HomeMy WebLinkAbout20173452.tiffCOLORADO
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
September 28, 2017
Dear Sir or Madam:
RECEIVED
OCT 02 2017
WELD COUNTY
COMPASSI MFRS
On October 5, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Noble Energy, Inc. - Guttersen St T3N-R63W-S17 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 & 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
DCACCO
; CAA-)
O/9!(?
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
c%c- PLC M(YVrP), - LCJY.)e
PwC-Jrc H(Ttr' r c Ic)
to/3/I?
2017-3452
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Noble Energy, Inc. - Guttersen St T3N-R63W-S17 L01 - Weld County
Notice Period Begins: October 5, 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: Guttersen St T3N-R63W-S17 L01
Oil Et Gas Wellsite
SWSW Sec17 T3N R63W
Weld County
The proposed project or activity is as follows: Vapor Recovery Tower used for Oil Et Gas separation at
wellsite. Controlled by enclosed flare with 95% control efficiency
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 17WE0409 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:
Christian Lesniak
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
ADO
n Centro
17WE0409
Issuance: 1
Noble Energy, Inc.
Facility Name:
Guttersen St T3N-R63W-S17 L01
Plant AIRS ID:
123/9CF0
Physical Location:
SWSW quadrant of Section 17, Township 3N, Range 63W
County:
Weld County
General Description:
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
VRT
014
Vapor Recovery Tower
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/ pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
COLORADO
Air Pollution Control Division
Page 1 of 7
3. expi -1J T1�.'� er or oper : or e source this perms .s issued:
tion/modif fi . _ •peration ource withi 3; 8 months
ce of tconstr -'on per f or the date on ich such
was s commen s set th in the perms v ..lication
a ed with thi "' `" (ii) : -s cons r : . =iod 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 shalt 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 I I.A.4. )
Annual Limits:
s permit s
does not c
er either,
stru•
�x
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
VRT
014
-
-
5.0
-
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 criteria 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
014
Emissions from the Separator are routed to an
Enclosed Flare granted a 95% control efficiency
VOC and HAP
COLORADO
{ Air Pollution Control Division
Page 2 of 7
8.
follows-processi ate`s listed be . Monthly
essi e.tes sh be main ed by owner or operate nd made
insp eque l.x�a�,� ��a��, ber 3, Par ��w
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
VRT
014
Liquids Throughput
161,184 bbl/yr
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 hydrocarbon liquid throughput records, calculation
methods detailed in the OEtM Plan, and the emission factors established in the Notes to Permit
Holder to demonstrate compliance with the process and emissions limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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 Et MAINTENANCE REQUIREMENTS
13. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 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)
Periodic Testing Requirements
15. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• 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
COLORADO
I Air Pollution Control Division
Page 3 of 7
ile ri ' +mpounds ( :,z nitrogen 'i:es ources (N• a in ozone
nmen ? eas y ting les ' an 10 i ns of V t or NO, per year, change in
actual fission one ._ ton p X ° chever is
��per or mo oor five percent 3. =
greater, ab• evel -. . • the la
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
20. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only for
the equipment and operations or activity specifically identified on the permit.
21. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and
COLORADO
Air Pollution Control Division
Page 4 of 7
n such oc
ny time p
CD) on gr
alit
nce . r shall be dnied ab in permit ma ire revoked
to s tion and flation by - it pollution Co •l Division
ds see Color • Air Qu Contrct and regulation •f the Air
Conn on (A. incl ing failur- . meet express term or dition of
rmit. If the ri. i• •erne . •- 1 , onditl• •os : •• a permit a • ted 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:
Christian Lesniak
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
COLORADO
• Air Pollution Control Division
Page 5 of 7
Notes t
1) The
fee
requi
fter t
e inv
permit iss
ees for the • :'= time fo a;'s p- it. An invo for these
ssued. 4 e permi lder sh •ay the invoice w n 30 days
invoievocation. Az 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
(lb/yr)
Controlled
Emissions
(lb/yr)
VRT
014
Benzene
71432
1461
73
Toluene
108883
623
32
Ethylbenzene
100414
30
2
Xylenes
1330207
151
8
n -Hexane
110543
8616
431
2,2,4-
Trimethylpentane
540841
277
14
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportab e 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 014:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/bbl)
Controlled
Emission Factors
(lb/bbl)
Source
V0C
1.2445
0.0622
HYSYS
71432
Benzene
0.0090
0.0004
HYSYS
108883
Toluene
0.0039
0.0002
HYSYS
110543
n -Hexane
0.0534
0.0027
HYSYS
540841
2,2,4-Trimethylpentane
0.0017
0.0001
HYSYS
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
Page 6 of 7
s list
f 16.1
based on model eparator t .era e of 70 ° F separator
6) In a rdance w' .R.S. ,-7 11 ` each Ai Y•ollutant fission ice (APEN) associ • with
t d for five *� he da - - �. by the Divi ' ' r vised
es..: 4a�� �.,. ��.��..
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, NOx, CO, HAPs, n -Hexane
PSD or NANSR
Synthetic Minor Source of: VOC, NOx, CO
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 7 of 7
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01 - Facility Information
Christian Lesniak
361707
8/22/2017
9/12/2017
Original received 4/27/17.
Company Name: Noble Energy, Inc,
County AIRS ID: 123
Plant AIRS ID: 9CF0
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
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
Weld
Quadrant
Section
Township
Range
SWSW
17
3N
63
Guttersen=St.T3N-R63W S17 LO1 .
SWSW quadrant of Section 17, Township 3N, Range 63W, in Weld County, Colorado
Exploration &e:Prodt tion. Weil Pad
Oil & Fatural Gas Production & Processing,,
yes
[articulate Matter (PM) [)Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
014
Vapor Recovery Tower (VRT)
VRT
Yes
17WE040e
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Original Submittal in MMscf/yr (4/27/17). Update received switching to a per barrel basis with O&M update (8/22/17)
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? N€t
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Colorado Air Permitting Project
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)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Ye
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ a ❑ ❑ ❑
❑ 0 2 0 ❑ ❑ ❑ ❑
SO2
NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑
❑ ❑ ❑ ❑ ❑ ❑ ❑
❑ ❑
Condensate Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
123
County
9(00
Plant
014
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
Vapor Recovery Tower for separation: of gas/liquid bytfrocarbons. liquids are sent to VRT from '.low-pressure separator, and continue to
condensate tank(s) after VRT. Emissions are controlledby an enclosed flare granted a 95% control effciency.
Enclosed flare equipped with ..auto-igntter
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Maximum vent rate
Requested Permit Limit Throughput
320.0. scf/hr
161184.0. Barrels (bbl) per year
Potential to Emit (PTE) Throughput = 161,184 Barrels (bbl) per year
Process Control (Recycling)
VRU:
VRU operation:
Bypass (annual)
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04 - Emissions Factors & Methodologies
Description
Vapor RecoveryTower for Separation
Input Parameters
Modeled Liquid Throughput
(If applicable)
2223 Btu/scf
7!39130435 scf/bbl
Control Efficiency %
Do we want to modify the control device descriptio
routed to an enclosed flare during vapor recovery a
Do we want to format the efficiency as a "%" or just "number". Actual value is 0.95 when formatted as a "%" but is 95
'%", all others are currently "number". Need to be consistent throughout (i.e. % control, % bypass, wt%) -Brad 7/13/1
Potential Process Parameters:
Gas Recycled: 0.00 MMscf/yr
Gas Routed to Control: 2.80 MMscf/yr
rocarbons. liquidsare sent:.to VRTfrom-.low-pressure separator, and continue to condense
are controlled by an enclosed flare granted 8 95% control efficiency.
447 Barrels (bbl) per day
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/Ib-cool) at 60F and 1 atm
MW
40.82
mass fraction (%)
Helium
0.00.
CO2
<'2.49
N2
1.97.
methane
4.15
ethane
, 24,97
propane
_.33.15.
isobutane
?351'.
n -butane
12.42
isopentane
2.00
n -pentane
2.98
cyclopentane
- 0.00.
n -Hexane
'-2,85
cyclohexane
:.0.00
Other hexanes
;(2.41
heptanes
:5.68.
methylcyclohexane
0.00
224-TMP
('0.09
Benzene
s.0 48
Toluene
0,21
Ethylbenzene
'''0.01
Xylenes
''005.
C8+ Heavies
0.50.
Total
VOC Wt %
100.0
66.44
Ib/Ib-mol
Note: lb/hr emission rates in the table above are based on 8760 hr/yr venting and requested gas volume
after VRT. Emissions:
3 of11
K:\PA\2017\17 W E0409.xlsm
Condensate Storage Tank(s) Emissions Inventory
Emission Factors
Pollutant
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Emission Factors
Pollutant
VOC
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Pollutant
PM10
PM2.5
NOx
CO
Separator Venting
Uncontrolled Controlled
(Ib/bbl)
(Liquid Throughput)
0.0090
0.0039
0.0002
0.0009
0.0534
0.0017
(lb/bbl) Emission Factor Source
(Liquid Throughput)
0.0622
Separator Venting
Uncontrolled Controlled
(Ib/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput)
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
.007
0.007
0.0580
O.3100?'s
Section 05 - Emissions Inventory
(Condensate Throughput)
0.000
0.000
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
PM10
PM2.5
NOx
CO
100.3
100.3
5.0
100.3
5.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.2
0.2
0.2
0.2
0.2
1.0
1,0
1.0
1.0
1.0
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) (lhs/year(
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
0.7246
0.7
0.0
0.7246
0.0362
1449
72
0.3170
0.3
0.0
0.3170
0.0159
634
32
0.0151
0.0
0.0
0.0151
0.0008
30
2
0.0755
0.1
0.0
0,0755
0.0038
151
8
4.3023
4.3
0.2
4.3023
0.2151
8605
430
0.1359
0.1
0.0
0.1359
0.0068
272
14
fiction 06 - a tm, tory 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 attainment -area status has not been established yet
Not enough information
Not enough information
4 of 11 K.\PA\2017\17WE0409.xlsm
Condensate Storage Tank(s) 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 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 model (e.g. ProMax, HVSyS, VMG5im( to estimate emissions?
If yes, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific gas sample from the equipment being permitted and conduct an emission
factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
If yes, the permit will contain a "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis.
Will the opeator have a meter installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to
exceed 180 days(. This condition will use the value in cell B31 (scf/hbl(.
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
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?s__,
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 tha
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
Welt has ;list been drilled or recompleted since August 2014, so Reg 7, Sec. XVII.B&G do not apply. Therefore, flare is subject to regubtion 1 requirements for opacity, not noIttsible emission standard, Operator wilt perform one-tme - -
method 9,- but: notperiodic, as this is covered in O&M plan..
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
Process # SCC Code
014 01
Uncontrolled
Emissions
Pollutant Factor Control % Units
lb/1,000 BBL
PM10 0.29 throughput
lb/1,000 BBL Ii.
PM2.5 0.29 throughput
lb/1,000 BBL Ii.
NOx 2.63 0 throughput
VOC 1244.50 95 lb/1,000 BBL Ii.
CO 11.98 0 lb/1,000 BBL Ii.
Benzene 8.99 95 lb/1,000 BBL Ii
Toluene 3.93 95 lb/1,000 BBL li
S of 11
K:\ PA \2017\ 17W E 0409. x l s m
Condensate Storage Tank(s) Emissions Inventory
Ethylbenzene 0.19 95 16/1,000 BBL li,
Kylene 0.94 95 18/1,000 BBL li
n -Hexane 53.38 95 18/1,000 BBL li,
224 TMP 1.69 95 lb/1,000 BBL li
6 of 11 K:\PA\2017\17WE0409.xksm
Condensate Storage Tank(s) Emissions Inventory
.n to go into more detail on the process
!nit downtime" -Brad 7/5/17
when formatted as a "number". Dehy Pi
7
7 of 11 K:\PA\2017\17WE0409.xIsm
Condensate Storage Tank(s) Emissions Inventory
8 of 11 K:\PA\2017\17WE0409.xksm
Condensate Storage Tank(s) Emissions Inventory
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9 of 11 K:\PA\2017\17WE0409.xlsm
Condensate Storage Tank(s) Emissions Inventory
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Section 02 — Re
Section 01— Administrative Information
Request for NEW permit or newly reported emission source
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Section 03 — General Information
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Section 04 — Processing Euuinment Information
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VRT-Natural-Gas-Venting-APEN (2)
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FORM APCD-211
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Ventin
Emission Source AIRS ID:
Permit Number:
Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
Section 05 — Stack Information (Combustion stacks must be listed here)
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Section 07 — Control Device Information
Section 08 — Emissions Inventory Information & Emission Control Information
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Estimation
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Requested Permitted Emissions
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(Tons/Year)
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0.38
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Uncontrolled
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Actual Calendar Year
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Uncontrolled
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Emission Factor
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Control
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95%
195%
195 95%
95%
Overall
Collection
Efficiency
Control Device Description
Secondary
Primary
VOC Burner
VOC Burner I
VOC Burner I
VOC Burner I
Pollutant
oxxO
O
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Benzene
Toulene
C
N
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Xylene
n -Hexane
it
Gabriela Veea
Name of Legally Authorized Person (Please print)
VRT-Natural-Gas-Venting-APEN (2)
FORM APCD-211
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Permit Number:
Noble Energy, Inc.
Company Name:
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Plant Location:
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E-mail Address:
Controlled Actual
Emissions
(lbs/year)
14
Uncontrolled
Actual Emissions
(lbs/year)
277
Emission Factor
Source
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April 14. 2014
Form Revision Date:
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