Waste Heat
Combusted)
0.0075
0.0075
0.0006
0.0680
03100
(Gas Throughput)
0.000
0.000
0.000
0.003
0.013
SOx
NOx
CO
Section 05 - Emissions Inventory
Criteria Pollutants
PM10
PM2.5
SOx
NOx
VOC
CO
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
0.02
0.02
0.00
0.16
76.53
0.71
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.0
0.0
0.0
0.17
76.5
0.72
0.0
0.0
0.0
0.2
3.8
0.72
Potential to Emit
Uncontrolled
lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) )Ibs/year)
Since source's values are slightly different (due to using lb/hr values instead of mol %),
I've used the source's values in the permit.
Based on lb/hr values in HVSVS
76.6
added in pilot light
EF
3.83 1.4126
Source's values
0.0706
Uncontrolled
(Ibs/year)
Controlled
(lbs/year)
Based on lb/hr
values in
Emission Factors (lb/bbl)
Uncontrolled
Controlled
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
476
346
22
87
476
346
22
87
24
470
345
18
86
24
17
469.536
345.144
0.0043
0.0032
0.0002
0.0008
0.0245
0.0018
0.0002
0.0002
17
17.52
0.00001
0.00004
2642
195
0
2642
195
132
10
2653
200
4
133
10
85.848
2652.528
0.0012
0.0001
199.728
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, 0
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Source is not subject to Regulation 7, Section XVII.0.2, G
The control device for this separator is not subject to Regulation 7, Section XV11.8.2.0
Section 07 - Initial and Periodic Sampling and Testing Requirements
You have indicated above the monitored process parameter is Liquid Througput. The following question does not require an answer.
Using Liquid Throughput to Monitor Compliance
Does the company use site specific mission factors based on a pressurized liquid sample (Sampled upstream of the?� --
equipment covered under this AIRS ID) and process simulation to estimate emissions? >'
This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g.,
no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample 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.
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
11ol 13
K:\PA\2012\12 W E2947.CP2.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
I am using the sources values for VOC and HAPs. The source used the lb/hr values in HYSYS instead of converting the weight percent into lb/hr. This difference in methods leads to slight rounding differences.
Section 09- Inventory SCC Coding and Emissions Factors
AIRS Point tt
012
Process It SCC Code
01 3-10-001-29 Oil 8 Gas Production: Gasiliquid separation
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.31 0 Ib/1000bbl
PM2.5 0.31 0 Ib/1000bbl
5Ox 0.02 0 Ib/1000bbl
NOx 3.20 0 Ib/1000bbl
VOC 1412.6234 95 lb/1000bbl
CO 13.34 0 Ib/1000bbl
Benzene 4.3341 95 Ib/1000bbl
Toluene 3.1814 95 Ib/1000hbl
Ethylbenzene 0.1660 95 lb/1000bbl
Xylene 0.7931 95 Ib/100obbl
n -Hexane 24.4648 95 Ib/1000bbl
224 TMP 1.8443 95 Ib/1000bbl
12 of 13
K:\PA\2012\12 W E2947.CP2xlsm
Separator Venting 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. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
'Source requires a 'hermit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
'Source is not subject to Regulation 7, Section CVII ti.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?
file control device for this separator is not snbfert to Regulation 7, Section XVII.R.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.
Yes
No
Source Req
Source Req
'Source is nu
'The control
Permit number:
Date issued:
Issued to:
ADOA
n Contra
c Heat
CONSTRUCTION PERMIT
12WE2947
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 2
Noble Energy, Inc.
Wells Ranch AF T5N-R6W-S8 L01
123/99A9
NWNW SEC 8 T5N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
Truck Load Out
009
Truck loadout of condensate by submerged
fill
Enclosed Flare
LP Burner
011
Two Low Pressure (LP) Separators
Enclosed Flare
VRT Burner
012
One Vapor Recovery Tower (VRT)
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/ pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
COLORADO
Air Pollution Control Division
Page 1 of 10
is permit
rtification.
y
gula
b
online at
er 3, Part B
acif/cdphe/air rmit-self-
3. his permit ll expif the er or o rator of source which this perm) as issued:
,d. 'com m encWieons true t 7: iGation is source w thi t nonths
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. AIRS ID 011: Within one hundred and eighty days (180) after issuance of this permit or upon
removal of the VRU, whichever is later, the operator shall install a flow meter to monitor and
record total volumetric flow rate of gas vented from all LP separators covered by this permit.
Until the flow meter is installed, the operator shall monitor and record condensate/crude
produced through the separator and estimate the gas flow rate based on standard cubic feet
(scf) per barrel (bbl) of 0.00009 scf/bbl estimated in the permit application.
5. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
6. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
Truck Load Out
009
---
---
0.7
---
Point
LP Burner
011
---
---
11.1
2.8
Point
VRT Burner
012
---
---
3.8
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
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.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. Regulation Number 3, Part B, Section III.E.)
Facility
AIRS
Pollutants
Equipment ID
Point
Control Device
Controlled
COLORADO
Air Pollution Control Division
Page 2 of 10
Truck Loa
Out
VRT Burner
012
Flare
Enclo
V
nd HAP
HAP
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Truck Load Out
009
Condensate Loaded
109,500 bbl
LP Burner
011
Natural Gas Venting
10.3 MMSCF
VRT Burner
012
Liquids Throughput
108,442 bbl
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
10. AIRS ID 011: Upon installation of the flow meter, the owner or operator shall continuously monitor
and record total 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.
11. AIRS ID 012: The owner or operator must use monthly condensate/crude oil throughput records,
calculation methods detailed in the OEtM Plan, and the emission factors established in the Notes
to Permit Holder to demonstrate compliance with the process and emissions limits specified in
this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. AIRS ID 011 and 012: No owner or operator of a smokeless flare or other flare for the combustion
of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is
in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty
consecutive minutes. (Regulation Number 1, Section II.A.5.)
14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
15. AIRS ID 009: 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)
COLORADO
Air Pollution Control Division
Page 3 of 10
16.
couplings an
d or vapoi uri
or shall foll lo:' g proced ' h . minimize th'� eakage of
g, but nottilf.= Referen eg tion 3, Paris l , III.D.2):
es shat e mainta 9 d to pr nt dripping, leakf j, or other
d unloads:
b. All compartment hatches at the facility (including thief hatches) shall be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect onsite loading equipment during loading operations
to monitor compliance with above conditions. The inspections shall occur at least
monthly. Each inspection shall be documented in a log available to the Division on
request.
17. AIRS ID 009: For tanks that are unloaded, the owner or operator shall:
a. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers shall be weighted and properly seated.
b. 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 routed to the control device under normal operating conditions.
c. Document annual inspections of thief hatch seals and PRD with an indication of status, a
description of any problems found, and their resolution.
18. AIRS ID 009: The owner or operator of a loadout that is controlled shall:
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that natural gasoline 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.
e. 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 routed to the control device under normal operating conditions.
f. Document annual inspections of PRD with an indication of status, a description of any
problems found, and their resolution.
OPERATING & MAINTENANCE REQUIREMENTS
19. AIRS ID 011 and 012: 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
20. AIRS ID 011: The owner/operator shall complete an initial site specific extended gas analysis
("Analysis") within one hundred and eighty days (180) after commencement of operation or
issuance of this permit, whichever comes later, of the natural gas vented from this emissions
unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-
trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall
COLORADO
Air Pollution Control Division
Page 4 of 10
used to cal'
is of lb/
mitted to '
tors ...
to sip . - -mission fa ors fe3fi the pollut renced in t ermit (in
F gas' n _„ sing Divisio method esu of the Ana s shall be
Divi as of the f-certifi on and st demonstrate t ^'' emissions
shed th ;:* •h the l sis less than ual too a emissions facto ubmitted
w1itie permit app ti i•n an '"S l here fief s to Permit o or this
emissions point. If any site specific emissions factor developed through this Analysis is greater
than the emissions factors submitted with the permit application and established in the "Notes
to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as
agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies).
21. AIRS ID 011 and 012: Within one hundred and eighty days (180) after commencement of operation
or issuance of this permit, whichever comes later, the owner or operator shall demonstrate
compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix
A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section
II.A.5)
ADDITIONAL REQUIREMENTS
22. All previous versions of this permit are cancelled upon issuance of this permit.
23. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
24. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
COLORADO
Air Pollution Control Division
Page 5 of 10
25.
s permit a'
e uest. The F
mber 3, Paf
devised
, Section II.
nd the Mired
s must be
.sued to a n
on a re
and mad `° i "ble for ins ion upon
the APC r s pr ided in AQC egulation
sfer of ` ership and the submittal of a
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.
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.
By:
Carissa Money
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
March 29, 2013
Issued to Noble Energy, Inc. for condensate loadout
Issuance 2
This Issuance
Issued to Noble Energy, Inc.
COLORADO
Air Pollution Control Division
Page 6 of 10
COLORADO
Air Pollution Control Division
D rea throughpi,
0 bbl/yr
ontrol d e.
dout (AIRS I +09)
0 bbl/yr. red
d new,mparator (AIRS"'` nd
VRT (AIRS ID 012).
Page 7 of 10
Notes to= ermit Hold t the;
permit isstinc
1) The rmit holde requi " to ees for th 3pro`c"€s's g time for" is pe it. An invojce for these
fee ll be issu fter tIt- ermi assued. ie permitder sh ^, ay the invoice whin 30 days
tMf e invoice ailure trx 4painvoice ,Lres zrevocation ts 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/agcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Truck Load
Out
009
n -Hexane
110543
295
15
LP Burner
011
Benzene
71432
1,307
65
Toluene
108883
1,003
50
Ethylbenzene
100414
53
3
Xylenes
1330207
261
13
n -Hexane
110543
7,490
375
2,2,4-
Trimethylpentane
540841
585
29
VRT Burner
012
Benzene
71432
470
24
Toluene
108883
345
17
Ethylbenzene
100414
18
1
Xylenes
1330207
86
4
n -Hexane
110543
2,653
133
2,2,4-
Trimethylpentane
540841
200
10
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
COLORADO
Air Pollution Control Division
Page 8 of 10
5) The `;: ission leve
Poi 09:
the folio
sion factor
Pol`Cutant
ontr ed
Emission actors
lb/bbl
trope
mission ac ors
lb/bbl
Source
V0C
0.2583
0.0129
AP -42
n -Hexane
110543
0.0027
0.0001
Source
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) = 6.9 psia
M (vapor molecular weight) = 62 lb/lb-mol
T (temperature of liquid loaded) = 520 °R
The controlled emissions factors for this point are based on the flare control efficiency of 95%. The uncontrolled
non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction
of each NCRP from Table 3-2 EPA -453/R -94-002a.
Point 011:
CAS #
Pollutant
Weight
Percent
of Gas
(%)
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
N0x
---
122.96
122.96
AP -42, Table 13.5-1
CO
---
547.34
547.34
AP -42, Table 13.5-1
V0C
52.0
43,277
2,163.9
Source (HYSYS)
71432
Benzene
0.15
127.09
6.3544
Source (HYSYS)
108883
Toluene
0.12
97.528
4.8764
Source (HYSYS)
100414
Ethylbenzene
0.01
5.1535
0.2577
Source (HYSYS)
1330207
Xylene
0.02
25.379
1.2689
Source (HYSYS)
110543
n -Hexane
0.87
728.30
36.415
Source (HYSYS)
540841
2'2'4-0.07
Trimethylpentane
56.883
2.8442
Source (HYSYS)
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The
uncontrolled VOC and HAP emissions were calculated based on a HYSYS model to estimate the VOC
and HAP content of the stream and stream flow.
Point 012:
CAS #
Pollutant
Weight
Percent
of Gas
(%)
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
(lb/bbl)
Source
N0x
---
0.003
0.003
AP -42, Table 13.5-1
CO
---
0.013
0.013
AP -42, Table 13.5-1
V0C
70.7
1.4126
0.0706
Source (HYSYS)
71432
Benzene
0.22
0.0043
0.0002
Source (HYSYS)
108883
Toluene
0.16
0.0032
0.0002
Source (HYSYS)
100414
Ethylbenzene
0.01
0.0002
0.00001
Source (HYSYS)
COLORADO
Air Pollution Control Division
Page 9 of 10
#Pgllutan
= ys,a1lbill*
C
O11 41 Kgi
aF,"
O
Uncol,ltrol,
A/bbIk
Contr)d,
:h
1330207
Xylene
0.04
0.0008
0.00004
Source (HYSYS)
110543
n -Hexane
1.22
0.0245
0.0012
Source (HYSYS)
540841
2'2'4
Trimethylpentane
0.09
0.0018
0.0001
Source (HYSYS)
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The
uncontrolled VOC and HAP emissions were calculated based on a HYSYS model to estimate the VOC
and HAP content of the stream and stream flow.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
V0C
NANSR
Synthetic Minor Source of:
V0C
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 10 of 10
d1�
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. In addition, the General APEN (Form APCD-200) is available if
the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on
the Air Pollution Control Division (APCD) website at: www.colorado,gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 12WE2947
AIRS ID Number: 123 /99A9 / 009
[Leave blank unless APCD has already assigned a.permit a and AIRS ID]
Company equipment Identification: Truck Load Out
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name':
Site Name:
Noble Energy, Inc.
Wells Ranch AF T5N-R6W-S8 L01
Site Location: NWNW SEC08 T05N R62W
Mailing (Include Address: 1625 Broadway, Suite 2200
Zip Code) y+
Denver, CO 80202
E -Mail Address': a.satterfield@nblenergy.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Allison Satterfield
Phone Number: 303-228-4137
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on
all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
OLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 1 I
Permit Number: 12WE2947
AIRS ID Number: 123 /99A9 /009
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
❑ NEW permit OR newly -reported emission source
❑ Request coverage under construction permit
❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted
along with the APEN Filing fee.
-OR -
❑/ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name
• Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
11 Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Noes: Emissions updated to reflect the presence of a control device.
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Condensate truck loadout
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
061 27 /2012
/
/
Will this equipment be operated in any NAAQS nonattainment area?
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Does this source load gasoline into transport vehicles?
Is this source located at an oil and gas exploration and production site?
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Does this source splash fill less than 6750 BBL of condensate per year?
Does this source submerge fill less than 16308 BBL of condensate per year?
Form APCD_20.3 -Hydrocarbon Liquid Loading APElii Rev 02'2017
• Yes ❑ No
❑ Yes E] No
❑ Yes I No
❑ Yes ❑ No
❑ Yes El No
❑ Yes O No
❑ Yes it No
COtORaDC
Permit Number: 12WE2947
AIRS ID Number: 123/99A9/009
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 4 - Process Equipment information
Product Loaded:
E Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
109,500
Bbl/yr
Actual Volume
Loaded:
Bbl/yr
4 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth
This product is loaded from tanks at this facility into:
(eg, "rail tank cars" or "tank trucks")
tank trucks
if site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
0.6
Average temperature
of bulk liquid loading:
60
°F
True Vapor
Pressure
6 9
Psia @ 60 °F
Molecular weight of
displaced vapors
62
Lb/lb mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume
Loaded5:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Bbl/yr
Actual Volume
Loaded:
Bbl/yr
Product Density:
Lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume
ft3/truckload
COLOR ADO
Form APCD-20_ -Hydrocarbon Liquid Load n APEN - Rev 02/2017 3
Permit Number: 12W E2947
AIRS ID Number: 123 /99A9/ 009
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 5 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.42 / -104.3554
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):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Section 6 - Control Device Information
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency
/0
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type: Enclosed Burner
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95 %
95
Waste Gas Heat Content
Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating
Btu/scf
MMBtu/hr
Cl Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0
cOLOR46O
Form APCD-203 -Hydrocarbon Liquid Loo dine APEN - Rev 0212017
Permit Number: 12WE2947 AIRS ID Number: 123/99A9/009
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? (] Yes ❑ No
If yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
Sox
NOX
CO
VOC
Enclosed Burner
95
HAPs
Enclosed Burner
95
Other:
❑ Using State Emission Factors (Required for GP07) VOC
❑ Condensate
❑ Crude
0.236 Lbs/BBL
0.104 Lbs/BBL
Benzene
0.00041 Lbs/BBL
0.00018 Lbs/BBL
n -Hexane
0.0036 Lbs/BBL
0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? N/A
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
"' .
Actual Annual Emissions _
- --
Requested Annual Permit `.
Emission Limit(s)5 °
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NOX
0.0037
Ib/Ib-VOC
CDPHE
0.02
0.02
0.02
0.02
VOC
0.2583
lb/bbl
AP -42
14.14
0.71
14.14
0.71
CO
0.0094
Ib/Ib-VOC
CDPHE
0.02
0.02
0.02
0.02
Benzene
0.0005
lb/bbl
AP -42
0.03
0.00
0.03
0.00
Toluene
0.0003
lb/bbl
AP -42
0.02
0.00
0.02
0.00
Ethylbenzene
0.0000
lb/bbl
AP -42
0.00
0.00
0.00
0.00
Xytenes
0.0001
lb/bbl
AP -42
0.00
0.00
0.00
0.00
n -Hexane
0.0027
lb/bbl
AP -42
0.15
0.01
0.15
0.01
2,2,4-0.0002
Trimethytpentane ylp
lb/bbl
AP -42
0.01
0.00
0.01
0.00
Other:
a Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission 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 - Rev 02/2017
Permit Number: 12WE2947
AIRS ID Number: 123199A9 / 009
[Leave blank unless APCD has already assigned a permit if 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 registra ion for coverage under General Permit GP07, I further certify that this source is and will
be operated in full compliance{ith each condition of the applicable General Permit.
Signature oegally Authorized Person (not a vendor or consultant) Date
Allison Satterfield
3/19/2018
Environmental Scientist
Name (print)
Title
Check the appropriate box to request a copy of the:
D Draft permit prior to issuance
Qr 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 $152.90 and the General
Permit registration fee of $250 as applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
43OO Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-208 -Hydrocarbon Liquid Loading /.PEH! - Rev 02/2017
VCOLORADO
coy
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
I ZIAI E 2947
AIRS ID Number: 1 23 / 99A9/ 01/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: LP Burner
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: Wells Ranch AF T5N-R6W-S8 L01
Site Location: NWNW SEC08 T05N R62W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver CO 80202
E -Mail Address' s.koziolkowsky@nblenergy.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Sarah Koziolkowsky
Phone Number: 303-228-4196
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 370171
1
COLORADO
Permit Number:
AIRS ID Number: 123 i 99A9 i T
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
OR-
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
LP Separator gas stream
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
04 / 01 / 2018
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year
Yes
❑ Yes
❑ No
I] No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I AaeL-
COLORADO
Eru.o m.n.
Permit Number:
AIRS ID Number: 123 / 99A9
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
O 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 Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:
1756
BTU/SCF
Requested:
10.283
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
32.01
VOC (Weight %)
51.94%
Benzene (mole %)
0.06163
Benzene (Weight %)
0.15%
Toluene (mole %)
0.04008
Toluene (Weight %)
0.12%
Ethylbenzene (mole %)
0.00183
Ethylbenzene (Weight %)
0.01%
Xylene (mole %)
0.00905
Xylene (Weight %)
0.02%
n -Hexane (mole %)
0.32006
n -Hexane (Weight %)
0.87%
2,2,4-Trimethylpentane
(mole %)
0.01885
2'2'4-Trimethylpentane
(Weight %)
0.070/0
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Er n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
3I A
COLORADO
Permit Number:
AIRS ID Number:
123 /99A9/
❑ Upward
❑ Horizontal
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.42 / -104.3554
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)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane
VOC Burner
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
MMBtu/hr
Make/Model:
95%
0/0
Waste Gas Heat Content
Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating
Btu/scf
MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
4j
Permit Number:
AIRS ID Number: 123 / 99A9i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO„
VOC
VOC Burner
95%
CO
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
Sax
NO,,
0.068
Ib/Ib-VOC
CDPHE
0.63
0.63
VOC
0.021639224
Ib/mscf
HYSYS
222.52
11.13
CO
0.310
Ib/Ib-VOC
CDPHE
2.81
2.81
Benzene
0.127101318
Ib/mscf
HYSYS
0.65
0.03
Toluene
0.097505284
Ib/mscf
HYSYS
0.50
0.03
Ethylbenzene
0.005131512
Ib/mscf
HYSYS
0.03
0.0
Xylenes
0.025361425
Ib/mscf
HYSYS
0.13
0.01
n -Hexane
0.728247281
Ib/mscf
HYSYS
3.74
0.19
2,2,4-
Trimethylpentane
0.003432617
Ib/mscf
HYSYS
0.29
0.01
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
5 I A
w�,-
Permit Number:
AIRS ID Number: 123 / 99A9i
[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. c
/
t G�t2017
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sarah Koziolkowsky
Environmental Scientist
Name (please 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)
Send this form along with $152.90 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
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
6 I to J Hem. E Er. reenrs,!n!
oP
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
12Vi E 291-1
AIRS ID Number: 1 23 / 99A91 o(2.
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: VRT Burner
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: Wells Ranch AF T5N-R6W-S8 L01
Site Location: NWNW SEC08 T05N R62W
Mailing Address:
(Include Zip Code) 1625 Broadway, Suite 2200
Denver CO 80202
E -Mail Address' s.koziolkowsky@nblenergy.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Sarah Koziolkowsky
Phone Number: 303-228-4196
'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will
appear on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-2O5 - Natural Gas Venting APEN - Rev 03/2017
370172
1
COLORADO
Permit Number:
AIRS ID Number: 123 / 99A9 i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
❑r NEW permit OR newly -reported emission source
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
OR -
• APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
II Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
VRT gas stream
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/
/
04 / 01 / 2018
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: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year
Yes ❑ No
❑ Yes O No
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 I
COLORADO
4 c,L^. � 2r.n onmen.
Permit Number:
AIRS ID Number: 123 /99A91-.
[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 Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:
BTU/SCF
Requested:
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
a (19,50'
Bbl/yr
Actual:
Bbl/yr
I ors, 1L. 1 y/,c1l s
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
54.89
VOC (Weight %)
70.73%
Benzene (mole %)
0.1 1-
Benzene (Weight %)
0.22%
Toluene (mole %)
0.07
Toluene (Weight %)
0.16%
Ethylbenzene (mole %)
0.00
Ethylbenzene (Weight %)
0.01%
Xylene (mole %)
0.01
Xylene (Weight %)
0.03%
n -Hexane (mole %)
0.57
n -Hexane (Weight %)
1.22%
2,2,4-Trimethylpentane 2,2,4-Trimethylpentane o
/o
(mole %) 0.03 (Weight %) 0.09
Additional Required Information:
❑� Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
COLORADO
3 I A
Permit Number:
AIRS ID Number: 123 i 99A9 i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.42 / -104.3554
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):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Section 6 - Control Device Information
❑✓ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane
VOC Burner
MMBtu/hr
Make/Model:
Requested Control Efficiency: 95% %
Manufacturer Guaranteed Control Efficiency %
Minimum Temperature:
Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating
Waste Gas Heat Content
Btu/scf
MMBtu/hr
El Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017
4 I A,
COLORADO
Permit Number:
AIRS ID Number: 1 23 / 99A9/ . _
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO.
VOC
VOC Burner
95%
CO
HAPs
VOC Burner
95%
Other:
From what year is the following reported actual annual emissions data?
N/A
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO.
0.068
lb/MMbtu
AP42
0.17
0.17
VOC
1.4020
lb/bbl
HYSYS
76.76
3.84
CO
0.31
Ib/MMbtu
AP42
0.72
0.72
Benzene
0.0043
lb/bbl
HYSYS
0.23
0.01
Toluene
0.0032
lb/bbl
HYSYS
0.17
0.01
Ethylbenzene
0.0002
lb/bbl
HYSYS
0.01
0
Xylenes
0.0008
lb/bbl
HYSYS
0.04
0
n -Hexane
0.0242
lb/bbl
HYSYS
1.33
0.07
2,2,4-0.0018
Trimethyipentane ylp
lb/bbl
HYSYS
0.10
0
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 I A
COLORADO
Permit Number:
AIRS ID Number: 123 / 99A9i
and correct.
[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
1 //
/,, :< < 10/5/2017
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sarah Koziolkowsky Environmental Scientist
Name (please print) Title
Check the appropriate box to request a copy of the:
J 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)
Send this form along with $152.90 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
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
6I ACOLORADO
.,;.
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