HomeMy WebLinkAbout20172834.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
August 8, 2017
Dear Sir or Madam:
RECEIVED
AUG 1 5 2017
WELD COUNTY
COMMISSIONERS
On August 10, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Holman Cockroft. 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
Pobl;c
iew
.I t/I7
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor ( Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
C.c:PLC- (NeNrYYf TO, HLCZ T3
PwC£RfCH/,'M Ices)
csf( (17
2017-2834
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Holman Cockroft - Weld County
Notice Period Begins: August 10, 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: Holman Cockroft
Oil and gas exploration and production facility
NENW Sec 15 T5N R64W
Weld County
The proposed project or activity is as follows: Source is proposing to operate a new unit at an existing oil
and gas exploration and production facility.
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 17WE0349 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
ACOLOR ADO
1 I AMPT
Permit number:
Date issued:
Issued to:
ADO
n Contro
c Healt
CONSTRUCTION PERMIT
17WE0349
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Noble Energy, Inc.
Holman Cockroft
123/9CA4
NENW SEC 15 T5N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT
009
Venting of gas from one Vapor Recovery
Tower (VRT)
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
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
D partrnent of P.u".€r Health & 7:P,vrronment
Page 1 of 7
3. expi er or oper �or f ' e source .-.', this permi as issued:
tion/modif t -t ,•peration, i -ource withi; 8 months
e of tr constr on per or t e date on , ich such
was suled commen�.s set h in the permi lication
a edwith thi i - (ii ) . : � ' fi -s cons ' • - 'od 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.)
Annual Limits:
s permit s
does not c
er either,,
stru
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
VRT
009
---
---
26.2
4.2
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.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
VRT
009
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.)
COLORADO
Air Pollution Control Division
Deparimenr .:ni Public )iealth c -nvxrrxnere'
Page 2 of 7
ss Para ter Annual L
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. The owner or operator must use monthly condensate/crude oil throughput records, calculation
methods detailed in the OEM Plan, and the emission factors established in the Notes to Permit
Holder to demonstrate compliance with the process and emissions limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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 TILE.) (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 £t 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. 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 initial 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
15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
COLORADO
Air Pollution Control Division
Deparhnent of Public Health & F..n.irnnrrent.
Page 3 of 7
tons per
ear or mor
or any no - - `a rep: utant
ore, a c
r is less,
actual emi
e level re
ns of five
ed on the
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.
16. 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
17. 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.
18. 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.
19. 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.
20. 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.
21. 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
COLORADO
Air Pollution Control Division
Department of PbA. Health c -nvvoxnrrant.
Page 4 of 7
rato
bef
it, the o
'vision's
perator of °'urce may
22. lion 25 7 4.7(2)( C R .uires t all sou requir file an Air Pollu Emission
) mus .. ,, .nn'. t :,Na,. r- er thf
ns and ad n. 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.
23. 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 vapor recovery
tower.
COLORADO
Air Pollution Control Division
Department of RANI, Health o -rvrrnmefr
Page 5 of 7
Notes t. : rmit Hold.t their• ' " permit iss
1) Thermit holderequi to • ees fort : • "= time fo is p- it. An invo '";, for these
fee s -ll be issu-,,' .fter t ermi ssued a perms gilder shay the invoice n 30 days
e invure evocationermit.
(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
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT
009
Benzene
71432
5,376
269
Toluene
108883
2,755
138
Ethylbenzene
100414
69
3
Xylenes
1330207
1,033
52
n -Hexane
110543
34,579
1,729
2,2,4-
Trimethylpentane
540841
1,121
56
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates equal to or greater
than 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 009:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/bbl)
Controlled
Emission Factors
(lb/bbl)
Source
NOx
0.0074
0.0074
AP -42, Table 13.5-1
CO
0.0337
0.0337
AP -42, Table 13.5-1
VOC
4.2403
0.2120
Source (HYSYS)
71432
Benzene
0.0217
0.0011
Source (HYSYS)
108883
Toluene
0.0111
0.0006
Source (HYSYS)
100414
Ethylbenzene
0.0003
0.00001
Source (HYSYS)
1330207
Xylene
0.0042
0.0002
Source (HYSYS)
110543
n -Hexane
0.1398
0.0070
Source (HYSYS)
COLORADO
Air Pollution Control Division
Department of P.irii,- Health c -nvirnn n nt.
Page 6 of 7
Uncontr• 3 ed
Emission
(lb/ l)N
Contr
= Emission
(lb/•
•
c o
S
ce
2 2
Trimethy pen ane
So :a.�
�F YS)
Note: 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
shalt 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, HAPs
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 Paid ,^ Ffealth & -nv.rnnrner,r.
Page 7 of 7
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name: Noble. Energy, Inc:
County AIRS ID: 123
Plant AIRS ID: 9CA4
Facility Name: Holman Cockroft
Physical Address/Location: NENW quadrant of Section 15, Township SN, Range 64W, in Weld County, Colorado
Type of Facility: Exploration &Production Well Pad
What industry segment? Oil &Natural Gas Production- _Processing,
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? ❑ Carbon Monoxide (CO)
Carissa Money
361030
4/14/2017
7/3/2017
Weld
Quadrant
Section
Township
Range
NENW
Section 02 - Emissions Units In Permit Application
❑ Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
Separator Venting .. '
VRT
Yes
17WE0349
1
Yep ;- ;
hermit Initial
: Issuance
Section 03 - Description of Project
Source is requesting a new permit for an existing VRT. The VRT used to be recycled via a VRU but Noble is removing the VRU. Now the VRT will be routed, to a
flare.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
Yes:
Requesting Synth€tic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? I�Io
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?
Colorado Air Permitting Project
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)
'Fes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
❑ ❑ ❑ O ❑ ❑ ❑ El
❑ El
Is this stationary source a major source? No
If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
Non -Attainment New Source Review (NANSR) ❑ ❑
Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
123
County
9CA44
Plant
009
Point
Section 02 - Equipment Description Details
Venting of gas from one vapor rec (VRT)_.,
Detailed Emissions Unit Description: - -
Enclosed combustion device
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Other Equipment
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Maximum vent rate -
Requested Permit Limit Throughput =
95
1,172.0: scf/hr
247,360.5'. Barrels (bbl) per year
Potential to Emit (PTE) Throughput = 247,361 Barrels (bbl) per year
Process Control (Recycling)
VRU:
VRU operation:
`/! zAir A% Bypass (annual)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Section 04 - Emissions Factors & Methodologies
Control Efficiency %
2617 Btu/scf Potential Process Parameters:
Gas Recycled: 0.0 MMscf/yr
Gas Routed to Control: 10.3 MMsd/yr
Description
This VRTis located downstream of an inlet (high pressure) separator and low pressure separator: where the liquids undergo gas/liquid separation prior to the VRT. A pressurized liquid
sample was taken from the high pressure separator at 182 prig} 97 deg P (sampled: 2/9/2017) and modeled, using HYSYS Version 84, through the LP separator and VRT. Themass
fractions, molecular weight (MW), and sent rate of the waste gas stream are derived from the modeled VRT gas .strearm "VRT Vapors to Bunter'. The model was based on the following
parameters.
Input Parameters
Modeled Liquid Throughput
(If applicable) 677.7 Barrels (bbl) per day
Separator Pressure ',122. psig
Separator Temperature 97 deg F
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 6OF and 1 atm
Modeled Vent Rate
........1,:172:0
sd/hr
41.5
scf/bbl
Throughput (Q)
10.3
MMscf/yr
1172
scf/hr
MW
46.95
lb/lb-mol
0.028128
MMscf/d
mass fraction (%)
lb/hr
lb/yr
tpy
Helium
0.00
0.00
0.00
CO2
0,96
1.39
12209.54
6.10
N2
020
0.29
2543.65
1.27
methane
:2.30
3.34
29252.03
14.'03
ethane
14.09
20.46
179200.45
89.60
propane
3187
46.27
405331 32
202.67
isobutane
'.730
10.60
92843 38
4642
n -butane
20.62
29.94
262250.77
131.13
isopentane
5.46
7.93
69441.76
34.72
n -pentane
6.63
9.63
84322.14
42.16
cyclopentane
x2.12
3.08
26962.74
13.48
n -Hexane
272
3.95
34593.70
17.30
cyclohexane
0.00
0.00
0.00
Other hexanes
2.35
4.14
36247.07
18.12
heptanes
1.69
2.45
21493.88
10.75
methylcyclohexane
0.00
0.00
0.00
224-TMP
'.0-09
0.13
1144.64
0.57
Benzene
0.42
0.61
5341.67
2.67
Toluene
1'.0:22
0.32
2798.02
1.40
Ethylbenzene
,-0.02
0.01
127.18
0.06
Xylenes
0.09
0.13
1144.64
0.57
C8+ Heavies
':0.38
0.55
4832.94
2.42
Total
VOC Wt %
100.02
82 47
Total VOC (Uncontrolled)) 524.44
Note: lb/hr emission rates in the table above are based on 8760 hr/yr venting and requested gas volume
3 of 6
K:\PA\2017\17W E0349.CP1.xlsm
Emissions Inventory
Emission Factors Separator Venting
Pollutant
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled Controlled
(Ib/bbl)
(lb/bbl) Emission Factor Source
(Liquid Throughput) (Liquid Throughput)
4.2403 0.2120
0.0217 0.0011
0.1398
0.0045 0.0002
0.00001
0.0002
0.0070
Emission Factors Separator Venting
Pollutant
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Pollutant
Uncontrolled Controlled
(Ib/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
/ ri/ ,;;;x;„r //' 6
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) lb/bbl
PM10 0.
0.0008
0.0008
0,0074
0.0337
Section 05 - Emissions Inventory
Zline
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
PM10
PM2.5
NOx
CO
524.4
524.4
26.2
524.4
26.2
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.9
0.9
0.9
0.9
0.9
4.2
4.2
4.2
4.2
4.2
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) llbs/year)
zrce's Requested Permit Lin
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
2.6880
2.7
0.1
2.6708
0.1335
5342
267
5376
269
1.3775
1.4
0.1
1.3990
0.0700
2798
140
2755
138
0.0345
0.1
0.0
0.0636
0.0032
127
6
69
3
0.5165
0.6
0.0
0.5723
0.0286
1145
57
1033
52
17.2895
17.3
0.9
17.2968
0.8648
34594
1730
34579
1729
0.5605
0.6
0.0
0.5723
0.0286
1145
57
1121
56
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Facility is located in non attainment area.
Separator is not subject to Reg 7
Separator is not subject to Reg 7
4 of 6 K:\PA\2017\ 17WE0349.CP1.xlsm
Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Reauirements
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 from the equipment being permitted? This sample should be considered representative which generally
means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be
appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to 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 a pressurized liquid sample and process simulation to estimate
emissions?
If yes, are the emissions factors based on an pressurized liquid sample drawn at the facility and from equipment located upstream of the permitted
equipment? This sample should be considered representative which generally means site -specific and collected within one year of the application
received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific
sample.
If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission
factors are less than or equal to the emissions factors established with this application.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Sincethis unit is a VRT,the source has requested to use liquid throughput for monitoring. Whilethis.is a forge emission source with potetntial uncontrolled emissions greater than 100 tpy. Dimsion policy into allow for liquids rnonitoringfi
due Yoffie lower pressureand harder to track flow for these types of units, Since the source wal: be monitoring liquids throughput, the only requirements is that the model be based on a site -specific pressurized liquids sample which it was
will be no additionalsampling requirements in the permit. ----
d on Notice of Startup, AIRS ID 061- 004 started 12/29/2013- I couldn't find'anAPEN or NOS for AIRS ID 007. Assuming the VRT was inpface before 8/1/2014. -
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
009
Process #
01
SCC Code
i1
Uncontrolled
Emissions
Pollutant Factor Control %
PM10 19.50 0
PM2.5 19.50 0
NOx 177.96 0
VOC 102162.70 95
CO 811.27 0
Benzene 523.63 95
Toluene 268.34 95
Ethylbenzene 6.72 95
Xylene 100.62 95
n -Hexane 3368.07 95
224 IMP 109.19 95
5 of 6 K:\PA\2017\17WE0349.CP1.xlsm
Separator Venting Regulatory Analysis Worksheet
C
a
E
a
0
W
E
a
C
a
z
a
eTs
C
Q
a
en
O
0
Colorado Re
ATTAINMENT
f11
0
O
v
m
0
.4 a
Q n'1
C .9
O
O
a 00
N .
>-
al
0-
0_ F-
M
C
O =
i0
OD
m
CC v
m
O
F-
.0
ry O
C
E
.. y
v 0
a 0
m y
a 0.
u o
o
o ti
C
7 «
�> v
c
a, m
L X
O
E z
O
— a
v F
c un
t° c
0
v
00
c
c o
o E
a. a
CO
c O
O >
•H 0)
E
v 72""..
j
0
C
p
v >
0
Cro
N
�
v a
a a
NON -ATTAINMENT
J
C
%1
c
O
0
Colorado Re
ally fractured, or recompleted on or after August 1, 2014?
Was the well newly constructed, hydra
tional Section
0
Alternative Emissions Control
v
O
C
a
•
C
L
G1
O
C
0
E
a
C
ai
C)
a
0
E
O
v
O
0
m
a
m
0
O
0
m
C)
m
ons control equipment
Section XVII.B.2.e — Alternativ
Disclaimer
0)
N
Emission Source AIRS ID:
Permit Number:
Facility Equipment ID:
Section 02 — Requested Action (check applicable request boxes)
Section 01— Administrative Information
L
a)
d...c0
.0.
0
vs
., ❑ o
R 0
O:
C o p.
c
oe E cal cu
m
x a A.. H
4� .°0 T a'"i C •c ..
i. ,. c o. .. o
Y
c 0 0 = °
et $
.y rio v y., 2
m u '.. y 0 i y.., v
5 .. 0 a m .0 C Ca
'a Q FL .a cri y 'a0s
I.tooiII
o Z . >+ m Z
v 47
F y 'tn O
< ,
- .C- a P.. C ;U L 'y
n U d o ° O
►• 0 A.
° V
Z A bbO bq ._a
ZP4^o
C O C)
n H U awn n P4'Ili10+
Ar A) 6) a)
0 :0 0 0
ag❑❑gc❑❑
ND DO
C)
T1 CD [V
CO
fN
°,� c c v
UU C > U
z ,i_.-
HOLMAN COCKROFT T5N-R64W-515 L01
Source Name:
NENW SEC25 TSN R64W
1625 Broadway, Suite 2200
303-228-4415
Phone Number
CC
CO
L'
el
Person To Conta
'C
CO
co
U
a
ece
a
C
L
aC)
.0
C
e
CD
111
CC
C
.0
Cn
C
TG
a
Section 03 — General Information
CC
b
•0
.2
0
a)
o
C
CC
u
u
c
a)
°
0
3
c1
24 hours/day 7
Vapor Recovery Tower
0 .0
C ��a0
O O
a) G)
o e
°
v
0 0
O
cry c
far 0
O
. C
a) E
O -0
°z
° a)
0 L
O
O
C
E p w °' rn m �i 2
° p_ C N .. Ol C'< CNi� .rn
.C CZ U '�._
y e o00
N U tp. r.
.p Q go() N• W `'"' 0 U
a77 'F, a .v'.,e„ w a >
> '� �: P-. V e,
SAcn C c VI m ��
Is. co
0to o
a.O _F U v t C O O
y- ° ^o -n v.0 o °; 00 V °
o G Cr) _..C, C Cl)a0 0. 0
aCi, ° > 3 c .. CD t°,' v
-, �« ;, s en ° Ct 3
L ° C° C
A ~ 3 p
�a v o o L4-• � -a
N' b i:uC"611 >> OQ)UN
-ameal. O „i..' Q U O ,C C.
C yU C 0. O..Cn y U a -.� " 0 O.
— o,o ` ° m cil U -CO c,. ea
C .2 aVO coC C°. � W .¢
•P.'U 'ty -a O ). to E w� UdvA w .< f.") Q ¢p
o
°
O
O
N
8
Gam.'
a)
c
.C
C)
C
0
a]
a
U
0 0
0 410
v °
c3
a)3
v,=
Section 04 Processing Equipment Information
401
0 0
ad C)
MMscf/event
0
CC
C)
0
0
U.
ba
0 R
cU G I G CS
0
o O 01 °
. G L v
"g b U n'
00Cty oo
EU U CO
C)
a.
a
C)
A
0
0
I
a)
C)
0
OOOOO N
� a
C
E
C
CO
U:C)
Y`
c
so O
o
1
C)
u
O• p
c.)
ti
h .0
OT....
0 0
o 0
p.
a 0.
al O
'0 O
0 0
ooP.
o
0 o
ea
C G'
0
° °
.0 .0
0 0
U U
U
v
an
N
Uh
V O
> -O
C.'
s:
C)
°
N
0
b
Cis
'C
et
Vented Gas Properties:
N
VRT-Natural-Gas-Venting-APEN (2)
O
C
1
U
a,
A
Emission Source.
Permit Number:
er Lat/Long or UTM)
6.1
0
tre
0
0
Section 06 —Stack (Source, if no combustio
0.
a
O
0 0
te
b ra
E
a 9
yrt
N
O
0
CO
ca
If
rr
0
v
Circular:
0
u
CO
00
CCO
0
D
7 — Control Device Information
U
0)
.
0
CO
0
C3
0
O
CO
.0
00
•0 a
a
4)
Cam)
C)
z°
0
v
CJ
U O
[ CT ❑
2 U
N
X67 .. W O>
Q s,::,,
3:0m obil
o
A U Ci.
0C ? Q C
.'
Z E '
O O .C o
U E • > C3
Make/Model:
U
U
U
O
y
C7
C)61
II
K
h
Cc
w CO
W �+
C u
a..
0 �O
D
O R ai
E
0
_y
`9 ^c7
C U
CS
CO a,
O
7-4
03
� Lr
CO v u
O CC
0 V 'Q
CO OO
•q7,1a
W .0
I 1 1
O CFJ E
0 C.)
CaC)
CC)
Estimation
Method or
Emission
Factor Source
th >.
AP -42 II
AP -42
>
x
> ,
Hysys
Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Requested Permitted Emissions
-
J $
8
a
o F
a
N
"
'2:
0
-1-
V
'1
o
n
0
o
0
a.0
0
LUncontrolled
(Tons/Year)
524.49
O
o
CY
co
'r-i
o
a
CV
Actual Calendar Year
Emissions4
Controlled
(Tons/Year)
Uncontrolled
(Tons/Year)
Emission Factor
Units
.a.
.0
0
.Q .
.0
a
.fl:
Uncontrolled
Basis
Do
0
•
ico
i
4
I' en
Control.
Efficiency
CA Reduction)
e
Cif
c
CC in
e
in
o
a
0
a
Overall
Collection
Efficiency
Control Device Description
T
CO
0
C)
Primary
VOC Burner
VOC Burner
VOC Burner
VOC Burner
VOC Burner
Pollutant
VOC
Z
CO
Benzene
a
G
>,
u.4
x
N
I
C
u eJ
0 " curl
U 44
se
O
0
0
i3J
ens
2
O
U
O
M
44
0
_ 9
_ .0 0
2 ar
7eo
.0
ca.
q CD
ai
o
.9
as
C U 0
r`l �J
O�F P
Q N i+
N p'.r
y..
4^, v
:. fin
Z C
U
w a).C
C3 :?
z cOc.O
0 4,O
o
44
CL
2- U
RC ++
CJ
U N 44
N
u
O
>.* .C
t7
0
O
0
U
a)
0
0)
r0-*
•0
0
CO
CO
a
4-r
O
E
z
re of Person. Legally Authorized to S
VRT:Natural-Gas-Venting-APEN (2)
cV
O
00
4
FORM APCD-211
Hello