HomeMy WebLinkAbout20172874COLORADO
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
1150O St
PO Box 758
Greeley, CO 80632
August 15, 2017
Dear Sir or Madam:
On August 17, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Butterball T3N-R64W-S19 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
nU l^bJ i C 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
V i QC() CC pLC(imi TP), Ht-C1T),
`t-roa$rl'7 Pc CER/c(-I/snn(cis)
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2017-2874
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Butterball T3N-R64W-S19 L01 - Weld County
Notice Period Begins: August 17, 2017
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: Butterball T3N-R64W-S19 L01
Exploration and Production Facility
NWNE Sec 19 T3N R64W
Weld County
The proposed project or activity is as follows: Existing EEtP facility. Emissions from the vapor recovery
tower (VRT), which are currently compressed by the ERS COMP1 engine (Point 123-9770-004), will be routed
to a VOC burner and the engine will be removed.
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 17WE0714 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:
Betsy Gillard
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
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package 4:
Received Date:
Review Start Date:
Section 01- Facility Information
Betsy Gillard
360374
3/30/2017
8/2/2017
Company Name: Noble Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: 9765
Facility Name: Butterball T3N-R64W-519 L01
Physical Address/Location: NWNE quadrant of Section 19, Township 3N, Range 64W, in Weld County, Colorado
Type of Facility: Exploration & Production Well Pad
What industry segment?Oil & Natural Gas Production & Procing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? ❑Carbon Monoxide (CO)
Weld
Quadrant
Section
Township
Range
MANE'
Section 02 - Emissions Units In Permit Application
❑Particulate Matter (PM)
QOzone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit 4
Issuance 4
Self Cert
Required?
Action
Engineering
Remarks
006
Vapor Recovery Tower (VRT)
VRT
Yes
17WE0714
1
Yes ..'.
Permit Inttial
Issuance
Section 03 - Description of Project
Existing E&P facility: Emissions from the vapor recovery tower (VRT), which are currently compressed by the ERS COMP1 engine (Point 123-9770-004), will be
routed to a VOC burner and the engine will be removed.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
`Ya
S02 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ El El El El
El ❑ El El El El El El
❑ o
Produced Natural Gas Venting/Flaring Preliminary Analysis
Equipment Description
This source vents natural gas from:
a VRT
Emissions from this source are:
routed to an enclosed flare
Natural gas venting from a VRT. Emissions from this source are routed to an enclosed flare.
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW`Xx/C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas' MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Colorado Department of Public Health and Environment
Air Pollution Control Division
Maximum Vent Rate I 154 scf/hr
tequestedThroughput (Q) 1.3 MMscf/yr
153.9 scf/hr I 0.000 MMscf/d I 0.11 MMscf/mol
% Vented I 100%
MW 39.520 Ib/Ib-mol
Component
mole %
MW
Ibx/Ibmol
mass fraction
E
Iblhr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.94
44.01
0.854
0.022
CO2
0.3
3037
1.52
N2
1.83
28.013
0.513
0.013
N2
0.2
1823
0.91
methane
20.71
16.041
3.322
0.084
methane
1.3
11816
5.91
ethane
27.76
30.063
8.345
0.211
ethane
3.4
29683
14.84
propane
25.1
44.092
11.0671
0.280
propane
4.5
39363
19.68
isobutane
3.58
58.118
2.0806
0.053
isobutane
0.8
7400
3.70
n -butane
9.69
58.118
5.6316
0.143
n -butane
2.3
20030
10.02
isopentane
1.83
72.114
1.3197
0.033
isopentane
0.5
4694
2.35
n -pentane
2.18
72.114
1.5721
0.040
n -pentane
0.6
5591
2.80
cyclopentane
2.59
70.13
1.8164
0.046
cyclopentane
0.7
6460
3.23
n -Hexane
1.3600
86.18
1.1720
0.030
n -Hexane
0.5
4169
2.08
cyclohexane
0.0000
84.16
0.0000
0.000
cyclohexane
0.0
0
0.00
Other hexanes
0
86.18
0.0000
0.000
Other hexanes
0.0
0
0.00
heptanes
0.79
100.21
0.7917
0.020
heptanes
0.3
2816
.1.41
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexant
0.0
0
0.00
224-TMP
0.02
114.23
0.0228
0.001
224-TMP
0.0
81
0.04
Benzene
0.25
78.12
0.1953
0.005
Benzene
0.1
695
0.35
Toluene
0.13
92.15
0.1198
0.003
Toluene
0.0
426
0.21
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0.05
106.17
0.0531
0.001
Xylenes
0.0
189
0.09
C8+ Heavies
0.18
357.648
0.6438
0.016
C8+ Heavies
0.3
2290
1.14
100 VOC mass fraction: 0.6702 Total VOC Emissions (Uncontrolled)
annual lim't assuming 95% control
Total unc. VOC Emissions (operator calcs)
Controlled VOC emissions (operator calcs)
47.1
2.4
47.1
2.4
Notes
Mole %, MW, and mass fractions from HYSYS analysis based off BUTTERBALL D18-75HN, D19-75HN, H24 -69H high pressure liquid sample collected
2/10/2017
Emissions are based on 8760 hours of operation per year.
I calculated the average MW of C8+ based on the average MW on the analysis for the gas.
Due to minor rounding issues, these values are not exactly the same as operator calculations. I have included operator calculations to show that they
are close enough and therefore considered acceptable. The permit reflects operator calculations.
The process parameter for this point is liquid throughput, because the division allows this for permits that are VRT only.
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
Flaring Information
Equipment Description
Flare to combust VRT cas.
Serial Number
Gas Heating Value
Throughput
2179
2937.292
Btu/scf
MMBtu/yr
Combustion emission factor source: AP -42: Chapter 13.5
0.068
lb NOX/MMBtu
tpy NOX
0.31
0.46
lb CO/MMBtu
tpy CO
0.10
Emissions Summary
Operator calcs
0.1
tpy NOX
0.1
Uncontrolled/PTE
0.5
tpy CO
0.46
47.1
tpy VOC
47.14
Controlled
2.4
tpy VOC
2.4
Uncontrolled
Total (lb/yr)
Scenario A
Reportable?
Controlled
Total (Ib/yr)
Operator Calcs (lb/yr)
Benzene
695
Yes
35
694
35
Toluene
426
Yes
21
427
21
Ethylbenzene
0
No
0
11
1
Xylenes
189
No
9
179
9
n -hexane
4169
Yes
208
4170
209
224-TMP
81
No
4
92
5
Emission Factors for Permit
VRT emissions will be monitored as a function of condensate throughput
Annual throughput:
100010 bbl
Uncontrolled
Engineer calcs
Operator
calcs
Controlled
Operator
Enctineercalcs calcs
% difference
- 0.09%
0.22%
#DIV/0!
- 5.20%
0.03%
13.22%
NOX
0.002
0.0020
lb/bbl
NOX
0.005
0.0020
lb/bbl
CO
0.009
0.0092
lb/bbl
CO
0.024
0.0092
lb/bbl
VOC
0.942
0.943
lb/bbl
VOC
0.047
0.0471
lb/bbl
Benzene
0.007
0.007
lb/bbl
Benzene
0.000
0.0003
lb/bbl
Toluene
0.004
0.004
lb/bbl
Toluene
0.000
0.0002
lb/bbl
Ethylbenzene
0.000
0.000
lb/bbl
Ethylbenzene
0.000
0.0000
lb/bbl
Xylenes
0.002
0.002
lb/bbl
Xylenes
0.000
0.0001
lb/bbl
n -Hexane
0.042
0.042
lb/bbl
n -Hexane
0.002
0.0021
lb/bbl
224-TMP
0.001
0.001
lb/bbl
224-TMP
0.000
0.0000
lb/bbl
Regulatory Applicability
AQCC Regulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'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.'
AQCC Regulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants
from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used
predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven
(7) or more volumes of odor free air."
AQCC Regulation 3
Part B:
A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year
in a nonattainment area for ozone.
This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT
for this source has been determined to be the use of a flare to control emissions.
Public comment?
AQCC Regulation 7
Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
no
This separator is not subject to Reg 7 Section XVII.G
Facility Status
This facility is a synthetic minor source of VOC for Title V applicability.
This facility is a synthetic minor source of VOC for NSR applicability.
Public Comment Not Required
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
CONSTRUCTION PERMIT
17WE0714
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Noble Energy, Inc.
Butterball T3N-R64W-S19 L01
123/9765
NWNE SEC 19 T3N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT
006
Vapor Recovery Tower controlled by VOC
burner
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
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
Page 1 of 7
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO„
VOC
CO
VRT
006
--
--
2.4
--
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Compliance with the annual limits for criteria air pollutants shall be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated based
on the previous twelve months' data. The permit holder shall calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT
006
Emissions from the VRT are routed to an
enclosed flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT
006
Condensate Throughput
100,010 bbl
COLORADO
Air Pollution Control Division
Page 2 of 7
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. 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)
10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
11. 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.
12. 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 Et MAINTENANCE REQUIREMENTS
13. 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 OEtM 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
14. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
15. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
COLORADO
Air Pollution Control Division
pt i E rronrrt�^.t
Page 3 of 7
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• 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.
17. 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
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
19. 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.
20. 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.
,COLORADO
Air Pollution Control Division
Page 4 of 7
21. 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.
22. 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.
23. 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.
24. 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:
Betsy Gillard
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
:COLORADO
Air Pollution Control Division
tr
Page 5 of 7
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 anyspecific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
Facility
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(tPY)
Controlled
Emissions
(tPY)
VRT
006
Benzene
71432
0.347
0.017
Toluene
108883
0.214
0.011
n -Hexane
110543
2.085
0.104
Note: All non-criter'a reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons
per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 006:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/bbl)
Controlled
Emission Factors
(lb/bbl)
Source
V0C
0.9427
0.0471
HYSYS simulation
based on site -specific
pressurized liquid
sample
71432
Benzene
0.0069
3.47E-04
108883
Toluene
0.0043
2.15E-04
110543
n -Hexane
0.0417
2.09E-03
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
The emission factors listed above are based on modeled separator temperature of 70 °F and separator
pressure of 4 psig.
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.
COLORADO
Air Pollution Control Division
Page 6 of 7
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
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 7 of 7
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Emission Source AIRS ID:
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Permit Number:
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
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Section 02 — Requested Action (check applicable request boxes)
Section 01— Administrative Information
Request for NEW permit or newly reported emission source
Change company name
0
0
Transfer of ownership
❑ ❑
Change fuel or equipment
Change permit limit
0
Request to limit HAPs with a Federally enforceable limit on PTE
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Section 03 — General Information
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FORM APCD-211
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Ventin
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Emission Source AIRS ID:
Permit Number:
Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
Section 05 — Stack Information (Combustion stacks must be listed here)
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Section 07 — Control Device Information
Section 08 — Emissions Inventory Information & Emission Control Information
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Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Requested Permitted Emissions
Uncontrolled Controlled
(Tons/Year) (Tons/Year)
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Control Device Description
Secondary
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VOC Burner
VOC Burner
VOC Burner
VOC Burner
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Gabriela Vega
Name of Legally Authorized Person (Please print)
VRT-Natural-Gas-Venting-APEN (2)
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FORM APCD-211
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