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Home My WebLink About20132248.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Karin McGowan Interim Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. - Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 July 29, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment RECEIIVED AUG0 tZ0i3 CWELD COUNTY OMMISSIONERS Dear Sir or Madam: On August 1,2013, the Air Pollution Control Division will publish a public notice for Noble Energy — Briggsdale OPF, in the Greeley Tribune. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure Co, vto LIP �I7 2013-2248 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co. us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Website Title: Noble Energy — Briggsdale OPF — Weld County Released To: The Greeley Tribune On: July 29, 2013 Published: August 1, 2013 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Colorado Department of Public Health and Environment 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 Facility: Briggsdale OPF Crude oil polishing facility. E1/2 NEI/4 of Section 25, Township 8 north, Range 63 west Weld County The proposed project or activity is as follows: Crude oil polishing 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I .a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • 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 12WE2008 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 www.colorado.gov/cdphe/AirPublicNotices 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: Michael Cleary Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE2008 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil polishing facility, known as the Briggsdale Processing Facility, located in E1/2 NE1/4 of Section 25, Township 8 North, Range 63 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Point Description 001 Eight (8) tanks, each capable of holding 84,000 gallons (2,000 barrels) crude oil, for storage and separation of oil and water. Emissions are routed to an enclosed flare with a destruction efficiency of 98%. 002 Fugitive emissions from equipment leaks. 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 THOSE 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 after commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, 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. (Reference: Regulation No. 3, Part B, II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction fora period of eighteen AIRS ID: 123/6916 Page 1 of 12 Condensate Tank Version 2009-1 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Point 001: The following information shall be provided to the Division within fifteen (15) days after commencement of operation. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type NO. VOC CO Oil Storage Tanks 001 160 1627 872 Point Fugitives 002 --- 1648 --- Fugitive (Note: Monthly limits are based on a 31 -day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC CO Oil Storage Tanks 001 1.0 9.6 5.4 Point Fugitives 002 --- 9.7 --- Fugitive AIRS ID: 123/9946 Page 2 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. Point 001: The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Oil Storage Tanks 001 Enclosed Flare VOC and HAPs 9. Point 002: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. PROCESS LIMITATIONS AND RECORDS 10. 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Point Process Parameter Monthly Limit Annual Limit 001 Throughput of crude oil 228,125 bbls 2.74 MMbbls The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9946 Page 3 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 11. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, II I.E.) (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 6, Subpart Kb, shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) Point 001: Condensate Oil Storage Tanks 14. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels for which construction, reconstruction or modification commenced after July 23, 1984, including, but not limited to, the following: a. The closed vent system shall be designed to collect all VOC vapors and gases discharged from the storage vessel and operated with no detectable emissions as indicated by an instrument reading of less than 500 ppm above background and visual inspections, as determined in part 60, subpart VV, §60.485(b). b. The control device shall be designed and operated to reduce inlet VOC emissions by 95 percent or greater. If a flare is used as the control device, it shall meet the specifications described in the general control device requirements (§60.18) of the General Provisions. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve AIRS ID: 123/9946 Page 4 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. 15. This source is subject to New Source Performance Standards (NSPS) requirements of Regulation No. 6, Part A, Subpart A, General Provisions.. The perinittee must adhere to the general control device requirements (§60.18) of the General Provisions, including but not limited to: a. Flares shall be designed for and operated with no visible emissions as determined by the methods specified in paragraph e., except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. (§60.18, paragraph (c)(1)) b. Flares shall be operated with a flame present at all times, as determined by the methods specified in paragraph e. (§60.18, paragraph (c)(2)) c. Owners or operators of flares used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs. Applicable subparts will provide provisions stating how owners or operators of flares shall monitor these control devices. (§60.18, paragraph (d)) d. Flares used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. (§60.18, paragraph (e)) e. Method 22 of appendix A to subpart A shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. (§60.18, paragraph (f)(1)) f. The exit velocity shall comply with the applicable section of 40 CFR 60.18 paragraph (f)(4) or (f)(5) (§60.18) Point 002: Equipment Leaks of VOC: 16. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, section III.D.2.a. a. RACT for fugitive equipment leaks from this facility will be the inspection and repair requirements as set forth below: Use either optical gas imaging (i.e. IR camera) or portable VOC measurement instrument (i.e. a Method 21 instrument) calibrated and maintained per the manufacturer's recommendations. ii. Screen all pumps, valves, connectors, and pressure relief devices as follows based on a quarterly basis. iii. If Method 21 is used, component leaks greater than 10,000 ppm shall be managed in accordance with Item (iv) below. If optical gas imaging is AIRS ID: 123/9946 Page 5 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division used, a component shall be considered leaking if any visible emissions are monitored and shall be managed in accordance with Item (iv) below iv. Component leaks shall be managed as set forth below: o A first repair attempt shall be made within five days, with the leak repaired as soon as practicable, but no later than 15 days. Repaired components shall be re -screened within five days of repair to determine if the leak is repaired. If the rescreening shows a leak, then attempt another repair as soon as practicable, but no later than 15 days. Repeat the process until the rescreening shows no leak. o If a leak is detected but it is technically infeasible to make the repair without a process unit shutdown, repair of this equipment shall occur before the end of the next process unit shutdown. Records documenting the rationale shall be maintained, the component placed on the Delay of Repair list, the ID number recorded, and an estimated date for repairing the component included in the facility records. Monitoring to verify the repair must occur within 15 days after startup of .the process unit. o Tag all leaking components with date of leak detected, date of repair and date of rescreening v. The following records shall be maintained and kept onsite for five years and shall be made available to the Division upon request: o List of components screened and associated dates o List of leaking components o List of repaired components along with the repair method and associated dates o List of successful repairs, repair delays, and post -repair screenings and associated dates o Dates of monitoring equipment calibration OPERATING & MAINTENANCE REQUIREMENTS 17. 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. Point 001: A source initial compliance test shall be conducted on the enclosed flare to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with a destruction efficiency of 98% for VOCs and the emissions limits contained in this permit. The test shall determine the mass emission rates of VOCs at the inlet and outlet of the control device, which shall be used to determine the destruction efficiency during the test. The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The protocol shall be submitted to the Division for review and approval at least thirty (30) days prior to AIRS ID: 123/9946 Page 6 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division testing. No compliance test shall be conducted without prior approval from the Division. (Reference: Regulation No. 3, Part B., Section IIl.G.3) Volatile Organic Compounds using EPA approved methods. 19. Point 001: The owner or operator shall demonstrate compliance with Condition 15 using EPA Method 22 to measure opacity from the flare, This measurement shall consist of a minimum twenty-four consecutive readings taken at fifteen second intervals over a six minute period. (Reference: Regulation No. 1, Section II.A.1 & 4) 20. Point 002: Within one hundred and eighty days (180) after commencement of operation, the owner or operator shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 21. Point 002: Within one hundred and eighty days (180) after commencement of operation, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 22. Point 001: On a weekly basis, the owner or operator shall demonstrate compliance with Condition 15, using EPA Method 22 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.1 & 4). 23. Point 002: On an annual basis, the owner or operator shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually 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 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. AIRS ID: 123/9946 Page 7 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 25. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) 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 No. 3 Part D). GENERAL TERMS AND CONDITIONS 26. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. 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 No. 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. 28. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 29. 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. 30. 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 applicant, or the Division revokes a permit, the applicant AIRS ID: 123/9946 Page 8 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 31. 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. 32. 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: Michael Cleary Permit Engineer Air Pollution Control Division Permit Histo Issuance Date Description Initial Approval This Issuance Issued to Noble Energy, Inc for crude oil storage tanks and fugitive emissions at a new synthetic minor facility. AIRS ID: 123/9946 Page 9 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder: 1) 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 permittee 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 application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee 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: http://www.cdphe.state.co. us/requlations/airreqs/100102agcccommonprovisionsreq.pdf. 3) 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. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Benzene 71432 A 16873 Yes 337 224 -IMP 540841 C 3777 Yes 76 n -Hexane 110543 C 55172 Yes 1103 Toluene 108883 C 9771 Yes 195 Ethylbenzene 100414 C 812 No 16 Xylene 1330207 C 3332 Yes 67 002 Benzene 71432 A 102 Yes 102 Toluene 108883 C 19 No 19 Ethylbenzene 100414 C 2 No 2 n -Hexane 110543 C 125 No 125 Xylene 1330207 C 17 No 17 4) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS Pollutant Emission Factors - Uncontrolled lb/bbl oil Emission Factors — Controlled lb/bbl oil Source NOx 6.86E-04 6.86E-04 AP -42 CO 3.75E-03 3.75E-03 VOC 0.349 1.75E-02 Engineering Calculation 108883 Benzene 6.16E-03 6.98E-03 100414 Toluzene 3.57E-03 1.23E-04 110543 Xylene 1.22E-03 7.14E-05 71432 Hexane 2.02E-02 5.93E-06 AIRS ID: 123/9946 Page 10 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division CAS Pollutant Emission Factors - Uncontrolled lb/bbl oil Emission Factors — Controlled Ib/bbl oil Source 540841 224-TMP 1.38E-03 2.43 E-05 • The emission factors included in this permit are derived by applying a factor of 2.0 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. • The controlled emission factors for point 001 were based on an enclosed flare control efficiency of 98%. Points 002: Emission estimates for fugitive equipment leaks are based on the following component counts and VOC content percentage. This component count is not intended to create an enforceable limit, but instead to provide the basis for emission calculations. Fuel Gas Train Process Train Component Gas Light Oil Gas Valves 110 125 40 Pump Seals 0 6 0 Others 6 0 20 Connectors 0 60 0 Flanges 220 270 80 Open-ended lines 0 20 0 VOC Content (wt%) 24.45% 100% 100% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents Emission Factors for Total Organic Compounds (kg/hr-component): Component Gas Service and Fuel Gas Light Oil Connectors 2.0E-04 2.1E-04 Flanges 3.9E-04 1.1E-04 Open-ended Lines 2.0E-03 1.4E-03 Other 8.8E-03 7.5E-03 Pumps 2.4E-03 1.3E-02 Valves 4.5E-03 2.5E-03 Source: EPA -453/R95-017 5) The following equipment is currently exempt from construction permitting requirements and/or APEN reporting requirements based on information provided by the operator for the Division's analysis: AIRS ID Facility ID Description Notes NA Polishing Three (3) Maxon Oven- These units are exempt from APEN Heaters (3) Pak -Le -35 3.5 MMBtu burner and pilot (low reporting requirements because the design rate is less than 5 MMBtu/hr each NOx), controls, regulators, valves, gauges, and piping. (Regulation No. 3, Part A, II.D.1.k), and are therefore also exempt from construction permitting requirements Natural gas fired, (Regulation no. 3, Part B, II.D.1.a). AIRS ID: 123/9946 Page 11 of 12 Noble Energy, Inc. Colorado Department of Public Health and Environment Air Pollution Control Division indirect heat. Criteria pollutant emission levels for these units are based on factors from AP -42, Chapter 1.4, Small Boilers < 100 MMBtu/hr (7/1998). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source: VOC, n -Hexane, total HAPS NANSR Synthetic Minor Source: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 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 AIRS ID: 123/9946 Page 12 of 12 Construction Permit Application Preliminary Analysis Summary FACILITY -WIDE PERMIT Section 1 — Applicant Information Company Name: Noble Energy Permit Number: 12WE2008 Source Location: E1/4 NE1/4 of Section 25, T8N, R63W Equipment Description: Point 001: Eight (8) tanks, each capable of holding 84,000 gallons (2,000 barrels) crude oil, for storage and separation of oil and water. Emissions controlled by the enclosed flare. Point 002: Fugtive emission from equipment leaks AIRS ID: 123-9946 Date: April 17, 2013 Review Engineer: Michael Cleary Control Engineer: Chris Laplante Permit Draft Location. K:/PERMITS/2012/12WE2008.CP1 Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X Initial Approval Transfer of Ownership APEN Exempt/Permit Exempt Section 3 — Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? 5/31/2012 Section 4 -- Source Description AIRS Point Equipment Description 001 Six (6) tanks, each capable of holding 84,000 gallons (2,000 barrels) crude oil, for storage and separation of oil and water. Emissions controlled by the flare. 002 Fugitive emission from equipment leaks Other Reference Notes to Permit Holder, #5 for information on equipment that is exempt from construction permitting requirements and/or APEN reporting requirements. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM,() CO X Ozone Page 1 Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM10 CO Ozone Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 001 VOC/HAPs: Site -specific using Tanks 4.0.9, HYSYS and the displacement equation/Wt. fraction. (see Section 14 for details); CO and NOx: AP -42, Section 13.5 Table 13.5-1 002 EPA -453/R-95-017, Table 2-4 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit (PTE). AIRS Point Process Consumption/Throughput/Production 001 2,737,500 bbls/yr 002 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 0 0 60 0 Flanges 300 0 270 0 Open -Ended Lines 0 0 20 0 Pump Seals 0 0 6 0 Valves 150 0 125 0 Other 26 0 0 0 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 2,737,500 bbls/yr 002 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 0 0 60 0 Flanges 300 0 270 0 Open -Ended Lines 0 0 20 0 Pump Seals 0 0 6 0 Valves 150 0 125 0 Other 26 0 0 0 Does this source use a control device? X Yes No AIRS Point. Process Control Device Description Reduction Granted 001 01 Cimmarron Enclosed Flare 95 Section 6 — Emission Summary (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 001 --- 478.0 --- 27.6 (Hexane) 43.0 002 --- 9.7 --- 0.06 (Hexane) 0.1 Total: --- 487.7 --- 27.7 (Hexane) 43.1 Page 2 Uncontrolled point source emission rate: 001 --- 478.0 --- 27.6 (Hexane) 42.6 002 --- 9.7 --- 0.06 (Hexane) 0.1 Controlled point source emission rate: 001 1.0 9.6 5.2 0.55 (Hexane) 0.7 002 --- 9.7 --- 0.06 (Hexane) 0.1 Total: 1.0 33.6 5.2 0.61 (Hexane) 0.8 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled I Arelhe Controlled Emission Emission Rate I emissions (Ib/yr) ' reportable? I Rate (lb/yr) Point 001 Benzene 71432 I A 16873 Yes 337 224-TMP 540841 C 3777 Yes 75 n -Hexane 110543 C 55172 Yes 1103 Toluene 108883 C 9771 Yes 195 Ethylbenzene 100414 C 812 No 16 i Xylene 1330207 C 3332 Yes 67 Point 002 Benzene 71432 A 102 Yes 102 Toluene 108883 C 19 No 19 Ethylbenzene 100414 C 2 No 2 n -Hexane 110543 C 125 No 125 Xylene 1330207 C 17 No 17 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8 —Testing Requirements Will testing be required to show compliance with any emission rate or regulatory standard? Yes X I No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 001 01 VOC, HAPS State only requirement Stack Test 002 01 HAPS State only requirement Gas Analysis 002 01 VOC, HAPS State only requirement Hard component count Section 9 - Source Classification Is this a new previously un-permitted source? Yes X No What is this point classification? Point 001 I True I Minor X Synthetic I Minor Major Page 3 Point 002 X True Minor Synthetic Minor Major What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Self-Cert Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 — Modeling Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? If "yes", for which pollutants? Why? Yes X No AIRS Point Section 12 — Regulatory Review Regulation 1 - Particulate, Smoke. Carbon Monoxide and Sulfur Dioxide 001-002 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases 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 2 — Odor 001-002 Section I.A - 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. Regulation 3 - APENs. Construction Permits, Operating Permits, PSD 002 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. (Applicant is required to file an APEN since emissions from condensate production exceed 1 ton per year VOC) 001-002- Part B — Construction Permit Exemptions Applicant is required to file a permit since uncontrolled VOC emissions are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a) Page 4 002 Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the fugitives emissions from a source that will have begun service after the date above, this source is considered "new or modified." Since source is in attainment, RACT is required. The permit will include the Division's standard LDAR language Regulation 6 - New Source Performance Standards 001 NSPS OOOO This is a future facility and the tanks will be considered "new". Therefore, this regulation is applicable. Emission from tanks with potential emissions greater than 6 tons per year shall control emission by 95% or greater. These tanks are subject to 40 CFR Part 60 - Subpart Kb and, thus, exempt from the control requirements in Subpart OOOO. Emissions from these tanks are routed to a thermal oxidizer with a control efficiency of 98%. NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? Yes Is this source subject to NSPS Kb? Yes WHY? Tank capacity is 2000 barrels each 002 NSPS OOOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. For fugitive emissions at natural gas processing plants subject to NSPS OOOO. This subpart establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (SO2) emissions from affected facilities that commence construction, modification or reconstruction after August 23, 2011. Is this source at a "natural gas processing plant?" No Is this source subject to NSPS OOOO? No WHY? Source is an oil polishing facility not engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids (NGLs) or both). NSPS KKK: Equipment Leaks of VOC from onshore natural gas processing plants. Affected facilities at onshore natural gas facilities (any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids (NGLs) or both). Source is an oil polishing facility is not engaged in either the extraction of natural gas liquids from field gas, or the fractionation of mixed natural gas liquids (NGLs) or both). Regulation 7- Volatile Organic Compounds 001 Source is used for the storage of crude oil and, thus, this regulation does not apply. 002 Section XII.G This facility is a not natural gas processing plant located in non -attainment area, therefore, not subject to Section XII.G. Re. ulation 8 — Hazardous Air Pollutants 001 002 MACT EEEE: Organic Liquids Distribution • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH • This source is not subject to MACT HH because it is not located at a major source of HAP. Page 5 MACT HH: If facility is MAJOR source for HAP at a natural gas processing plant ONLY (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. 002 Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Source not subject to MACT HH because it is an area source Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Factor Pollutant / # Fugitive (")CAS () Emission Factor Source Control (ova) 001 01 Condensate Storage Tanks 0.0068 Lb/MMBtu N0x No AP-42 --- 0.370 Lb/MMBtu CO No --- 8.314 Ibs/g1a 00 al V0C No See Section 14 98 0.147 Ibslg1a 00 Benzene No 98 0.085 Ibs//1000 gal Toluene No 98 0.007 Ibs/1000 gal Ethylbenzene No 98 0.029 Ibs/g1a 00 Xylenes No 98 0.480 Ibs/g1a100 a0.033 n -hexane No 98 Ibs/�1a 00 224-TMP No 98 SCC 40400312 — Fixed Roof Tank, Crude Oil, working+breathing+flashing losses Point Process Process Description Pollutant / CAS # Fugitive (Y/N) Emission Factor Source Control (%) 002 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95-017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Page 6 Section 14— Miscellaneous Application Notes Single Source Determination The Division evaluated whether or not an oil polishing train operated by Noble, and tanks operated by Rose Rock as part of the Briggsdale Station should be considered part of a single stationary source. Summary Description of Source Operations Tank trucks carry and deliver stable oil for Noble Energy to the truck unloading facility owned and operated by Rose Rock located at the Briggsdale Station. The stable oil is analyzed in the truck unloading facility to determine if it meets specifications for basic sediment and water (BS&W) content. If the oil meets BS&W specifications required by Rose Rock, the oil is transferred via pipe to oil storage tanks owned and operated by Rose Rock and eventually into the White Cliffs Pipeline to be delivered to Cushing, Oklahoma. If oil does not meet the required BS&W specifications it is transferred via pipe to one of the oil polishing trains owned and operated by Noble to bring it into specification before being transferred to the oil storage tanks owned and operated by Rose Rock. Meeting the BS&W specification is required by Rose Rock to minimize impurities such as sediment which may partially block the flow in the pipeline or contribute to the erosion of the pipeline's interior surface. In addition, excess water in the oil contributes to corrosion of the pipeline. Therefore, Noble Energy's oil polishing operations have been deemed integral to each company being able to deliver their oil to the Rose Rock pipeline injection operations. Using the 3 -Part Test, the following emissions sources evaluated in this stationary source determination include the Noble Energy oil polishing operations and the Rose Rock oil unloading, storage and pipeline injection operations. 1. Are the operations located on contiguous or adjacent properties? The Noble Energy operation and the Rose Rock operations are located on contiguous properties and are connected by a road and piping. 2. Are these facilities all classified under the same major two -digit Standard Industrial Classification (SIC)? Absent the same two- digit major SIC Code, activities may belong to the same industrial grouping if one activity is characterized as a support activity for the primary activity. The Division determined the Noble Energy oil polishing activities do have a support facility relationship with Rose Rock's primary operations. Thus, these operations are considered to be under the same major SIC code 4612 for the purpose of this source determination analysis. 3. Are these facilities under common ownership or common control? Rose Rock and Noble Energy are all separate corporate entities (i.e. no common ownership). Absent common ownership, common control may still exist. The Division may determine common control by looking at relevant factors such as if a support/dependency relationship exists. The Division determined a support/dependency relationship exists between each oil polishing and the oil storage and pipeline transfer operation since the pollutant emitting activities have significant operational ties to one another. Noble Energy maintains a contractual relationship with Rose Rock. Including an elements that stipulates Noble must meet minimum monthly volumes of deliverable oil to Rose Rock. Noble Energy also uses the oil loading rack owned by Rose Rock to offload their product from tanker trucks in order to move their product on site and, as needed, to their respective oil polishing facilities. Each of these facts was influential in the Division's decision. The Division has concluded that these facilities satisfy the requirements and should be considered part of a single stationary source. Page 7 Section 14 —Miscellaneous picaiA ftono Notes AIRS Point Extended gas analyses was provided in the application with a sampling date of May 3, 2012. Product processed at this facility is brought in via tanker truck from multiple locations. Analyses are from four of the Company's sites in the area. An average of these analyses was used in emission estimate computations. This is a reasonable approach for establishing permit limits for this facility prior to construction. The product brought to this facility is reportedly stabilized. It would seem unlikely that significant variance would occur so further site specific sampling will not be required. Working and breathing losses were estimated using EPA Tanks 4.0.9d. The entire daily throughput of 7,500 barrels was modeled in one (1) tank and the resulting output multiplied by the number of tanks (8). This approach yields conservative results but the operator chose to double (x2) these estimates for further factor of safety (F.O.S.). 001 Crude Oil Storage Tanks 23,284.55 lbs ton x 8 tanks x 2 (F. 0.5.) = 186.28 TPY VOC yr x 2000lbs This facility is designed to take oil that contains solids and water and heat it to facilitate separation. The temperature of the product is estimated to rise from an average starting temperature of 70°F up to as high as 120°F. This reduces surface tension and viscosity of the oil and thus assists in releasing gas that is hydraulically retained in the oil. Heating losses were estimated using the Aspen HYSYS modeling system. The resulting estimates were also doubled for a factor of safety. 20.21 lbs 8760 hrs ton hr x 2(F.O.S.) x yr x 2000 lbs = 177.04TPYVOC Blanket gas is be used to prevent ingress of air into the storage tanks. The addition of this gas contributes to VOC and HAP emissions as it is displace by liquid added to the tank. Operator provided an extended gas analysis and emissions were calculated using EPA Emission Inventory Improvement Program Publication, Volume II, Chapter 10 -Displacement equation (10.4-3) where: 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 Emissions generates from me oianKet ga Uncontrolled Total (lb/yr) VOC 229,348 n -hexane 4,584 224-TMP 0 Benzene 5,694 Toluene 933 Xylenes 537 Ethylbenzene 64 s are: Emission of CO and NOx resulting from the combustion of these gases was estimated using AP -42 emission factors from Section 1.4, Table 1.4-1. Volumetric flow -rate estimates of gas being routed to the flare were based upon EPA Tanks and HYSYS output reports. Page 8 AIRS Point 001 Crude Oil Storage Tanks TOTAL= Working & Breathing + Heating losses + Blanket gas displacement 186.28 + 177.04 + 114.67 = 477.99 TPY Lb/1000 VOC 477.99 x 2000 - 2737500 bbl/yr = 0.349 lb/bbl 8.31 gal Lb/1000 Benzene 16872.89 lbs + 2737500 bbl/yr = 6.16e-03 lb/bbl 1.47e-02 gal Lb/1000 Toluene 9771.54 lbs 2737500 bbl/yr = 3.57e-03 lb/bbl 8.50e-02 gal Lb/1000 Ethylbenzene 812.26 lbs + 2737500 bbl/yr 2.97e-04 lb/bbl 7.06e-03 gal Lb/1000 Xylenes = 3332.19 lbs - 2737500 bbl/yr = 1.22e-03 lb/bbl 2.90e-02 gal Lb/1000 n -hexane = .55172.47 lbs + 2737500 bbl/yr 2.02e-02 lb/bbl 4.80e-01 gal 6/11/2013: The control percentage of 98% exceeds that standard for an enclosed flare. A condition requiring the operator demonstrate the destruction efficiency is warranted and will be included in the Initial Testing Requirements section of the permit. Section 14 — Miscellaneous Application Notes AIRS Point 002 Fugitive Emissions A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (attainment, permit threshold). Emissions were based upon "estimated" component counts. The permit will contain a condition requiring an actual count. Emissions calculations were executed using a gas composition compiled as an 'average' of the analyses of four Noble sources. Page 9 Cl o- 0 a N Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] co 9 9 \tl 3 R s. O On O nested Action (Check applicable request boxes) Section 02 — Re Section 01— Administrative Information 0 W A LC Z fr.; O W r a 8 p, V Q z 0 .• .00 - • 0 O oo p 0 a) F R c V 0 'F o a 3 COd Ot W O cc 0. o z Z O 00 00 ,, gar F .0 Fccl W Q En 41 00 U U 0 0 0 al a c4❑❑a a co - t 0 00 O 45 b K U 4 U ai 0. Z n W N E1/2 NE1/4 SEC25 T8N R63W Source Location: 1625 Broadway, Suite 2200 Mailing Addres 0 0 o R. O O c 6 0 G O —' C d 0 O w O C b0 o 0 y o 0 0 .0 >. `d E b Y U W p C 0 R • o >+ 0 0 O 6 CO 'd 0 0.4 0411) 2 ❑ ❑ Taryn Phillips Person To Contact: tph illips@n obleenergyinc E-mail Address: tiz Section 03 — General Information N For new or reconstructed sources, the projected startup date 52 weeks/year 3 3 O 0 c "0 C] 0 ❑ ❑ zzzz ® ❑ ® ❑ Q CO ❑ Z ❑ ® r R m •O O 0 a m oR an 0 7: m O ^ O5 Z Fa y. C C y .a .i• °o c k :? ctl. R w O ° 0 7a G 0 t. O 6 c G > a a ° >4- X � � V a a p. p .. 3. O U b p c g 2 0 0 0 t-, m Z o Q o 3 Al O -a y o vy U 00 O c 0 o N 3 cL ° R 3 .O 4 °' x 3 E 0 .. - P L-- �7 6. "I '� '� y. C. c°3 0 C, , C p C a 0 o ^ X m 0 o m^ c a cc O C 6 0 0 O i. o a N 9 • Vl V] AlI -, '00 N N N N O N O o O Z Z O O O C C 0 0 0 U O .9 CO 0 4),t O' 2 0 O N Q 7 N 0 Q C➢ b!0p ..g roil �.a'7, 1 �.. p, 0 O T O O yt C FL ,c! U 0 a 0 0 R 0 0 y b m 7 E '° a W0 e N C -. a) a) p .0 .0 G E T O`.0 p 4 ti 0 ° F F >~ m O 'e O O R2 Co y a, U O. a3i 0 Al , C X MR 0 Q o ro C o0 .. �. C U O 0 O.- 7r' R w o o O E.n°J" " 0. 8 .o � � Ew'? I O y T 0 C 0 E ° '0- Qa � 0 ° 'z O A A A 4 v wn ° o Mi O 6.3 R N C' C uO-1 00 v 0 G X Eft, 0 i 'O 0.. 0 ok l '.q, cod R w.c \c,, 00 N> p R F 64„E .-.... .0 q GO 0 0 u. -, O F C O a -CO 0 0 .,S s. C R Q 0 N ,. 0 d R U O CA X O x i-00 pa, m 0 .�. 0 T o 2. u m •G e O O O F a' R •b0 O ) F 0. U 2 O .CO Y .,„ W 0 .> 0 a , O •3 O i. On O 4 R Y. a c E c q'^ o an .2 > is 0° Lg. L N i O Qy4, F Ev°'^'U°°U.. °°' O cu bO q V] L O OU c y O u U a'gy m '2 Rvc4 i :° an y u = N o U o > 000 0`. '' (1° R.LOQY0N F H o'.cc> w UQaq w Qri� 0 O F O co N M M M D C ON ''o O '0 ' 0 0 0 0 ° en c22, M > 0 G O N E i R v U .c 0 w cW 0 ti .0 z P O 0 m D "9 - p 0 0 1/40 A. True Vapor Pressure: O % Al l't.qa' P. {� CO m co N O C an U ,'C is O'O O.20Y0000O c O Ed F d M N 00 a a M 'O U .C ° 0 • 0 ." R 7 N > O U .C m m R y x o m- E 0 w d 0-4 c >. ^ y O R p °O, m m 9 = a 0 E to J U b C cC U N a 0 Y 0 E :: a 0 0 G 0 A m G 5 J 7 O d .4 0 v 0 c U c C F 0 o < a 'O O P. o n d a o c 14 o i .0 s u U U 0 i h y 03 C co 0 o a' P. t botr yCL, 4-> 0 1- y O W T N C roams R E 3 a Cd N o. > O ' U O IO c T C N :O 2 N 0 2 o . 8 O 0 0 b X N N E m 5..; w 9 ..N. o 0 C 0 0 e' y ° • F C H 0 O N P. 0 .0 .F cn N •y Z o 9 H H 0. 000.Q R W W ro 6 6 Q Q Q ❑ El IZ CO R o R ° 9 0 C a4a 123-9946-001-APEN-2012-05-31-01 CD " J FORM APCD-204 • -140 iJI SSION NOTICE (APEN) & Application Emission Source Permit Number: v o 8. 734 ft ° F� f3 vi d ❑' 0 O v 0 on 0 C Gil Section 07 Control Device Information O 0 6 44. H 0 0 O U 444 O O 0 0 6 w 14 O d a 00 0 u 6) rip 00 v V U.' a O 0 s 0 q C L ea O C G V is V V G 4 Vd C0 A HYSYS/EPA Tanks HYSYS/EPA Tanks HYSYS/EPA Tanks HYSYS/EPA Tanks C C 1- <4 a rn Non -Criteria Reportable Air Pollutant Addendum form to re •ort iollutants not listed above. Requested Permitted • Emissionss Uncontrolled Controlled (Tons/Year) Tons/Year) _ Actual Calendar Year Emissions4 Controlled . (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units : .0.0 -25 .0 1 .0 .0 .0 .0 .0 .c .0 .0 .0 .0 ,. .0 .0 .a Uncontrolled Basis 0.30 M O © O O O 4 O O O O O' Control Efficiency (% Reduction) Identify in Section 07 Please use the APCD Control Device Description Secondary 0 a. Pollutant VOC CO 0 Xylene n -Hexane O i a) Z E•••• MI 0. .5 Environmental En .n Q. Q w 0 a 0 O 0 QT— • i to Q I �s N O70 6) Q+ Cf y N V 0 Cr O a U Con 4.. O U S.i 4.1 0 z Wl CU E^I z W 1.13 N }G� IR }a p rs [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: 0 N a) a 0 7 F a. 0 O a) Q F T4 W w •o p. P a A m O 0 0 m ,---,,---,F mF o c cii kcU ta a T A t u a cn y d C74 N L y z en N E 2, A o v cz y L Po o a d ❑ ❑ a v c O vC aG.. P. o y z .c a 01 ¢ O -el o .n y4 d y 0 . PO P 3 0 m '� n, a 0 z o 00 00 o E E CY d 0 0 c C' a a ❑ ❑ Section 02 — Re Section 01— Administrative Information O CO M Transfer of ownership T Request to limit HAPs with a Federally enforceable limit on PTE O 00 FO ,0 L7 U o > U Z up W N Noble Energy, Inc Briggsdale Processing Facility E1/2 NW1/4 SEC 25 T8N R63W Source Location: 1625 Broadway, Suite 2200 T Tri Jt F . q O - d '. y .0 c. - d 0 0 L.--. o 0 C u F .0 0rn O m x o 9 0 ' F .0 s. .0 u 4 C N C 0 'z O o w up o C 0 o 0 U (p y a m o . FLn-0 z 0 u g W : c z al z ❑ ❑ Mailing Address: Phone Number: 303-228-4362 Section 03 — General Information For new or reconstructed sources, the projected startup date i ti m od 'O N 3 a Jai N M x G 3 0 a 0 al 0 N n 0 z 0 o N h these components: C d 0 m z o aO O .0 ', o c 0 d ut 0 w N W 0 L w0 c 0 O 0 0. o 'C. x 7a 0 G 0 p ' w° Z w" O a)O o 0 a 0 c.:0:: o , ,,,,, c,c 1.4 cPfi Ca p L' 1.->i CS /a): N1MM o12 .d 0.Ui> E 0 0 7-1 1 M a M QC tact, '74 SA G -' W 000 N� �f .—,Z p c = O o Q N cc U 'o y 44rn v C> C> 2 7.m 3 a0i .. r7. 5 P o. C T. F N Y ) N V w o Lo a u s ❑ 0.. o 3 4U. v5.'o, 0 c a Oc. 3 m e > y. 3 '° O0>c0i3 }"4+LY;C:°4 MQ^1.roGqV1c. p"b�•oE`n o Q L N >.VR LN F p Q' LNd ^r00O.AO O O,G Co 0 u G.a yort y fL E .�. p N Vl -a .O µ. U �. 0 a 2 g o m '5 0 ._ z ,0 ap. .r o C.1 UCD v W G F WW, a o F .o 0 0 0 _o 0 ❑ ❑ ❑ z a) 0 m c a) N o F G C. 0 Vi a d O C c o om a o F n • 0 3 3 • 30 Information 0 a Section 04 — Re z z E El r r ❑ ❑ Is this equipment subject to NSPS 40 CFR Part 60, Subpart KICK? ast cco o 0, rx U a W cr List any other NSPS or NESHAP Subpart that applies to this equipment: Section 05 — Stream Constituents ® n -Hexane (wt. %) N In o O: .. .o .. Xylene (wt. %) '0 a O N ti O O Ethylbenzene (wt. %) I0'0 CO 0 v ., y e .-1 ❑ p f a .y 0 N 0 ..i Benzene I (wt. %) N O o 0 o a r4 Ue y'2, N I E Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 0 rn aa C7 co ,— O I U G O E o I 0 a ~ G0, m o O Lf0 0 o 0 I a a ri 0 O O N R d m G a 4- 'o < w w I 0 0 a >... 0 O 0 0 0 cO en cs, 0 0 C 0 0 O4 0 Ol 01 L I 0 o m O O N .l P .0 CD o 0 U c 0 Tdd G 0 an 0 0. E9 0 X 0 H � to Cr) c N O 00 a. FORM APCD-203 b Emission Source Permit Number: & Control Informatio Section 07 —Leak Detection & Re Section 06 — Location Information (Provide Datum and either Lat/Long or UTM) 4) TA 444 ▪ b) 03 2 • Q• /� (�• 1- lI •rx 0 0 0 u� W ❑ LDAR per NSPS O Other: En z N R ❑ ❑ aN ) w 0 0 L a 0 b ar a C O 0 a .y o t� m E u4.4 C O 0e W k h C F � E +� A .o a; co ▪ a ° O 4 44 F 0 N b� y u L CI.) 0 L as M u CI -1 I _1- .7-: U . 0 0 0 0 0 0 Light Oil (or Light Liquid) Units Cc l Count' ,o 270 N 125 Heavy Oil (or Heavy Liquid) I Units Counts E.F. 0 0 0 0 0 0 co cs Units M Li 3 1 S Counts 0 302 OS/ 0 0 Equipment Type Connectors Flanges Open -Ended Lines Pump Seals Valves Other c O 00. 11 0 v V b c 0 C 7 0 4) U I si$ Section 09 - Emissions Inventory Information & Emission Control Information Estimation Method or Emission Factor Source EPA Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions3 Controlled (Tons/Year) lei HAP Total L. P I Limits I '6 L. 1-t Uncontrolled (Tons/Year) oo ci d7 o N Actual Calendar Year Emissions2 Controlled (Tons/Year) Uncontrolled (Tons/Year) not reportable not reportable not reportable not reportable not reportable Emission Factor Uncontrolled Basis Units. Identify in Section 07 Identify in Section 08 Control Efficiency (% Reduction) LControl Device Description Primary Secondary Pollutant Benzene IToluene I Xylene V U o °4) g w xK . in Sec. 03 - 09. .o 2 • 4) N o gN 6611 73 • 6 a�A e > o A p, ? O I fJ q U b yr' G 03 •9. o 00 SR O 8 8 �o O R U O �O y d 51 74 9 a6 o • o • vl N -0 goo if y � U � • E g Section 10 —A o b0 0 0 0 00 N O1 7 z W 104 0 N w 0 N c al Hello