HomeMy WebLinkAbout20174143COLORADO
Department of Public
Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
December 5, 2017
Dear Sir or Madam:
RECEIVED
DEC 082017
WELD COUNTY
COMMISSIONERS
On December 7, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - 415860797 Frico/Farmers 2-14HZ. 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 a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
PVbliG �.vie,cu cc:PLCMmITP,), HLCST.,
/�31i7 pc.Je R SmICtc/C'H)
/
2017-4143
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - 415860797 Frico/Farmers 2-14HZ - Weld County
Notice Period Begins: December 7, 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: 415860797 Frico/Farmers 2-14HZ
Oil and gas exploration and production facility
NWNE Sec 14 T3N R65W
Weld County
The proposed project or activity is as follows: Source proposes to vent an existing low-pressure separator to
an enclosed 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 17WE0967 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
Permit number:
Date issued:
Issued to:
ADO
n Contro
c Hea
CONSTRUCTION PERMIT
17WE0967
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Noble Energy, Inc.
415860797 Frico/Farmers 2-14HZ
123/7234
NWNE SEC 14 T3N R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LP Separator
005
One Low Pressure (LP) Separator
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
Dapartrnert of Public_ I fealth: 8 .O oonrrnnt.
Page 1 of 7
3. expi er or oper or • °, e source this perm] as issued:
enc;.,, o tion/modif •peration i ource withi 8 months
e da' .•f is ace of tr constr on per .'' or t e date on ich such
k commen s set h in the ermi' • •lication
r activ was s uled p
a e with thi - ; (ii) : r -s cons r •'' • -nod of eigh - the 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.)
s permit s
does not c
er either,
struu
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
LP Separator
005
---
---
8.2
1.8
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.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
LP Separator
005
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
' LP Separator
005
Natural Gas Venting
6.6 MMSCF
COLORADO
Air Pollution Control Division
Department of Rabb,. t fealtn & Eic ::oninenf
Page 2 of 7
ghput limi determm , •lling twelv 2) month
h a new twtotal d based on previous
���� � .�Fis t u a�=
t holderto thro put each month d keep a
cal fi . office wi ite res sibility, for Divis review.
9. The owner or operator shall continuously monitor and record the volumetric flow rate of gas
vented from the separator(s) using the flow meter. The owner or operator shall use monthly
throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
11. 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.)
12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
OPERATING ft MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEM 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/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 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 be used to calculate site -
specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas
vented) using Division approved methods. Results of the Analysis shall be submitted to the
Division as part of the self -certification and must demonstrate the emissions factors established
through the Analysis are less than or equal to, the emissions factors submitted with the permit
application and established herein in the "Notes to Permit Holder" for this emissions point. If
any site specific emissions factor developed through this Analysis is greater than the emissions
factors submitted with the permit application and established in the "Notes to Permit Holder"
the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the
Division, a request for permit modification to address this/these inaccuracy(ies).
15. 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. The observation period shall be 1 hour in duration. (Regulation Number 1, Section
II.A.5)
ADDITIONAL REQUIREMENTS
16. 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:
COLORADO
Air Pollution Control Division
Department of P ib@c Health b t_nvimnnent
Page 3 of 7
than 10
bove
ge in actual emi °:ns of five
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.
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 fortransfer 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
Department of Pi81ic Health & EPaaPannrrent
Page 4 of 7
21.
less specifi
e been de
tion 25-7-
e, the gen
D to be
contained i
e with the
is permit
visions of
22. ery cf t a ma and is not 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:
Carissa Money
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc. for one low pressure
separator routed to enclosed flare.
COLORADO
Air Pollution Control Division
Department of Pubic Health: 6 E iivirorm:Rtt
Page 5 of 7
Notes t. -rmit Hold
1) The rmit holde requi to •'" eel for t - time fo is p- it. An lnv• for these
fee;. ll be issu '•fter t lder sh. •ay the invoice n 30 days
e invE' ure invoi evocation ermit.
(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 clay, 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
(Ib/yr)
Controlled
Emissions
(lb/yr)
LP Separator
005
Benzene
71432
2,095
105
Toluene
108883
1,496
75
Ethylbenzene
100414
25
1
Xylenes
1330207
718
36
n -Hexane
110543
11,790
589
2,2,4-
Trimethylpentane
540841
419
21
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.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Weight
Percent of
Gas (%)
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
---
122.400
122.400
AP -42, Table 13.5-1
CO
---
558.000
558.000
AP -42, Table 13.5-1
VOC
54.9
49,796
2,489.8
Source (HYSYS)
71432
Benzene
0.35
317.40
15.870
Source (HYSYS)
108883
Toluene
0.25
226.72
11.336
Source (HYSYS)
COLORADO
Air Pollution Control Division
Department of P.xclfc Heath & Environment
Page 6 of 7
Source (HYSYS)
lutan
eight
ent of
96
100414
Ethylbenzene
<0,01
3.7168
0.1858
1330207
Xylene
0.12
108.82
5.4412
Source (HYSYS)
110543
n -Hexane
1.97
1,786.5
89.326
Source (HYSYS)
540841
2,2,4-
Trimethylpentane
0.07
63.480
3.1740
Source (HYSYS)
Note: 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. The controlled emissions factors for this point
are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This 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
Department of Pail Health & Environment
Page 7 of 7
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
C ri'ssa M
368496
8/30/2O,
11/2/2017
Noble Energy: Inc.
12:
7234
415860797 Frico/Farmers "2-14Hz'.'
NWNE quadrant of Section 14, Township 3N, Range 65W, in Weld County, Colorado
'Exploration &Production Well Pad
Qil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) O Ozone (NOx & VOC)
Weld
Quadrant
Section
Township
Range
NWNE
14
3N,
65
Section 02 - Emissions Units In Permit Application
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
= 005
Separator Venting
LP separator
Yes
17W50967
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Noble €s submitting this application for an existing low pressure (LP) separator. Emissions from the LP separator 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 emissions to flare instead, of recycling.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
`Yes
Requesting Synthetic Minor Per
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? p
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?
No
Yes
Colorado Air Permitting Project
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) O O O O O O
Title V Operating Permits (OP) O O O O O O O O
Non -Attainment New Source Review (NANSR) O O
Is this stationary source a major source?
If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) O O O O O ❑
Title V Operating Permits (OP) O O O O O O O
Non -Attainment New Source Review (NANSR) O O
Separator Venting Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
123:
County
7234.
Plant
005
Point
Section 02- Equipment Description Details
06elaw pressure (LP)separator;,::
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Throughput=
MMscf per year
MMscf-per year
6.6 MMscf per year
Process Control (Recycling)
Equipped with a VRU
Is VRU process equipment: r11J� t`Jf
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value: rr .-1800: Btu/scf
Volume of waste gas emitted per BBL of FP�J,J�/` j
liquids throughput: O�✓G✓x�,i, scf/bbl
Section 04- Emissions Factors & Methodologies
Description
Zhis:sautceisatawpressaresepacatarwllezethe tigpEi undVug
P (sampled: 213:5/2027)'aod madded, using HMS VofvEost6, T
gasstream."LPGPs"..
Input Parameters
Modeled Liquid Throughput
(If applicable)
,, Barrels (bbl) per day
(s Ayaressuriaedfi said samefeswas takeo•fronytt a lbV :pre
ocular weight (MW)k and vent rate oftliewastegasstream are
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*)(x/C
Ex = emissions of pollutant x
O.= 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
Ib/Ib-mol
mass fraction (%)
lb/hr
Helium
CO2
- ,:"'......_-: `.4.24'
2.8994
N2
"- ::'::. 4.79
3.2779
methane
15.61
10.6726
ethane
1:59.46
13,9883
propane
:,.i-z22.O0
15.0388
isobutane
- -.. • 5,52
3.7734
n -butane---
`'' 1102
7.5345
Isopentane
4.34.
2.9676
n -pentane
. _. --: 3.95
2.7021
cyclopentane
C-.3.72
2.5421
n -Hexane:
1.97
1.3467
cyclohexane
Other hexanes
heptanes
- ";-.' 1.35
0.9220
methylcyclohexane
224-TMP
0.07
0.0506
Benzene
` 0.35
0.2371
Toluene
--. 0.25
0.1720
Ethylbenzene
0.0028
Xylenes
O:12
0.0188
C8+ Heavies
0.1734
Total
VOC Wt %
100.01
68.3201
54.91
68.37
37.5318
total from HYSYS
VOC
lb/yr tpy
11797 5.90
443 0.22
2077 1.04
1507 0.75
25 0.01
165 0.08
328779 164.39
'Emission Factors
Separator Venting
3 of 6 K:\PA\2017\17WE0967.CP1.xlsm
Separator Venting Emissions Inventory
Section 05 - Emissions Inventory
Pollutant
Uncontrolled Controlled
(Ib/MMscf( (lb/MMscf)
(Gas Throughput)
VOC 49796
Benzene 317.40
Toluene 226.72
Ethylbenzene
Xylene
n -Hexane
224TMP 63.480
Pollutant
(Gas Throughput)
15.870
11.336
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) lb/MMscf
(Waste Heat
Combusted)
PM10
PM2.5
75'
k7!
i8I
NOx
CO
(Gas Throughput)
13.412
13.412-
122.400
558.000
Emission Factor Source
Emission Factor Source
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)
VOC
164.31
0.00
0.00
164.31
8.2
PM10
0.04
0.00
0.00
0.04
0.0
PM2.5
0.04
0.00
0.00
0.04
0.0
NOx
0.40
0.00
0.00
- 0.40
0.4
CO
1.84--
0.00
0.00
1.84-
1.8
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants -
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(Ibs/year) (Ibs/year)
(Ibs/year) (Ibs/year)
Benzene
2095
0
0
2095
100
Toluene
1496
0
0
1496
75
Ethylbenzene
25
0
0
25
1
Xylene
718
0
0
718
36
n -Hexane
11790
0.
0
11790
589
224 TMP
419
0
0
419
21
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, G
Source is not subject to Regulation 7, Section XVII.B.2, G
Regulation 7, Section XVII.B.2.e
The control device for this separator is not subject to Regulation 7, Section XVII.8.2.e
(See regulatory applicability worksheet for detailed analysis)
used lb/hr values from HYSYS to get emission factor
Source's values Permit values
Uncontrolled Controlled ' Uncontrolled Controlled I
lb/yr lb/yr tpy tpy
2081 104 1.047 0.052
]509 75 0-748 0.037
24 1 0.012 0.001
604 30 0.359 0.018
11818 591 - 5.895 0.295
444 22 0.209 0.010
•
4 of 6 K:\PA\2017\17WE0967.CP1.xlsm
Separator Venting Emissions Inventory
Section 07- Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Does the company use site specific emission factors based on a gas sample to estimate emissions?
If yes, are the emissions factors based on an gas sample drawn at the facility- and fromthe equipment being permitted? This sample -should beconsidered representative which
generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then.
it may beappropriateto use an older site -specific sample.
• If no, the permit willcontainan "Initial Compliance" testing requirement to collect a site -specific 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 use site specific emission factors based on apressurized liquid sample and process model (e.g. ProMax, HYSYS, VMGSim( to estimate emissions?
If yes, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific gal 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 emissionsfactors established with this application.
Are facility -wide- permittedemissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct anemission factor analysis to
demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
If yes, the permit will contain a "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permittedand conduct an emission factor analysis to
demonstrate that the emission factors are less than or equal to the emissions'factors established with this applicationon an annual -basis. -
Will the opeator have a meter installed arid operational upon startup of this point? Yes
If no„ the permit will containa 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 value in cell B31 (scf/bbl).
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initialcompliancetest condition to demonstrate the destruction efficiency of the combustiondevice based on
inlet and outlet concentration sampling
Using. Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample and process simulation to
estimate emissions?
AA
If yes, are the emissions -factors based on an pressurized liquidsample drawn at the facility and from equipment located upstream of the
permitted equipment? ibis sample should be considered representative which generally -means site -specific and collected within one year of the
application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an
older site -specific. sample.
I� 'R
AA AA'
If no, the permit will contain an "Initial Compliance" testing requirement to collecta site -specific liquid sample and conduct an emission factor analysis to demonstrate that the
emission factors are lessthan or equal to the emissions factors established with this apptucation.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? A'TUEF
If yes, the permit will contain and initialcompliance test conditionto demonstrate the destruction efficiency of the combustion device based on
inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
The APEN did not indicate whentheEP separator beg n open
8/1/2014, the P pastor is not sutjzct to Rag7
- Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
n. The APENs for the tanks indicate the tan
Process # SCC Code
005 01 t "
Uncontrolled.
Emissions
Pollutant Factor - Control % Units
PM10 13.41 0 lb/MMSCF
PM2.5 - 13.41 0 lb/MMSCF
' NOx 122.40 0 lb/MMSCF
VOC 49796 95 --.Ib/MMSCF
CO 558.00 0 lb/MMSCF
Benzene - 317.40 95 Ib/MMSCF
Toluene 226.72 95 lb/MMSCF
Ethylbenzene 3.7168 95 lb/MMSCF
Xylene 108.82 95 lb/MMSCF
n -Hexane 1786.51 95 lb/MMSCF
224 TMP - 63.48 95 ° Ib/MMSCF
5 of 6
K:\PA\2017\17 W E0967.CP 1.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
'You have indicated that 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 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 XVII.B.2, G
Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
'The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control
Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts
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 ev
conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations,
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 APC
interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Natural Gas Venting APEN - Form APCD-2 ai
o
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.eov/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: t ( 1 W' (Q(Lj --71-AIRS ID Number:
[Leave -blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: LP Separator
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
123 /7234/ -Do 5
Section 1 - Administrative Information
Company Name': Noble Energy, Inc.
Site Name: 415860797 Frico/Farmers 2-14HZ
Site Location: NWNE SEC14 T3N R65W
lu Address:
p Coe1625 Broadway, Suite 2200
(Include Zip Code)
Denver CO 80202
E -Mail Address2: 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
368494 1 I `
COLORADO
Permit Number:
AIRS ID Number: 123 /7234 / TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
IZ NEW permit OR newly -reported emission source
-OR-
t1
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Please note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info 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:
/ /
/ /
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: 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 0 No
0 Yes 0 No
WV COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
Permit Number: AIRS ID Number:
≥A
;:1
(41
;;1
123 /7234/TBD 'i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
,41
Section 4 - Process Equipment Information
❑ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
O 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? O Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
755
SCF/hr
Vent Gas
Heating Value:
1799.88
BTU/SCF
Requested:
6.61278
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 %)
33.98
VOC (Weight %)
54.90%
Benzene (mole %)
0.15
Benzene (Weight %)
0.35%
Toluene (mole %)
0.09
Toluene (Weight %)
0.25%
Ethylbenzene (mole %)
0.0
Ethylbenzene (Weight %)
0.0%
Xylene (mole %)
0.03
Xylene (Weight %)
0.08%
n -Hexane (mole %)
0.79
n -Hexane (Weight %)
1.97%
2,2,4-Trimethylpentane
(mole %)
0.02
2,2,4-Trimethylpentane
(Weight %)
0.07%
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Zt n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and
pressure)
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
3 I �COLORADO
J
Permit Number:
AIRS ID Number:
123 /7234/TBD
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.2280 / -104.6244
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp._
C 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):
0 Upward with obstructing raincap
Section 6 - Control Device Information
O 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 %
Waste Gas Heat Content
Constant Pilot Light: ❑ Yes 0 No Pilot burner Rating
Btu/scf
MMBtu/hr
0 Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0./0
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
pp� COLORADO
4I 1��
Permit Number:
AIRS ID Number: 123 /7234i TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Criteria Pollutant Emissions Information
Attach all emission calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑ Yes ❑ No
If please describe the control eauipment AND state the overall control efficiency (% reduction):
yes
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
13 a ,-t
I b /t 11115(C-
AF-- L-1`,)
NOX
3770==03
Ib/Ib-VOC
i'I'SYS-
-8:61 C A
.,0.61 c.'.1
._0:6; c,tg.4
-076-1--c-`i
VOC
49.807
lb/Mscf
CDPHE
164.6814
8.2341
164.6814
8.2341
CO 55
-9,40E-03
'IWti
-1..55-
-1-55-
---1-.-55'1.S
4755. I.
Benzene
0.315
lb/Mscf
CDPHE
1.0403
0.0520
1.0403
0.0520
Toluene
0.228
lb/Mscf
CDPHE
0.7546
0.0377
0.7546
0.0377
Ethylbenzene
0.004
lb/Mscf
CDPHE
0.0122
0.0006
0.0122
0.0006
Xylenes
0.074
lb/Mscf
CDPHE
0.3019
0.0151
0.3019
0.0151
n -Hexane
1.787
lb/Mscf
CDPHE
5.9090
0.2954
5.9090
0.2954
2,2,4-
Trimethylpentane
0.067
lb/Mscf
CDPHE
0.2219
0.0111
0.2219
0.0111
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
� COtORaDO
5I w
Permit Number:
AIRS ID Number: 123 /7234/ TBD
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
F/?q//7
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-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017
r COLORADO
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