HomeMy WebLinkAbout20171724COLORADO
Department of Public
Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
June 1, 2017
Dear Sir or Madam:
RECEIVED
JUN 0 2 2017
WELD COUNTY
COMMISSIONERS
On June 8, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Noble
Energy, Inc. - Frankie T4N-R65W-S4 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 I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
Ram i e►.tJ
Co/i a/( 7
Cc:PLCmMl TP3, KL CP8),
PctC'z_R(cH/3-M/Ctc)
Co/Co/V7
2017-1724
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Frankie T4N-R65W-S4 L01 - Weld County
Notice Period Begins: June 8, 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: Frankie T4N-R65W-S4 L01
Exploration and Production
NWSW Sec 4 T4N R65W
Weld County
The proposed project or activity is as follows: Existing EttP facility. Emissions from the vapor recovery
tower (VRT), which are currently compressed by the ERS COMP1 engine (Point 015), 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 17WE0150 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.govtpacific/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
1 I co cr Aao
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Betsy Gillard
358378
2/14/2017
4/26/2017
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Noble Energy, Inc,
123
9888
FrankieT4N-R651W-54_ L01
Weld
Quadrant
Section
Township
Range
SWSW quadrant of Section 4, Township 4N, Range 65W, in Weld County, Colorado
foratiork& Production W Pad
turaG tass Production & P
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
E articulate Matter (PM)
I:Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
015
Vapor Re er ilower(VR'
VRT
Ye's
17WE0150
1
Yes
Perttttt Il itial
°j once
005
Hydro arb L id Loading;
13WE2569
Cancellation ;
No longer exists
007
drocarbon LicgdeVEiaarting
13WE2571
me lad n '
No longer exists
010
Natural Gas R g,;
GP02
'��"��
i.. Can
No longer exists
s .t,
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 015), will be routed to a
VOC burner and the engine will be removed.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
estfng Synthetic Minor Pe
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)
502
NOx
CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑
❑ o ❑ ❑ ❑ o
O
Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment
Air Pollution Control Division
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
Maximum Vent Rate I 761 scf/hr
2equestedThroughput (O) 6.7 MMscf/yr
760.7 scf/hr I 0.000 MMscf/d I 0.57 MMscf/mol
% Vented I 100%
MW 44.880Ib/Ib-mol
Component
mole %
MW
Ibx/lbmol
mass fraction
E
lb/hr
lb/yr
tpy
Helium
0
4.0026
0.000
0.000
Helium
0.0
0
0.00
CO2
1.76
44.01
0.775
0.017
CO2
1.6
13619
6.81
N2
0
28.013
0.000
0.000
N2
0.0
0
0.00
methane
7.82
16.041
1.254
0.028
methane
2.5
22056
11.03
ethane
28.45
30.063
8.553
0.191
ethane
17.2
150387
75.19
propane
30.45
44.092
13.4260
0.299
propane
26.9
236071
118.04
isobutane
6.02
58.118
3.4987
0.078
isobutane
7.0
61518
30.76
n -butane
13.1
58.118
7.6135
0.170
n -butane
15.3
133868
66.93
isopentane
3.64
72.114
2.6249
0.058
isopentane
5.3
46155
23.08
n -pentane
4.51
72.114
3.2523
0.0/2
n -pentane
6.5
57186
28.59
cyclopentane
1.58
70.13
1.1081
0.025
cyclopentane
2.2
19483
9.74
n -Hexane
1.2100
86.18
1.0428
0.023
n -Hexane
2.1
18335
9.17
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
0.67
100.21
0.6714
0.015
heptanes
1.3
11805
5.90
methylcyclohexane
0
98.19
0.0000
0.000
methylcyclohexane
0.0
0
0.00
224-TMP
0.14
114.23
0.1599
0.004
224-TMP
0.3
2812
1.41
Benzene
0.18
78.12
0.1406
0.003
Benzene
0.3
2472
1.24
Toluene
0.16
92.15
0.1474
0.003
Toluene
0.3
2592
1.30
Ethylbenzene
0
106.17
0.0000
0.000
Ethylbenzene
0.0
0
0.00
Xylenes
0.03
106.17
0.0319
0.001
Xylenes
0.1
560
0.28
C8+ Heavies
0.26
223.292
0.5806
0.013
C8+ Heavies
1.2
10208
5.10
100 VOC mass fraction: 0.7642 Total VOC Emissions (Uncontrolled)
annual limit assuming 95% control
Total unc. VOC Emissions (operator calcs)
Controlled VOC emissions (operator calcs)
301.5
15.1
301.7
15.1
Notes
Mole %, MW, and mass fractions from HYSYS analysis based off KNAUB PC G04-67-1 HN high pressure liquid sample collected 1/11/2017
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 PFD provided with this permit application indicates that there is also an LP separator at the facility, with vapors being routed to a flare. I asked
Gabriela Vega about this in an email 4/26/17, and she explained that the stream was mis-labeled and the vapors from the LP separators are routed to a
VRU and therefore do not require a permit.
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 b t VRT as.
g
Gas Heating Value 1
Serial Number
1154
7690.256
Btu/scf
MMBtu/yr
Combustion emission factor source: AP -42: Chapter 13.5
0.068
lb NOX/MMBtu
tpy NOX
0.31
1.19
lb CO/MMBtu
tpy CO
0.26
Emissions Summary
Operator calcs
0.3
tpy NOX
1.13
Uncontrolled/PTE
1.2
tpy CO
2.84
301.5
tpy VOC
301.7
Controlled
15.1
tpy VOC
15.1
Uncontrolled
Total (Ib/yr)
Scenario A
Reportable?
Controlled
Total (Ib/yr)
Operator Calcs (lb/yr)
Benzene
2472
Yes
124
2409
120
Toluene
2592
Yes
130
2606
130
Ethylbenzene
0
No
0
13
1
Xylenes
560
Yes
28
714
36
n -hexane
18335
Yes
917
18383
919
224-TMP
2812
Yes
141
2776
139
Emission Factors for Permit
VRT emissions will be monitored as a function of condensate throughput
Annual throughput:
100010 bbl
Uncontrolled
NOX
0.005
0.0226
lb/bbl
NOX
0.005
0.0226
lb/bbl
CO
0.024
0.0568
Ib/bbl
CO
0.024
0.0568
lb/bbl
VOC
6.030
6.033
Ib/bbl
VOC
0.302
0.302
lb/bbl
Benzene
0.025
0.024
lb/bbl
Benzene
0.001
0.0012
lb/bbl
Toluene
0.026
0.026
lb/bbl
Toluene
0.001
0.0013
lb/bbl
Ethylbenzene
0.000
0.000
Ib/bbl
Ethylbenzene
0.000
0.0000
lb/bbl
Xylenes
0.006
0.007
lb/bbl
Xylenes
0.000
0.0004
lb/bbl
n -Hexane
0.183
0.184
lb/bbl
n -Hexane
0.009
0.0092
lb/bbl
224-TMP
0.028
0.028
lb/bbl
224-TMP
0.001
0.0014
lb/bbl
Enoineer calcs
Operator
calcs
Controlled
Operator
Engineercalcs calcs
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 Required
Permit number:
Date issued:
Issued to:
CO
Asir Po
Depar
CONSTRUCTION PERMIT
17WE0150
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
Noble Energy, Inc.
Frankie T4N-R65W-S4 L01
123/9888
NWSW SEC 4 T4N R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT
016
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
COLORADO
Air Pollution Control Division
p>nt Cp l HoOh E,iJnrrtent
Page 1 of 8
www.colorado.gov/pacifi • • -/ m: rmit
Section III.G.2.)
3. This permit shall expire i e owner or operator o t e source r 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:
-cer fi atior>] (Regulation Number 3, Part B,
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
VRT
016
--
1.2
15.1
2.9
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder shall
calculate actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT
016
Emissions from the VRT are routed to an
enclosed flare
VOC and HAP
COLORADO
Air Pollution Control Division
L-rn.'.teat
Page 2 of 8
PROCESS LIMITATIONS AND REC
8. This source shall be limit a ll• ins a ur roces g rates as listed below. Monthly
records of the actual processing ra es s a .e maintained by e 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
O16
Condensate Throughput
100,010 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.
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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COLORADO
Air Pollution Control Division
u rtfn ntorPui i. Lei:% E,-roorr e,tt
Page 3 of 8
COMPLIANCE TESTING AND SAM
Initial Testing Requirem
FT
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 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 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. 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
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
iCOLORADO
Air Pollution Control Division
Page 4 of 8
• Whenever a perm
• No later than 30
r
difi r
PE expire
18. 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
19. 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.
20. 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.
21. 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.
22. 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.
23. 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.
24. 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.
25. 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.
COLORADO•
Air Pollution Control Division
Deputment Ci Pub Heats 6 r nrWettE
Page 5 of 8
DRAFT
By:
Betsy Gillard
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
COLORADO
Air Pollution Control Division
"fG s. ^t t Pc. €
Page 6 of 8
Notes to Permit Holder at the tim
1) The permit holder is requiray -s = e = = =--'ng ti r for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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
016
Benzene
71432
1.205
0.060
Toluene
108883
1.303
0.065
Xylenes
1330207
0.357
0.018
n -Hexane
110543
9.192
0.460
2,2,4-
Trimethylpentane
540841
1.388
0.069
Note: All non -criteria 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 016:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/bbl)
Controlled
Emission Factors
(lb/bbl)
Source
NOx
0.023
0.023
CDPHE
CO
0.057
0.057
CDPHE
VOC
6.034
0.302
HYSYS simulation
based on
representative HP
gas sample
71432
Benzene
0.024
0.0012
108883
Toluene
0.026
0.0013
1330207
Xylene
0.007
0.0004
110543
n -Hexane
0.184
0.0092
540841
2'2'4
Trimethylpentane
0.028
0.0014
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
Page 7 of 8
The emission factors listed
pressure of 4 psig.
6) In accordance with C.R.S. 2'- i .1, -. h -.11 . t flissioi'f'1aOtice (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:
mperature of 70 °F and separator
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
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
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
Pt.0A,s e En,rortrnent
Page 8 of 8
Emission Source AIRS ID:
[Leave blank unless APCD has already assigned a permit # & AIRS ID]
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
nested Action (check applicable request boxes)
Section 02 — Re
Section 01 — Administrative Information
Request for NEW permit or newly reported emission source
Request MODIFICATION to existing permit (check each box below that applies)
Change company name
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Transfer of ownership
❑❑
Change fuel or equipment
Change permit limit
❑ ❑
Request to limit HAPs with a Federally enforceable limit on PTE
Request APEN update only (check the box below that applies)
® ❑ ❑ ❑
Noble Energy, Inc.
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303-228-4286
Fax Number:
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E-mail Address:
Section 03 — General Information
For new or reconstructed sources, the projected startup date is:
Vapor Recovery Tower
General description of equipment and purpose:
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Well Head Casing
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Check box to request copy of draft permit prior to issuance.
Check box to request copy of draft permit prior to public notic
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VRT-Natural-Gas-Venting-APEN Re
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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 08 — Emissions Inventory Information & Emission Control Information
Estimation
Method or
Emission
Factor Source
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CDPHE
CDPHE
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Hysys
Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Requested Permitted Emissions
Controlled
(Tons/Year)
0.02
Uncontrolled
(Tons/Year)
7301.72
2.84
1.2
Actual Calendar Year
Emissions'
Controlled
(Tons/Year)
Uncontrolled
(Tons/Year)
Emission Factor
Units
Uncontrol led
Basis
6.0338
0.0241
Control
Efficiency
(% Reduction)
95%
Overall
Collection
Efficiency
Control Device Description
Secondary
VOC Burner
VOC Burner
VOC Burner
VOC Burner
VOC Burner
Pollutant
VOC
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Benzene
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Name of Legally Authorized Person (Please print)
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gabriela.vega@nblenergy.com
E-mail Address:
Controlled Actual
Emissions
(lbs/year)
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Uncontrolled
Actual Emissions
(lbs/year)
2776
Emission Factor
Source
Hysys
Emission Factor
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