HomeMy WebLinkAbout20132852.tiffSTATE OF COLORADO
John W. Hickenlooper, Governor
Larry Wolk, MD, MSPH
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. Laboratory Services Division
Denver, Colorado 80246-1530 8100 Lowry Blvd.
Phone (303) 692-2000 Denver, Colorado 80230-6928
Located in Glendale, Colorado (303) 692-3090
www.colorado.gov/cdphe
Weld County Clerk & Recorder
1402 N 17th Ave
Greeley, CO 80631
October 2, 2013
Dear Sir or Madam:
RECEIVED
OCT 0t2013
WELD COUNTY
COMMISSIONERS
Colorado Department
of Public Health
and Environment
On October 5, 2013, the Air Pollution Control Division will publish a public notice for Noble Energy, Inc —
Keota Gas/LNG Plant, in the 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 I
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
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2013-2852
STATE OF COLORADO
John W. Hickenlooper, Governor
Larry Wolk, MD, MSPH
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
www.colorado.gov/cdphe
Laboratory Services Division
8100 Lowry Blvd.
Denver, Colorado 80230-6928
(303) 692-3090
Website Title: Noble Energy, Inc — Keota Gas/LNG Plant — Weld County
Released To: The Greeley Tribune
On: October 2, 2013
Published: October 5, 2013
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
Colorado Department
ofPublic 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, Inc
Facility: Keota Gas/LNG Plant
Natural Gas Processing Plant
NW Section 21 T9N R61 W
Weld County
The proposed project or activity is as follows: Noble is proposing construction of a new natural gas processing
plant in Weld County.
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 13 WE 1736 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:
Peter Armington
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B 1
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: 1 3WE1 736
DATE ISSUED:
ISSUED TO:
Noble Energy, Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section 21,
Township 9N, Range 61W, in Weld County, Colorado
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
TBN 1
001
One (1) Solar, Model Taurus 60, Serial Number TBD, natural-gas
fired, combustion turbine rated at 7,700 horsepower, RPM to be
determined. The turbine is design rated for a heat input of 61.33
MMBtu/hr (LVH). This turbine is used for electric generation. This
turbine is equipped with SoLoNO, technology. Emissions from the
turbine are not controlled.
TBN 2
002
One (1) Solar, Model Taurus 60, Serial Number TBD, natural-gas
fired, combustion turbine rated at 7,700 horsepower, RPM to be
determined. The turbine is design rated for a heat input of 61.33
MMBtu/hr (LVH). This turbine is used for electric generation. This
turbine is equipped with SoLoNO„ technology. Emissions from the
turbine are not controlled.
These turbines may be replaced with other Solar, Model Taurus 60 turbines in accordance
with the temporary turbine replacement provision or with another Taurus 60 in accordance with
the permanent replacement provision of the Alternate Operating Scenario (AOS), included in
this permit as Attachment A.
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:
AIRS ID: 123/9629/001-002
Page 1 of 15
Turbine SM/M Version 2012-1
t of Public Health and Environment
Air Pollution Control Division
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 for a period of eighteen
months or more; (Hi) 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, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• 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
Tons
per
Month
Emission
Type
NO„
VOC
CO
SO2
PM10
PM2,5
CO2e2
TBN 1
001
4,535
934
5,504
---
815
815
3,047
Point
AIRS ID: 123/9B29/001-002
Page 2 of 15
TBN 2
002
4,535
934
5,504
815
oPublic Health and Environment
Air Pollution Control Division
815
3,047
Point
Monthly limits are based on a 31 -day month.
2CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each
greenhouse gas emission multiplied by global warming potential for each greenhouse gas. The
greenhouse gas emissions in this inventory include CO2, CH4 and N2O.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 Year3
Emission
Type
NO,
VOC
CO
SO2
PMio
PM2.5
CO2,
TBN 1
001
26.7
5.5
32.4
---
4.8
4.8
35,881
Point
TBN 2
002
Point
3 The annual emissions limits contained in this table represent the combined allowable emissions for
both turbines combined. Noble's emissions for these two points are limited to the equivalent of one
turbine operating at 100% annual capacity.
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 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.
GREENHOUSE GAS (GHG) REQUIREMENTS
8. The owner or operator shall calculate, on a monthly basis, the amount of CO2 emitted from
fuel combustion using equation C -2a in 40 CFR Part 98 Subpart C, default natural gas CO2
emission factor in Table C-1, measured actual heat input (HHV), and measured actual
monthly natural gas volume combusted. The gas volume may be estimated using
manufacturer data and hours of operation during periods of meter downtime. Downtime
shall not account for greater than 5% of any rolling six month period.
AIRS ID: 123/9B29/001-002 Page 3 of 15
Public Health and Environment
Air Pollution Control Division
9. The owner or operator shall calculate CH4 and N2O emissions from fuel combustion on a
monthly basis using equation C -9a of 40 CFR Part 98 Subpart C, default CH4 and N2O
emission factors for natural gas contained in Table C-2, measured actual heat input (HHV)
and measured actual monthly natural gas volume combusted. The gas volume may be
estimated using manufacturer data and hours of operation during periods of meter
downtime. Downtime shall not account for greater than 5% of any rolling six month period.
10. A complete record of the methods used, the measurements made, and the calculations
performed to quantify monthly natural gas combusted shall be kept.
11. The owner or operator shall calculate the CO2e emissions based on the procedures and
Global Warming Potentials (GWP) contained in Greenhouse Gas Regulations, 40 CFR Part
98, Subpart A, Table A-1
PROCESS LIMITATIONS AND RECORDS
12. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate 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
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly
Limit (31
days)
TBN 1
001
Consumption of natural gas as a
fuel
537.3
MMscf/yr
91.3
MMscf/month
TBN 2
002
The annual process limits contained in this table represent the combined allowable limit for both
emissions points combined. Noble's fuel consumption and hours of operation for these points are
limited to the equivalent of one turbine operating at 100% annual capacity.
The owner or operator shall calculate monthly process rates based on the calendar month.
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
13, 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, III.E.)
(State only enforceable)
14. 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 7, Sections
AIRS ID: 123/9B29/001-002 Page 4 of 15
o Public Health and Environment
Air Pollution Control Division
XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
15. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
16. This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation 1 including, but not limited to, the following (Regulation 1, Section III.A.1)::
a. Emissions of sulfur dioxide shall not emit sulfur dioxide in excess of the following
combustion turbine limitations. (Heat input rates shall be the manufacturer's
guaranteed maximum heat input rates).
New sources (Regulation 1, Section VI.B.4.c):
Combustion Turbines with a heat input of less than 250 Million BTU per hour:
0.8 pounds of sulfur dioxide per million BTU of heat input.
17. These units are subject to the New Source Performance Standards requirements of
Regulation 6, Part B including, but not limited to, the following (Regulation 6, Part B, Section
II):
a. Standard for Particulate Matter — On and after the date on which the required
performance test is completed, no owner or operator subject to the provisions of this
regulation may discharge, or cause the discharge into the atmosphere of any
particulate matter which is:
(i) - For fuel burning equipment generating greater than one million but less than
250 million Btu per hour heat input, the following equation will be used to
determine the allowable particulate emission limitation:
PE=0.5(FI)-o.26
(i)
Where:
PE is the allowable particulate emission in pounds per million Btu heat input.
Fl is the fuel input in million Btu per hour.
(ii) Greater than 20 percent opacity.
b. Standard for Sulfur Dioxide — On and after the date on which the required
performance test is completed, no owner or operator subject to the provisions of this
regulation may discharge, or cause the discharge into the atmosphere sulfur dioxide
in excess of:
(i) Sources with a heat input of less than 250 million Btu per hour: 0.8 lbs.
SO2/million Btu.
18. The combustion turbines are subject to the New Source Performance Standards
requirements of Regulation No. 6, Part A, Subpart KKKK, Standards of Performance for
Stationary Combustion Turbines including, but not limited to, the following:
• 40 CFR, Part 60, Subpart A — General Provisions
• §60.4320 — Nitrogen Oxide Emissions Limits
o §60.4320 (a) - NOx emissions shall not exceed 25 ppm at 15% O2 or 1.2 lb/MW-
hr;
• §60.4330 - Sulfur Dioxide Emissions Limits
o §60.4330 (a)(1) - SO2 emissions shall not exceed 0.9 lb/MW-hr gross output; or
AIRS ID: 123/9629/001-002 Page 5 of 15
Public Health and Environment
Air Pollution Control Division
o §60.4330 (a)(2) - Operator shall not burn any fuel that contains total potential
sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input.
• §60.4333 — General Requirements
o §60.4333 (a) - Operator must operate and maintain your stationary combustion
turbine, air pollution control equipment, and monitoring equipment in a manner
consistent with good air pollution control practices for minimizing emissions at all
times including during startup, shutdown and malfunction.
• §60.4340 — NO„ Monitoring
o §60.4340 (a) - Operator shall perform annual performance tests in accordance
with §60.4400 to demonstrate continuous compliance with NOx emissions limits.
• §60.4365 (or §§60.4360 and 60.4370) — SO2 Monitoring
o The operator shall comply with §60.4365 or with both §§60.4360 and 60.4370 to
demonstrate compliance with SO2 emissions limits.
• §60.4375 — Reporting
o §60.4375 (b) - For each affected unit that performs annual performance tests in
accordance with §60.4340(a), you must submit a written report of the results of
each performance test before the close of business on the 60th day following the
completion of the performance test.
• §§60.4400 and 60.4415 — Performance Tests
o Annual tests must be conducted in accordance with §60.4400(a) and (b).
o Unless operator chooses to comply with §60.4365 for exemption of monitoring
the total sulfur content of the fuel, then initial and subsequent performance tests
for sulfur shall be conducted according to §60.4415.
19. The source is subject to the requirements of Regulation No. 6, Part A, Subpart A, General
Provisions, including, but not limited to, the following:
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 6, Part A. General Provisions from 40 CFR 60.11(d))
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
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.
e. Performance tests shall be conducted as required under §60.8.
AIRS ID: 123/9829/001-002 Page 6 of 15
OPERATING & MAINTENANCE REQUIREMENTS
20. This source is not required to follow a Division -approved operating and maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
21. These turbines are subject to the initial testing requirements of 40 C.F.R. Part 60, Subpart
KKKK; as referenced in this permit.
22. The owner or operator shall complete the initial fuel sampling for high heat value (HHV) of
the fuel used in the turbines as required by this permit and submit the results to the Division
as part of the self -certification process to ensure compliance with emissions limits.
(Reference: Regulation No. 3, Part B, Section III.E.)
Periodic Testing Requirements
23. These turbines are subject to the periodic testing requirements of 40 C.F.R. Part 60, Subpart
KKKK, as referenced in this permit.
24. The fuel high heat value (HHV) of the fuel used in the turbines shall be determined, at a
minimum, once per every six months with consecutive samples taken at least four months
apart by the procedures contained in 40 CFR Subpart C, Part 98.34(a)(6) and records shall
be maintained of the annual fuel HHV for a period of two years. Upon request, the owner or
operator shall provide a sample and/or analysis of the fuel that is fired in the units. If
sampling is performed more often, the results of all valid fuel analyses shall be used in the
GHG emission calculations.
ADDITIONAL REQUIREMENTS
25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For 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.
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.
Public Health and Environment
Air Pollution Control Division
AIRS ID: 123/9B29/001-002 Page 7 of 15
Public Health and Environment
Air Pollution Control Division
f. Within 14 calendar days of commencing operation of a permanent replacement
turbine under the alternative operating scenario outlined in this permit as Attachment
A. The APEN shall include the specific manufacturer, model and serial number and
horsepower of the permanent replacement turbine, the appropriate APEN filing fee
and a cover letter explaining that the owner or operator is exercising an alternative -
operating scenario and is installing a permanent replacement turbine. Submittal of
an updated APEN is also required for replacement of components if such
replacement results in a change of serial number.
26. The exhaust stack(s) for these points shall vent emissions at a point greater than or equal to
13.72 meters above the ground.
27. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for this
facility. This requirement is imposed as a result of the modeled ambient air NOx and CO
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B, Section
111. B.5)
28. 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).
29. MACT Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for
Stationary Combustion Turbines requirements shall apply to this source at any such time
that this source becomes a major source of hazardous air pollutants (HAP) solely by virtue of
a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of that Subpart on the date as stated in the rule as published in the Federal
Register. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS:
30. 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.
31. 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.
32. 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
AIRS ID: 123/9629/001-002 Page 8 of 15
of Public Health and Environment
Air Pollution Control Division
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.
33. 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.
34. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
35. 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.
36. 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:
Peter Armington
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy, Inc.
AIRS ID: 12319B291001-002 Page 9 of 15
to? Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit: An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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: http://www.cdphe.state.co.us/requlations/airreqs/100102agcccommonprovisionsreq.pdf.
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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
91 (total
allowable
from both
engines is
91)
001-002
each
Acetaldehyde
75070
A
91
Yes
Formaldehyde
50000
A
- 1,547
Yes
1,547 (total
allowable
from both
engines is
1,547)
Note: All non -formaldehyde HAPs are assumed to be acetaldehyde.
5) The emission levels contained in this permit are based on the following emission factors:
Points 001 and 002:
CAS
Pollutant
Emission Factors -
Uncontrolled
Source
NOx
0.36 g/hp-hr
Mfr
CO
0.44 g/hp-hr
Mfr
VOC
0.07 g/hp-hr
Mfr
PM10
0.018 lb/MMBTU
Mfr
PM2.5
0.018 Ib/MMBTU
Mfr
SO,
0.0034 lb/MMBTU
AP -42, Table 3.1-2a
50000
Formaldehyde
0.00288 lb/MMBTU
Mfr
75070
Acetaldehyde
0.00017 lb/MMBTU
Mfr
AIRS ID: 123/9629/001-002
Page 10 of 15
Greenhouse Gas Emission Factors
or Public Health and Environment
Air Pollution Control Division
Pollutant
kg/MMBtu
GWP
Source
CO2
53.02
1
40 CFR 98 Subpart C
CH4
0.001
25
40 CFR 98 Subpart C
N2O
0.0001
310
40 CFR 98 Subpart C
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7965 Btu/hp-hr, a site -
rated horsepower value of 7700 HP and a fuel heat value of 1000 Btu/scf.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs
PSD
Synthetic Minor Source of: VOC
MACT YYYY
Area Source: 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
SubpartA— 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
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
www.colorado.qov/cdphe/oilqaspermits
AIRS ID: 123/9629/001-002
Page 11 of 15
-₹'
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
TURBINES WITHOUT CONTINUOUS EMISSIONS MONITORING
Public Health and Environment
Air Pollution Control Division
August 16, 2011
1. Routine Turbine Component Replacements
The following physical or operational changes to the turbines in this permit are not considered a
modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3,
Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS
GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions.
1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers,
seals, and shaft packings, provided that they are of the same design as the original.
2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were
designed for its use.
3) An increase in the hours of operation (unless limited by a permit condition)
4) Variations in operating loads within the engine design specification.
5) Any physical change constituting routine maintenance, repair, or replacement.
Turbines undergoing any of the above changes are subject to all federally applicable and state only
requirements set forth in this permit (including monitoring and record keeping). If replacement of any of
the components listed in (1) or (5) above results in a change in serial number for the turbine, a letter
explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the
Division within 30 days of the replacement.
Note that the repair or replacement of components must be of genuinely the same design. Except in
accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this
allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one
similar in design or function. Rather, the Division considers the repair or replacements to encompass the
repair or replacement of components at a turbine with the same (or functionally similar) components.
2. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
combustion turbines and turbine components has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility- Alternative Operating Scenarios,
Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source
New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any turbine or turbine component replacement performed in accordance with this
AOS, and the owner or operator shall be allowed to perform such turbine or turbine component
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
2.1 Turbine Replacement
The following AOS is incorporated into this permit in order to deal with a turbine breakdown or
periodic routine maintenance and repair of an existing onsite turbine that requires the use of a
temporary replacement turbine. "Temporary" is defined as in the same service for 90 operating days
AIRS ID: 123/9629/001-002 Page 12 of 15
Public Health and Environment
Air Pollution Control Division
or less in any 12 month period. "Permanent" is defined as in the same service for more than 90
operating days in any 12 month period. The 90 days is the total number of days that the turbine is in
operation. If the turbine operates only part of a day, that day shall count as a single day towards the
90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
Any permanent turbine replacement under this AOS shall result in the replacement turbine being
considered a new affected facility for purposes of NSPS and shall be subject to all applicable
requirements of that Subpart including, but not limited to, any required Performance Testing.
All replacement turbines are subject to all federally applicable and state -only requirements set forth in
this permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with the NSPS requirements. Results of all tests shall be kept on site for
five (5) years and made available to the Division upon request.
The owner or operator shall maintain a log on -site and contemporaneously record the start and stop
date of any turbine replacement, the manufacturer, date of manufacture, model number, horsepower,
and serial number of the turbine (s) that are replaced during the term of this permit, and the
manufacturer, model number, horsepower, and serial number of the replacement turbine.
2.1.1 The owner or operator may temporarily replace an existing turbine that is covered by this permit
with a turbine that is the exact same make and model as the existing turbine without modifying
this permit, so long as the temporary replacement turbine complies with the emission limitations
for the existing permitted turbine and other requirements applicable to the original turbine.
Measurement of emissions from the temporary replacement turbine shall be made as set forth
in section 2.2.
2.1.2 The owner or operator may permanently replace the existing turbine that is covered by this
permit with a turbine that is the exact same make and model as the existing turbine without
modifying this permit so long as the permanent replacement turbine complies with the emission
limitations and other requirements applicable to the original turbine as well as any new
applicable requirements for the replacement turbine. Measurement of emissions from the
temporary replacement turbine shall be made as set forth in section 2.2.
2.1.3 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and
serial number and horsepower of the permanent replacement turbine shall be filed with the
Division for the permanent replacement turbine within 14 calendar days of commencing
operation of the replacement turbine. The APEN shall be accompanied by the appropriate
APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
operating scenario and is installing a permanent replacement turbine. This AOS cannot be
used for permanent turbine replacement of a grandfathered or permit exempt turbine or a
turbine that is not subject to emission limits. The owner or operator shall agree to pay fees
based on the normal permit processing rate for review of information submitted to the Division
in regard to any permanent turbine replacement.
2.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
AIRS ID: 123/9B291001-002 Page 13 of 15
or Public Health and Environment
Air Pollution Control Division
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required
by this Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the
exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement turbine.
All portable analyzer testing required by this permit shall be conducted using the most current version of
the Division's Portable Analyzer Monitoring Protocol as found on the Division's website. Results of the
portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
turbine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above -mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary, the source may certify that the turbine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the turbine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or
until the turbine is taken offline.
2.3 Applicable Regulations for Permanent Turbine Replacements
2.3.1 NSPS for Stationary Gas Turbines: 40 CFR 60, Subpart GG
§60.330 Applicability and designation of affected facility.
(a) The provisions of this subpart are applicable to the following affected facilities: All stationary gas
turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per
hour, based on the lower heating value of the fuel fired.
(b) Any facility under paragraph (a) of this section which commences construction, modification, or
reconstruction after October 3, 1977, is subject to the requirements of this part except as provided
in paragraphs (e) and (j) of §60.332.
A Subpart GG applicability determination as well as an analysis of applicable Subpart GG
monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
AIRS ID: 123/9629/001-002 Page 14 of 15
of Public Health and Environment
Air Pollution Control Division
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS GG requirements).
2.3.2 NSPS for Stationary Combustion Turbines: 40 CFR 60, Subpart KKKK
§60.4305 Does this subpart apply to my stationary combustion turbine?
(a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load
equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of
the fuel, which commenced construction, modification, or reconstruction after February 18, 2005,
your turbine is subject to this subpart. Only heat input to the combustion turbine should be included
when determining whether or not this subpart is applicable to your turbine. Any additional heat input
to associated heat recovery steam generators (HRSG) or duct burners should not be included when
determining your peak heat input. However, this subpart does apply to emissions from any
associated HRSG and duct burners.
(b) Stationary combustion turbines regulated under this subpart are exempt from the requirements
of subpart GG of this part. Heat recovery steam generators and duct burners regulated under this
subpart are exempted from the requirements of subparts Da, Db, and Dc of this part.
A Subpart KKKK applicability determination as well as an analysis of applicable Subpart KKKK
monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall
be included in any request for a permanent turbine replacement
Note that under the provisions of Regulation No. 6. Part B, Section I.B. that Relocation of a source
from outside of the State of Colorado into the State of Colorado is considered to be a new source,
subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to
Colorado becomes equivalent to the commence construction date for purposes of determining the
applicability of NSPS KKKK requirements).
2.4 Additional Sources
The replacement of an existing turbine with a new turbine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for any
site; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved
replacement of an existing onsite turbine has to go through the appropriate Construction/Operating
permitting process prior to installation
AIRS ID: 12319B29/001-002 Page 15 of 15
Summary of Preliminary Analysis - NG RICE
Company Name
Facility Name
Facility Location
Facility Equipment ID
Noble Energy, Inc
Keota Gas / LNG Plant
NW Sec 21 T9N R61W
TBN 1
Permit No.
AIRS
Review Date
Permit Engineer
13WE1736
123/9B291001
05/23/2013
Peter Armington
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) Taurus, Model 60, Serial Number TBD, natural gas -fired, naturally aspirated, turbine, rated at 7700 horsepower.
Natural Gas Consumption
Requested (mmscf/yr)
537.26
Requested (mmscf/m)
45.63
Fuel Heat Value (btu/scf)
1000
BSCF (Btu/hp-hr)
7965
Uncontrolled
Controlled
NOx
Manufacturer
0
VOC
Manufacturer, estimated as 20% of UHC Vz
0
CO
Manufacturer
0
Formaldehyde
Manufacturer
0
SOX
AP -42, Table 3.1-2a
No Control
TSP
Manufacturer
No Control
PM10
Manufacturer
No Control
PM2.5
Manufacturer
No Control
Other Pollutants
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
26.9
26.9
26,9
0.0%
VOC
5.2
5.2
5.2
0.0%
CO
32.5
32.5
32.5
0.0%
SOx
0.9
0.9
0.9
0.0%
TSP
4.8
4.8
4.8
0.0%
PM10
4.8
4.8
4.8
0.0%
PM2.5
4.8
4.8
4.8
0.0%
Total HAPs*
0.0
0.0
0.9
-59.0%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/vr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
1547
1547
1547
0.0%
Methanol
*
*
*
#DIV/0!
Acrolein
*
*
3
-30418.7%
n -Hexane
*
*
*
#DIV/0!
Benzene
*
*
6
0.0%
Toluene
*
*
70
0.0%
1,3 -Butadiene
*
0
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
No NAAQS violations expected (see details of modeling analysis)
Public Comment
Public Comment required
MACT YYYY
NA
Comments/Notes
Turbines are subject to NSPS KKKK.
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name:
Noble Energy, Inc
Permit Number:
13WE1739
Source Location:
NW Section 21 T9N R61W
Equipment Description:
Amine Sweetening Unit
AIRS ID:
12319B29/004
Date:
5/23/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
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?
March 8, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
004
One (1) Methyldiethanolamine (MDEA) natural gas sweetening system for acid gas
removal with a design capacity of 45 MMSCF per day (make, model, serial number: TBD).
This emissions unit is equipped with one electric amine recirculation pump with a total
design capacity of 300 gallons per minute. This system includes a natural gas/amine
contactor, a flash tank, and an oil -heated amine regeneration reboiler. The heater for the
reboiler is covered under a separate point (AIRS Point 005). Flash tank emissions are
recycled to the fuel system or plant inlet for 100% recycle. Still vent emissions are routed
to a regenerative thermal oxidizer with a destruction efficiency of 95%.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM10
CO
Ozone
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 lll.D.2)
PM10
CO
Ozone
Page 1
Is this source located in the 8 -hour ozone non -
attainment region? (Note: If "yes" the provisions of
Yes X
No
Regulation 7, Sections XII and XVII.C may apply)
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
004
Site-specfic using VMG Simulation Model (refer to Section 14 for calculations)
Did the applicant
provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PIE)
AIRS Point
Process Consumption/Throughput/Production
004
16,425 mmscf per year natural gas throughput, 300 gallons per minute lean amine
circulation rate
Basis for
Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
004
16,425 mmscf per year natural gas throughput, 300 gallons per minute
lean amine circulation rate
Projected
Basis for Permitted Emissions (PermitLimits)
AIRS Point
Process Consumption/Throughput/Production
004
16,425 mmscf per year natural gas throughput, 300 gallons per minute lean amine
circulation rate
Does this source use a control device?
X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
004
01
Thermal Oxidizer
95
Section 6 — Emission Summa
(tons per year)
Point
NO.
VOC
CO
Single HAP
Total HAP
PTE:
004
346.0
46.4 (benzene)
102.8
Uncontrolled point
source emission rate:
004
-
346.0
46.4 (benzene)
102.8
Controlled point
source emission rate:
004
25.0
2.3 (benzene)
5.0
Total APEN Reported
emissions:
004
25.0
2.3 (benzene)
5.0
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate Ibl r
t Y )
Benzene
71432
A
92,800
Yes
4,600
Toulene
110543
C
73,600
Yes
3,600
Ethylbenzene
100414
C
9,800
Yes
400
Xylenes
1330207
C
8,600
i Yes
400
n -Hexane
110543
C
20,800
Yes
1,000
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.
Page 2
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
X
Yes
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
004
01
VOC,
HAPS
Regulation No. 3, Part B., Section III.G.3
Stack Test
Section 9 — Source Classification
Is this a new previously un-permitted source? X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs? X
Title V
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why?
NOx, VOC, CO, HAPs
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, 111.0.1.c.iii (subject to MACT)?
Yes
X
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?
X
Yes
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide;: ,;_`:,
004
Section 1I.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 Il. A and B of this regulation.
Regulation 2 - Odor s
004
Section l.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 O eratinq Permits, PSD
004
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed) for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
004
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section ll.D.3.a)
_ .
Regulation 6 - New Source Performance Standards .. .,.. ,..
Page 3
004
NSPS LLL: Each sweetening (amine) unit and each sweetening unit followed by a
sulfur recovery unit; manufacturer date after January 24, 1984.
Applicant is not subject to NSPS LLL because it will be constructed after 2011.
004
NSPS OOOO: Each sweetening (amine) unit and each sweetening unit followed by a
sulfur recovery unit; manufacturer date after August 23, 2011.
Applicant is subject to NSPS OOOO because it will be manufactured after 2011.
This source will have a design capacity less than 2 long tons/day H2S in the acid gas based
on the information submitted in the application. This source will be required by 60.5423(c)
to keep for the life of the equipment an analysis demonstrating that the facility's design
capacity is less than 2 LT/D of H2S expressed as sulfur. No other requirements apply.
Res ulation 7 — Volatile Organic °Compounds
004
None
Regulation 8 - Hazardous Air Pollutants
004
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant/
CAS #
Fugitiv
e
(Y/N)
Emission
Factor Source
Control
(%)
004
01
Amine Unit
42.1
lbs/mmscf
VOC
No
Process
Simulator
95
5.66
lbs/mmscf
Benzene /
71432
No
Process
Simulator
95
4.48
lbs/mmscf
Toluene /
108883
No
Process
Simulator
95
0.599
lbs/mmscf
Ethylbenzene /
100414
No
Process
Simulator
95
0.528
lbs/mmscf
Xylenes /
1330207
No
Process
Simulator
95
1.26
lbs/mmscf
n -Hexane/
110543
No
Process
Simulator
95
SCC
31000305 — Gas Sweetening; Amine process
Emission factors include flash tank and still vent and that factors are based on natural gas
processing of 16,425 MMScf/yr.
Section 14 — Miscellaneous Application Notes
AIRS Point
004
Amine Unit
A permit will be issued.
The table below summarizes the inputs to the process simulation used to calculate the PTE for this
equipment.
Parameter
Value
Inlet Gas Temperature
115 °F
Inlet Pressure
894 psia
Does this amine unit have a reboiler? Yes, but it is heated with facility hot oil which is covered under a
different permit.
Noble is assuming that 100% of flash tank emissions will be recycled. These emissions are not included
in the uncontrolled emission limits.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1739
Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy Inc
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section 21,
Township 9N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
AMINE
004
One (1) Methyldiethanolamine (MDEA) natural gas sweetening
system for acid gas removal with a design capacity of 45 MMSCF per
day (make, model, serial number: TBD). This emissions unit is
equipped with one or more electric amine recirculation pumps with a
total design capacity of 300 gallons per minute, plus spare pump(s),
number of pumps to be determined. This system includes a natural
gas/amine contactor, a flash tank, and an oil -heated amine
regeneration reboiler. The heater for the reboiler is covered under a
separate point (AIRS Point 005). Flash tank emissions are recycled
to the fuel system or plant inlet for 100% recycle. Still vent emissions
are routed to a regenerative thermal oxidizer (RTO) with a
destruction efficiency of 95%.
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, bV 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.
AIRS ID: 123/9629/004
Page 1 of 11
Amine SM/M Version 2012-1
Public Health and Environment
Air Pollution Control Division
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
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, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5 The following information shall be provided to the Division within fifteen (15) days after
commencement of operation.
• manufacturer
• model number
• serial number
• number of pumps
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
Pointmission
Pounds per Month
Type
SO2SO
H2S
NOx
VOC
CO
AMINE
004
2,378
68
---
4,247
---
Point
(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.
AIRS ID: 123/9629/004
Page 2 of 11
o Public Health and Environment
Air Pollution Control Division
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
SO2
H2S
NOx
VOC
CO
AMINE
004
14.0
0.4
---
25.0
---
Point
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 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.
Compliance with the VOC emission limits in this permit shall be demonstrated by running a
simulation model on a monthly basis using the most recent amine unit inlet extended sour
gas analysis and recorded operational values (including plant inlet gas throughput, inlet gas
temperature, inlet gas pressure, lean amine strength, lean amine recirculation rate, and
other operational values as specified in the O&M plan). Recorded operational values shall
be averaged on a monthly basis for input into the simulation model. The simulation package
used shall be VMG, Prosim, or HYSYS.
9. 100% of emissions that result from the flash tank associated with this amine unit shall be
recycled to the fuel system or facility inlet and recompressed.
10. 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
AMINE
004
Regenerative Thermal Oxidizer
VOC and HAPs
AIRS ID: 123/9629/004
Page 3 of 11
r.t or Public Health and Environment
Air Pollution Control Division
GREENHOUSE GAS (GHG) REQUIREMENTS
11. Conditions 12-18 in this section shall apply until any such time that this facility becomes a
true minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a cancellation
request for permit 13WE1736 has been received, the CO2eq emission limits do not apply
and only GHG emission calculations specifically required by 40 CFR Part 98 are necessary.
12. Emissions of greenhouse gases 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
Tons per Month
Emission Type
CO2e1
AMINE
004
3,121
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility Equipment ID
AIRS Point
Tons per Year
Emission Type
CO2e
AMINE
004
36,745
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
1 CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each greenhouse gas
emission multiplied by global warming potential for each greenhouse gas. The greenhouse gas emissions in this
inventory include CO2, CI -I4 and N2O.
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.
13. The owner or operator shall calculate, on a monthly basis, the amount of CO2 emitted from
fuel and waste gas combustion using equation C -2a in 40 CFR Part 98 Subpart C, default
natural gas CO2 emission factor in Table C-1 and estimated waste gas volume and HHV.
14. The owner or operator shall calculate CH4 and N2O emissions from fuel and waste gas
combustion on a monthly basis using equation C -9a of 40 CFR Part 98 Subpart C, default
AIRS ID: 123/9B291004 Page 4 of 11
Public Health and Environment
Air Pollution Control Division
CH4 and N2O emission factors for natural gas contained in Table C-2 and estimated waste
gas volume and HHV.
15. A complete record of the methods used, the measurements made, and the calculations
performed to quantify monthly natural gas volume shall be kept.
16. The owner or operator shall calculate the CO2e emissions based on the procedures and
Global Warming Potentials (GWP) contained in Greenhouse Gas Regulations, 40 CFR Part
98, Subpart A, Table A-1
17. The owner or operator shall calculate CO2 and CH4 emissions from acid gas sweetening, on
a monthly basis, using the simulation model that is used for Condition 8, consistent with 40
CFR Part 98, Subpart W [98.233(d)(4)] along with the most recent results from the extended
sour gas analysis as required by this permit.
18. Total CO2e emissions from the amine unit and RTO shall be based on the sum of GHG
emissions from waste gas combustion, calculated as per Conditions 13, 14 and 16 plus, CO2
emissions from the amine unit acid gas sweetening calculated per Condition 17. The sum
total of CO2e emissions generated from the amine unit acid gas sweetening shall be
compared to the CO2e limits listed in this section above to demonstrate compliance.
PROCESS LIMITATIONS AND RECORDS
19. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual natural gas 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
AMINE
004
Natural gas throughput
16,425
MMscf/yr
1,395
MMscf/month
Supplemental gas to RTO
1
MMscf/yr 1
1.12
MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar month.
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.
20. This unit shall be limited to the maximum lean amine recirculation pump rate of 300 gallons
per minute. The lean amine recirculation rate shall be recorded weekly in a log maintained
on site and made available to the Division for inspection upon request. An amine flow meter
may be used to demonstrate compliance with this condition. (Reference: Regulation No. 3,
Part B, II.A.4)
AIRS ID: 123/9629/004 Page 5 of 11
Corny., do
or Public Health and Environment
Air Pollution Control Division
STATE AND FEDERAL REGULATORY REQUIREMENTS
21. 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, III.E.)
(State only enforceable)
22. 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 7, Sections
XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
23. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
24. The permit holder shall measure and record the lean amine strength on a weekly basis. The
lean amine strength is defined as the combined weight percent of DEA, MDEA and
piperazine in the lean amine stream. Measurements of lean amine strength do not have to
be speciated. Records of the amine strength shall be made available to the Division for
inspection upon request. (Colorado Regulation No. 3, Part A, H)
25. The amine units addressed by AIRS ID 004 are subject to the New Source Performance
Standards requirements of Regulation No. 6, Part A, Subpart OOOO, Standards of
Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
including, but not limited to, the following:
• §60.5365 — Applicability and Designation of Affected Facilities
o §60.5365(g)(3) - Facilities that have a design capacity less than 2 long tons per
day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are
required to comply with recordkeeping and reporting requirements specified in
§60.5423(c) but are not required to comply with §§60.5405 through 60.5407 and
§§60.5410(g) and 60.5415(g).
• §60.5423 — Record keeping and reporting Requirements
o §60.5423(c) - To certify that a facility is exempt from the control requirements of
these standards, for each facility with a design capacity less that 2 LT/D of H2 S
in the acid gas (expressed as sulfur) you must keep, for the life of the facility, an
analysis demonstrating that the facility's design capacity is less than 2 LT/D of
HZS expressed as sulfur.
OPERATING & MAINTENANCE REQUIREMENTS
26. Upon startup of this point, 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
AIRS ID: 123/9B29/004 Page 6 of 11
of Public Health and Environment
Air Pollution Control Division
27. A source initial compliance test shall be conducted on emissions point 004 to measure the
emission rate(s) for the pollutants listed below in order to demonstrate compliance with the
emission limits contained in this permit. For NOx and CO, initial compliance test shall
demonstrate compliance that emissions are below APEN reporting threshold of 2 tons per
year.
The operator shall also demonstrate the thermal oxidizer achieves a minimum destruction
efficiency of 95% for VOC. The lean amine strength and sulfur content of the sour gas
entering the amine unit shall both be measured at least once per test. The inlet to the amine
contactor throughput and lean amine circulation rate shall be monitored and recorded during
the test. The flow rate of supplemental fuel fired in the thermal oxidizer shall be monitored
and recorded during the test, and the Btu content of such gases shall be determined using
the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The
operator shall also monitor and record combustion temperature during the initial compliance
test to confirm the minimum temperature in the O&M plan.
The test protocol must be in accordance with the requirements of the Air Pollution Control
Division Compliance Test Manual and shall be submitted to the Division for review and
approval at least thirty (30) days prior to testing. No compliance test shall be conducted
without prior approval from the Division. Any compliance test conducted to show compliance
with a monthly or annual emission limitation shall have the results projected up to the
monthly or annual averaging time by multiplying the test results by the allowable number of
operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section
III.G.3)
Sulfur Dioxide using EPA approved methods.
Oxides of Nitrogen using EPA approved methods.
Volatile Organic Compounds using EPA approved methods.
Carbon Monoxide using EPA approved methods.
BTEX compounds and n -Hexane using EPA approved methods.
Hydrogen Sulfide using EPA approved methods.
28. The owner or operator shall complete the initial annual extended sour gas analysis testing
required by this permit and submit the results to the Division as part of the self -certification
process. Results of the sour gas analysis shall be used to calculate emissions of criteria
pollutants and hazardous air pollutants per Condition 8.
29. The operator shall complete an initial sample of the inlet gas to the plant to determine the
concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be
submitted to the Division as part of the self -certification process and used to demonstrate
compliance with condition 25. The testing required by Condition 28 may be used for this
demonstration.
Periodic Testing Requirements
30. The operator shall sample the inlet gas to the plant on an annual basis to determine the
concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be
monitored to demonstrate that this amine unit qualifies for the exemption from the Standards
of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
(§60.5365(g)(3). The testing required by Condition 31 may be used for this demonstration.
31. The owner or operator shall complete an extended sour gas analysis prior to the inlet of the
amine unit on an annual basis. Results of the sour gas analysis shall be used to calculate
emissions of criteria pollutants and hazardous air pollutants per Condition 8.
AIRS ID: 12319B291004 Page 7 of 11
pg('ne o? Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
32. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C),
Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For 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.
33. The exhaust stack for this emission point shall vent emissions at a point greater than or
equal to 13.72 meters above the ground.
34. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for this
facility. This requirement is imposed as a result of the modeled ambient air NOx and CO
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B, Section
III.B.5)
35. 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:
36. 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.
37. 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
AIRS ID: 12319B29/004 Page 8 of 11
e
of Public Health and Environment
Air Pollution Control Division
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.
38. 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.
39. 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.
40. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
41. 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.
42. 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:
Peter Armington
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9829/004
Page 9 of 11
G.(
.,
•
LyS
e^ t o Y Public Health and Environment
Air Pollution Control Division
Asa
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAPs
PSD
, Synthetic Minor Source of: VOC, GHG, HAPs
NSPS LLL
Not Applicable
MACT DDDDD
Not Applicable
MACT JJJJJJ
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 j 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
9) An Oil and Gas industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
www.colorado.qov/cdphe/oilgaspermits
AIRS ID: 123/9B29/004
Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Noble Energy Inc
Permit Number:
13WE1740
Source Location:
NW Section 21 T9N R61W
Equipment Description:
One 37.0 MMBTU/hr natural gas fired hot oil heater
AIRS ID:
123/9829/005
Date:
5/24/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
*If tank is a true minor source at a true minor facility, it shall be granted "Final Approval"
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
i Information Request letter to the source?
On what date was this application complete?
March 8, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
005
One (1) 37.0 MMBTU/hr natural gas fired hot oil heater. Emissions from this unit are
not controlled.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM,o
CO
Ozone
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)
Yes
X
No
Page 1
_ Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
005
AP -42, Chapter 1.4
Did the applicant provide actual process data for the emission inventory?
X
Yes
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/ThroughputlProduction
005
324.12 MMscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
005
324.12 MMscf/yr
Projected
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
005
324.12 MMscf/yr
Does this facility use control devices?
Yes
X
No
Section 6 — Emission Summa
(tons per year)
Point
NO„
VOC
CO
SOx
PM10
Single
HAP
Total
HAP
PTE:
005
15.9
0.9
13.4
0.10
1.21
---
---
Uncontrolled point
source emission rate:
005
15.9
0.9
13.4
0.10
1.21
---
---
TOTAL PERMITTED
(TPY)
005
15.9
0.9
13.4
-'-
--
"-
---
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
Section 9 — Source Classification
Is this a new previously un-permitted source?
Yes
What is this point classification?
True Minor
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
Page 2
If "yes", for which pollutants? Why? VOC
For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, II1.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)?
X
Yes
No
I Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
NO„, PM2.5
X
Yes
No
AIRS Point 1
Section'12 — Regulatory Review
Regulation 1 - Particulate, Smoke; Carbon Monoxide and Sulfur Dioxide'"
005
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.
Regulation 2 — Odor
005
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, Operatiri— Permits, PSD
005
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
005
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a)
Regulation 6 - New Source Performance Standards
005
NSPS Dc- Recordkeeping and reporting requirements
Regulation 7 — Volatile Or anic Compounds,
005
None
Regulation 8 — Hazardous Air Pollutants
005
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(YIN)
Emission Factor
Source
Control
(%)
005
01
Natural Gas Fired Heater
5.5 lb/MMscf
VOC
No
AP 421,E able
NA
100
lb/MMscf
NOx
No
AP -42, Table
1.4
NA
84 lb/MMscf
CO
No
AP-42Table
NA
7.6 lb/MMscf
PM10
No
AP -42,4
1.4E able
NA
SCC
1-03-006-02: External Combustion Boilers- Natural Gas
Page 3
Section 14 — Miscellaneous Application Notes
r —
AIRS Point 005 Hot Oil Heater
To convert from BTU to scf, source is using a HHV of 1000 BTU/scf.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1740
Noble Energy Inc
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section 21,
Township 9N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
HTR HO
005
One (1) natural gas -fired hot oil heater (make, model, serial
number: TBD) rated up to 37.0 MMBTU/hr. Emissions from this
unit are not controlled.
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; (H) discontinues construction for a period of eighteen
AIRS ID: 123/9B29/005 Page 1 of 10
Wellhead Version 2012-1
Public Health and Environment
Air Pollution Control Division
months or more; (Hi) 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, III.F.4.)
4. 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
5. 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
NOx
VOC
CO
HTR HO
005
2,701
---
2,276
Point
(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
NO„
VOC
CO
HTR HO
005
15.9
---
13.4
Point
ee "Notes to Permit Ho der #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.
GREENHOUSE GAS (GHG) REQUIREMENTS
AIRS ID: 123/9B29/005 Page 2 of 10
f Public Health and Environment
Air Pollution Control Division
6. Conditions 7-11 in this section shall apply until any such time that this facility becomes a true
minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a cancellation
request for permit 13WE1736 has been received, the CO2eq emission limits do not apply
and only GHG emission calculations specifically required by 40 CFR Part 98 are necessary.
7. Emissions of greenhouse gases 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
Tons per Month
Emission Type
CO2e1
HTR HO
005
1,611
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS Point
Tons per Year
Emission Type
COZe'
HTR HO
005
18,963
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
1 CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each greenhouse gas
emission multiplied by global warming potential for each greenhouse gas. The greenhouse gas emissions in this
inventory include CO2, CIS and N2O.
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. The owner or operator shall calculate, on a monthly basis, the amount of CO2 emitted from
fuel combustion using equation C -2a in 40 CFR Part 98 Subpart C, default natural gas CO2
emission factor in Table C-1, measured actual heat input (HHV), and measured actual
monthly natural gas flow volume.
9. The owner or operator shall calculate CH4 and N2O emissions from fuel combustion on a
monthly basis using equation C -9a of 40 CFR Part 98 Subpart C, default CH4 and N2O
AIRS ID: 123/9B29/005 Page 3 of 10
mentf Public Health and Environment
Air Pollution Control Division
emission factors for natural gas contained in Table C-2, measured actual heat input (HHV)
and measured actual monthly natural gas volume.
10. A complete record of the methods used, the measurements made, and the calculations
performed to quantify monthly natural gas volume shall be kept.
11. The owner or operator shall calculate the CO2e emissions based on the procedures and
Global Warming Potentials (GWP) contained in Greenhouse Gas Regulations, 40 CFR Part
98, Subpart A, Table A-1
PROCESS LIMITATIONS AND RECORDS
12. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Monthly Limit
HTR HO
005
Natural Gas Consumption
324 MMscf/yr
27.6
MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar month.
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
13. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
14. 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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
15. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
16. This source is subject to the New Source Performance Standards requirements of
Regulation No. 6, Part A Subpart Dc, Standards of Performance for Small Industrial -
Commercial -Institutional Steam Generating Units including, but not limited to, the following:
a. The owner or operator of the facility shall record and maintain records of the amount of
fuel combusted during each month (40 CFR Part 60.48c(g)).
AIRS ID: 123/9629/005 Page 4 of 10
f Public Health and Environment
Air Pollution Control Division
b. Monthly records of fuel combusted required under the previous condition shall be
maintained by the owner or operator of the facility for a period of two years following the
date of such record (40 CFR Part 60.48c(i)).
In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General
Provisions, apply.
c. 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
d. 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 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)
e. Written notification of construction and initial startup dates shall be submitted to the
Division as required under § 60.7.
f: Records of startups, shutdowns, and malfunctions shall be maintained, as required
under § 60.7.
17. These units are subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation 1 including, but not limited to, the following:
a. No owner or operator shall cause or permit to be emitted into the atmosphere from
any fuel -burning equipment particulate matter in the flue gases which exceeds the
following (Regulation 1, Section III.A.1):
For fuel burning equipment with designed heat inputs greater than 1x106
BTU per hour, but less than or equal. to 500x106 BTU per hour, the following
equation will be used to determine the allowable particulate emission
limitation.
PE=0.5(FI)-oss
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. Sources of sulfur dioxide shall not emit sulfur dioxide in excess of the following
limitations. (Heat input rates shall be the manufacturer's guaranteed maximum heat
input rates). (Regulation 1, Section VI.B)
(i) Limit emissions to not more than two (2) tons per day of sulfur dioxide
(Regulation 1, Section VI.B.5.a)
18. Particulate emissions shall be limited as per: Regulation 6, Part B, II.C.2. where:
PE=0.5*(FI)-026
Where:
PE = allowable particulate emissions in pounds per million Btu heat input
AIRS ID: 123/9629/005 Page 5 of 10
A
olo1 p Devi ment f Public Health and Environment
00 3i Air Pollution Control Division
Fl = fuel input in million Btu per hour
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
19. The owner or operator shall complete the initial fuel sampling for high heat value (HHV) of
the fuel used in the heater as required by this permit and submit the results to the Division as
part of the self -certification process to ensure compliance with emissions limits. (Reference:
Regulation No. 3, Part B, Section III.E.)
Periodic Testing Requirements
20. The high heat value (HHV) of the fuel used in the heater shall be determined, at a minimum,
once per every six months with consecutive samples taken at least four months apart by the
procedures contained in 40 CFR Subpart C, Part 98.34(a)(6) and records shall be
maintained of the annual fuel HHV for a period of two years. This condition will only apply
while the operator is required to track CO2e. Upon request, the owner or operator shall
provide a sample and/or analysis of the fuel that is fired in the units. If sampling is
performed more often, the results of all valid fuel analyses shall be used in the GHG
emission calculations.
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, I I.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 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.
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.
22. The exhaust stack for this point shall vent emissions at a point greater than or equal to 9.14
meters above the ground.
23. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for this
facility. This requirement is imposed as a result of the modeled ambient air NOx and CO
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B, Section
lll.B.5)
AIRS ID: 123/9629/005 Page 6 of 10
Public Health and Environment
Air Pollution Control Division
24. 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
25. 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.
26. 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.
27. 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 applicants agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
28. 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.
29. 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
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
30. 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.
AIRS ID: 12319B29/005 Page 7 of 10
ent, bf Public Health and Environment
Air Pollution Control Division
31. 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:
Peter Armington
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9629/005 Page 8 of 10
f Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 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.
3) 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.cd phe. state.co. us/regulations/airregs/100102agcccommonprovisionsreq. pdf.
4) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Emission Factor
Source
NOx
100 lb/MMscf
AP -42, Chapter 1.4
VOC
5.5 lb/MMscf
AP -42, Chapter 1.4
CO
84 lb/MMscf
AP -42, Chapter 1.4
Greenhouse Gas Emission Factors
Pollutant
kg/MMBtu
GWP
Source
CO2
53.02
1
40 CFR 98 Subpart C
CH4
0.001
25
40 CFR 98 Subpart C
N2O
0.0001
310
40 CFR 98 Subpart C
Source used a heat rate of 37.0 MMBTU/hr, a heating value of 1000 BTU/scf, and 8760 hours of
operation per year.
5) 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.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAPs
PSD
Synthetic Minor Source of: VOC, GHG
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
AIRS ID: 12319B29/005
Page 9 of 10
http://ecfr.gpoaccess.gov/
r mentf Public Health and Environment
Air Pollution Control Division
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
i 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
8) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilgaspermittinq. html
AIRS ID: 123/9B29/005 Page 10 of 10
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information 4
Company Name:
Noble Energy Inc
Permit Number:
13WE1741
Source Location:
NW Section 21 T9N R61W
Equipment Description:
One 9.1 MMBTUIhr natural gas fired heater for molecular sieve
regeneration
AIRS ID:
123/9B29/006
Date:
5/24/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
CP1
Transfer of Ownership
APEN Exempt/Permit Exempt
'If tank is a true minor source at a true minor facility, it shal be granted "Final Approval"
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?
March 8, 2013
Section 4 — Source Description
AIRS Point I Equipment Description
One (1) 9.1 MMBTU/hr natural gas fired heater for molecular sieve regeneration.
006 I The heater will run for 6,132 hours per year. Emissions from this unit are not
I controlled.
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM10
CO
Ozone
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)
PMN
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)
Yes
X
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
006
AP -42, Chapter 1.4
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
006
56 MMscf/yr
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
006
55.8 MMscf/yr
Projected
Basis for Permitted Emissions (Permit Limits)
AIRS Point
Process Consumption/Throughput/Production
006
56 MMscf/yr
Does this facility use control devices?
Yes
X
No
Section 6 — Emission Summary (tons per year)
Point
NOX
VOC
CO
SOx
PM10
Single
HAP
Total
HAP
PTE:
006
2.74
0.15
2.30
0.02
0.21
---
---
Uncontrolled point
source emission rate:
006
2.74
0.15
2.30
0.02
0.21
---
---
TOTAL PERMITTED
(TPY)
006
2.74
---
2.30
---
---
---
---
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
No
If "yes", complete the information listed below
AIRS Point
Process
Pollutant
Regulatory Basis
Test Method
Section 9 — Source Classification
Is this a new previously un-permitted source?
Yes
What is this point classification?
True Minor
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
Synthetic
Minor
Major
Page 2
Section 10 — Public Comment
Does this permit require public comment per CAQCC Regulation 3?
X
Yes
No
If "yes", for which pollutants? Why? VOC
For Reg. 3, Part B, IlI.C.1.a (emissions increase > 25/50 tpy)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
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?
NOx, PM2.5
X
Yes
No
AIRS Point
Section 12 — Regulatory Review
Regulation 1 - Particulate. Smoke, Carbor/" /onoxide and Sulfur Dioxide
006
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.
•
Regulation 2 — Odor'
006
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 •
006
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed)
for which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
006
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the £0 TPY threshold (Reg. 3, Part B, Section ll.D.3.a)
Regulation 6 - New Source Performance Standards
006
None- Rated less than 10 MMBTU/hr
;ti,
Regulation 7 — Volatile Organic Compounds
006
None
Regulation 8 — Hazardous Air Pollutants
006
None
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
006
01
Natural Gas Fired Heater
5.5 lb/MMscf
VOC
No
AP-42,1.� able
NA
100
lb/MMscf
NOx
No
AP -42, Table
1.4
NA
84 lb/MMscf
CO
No
AP-42Table
.4
NA
7.6 lb/MMscf
PM10
No
AP -42,E able
NA
Page 3
SCC
1-03-006-02: External Combustion Boilers- Natural Gas
Section 14 — Miscellaneous Application Notes
AIRS Point
006
Regenerator Heater
To convert from BTU to scf, source is using a HHV of 1000 BTU/scf. This heater is permitted at
6132 hr/yr.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1741
Noble Energy Inc
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section 21,
Township 9N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
HTR RG
006
One (1) maximum design rated up to 9.1 MMBTU/hr, natural gas-
fired heater (make, model, serial number: TBD) for mole sieve
regeneration. Emissions from this unit are not controlled.
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; (H) discontinues construction for a period of eighteen
AIRS ID: 123/9B29/006 Page 1 of 9
Wellhead Version 2012-1
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, III.F.4.)
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
5. 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
NOx
VOC
CO
HTR RG
006
459
---
391
Point
(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
NOx
VOC
CO
HTR RG
006
2.7
---
2.3
Point
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.
GREENHOUSE GAS (GHG) REQUIREMENTS
AIRS ID: 123/9B29/006 Page 2 of 9
f Public Health and Environment
Air Pollution Control Division
6. Conditions 7-11 in this section shall apply until any such time that this facility becomes a true
minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a cancellation
request for permit 13WE1736 has been received, the CO2eq emission limits do not apply
and only GHG emission calculations specifically required by 40 CFR Part 98 are necessary.
7. Emissions of greenhouse gases 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
Tons per Month
Emission Type
CO2e1
HTR RG
006
277
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS Point
Tons per Year
Emission Type
CO2e1
HTR RG
006
3265
Point
See "Notes to Permit Holder for information on emission factors and methods used to callimit
culate s.
CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each greenhouse gas
emission multiplied by global warming potential for each greenhouse gas. The greenhouse gas emissions in this
inventory include CO2, CIS and N2O.
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. The owner or operator shall calculate, on a monthly basis, the amount of CO2 emitted from
fuel combustion using equation C -2a in 40 CFR Part 98 Subpart C, default natural gas CO2
emission factor in Table C-1, measured actual heat input (HHV), and measured actual
monthly natural gas flow volume.
9. The owner or operator shall calculate CH4 and N2O emissions from fuel combustion on a
monthly basis using equation C -9a of 40 CFR Part 98 Subpart C, default CH4 and N2O
AIRS ID: 123/9629/006 Page 3 of 9
Public Health and Environment
Air Pollution Control Division
emission factors for natural gas contained in Table C-2, measured actual heat input (HHV)
and measured actual monthly natural gas volume.
10. A complete record of the methods used, the measurements made, and the calculations
performed to quantify monthly natural gas volume shall be kept.
11. The owner or operator shall calculate the CO2e emissions based on the procedures and
Global Warming Potentials (GWP) contained in Greenhouse Gas Regulations, 40 CFR Part
98, Subpart A, Table A-1
PROCESS LIMITATIONS AND RECORDS
12. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made available
to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Monthly Limit
HTR RG
006
Natural Gas Consumption
56 MMscf/yr
4.8 MMscf/month
The owner or operator shall calculate monthly process rates based on the calendar month.
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
13. The permit number and AIRS ID number shall be marked on the subject equipment for ease
of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable)
14. 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. (Reference: Regulation No. 1, Section II.A.1. & 4.)
15. These sources are subject to the odor requirements of Regulation No. 2. (State only
enforceable)
16. These units are subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of
Regulation 1 including, but not limited to, the following:
a. No owner or operator shall cause or permit to be emitted into the atmosphere from
any fuel -burning equipment particulate matter in the flue gases which exceeds the
following (Regulation 1, Section III.A.1):
AIRS ID: 123/9B29/006 Page 4 of 9
(i)
f Public Health and Environment
Air Pollution Control Division
For fuel burning equipment with designed heat inputs greater than 1x106
BTU per hour, but less than or equal to 500x106 BTU per hour, the following
equation will be used to determine the allowable particulate emission
limitation.
PE=0.5(Fl °26
Where:
PE = Particulate Emission in Pounds per million BTU heat input.
Fl = Fuel Input in Million BTU per hour.
b. Sources of sulfur dioxide shall not emit sulfur dioxide in excess of the following
limitations. (Heat input rates shall be the manufacturer's guaranteed maximum heat
input rates). (Regulation 1, Section VI. B)
(i) Limit emissions to not more than two (2) tons per day of sulfur dioxide
(Regulation 1, Section VI.B.5.a)
17. Particulate emissions shall be limited as per Regulation 6, Part B, II.C.2. where:
PE=0.5*(FI)4)26
Where:
PE = allowable particulate emissions in pounds per million Btu heat input
Fl = fuel input in million Btu per hour
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner or operator shall complete the initial fuel sampling for high heat value (HHV) of
the fuel used in the heater as required by this permit and submit the results to the Division as
part of the self -certification process to ensure compliance with emissions limits. (Reference:
Regulation No. 3, Part B, Section III.E.)
Periodic Testing Requirements
19. The high heat value (HHV) of the fuel used in the heater shall be determined, at a minimum,
once per every six months with consecutive samples taken at least four months apart by the
procedures contained in 40 CFR Subpart C, Part 98.34(a)(6) and records shall be
maintained of the annual fuel HHV for a period of two years. This condition will only apply
while the operator is required to track CO2e. Upon request, the owner or operator shall
provide a sample and/or analysis of the fuel that is fired in the units. If sampling is
performed more often, the results of all valid fuel analyses shall be used in the GHG
emission calculations
ADDITIONAL REQUIREMENTS
20. 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
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f Public Health and Environment
Air Pollution Control Division
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.
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.
21. The exhaust stack for this point shall vent emissions at a point greater than or equal to 9.14
meters above the ground.
22. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for this
facility. This requirement is imposed as a result of the modeled ambient air NOx and CO
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B, Section
II1.B.5)
23. 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
24. 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.
25. 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.
26. 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.
AIRS ID: 123/9629/006 Page 6 of 9
f Public Health and Environment
Air Pollution Control Division
27. 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.
28. 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
or owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
29. 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.
30. 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:
Peter Armington
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9629/006
Pagel of 9
ermentf Public Health and Environment
u Air Pollution Control Division
r]
Notes to Permit Holder:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 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.
3) 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.cd phe.state.co.us/requ lations/a irregs/100102agcccom monprovisionsreq. pdf.
4) The emission levels contained in this permit are based on the following emission factors:
Pollutant
Emission Factor
Source
NOx
100 lb/MMscf
AP -42, Chapter 1.4
VOC
5.5 lb/MMscf
AP -42, Chapter 1.4
CO
84 lb/MMscf
AP -42, Chapter 1.4
Greenhouse Gas Emission Factors
Pollutant
kg/MMBtu
GWP
Source
CO2
53.02
1
40 CFR 98 Subpart C
CH4
0.001
25
40 CFR 98 Subpart C
N2O
0.0001
310
40 CFR 98 Subpart C
Source used a heat rate of 9.1 MMBTU/hr, a heating value of 1000 BTU/scf, and 6132 hours per year
operation.
5) 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.
6) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAPs
PSD
Synthetic Minor Source of: VOC, GHG
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
AIRS ID: 123/9629/006
Page 8 of 9
wesmiuunki
a:r:ment f Public Health and Environment
Air Pollution Control Division
hit p://ecfi .upoaccess.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
8) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilciaspermitting.html
AIRS ID: 123/9629/006 Page 9 of 9
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Noble Energy Inc
Permit Number:
13WE1742
Source Location:
NNW Section 21, T9N, R61W
Equipment Description:
Fugitive Emissions
AIRS ID:
12319B29/007
Date:
6/27/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
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?
March 8, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
007
Fugitive VOC leak emissions
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
Milo
CO
Ozone
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.2J
PM,o
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)
Yes
X
No
Page 1
Section 5 — Emission Estimate Information
AIRS
Point
Emission Factor Source
007
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
007
Equipment Type
Gas-
VOC
Gas- non
VOC
Heavy Oil
(or Heavy
Liquid)
Light Oil (or
Light
Liquid)
Water/Oil
Connectors
4100
3000
1600
1600
1600
Flanges
1100
900
500
500
500
Open -Ended
Lines
75
70
25
25
25
Pump Seals
0
20
0
20
20
Valves
1200
1000
900
900
900
Other
60
110
10
10
10
Basis for Actual Emissions Reported During-this.APEN Filing (Reported to Inventory)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas-
VOC
Gas- non
VOC
Heavy Oil
(or Heavy
Liquid)
Light Oil (or
Light
Liquid)
Water/Oil
Connectors
4100
3000
1600
1600
1600
Flanges
1100
900
500
500
500
Open -Ended
Lines
75
70
25
25
25
Pump Seals
0
20
0
20
20
Valves
1200
1000
900
900
900
Other
60
110
10
10
10
Basis for Permitted Emissions (Permit Limits)
AIRS
Point
Process Consumption/Throughput/Production
007
Equipment Type
Gas-
VOC
Gas- non
VOC
Heavy Oil
(or Heavy
Liquid)
Light Oil (or
Light Liquid)
Water/Oil
Connectors
4100
3000
1600
1600
1600
Flanges
1100
900
500
500
500
Open -Ended
Lines
75
70
25
25
25
Pump Seals
0
20
0
20
20
Valves
1200
1000
900
900
900
Other
60
110
10
10
10
Does this source use a control
device?
Yes
X
No
Section 6 — Emission Summary (tons per year)
Point
NO„
VOC
CO
Single HAP
Total HAP
PTE:
007
57.3
1.8 (Hexane)
3.8
Uncontrolled point
source emission rate:
007
57.3
1.8 (Hexane)
3.8
Page 2
Controlled point
source emission rate
007
30.0
0.9
3.8
Total APEN Reported
emissions:
007
30.0
0.9
3.8
Section 7 — Non -Criteria / Hazardous Air Pollutants j
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
r
Controlled Emission
Rate (Iblyr)
Benzene
71432
A
1,915
Yes
944
Toluene
108883
C
1,915
Yes
944
Ethylbenzene
100414
C
203
No
106
Xylenes
1330207
C
203
No
106
n -Hexane
110543
C
3,655
Yes
1793
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
No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
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
X
No
For Reg, 3, Part B, IIl.C.1.d (synthetic minor emission limits)?
Yes
X
No
Section 11 — Modeling
Is modeling required to demonstrate compliance with National Ambient
Air Quality Standards (NAAQS)?
If "yes", for which pollutants? Why?
X
Yes
No
AIRS Point
Section 12 — Regulatory Review
Rggulation 1 - Particulate Smoke,., Carbon Monoxide and Sulfur Dioxide
007
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.
Page 3
Re•"ulatioh 2 — Odor
007
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 Operatin• Permits, PSD
007
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed) for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
007
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part 8, Section 11.D.3.a)
007
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 not located in the 8 -hour
ozone nonattainment area.
Since source is in attainment, RACT is not required.
LRe. ulation 6 - New=Source Performance Standards
007
NSPS KICK: 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).
Is this source at a "natural gas processing plant?" Yes
Is this source subject to NSPS KKK? No
Subject to OOOO
007
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?" Yes
Is this source subject to NSPS OOOO? Yes
Regulation 7— Volatile Or•anic Compounds
007
Section XII.G: If facility is a natural gas processing plant located in non -attainment
area, then subject to Section XII.G.
Regulation 8 - Hazardous Air Pollutants
007
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.
Is this facility considered MAJOR for HAPS? No
Is this source subject to MACT HH? No
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process Description
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor
Source
Control
(%)
007
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 4
Section 14 —Miscellaneous Application Notes
AIRS Point
A permit will be issued. Operator will conduct quarterly monitoring of valves and monthly monitoring of
pump seals in order to comply with 0000 requirements. The control efficiencies reflect this.
007
Fugitive VOC Leak Emissions
Page 5
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
13WE1742
Noble Energy Inc
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW Sec 21 T9N
R61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
FUG
007
Equipment leaks (fugitive VOCs) from a natural gas processing
plant.
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; (H) discontinues construction for a period
AIRS ID: 123/9B29/007 Page 1 of 11
Fugitive SM/M Version 2012-2
Health and Environment
it Pollution Control Division
of eighteen moil` me = (i"` ®8 = n Irate co® _ ction 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,
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 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 (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
VOC
FUG
007
5096
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
FUG
007
30.0
Fugitive
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 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.
AIRS ID: 123/9B29/007
Page 2 of 11
IicPHealth and Environment
it Pollution Control Division
The permit hal® - s - I caloldat siora onth elchkeep 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.
7. 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.
GREENHOUSE GAS (GHG) REQUIREMENTS
8. Conditions 9-10 in this section shall apply until any such time that this facility becomes a
true minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a
cancellation request for permit 13WE1736 has been received, the CO2eq emission limits
do not apply and only GHG emission calculations specifically required by 40 CFR Part
98 are necessary.
9. Emissions of greenhouse gases 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:
limits
Facility
Equipment ID
AIRS Point
Tons per Month
Emission Type
CO2e
FUG
007
195
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment ID
AIRS Point
Tons per Year
Emission Type
co2et
FUG
007
2301
Point
l
See "Notes to Permit Holder for information on emission factors and methods used to calcuate
CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each greenhouse
gas emission multiplied by global warming potential for each greenhouse gas. The greenhouse gas
emissions in this inventory include CO2, CH4 and N2O.
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.
AIRS ID: 123/9629/007
Page 3 of 11
li'Health and Environment
.kir Pollution Control Division
Compliance wit nnua[dim _.= I b eraained by -.-cording 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.
10. 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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. 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 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
13. The fugitive emissions addressed by AIRS ID 007 are subject to the New Source
Performance Standards requirements of Regulation No. 6, Part A, Subpart 0000,
Standards of Performance for Crude Oil and Natural Gas Production, Transmission and
Distribution including, but not limited to, the following:
• §60.5365 Applicability - The group of all equipment, except compressors, within a
process unit for which you commence construction, modification or reconstruction
after August 23, 2011 is an affected facility per §60.5365(f).
• §60.5400 Standards - The group of all equipment, except compressors, within a
process unit must comply with the requirements of §60.5400 and §60.5401.
• §60.5410 - Owner or operator must demonstrate initial compliance with the
standards using the requirements in §60.5410(f).
• § 60.5415 - Owner or operator must demonstrate continuous compliance with the
standards using the requirements in §60.5415(f).
• § 60.5421 - Owner or operator must comply with the recordkeeping requirements of
§60.5421(b).
• § 60.5422 - Owner or operator must comply with the reporting requirements of
paragraphs (b) and (c) of this section in addition to the requirements of § 60.487a(a),
(b), (c)(2)(i) through (iv), and (c)(2)(vii) through (viii).
14. The reciprocating compressors grouped with the fugitive emissions addressed by AIRS
ID 007 are subject to the New Source Performance Standards requirements of
Regulation No. 6, Part A, Subpart 0000, Standards of Performance for Crude Oil and
AIRS ID: 123/9629/007 Page 4 of 11
Health and Environment
it Pollution Control Division
Natural Gas ,•4 gin, Ti-nsrfussio(aI antion i .Wding, but not limited to, the
following:
§60.5385(a) — Owner or operator must replace the reciprocating compressor rod
packing according to either paragraph§60.5385(a)(1) or (2).
(i) §60.5385(a)(1) - Before the compressor has operated for 26,000 hours. The
number of hours of operation must be continuously monitored beginning
upon initial startup of your reciprocating compressor affected facility, or
October 15, 2012, or the date of the most recent reciprocating compressor
rod packing replacement, whichever is later.
(ii) §60.5385(a)(2) - Prior to 36 months from the date of the most recent rod
packing replacement, or 36 months from the date of startup for a new
reciprocating compressor for which the rod packing has not yet been
replaced.
§60.5410 — Owner or operator must demonstrate initial compliance with the
standards as detailed in §60.5410(c).
• §60.5415 — Owner or operator must demonstrate continuous compliance with the
standards as detailed in §60.5415(c).
• §60.5420 - Owner or operator must comply with the notification, reporting, and
recordkeeping requirements as specified in §60.5420(a), §60.5420(b)(1),
§60.5420(b)(4), and §60.5420(c)(3).
OPERATING & MAINTENANCE REQUIREMENTS
15. This source is not required to follow a Division -approved operating and maintenance
plan. All O&M requirements are fulfilled by meeting the requirements of NSPS Subpart
OOOO.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. 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 emission
calculations to the Division as part of the self -certification process to ensure compliance
with emissions limits.
17. 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
18. 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
AIRS ID: 12319B29/007 Page 5 of 11
iceHealth and Environment
r Pollution Control Division
extended gas .. rs shall be _e.o the brr ance d; osrstration as required in the
Emission Limits and Records section of this permit.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, 'LC)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For 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.
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.
20. 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).
21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil
and Natural Gas Production Facilities major stationary source requirements shall apply
to this stationary source at any such time that this stationary source becomes major
solely by virtue of a relaxation in any permit limitation and shall be subject to all
appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part
E)
22. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines requirements shall apply to this
source at any such time that this source becomes major solely by virtue of a relaxation in
any permit limitation and shall be subject to all appropriate applicable requirements of
that Subpart on the date as stated in the rule as published in the Federal Register.
(Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS:
AIRS ID: 123/9B29/007 Page 6 of 11
Health and Environment
it Pollution Control Division
23. This permit ast be etaihed and 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.
24. 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.
25. 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.
26. 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.
27. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
28. 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.
29. 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:
AIRS ID: 12319B291007 Page 7 of 11
j
Ii&Health and Environment
-ir Pollution Control Division
Peter usgt6
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9B291007 Page 8 of 11
Health and Environment
Air Pollution Control Division
Notes to Permit Holder at` = 'me o fins e seuan
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The 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: http://www.cdphe.state.co.us/regulations/airregs/100102aocccommonprovisionsreq.pdf.
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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate
(Ib/yr)
007
Benzene
71432
A
1,915
Yes
944
Toluene
108883
C
1,915
Yes
944
Ethylbenzene
100414
C
203
No
106
Xylenes
1330207
C
203
No
106
n -Hexane
110543
C
3,655
Yes
1793
5) The emission levels contained in this permit are based on the following emission factors:
Component
Gas
Service-
VOC
Gas
Service-
non VOC
Heavy Oil
Light Oil
Water/Oil
Service
Connectors
4100
3000
1600
1600
1600
Flanges
1100
900
500
500
500
Open-ended Lines
75
70
25
25
25
Pump Seals
0
20
0
20
20
Valves
1200
1000
900
900
900
Other*
60
110
10
10
10
VOC Content (wt.
fraction)
0.3500
0.0500
1.0000
0.0500
1.0000
Benzene Content
(wt. fraction)
0.0010
0.0001
0.0300
0.0300
• 0.0003
Toluene Content
(wt. fraction)
0.0010
0.0001
0.0300
0.0300
0.0003
AIRS ID: 12319B29/007
Page 9 of 11
en )Wf P4idHealth and Environment
pair Pollution Control Division
Ethylbenzene (wt.
fraction)
0.00
01 _
030
0.0030
0.0000
Xylenes Content
(wt. fraction)
0.0001
0.0001
0.0030
0.0030
0.0000
n -hexane Content
(wt. fraction)
0.0050
0.0001
0.0500
0.0500
0.0005
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains, dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (lb/hr-component):
Component
Gas Service
Heavy Oil
Light Oil
Service
Connectors
4.41E-04
1.65E-05
4.63E-04
2.43E-04
Flanges
8.60E-04
8.60E-07
2.43E-04
6.39E-06
Open-ended Lines
4.41E-03
3.09E-04
3.09E-03
5.51E-04
Pump Seals
5.29E-03
NA
2.87E-02
5.29E-05
Valves
9.92E-03
1.85E-05
5.51E-03
2.16E-04
Other
1.94E-02
7.05E-05
1.65E-02.
3.09E-02
Source: EPA -453/R95-017
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC content
from the most recent gas analysis.
A 70% control for valves in gas service and 61% control for valves in light oil service shall be applied
because that operator has agreed to monitor these components quarterly. A 68% control shall be
applied to pump seals in light liquid service on account of monthly monitoring.
For CO2e emissions, the TOC emission factors listed in the table above with representative
component count will be multiplied by the CH4 and CO2 content from the most recent gas analysis.
CO2e emissions are then calculated based on procedures in 40 CFR 98 Subpart A.
Global Warming Potentials (GWP)
Pollutant
GWP
Source
CO2
1
40 CFR 98 Subpart A and C
CH4
25
40 CFR 98 Subpart A and C
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAPs
AIRS ID: 123/9B29/007
Page 10 of 11
olor °Depaf P : blicHealth and Environment
Pollution Control Division
PSD ` `-l"'"'-•''
/
SyntRet c Mirfor`S&rc ; GHG
MACT HH
Area Source Requirements: Not Applicable
NSPS KKK
Not Applicable
NSPS OOOO
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 DOD
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
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit
packet. Please use this form to complete the self -certification requirements as specified in the permit
conditions. Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilclaspermittinq.html
AIRS ID: 123/9B29/007 Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Noble Energy Inc
Permit Number:
13WE1743
Source Location:
NNW Section 21 T9N R61 W
Equipment Description:
Condensate Storage Tanks
AIRS ID:
123/9B29/008
Date:
5/28/2013
Review Engineer:
Peter Armington
Control Engineer:
Carissa Money
Section 2 — Action Completed
Grandfathered
Modification
APEN Required/Permit Exempt
X
Initial Approval
Transfer of Ownership
APEN Exempt/Permit Exempt
If tank is a true minor source at a true minor facility, it may be granted "Final Approval" without first
being issued an Initial Approval permit
`Grandfathered exemption is for any tanks in service prior to December 30, 2002
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?
March 8, 2013
Section 4 — Source Description
AIRS Point
Equipment Description
008
Four (4) above ground 2000 bbl atmospheric condensate storage tanks
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PM10
CO
Ozone
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)
Yes
X
-
No
Page 1
Section 5 — Emission Estimate Information
AIRS Point ' Emission Factor Source
008 I EPA TANKS
Did the applicant provide actual process data for the emission inventory?
1 Yes
X
No
Basis for Potential to Emit (PTE)
AIRS Point
Process Consumption/Throughput/Production
008
730,000 BBL per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point
Process Consumption/Throughput/Production
Data Year
008 NA
Basis for Permitted Emissions (Permit Limits) }
AIRS Point
Process Consumption/Throughput/Production
008
730,000 BBL per year
Does this source use a control device? I X
Yes
No
AIRS Point
Process
Control Device Description
% Reduction
Granted
008
01
Combustor
95
I Section 6 — Emission Summa (tons per year)
Point NO„
VOC
CO
Single HAP
I
Total HAP
PTE:
008
92.7
1.5 (Hexane)
3.3
Uncontrolled point
source emission rate:
008
92.7
1.5 (Hexane)
3.3
Controlled point
source emission rate:
008
4.6
0,07 (Hexane)
0.16
Total APEN Reported
emissions:
008
4.6
0.07 (Hexane)
0.16
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
(lb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Benzene
71432
A
1400
Yes
70
Toluene
108883
C
2200
Yes
110
n -Hexane
110543
C '
3000
Yes
150
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
No
I Section 9 — Source Classification
Is this a new previously un-permitted source?
X Yes
No
Page 2
What is this facility classification?
True
Minor
X
Minor Synthetic
Major
Classification relates to what programs?
X
Title V
X
PSD
NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
If "yes" what kind of modification?
Minor
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)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)?
Yes
X
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?
NOx
X
Yes
No
AIRS Point
Section 12 —Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and,Sulfur Dioxide
008
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 Odor
008
Section LA - 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.
Requlation'3-APENs. Construction --Permits, Operating Permits, PSD
008
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed) for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
008
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section Il.D.3.a)
Re ulation 6 - New Source Performance Standards
008
NSps Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is is source greater than 19,800 gallons (471 bbl)? Yes
s this source subject to NSPS Kb? Yes
Page 3
Re• ulation 7 — Volatile Or• anic Compounds
008
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is not subject to the emission control requirements for condensate tanks
since it is located in an attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently not subject to this section because the tanks are subject to
NSPS Kb.)
Regulation 8 - Hazardous Air Pollutants
008
MACT EEEE: Organic Liquids Distribution
Pick one:
• This source is not subject to MACT EEEE because it is not located at a major
source of HAP.
008
MACT HH
Pick one:
• This source is not subject to MACT HH because it is not located at a major source
of HAP.
Section 13 — Aerometric Information Retrieval System Coding Information
Point
Process
Process
Description
Emission
Factor
Pollutant /
CAS #
Fugitive
(Y/N)
Emission Factor Source
Control
(%)
008
01
Midstream
Condensate
Storage Tanks
6.05
lb/1000 gal
throughput
V0C
No
EPA TANKS
95
0.05
lb/1000 gal
throughput
Benzene /
71432
No
EPA TANKS
95
0.05
lb/1000 gal
throughput
Toluene /
108883
No
EPA TANKS
95
0.10
lb/1000 gal
throughput
n -Hexane
/ 110543
No
EPA TANKS
95
SCC
40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses
Section 14 — Miscellaneous Application Notes
AIRS Point
008
Condensate Storage Tanks
A permit will be issued.
Noble modeled emissions in EPA TANKS using RVP 10 oil.
This source is not located in the 8 -hour ozone non -attainment area (this part of Weld County is in
attainment). Therefore, the provisions of Regulation 7, Section XII do not apply to this source.
Uncontrolled emissions are greater than 20 tpy; however, per Reg 7, XVII.B.4, tanks are not subject to
controls under Reg 7 Section XVII since the tanks are subject to emission control per NSPS Kb.
Per 40 CFR 60.5395(d), NSPS OOOO standards do not apply to this source as it is subject to NSPS
Subpart Kb.
Page 4
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 13WE1743
DATE ISSUED:
ISSUED TO:
Noble Energy Inc
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section 21,
Township 9N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
TK CND
008
Four (4) 2000 BBL fixed roof storage tanks used to store
condensate. Emissions from these tanks are controlled by a
combustor.
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
AIRS ID: 123/9B29/008 Page 1 of 11
3f Pli'Health and Environment
Air Pollution Control Division
application associate pt h*iit (ai) dis_ontihkes cons tuption for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 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 (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
TK CND
008
----
781
---
Point
(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
NO,
VOC
CO
TK CND
008
---
4.6
---
Point
ee "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 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
AIRS ID: 123/9629/008
Page 2 of 11
liHealth and Environment
it Pollution Control Division
at a local field ' - ! h - ; s °m ilityJ ® Mion re, , , This rolling twelve-month
total shall apply to all permitted emission units, requiring an APEN, at this facility.
7. 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
TK CND
008
Combustor
VOC
GREENHOUSE GAS (GHG) REQUIREMENTS
8. Conditions 9-13 in this section shall apply until any such time that this facility becomes a true
minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a cancellation
request for permit 13WE1736 has been received, the CO2eq emission limits do not apply
and only GHG emission calculations specifically required by 40 CFR Part 98 are necessary.
9. Emissions of greenhouse gases 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
Tons per Month
Emission Type
CO2et
TK CND
008
26
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility Equipment ID
AIRS Point
Tons per Year
Emission Type
CO2e
TK CND
008
309
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each greenhouse gas,
emission multiplied by global warming potential for each greenhouse gas. The greenhouse gas emissions in this
inventory include CO2, CH4 and N2O.
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.
AIRS ID: 123/9629/008.
Page 3 of 11
lic`PHealth and Environment
rPollution Control Division
Compliance nnia ,.kttm I ,®r,l be'ciet-, : ed b =, ording 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.
10. The owner or operator shall calculate CO2, CH4, and N2O emissions from the combustion
of waste gas in the enclosed combustor, on a monthly basis, using equations and
procedures outlined in 40 CFR Part 98, Subpart W 98.233(n)(4-6) along with EPA Tanks,
engineering calculations based on process knowledge, company records, and best available
data. The minimum combustion efficiency of this unit is assumed as 95%.
PROCESS LIMITATIONS AND RECORDS
11. 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
TK CND
008
Condensate throughput
730,000
BBUyr
62,000
BBUmonth
The owner or operator shall calculate monthly process rates based on the calendar month.
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
12. 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, III.E.)
(State only enforceable)
13. 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 7, Sections
XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1,
Section II.A.1. & 4.)
AIRS ID: 123/9B29/008 Page 4 of 11
lic'Health and Environment
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14. This source is getfot r! qubmal .oS' ulati o. 2. (State only enforceable)
15. 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:
§ 60.112b: Standard for volatile organic compounds (VOC).
• 60.112b(a)(3): A closed vent system and control device shall meet the following
specifications:
o (i) 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).
o (ii) 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.
§ 60.113b Testing and procedures
• 60.113b(c): The owner or operator of each source that is equipped with a closed
vent system and control device as required in § 60.112b (a)(3) or (b)(2) (other
than a flare) is exempt from § 60.8 of the General Provisions and shall meet the
following requirements.
o (1) Submit forapproval by the Administrator as an attachment to the
notification required by § 60.7(a)(1) or, if the facility is exempt from
§ 60.7(a)(1), as an attachment to the notification required by § 60.7(a)(2),
an operating plan containing the information listed below.
(i) Documentation demonstrating that the control device will
achieve the required control efficiency during maximum loading
conditions. This documentation is to include a description of the
gas stream which enters the control device, including flow and
VOC content under varying liquid level conditions (dynamic and
static) and manufacturer's design specifications for the control
device. If the control device or the closed vent capture system
receives vapors, gases, or liquids other than fuels from sources
that are not designated sources under this subpart, the efficiency
demonstration is to include consideration of all vapors, gases, and
liquids received by the closed vent capture system and control
device. If an enclosed combustion device with a minimum
residence time of 0.75 seconds and a minimum temperature of
816 °C is used to meet the 95 percent requirement, documentation
that those conditions will exist is sufficient to meet the
requirements of this paragraph.
AIRS ID: 123/9B29/008 Page 5 of 11
Ii -Health and Environment
it Pollution Control Division
Irv' aa.� Yi.
(ii) A description of the parameter or parameters to be monitored
to ensure that the control device will be operated in conformance
with its design and an explanation of the criteria used for selection
of that parameter (or parameters).
o (2) Operate the closed vent system and control device and monitor the
parameters of the closed vent system and control device in accordance
with the operating plan submitted to the Administrator in accordance with
paragraph (c)(1) of this section, unless the plan was modified by the
Administrator during the review process. In this case, the modified plan
applies.
• §60.115b —;Reporting and recordkeeping requirements
§60.115b(d) After installing a closed vent system and flare to comply with
§60.112b, the owner or operator shall meet the following requirements.
§60.115b(d)(1) A report containing the measurements required by
§60.18(f) (1), (2), (3), (4), (5), and (6) shall be furnished to the
Administrator as required by §60.8 of the General Provisions. This report
shall be submitted within 6 months of the initial start -update.
• §60.115b(d)(2) Records shall be kept of all periods of operation during
which the flare pilot flame is absent.
§60.115b(d)(3) Semiannual reports of all periods recorded under
§60.115b(d)(2) in which the pilot flame was absent shall be furnished to
the Administrator.
• §60.116b - Monitoring of operations
• §60.116b(a) The owner or operator shall keep copies of all records required by
this section, except for the record required by paragraph (b) of this section, for at
least 2 years. The record required by paragraph (b) of this section will be kept for
the life of the source.
• §60.116b(b) The owner or operator of each storage vessel as specified in
§60.110b(a) shall keep readily accessible records showing the dimension of the
storage vessel and an analysis showing the capacity of the storage vessel.
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: 123/9629/008 Page 6 of 11
lid'Health and Environment
kir Pollution Control Division
compli v tli ar fpa nd a s s:<rd which is based on the
concentration of a pollutant in the gases discharged to the atmosphere. (§ 6O.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.
e. Written notification of opacity observation or monitor demonstrations shall be
submitted to the Division as required under § 60.7.
f.. Excess Emission and Monitoring System Performance Reports shall be submitted as
required under § 60.7.
g. Performance tests shall be conducted as required under § 60.8.
h. Compliance with opacity standards shall be demonstrated according to § 60.11.
i. The flare shall be designed and operated, and records and reports shall be
furnished, as required under § 60.18.
OPERATING & MAINTENANCE REQUIREMENTS
16. 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
17. The owner or operator shall demonstrate compliance with Condition 12 using EPA Method
22 to measure opacity from the flare. The observation period shall be a minimum of fifteen
consecutive minutes.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. 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 APE N; 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: 123/9B291008 Page 7 of 11
Iio Health and Environment
4ir Pollution Control Division
b. Whene, of h e i eh a' f,..ge 1, th sr open`® ,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.
19. The exhaust stack for this point shall vent emissions at a point greater than or equal to 15.24
meters above the ground.
20. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for this
facility. This requirement is imposed as a result of the modeled ambient air NOx and CO
impacts that result from the facility operations. (Reference: Regulation No. 3, Part B, Section
111.8.5)
21. 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).
22. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and
Natural Gas Production Facilities major stationary source requirements shall apply to this
stationary source at any such time that this stationary source becomes major solely by virtue
of a relaxation in any permit limitation and shall be subject to all appropriate applicable
requirements of Subpart HH. (Reference: Regulation No. 8, Part E)
GENERAL TERMS AND CONDITIONS
23. 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 11.B upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. 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.
25. 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.
AIRS ID: 123/9829/008 Page 8 of 11
Ii Health and Environment
it Pollution Control Division
26. Unless specifies ed wa ≤ a g spe ;, onditions 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.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. 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.
29. 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:
Peter Armington
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9B29/008
Page 9 of 11
IiHealth and Environment
it Pollution Control Division
Notes to Permit Holder at' f " e oftfs pe
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees
will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of
the invoice, Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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:
http://www.cd phe. state.co. us/req ulations/airreqs/100102agcccommonp rovis ionsreq. pdf.
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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
008
Benzene
71432
A
1400
Yes
70
Toluene
108883
C
2200
Yes
110
Hexane
110543
C
3000
Yes
150
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
CAS #
Pollutant
Emission Factors
Uncontrolled
Ib/BBL
Condensate
Throughput
Emission Factors
Controlled
lb/BBL
Condensate
Throughput
Source
VOC
0.254
0.0127
EPA TANKS
110543
n -Hexane
0.004
0.0002
EPA TANKS
71432
Benzene
0.002
0.0001
EPA TANKS
108883
Toluene
0.002
0.0001
EPA TANKS
Note: The controlled emissionsfactors for point 008 are based on the flare control efficiency of
95%.
HAP emissions were calculated by multiplying the HAP concentration from Table 3-2 of DOC# EPA
453/R -94-002a by the VOC emission factor.
AIRS ID: 123/9B29/008
Page 10 of 11
Health and Environment
it Pollution Control Division
GHG emissions from combustion are based on the assumption that vapors have an average of five
carbon atoms and molecular weight of 66.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division. A revised APEN
shall be submitted no later than 30 days before the five-year term expires. Please refer to the most
recent annual fee invoice to determine the APEN expiration date for each emissions point associated
with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-
3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAPs
PSD
Synthetic Minor Source of: VOC, GHG
MACT HH
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. zov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
SubpartA—SubpartKKKK
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
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit packet.
Please use this form to complete the self -certification requirements as specified in the permit conditions.
Further guidance on self -certification can be found on our website at:
http://vwvw.cdphe.state.co.us/ap/oilqaspermittinq.html
AIRS ID: 12319B29/008
Page 11 of 11
Construction Permit Application
Preliminary Analysis Summary
Section 1 — Applicant Information
Company Name:
Noble Energy Inc
Permit Number:
13WE1744
Source Name:
Keota Gas/LNG Plant
Source Location:
NW Section 21, T9N R61 W
Equipment Description:
Condensate Truck Loading
AIRS ID:
123/9B29/009
Review Date:
5/28/2013
Review Engineer
Peter Armington
Section 2 — Action Completed
X
CP1
Modification
APEN Required/Permit Exempt
Final 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?
March 8, 2013
Section 4 —Source Description
AIRS Point
Equipment Description
009
Truck Condensate Loadout
Is this a portable source?
Yes
X
No
Is this location in a non -attainment area for any criteria
pollutant?
Yes
X
No
If "yes", for what pollutant?
PKo
CO
Ozone
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)
Yes
X
No
Is this source located at an oil and gas exploration site?
Yes
X
No
Page 1
If yes, does this source load less than 10,000 gallons of
crude oil per day on an annual average. splash fill less
than 6750 bbl of condensate (hydrocarbons that have
an API gravity of 40 degrees or greater) per year or
submerged fill less than 16,308 bbl of condensate per
year?
Yes
No
Is this source located at a facility that is considered a
major source of hazardous air pollutant (HAP)
emissions?
Yes
X
No
Will this equipment be operated in any NAAQS
nonattainment area?
Yes
X
No
Does this source load gasoline into transport vehicles?
Yes
X
No
Section 5 — Emission Estimate Information
AIRS Point
Emission Factor Source
009
AP -42: Chapter 5.2, Equation 1
L = 12.46*S*P*M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Did the applicant provide actual process data for the emission inventory?
Yes
X
No
'"'
Basis for Potential to Emit (PTE) 'r':`;'':.<
AIRS Point
Process Consumption/Throughput/Production
009
730,000 BBL per year condensate loaded
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point ! Process Consumption/Throughput/Production
009
NA
Basis for Permitted Emissions (Permit Limits) -
......_
AIRS Point
Process Consumption/Throughput/Production
009
730,000 BBL per year condensate loaded
Does this source use a control device?
X Yes
No
ISection 6 — Emission Summary (tons per year)
Point
i NO,
VOC CO
Single HAP
HAP
PTE:
009
62.4
1.1 (n -hexane)
2.5
Uncontrolled point
source emission rate:
009
62.4
1.1 (n -hexane)
2.5
Controlled point
source emission rate:
009
3.1
0.05 (n -hexane)
0.13
Permitted point source
emission rate:
009
3.1
0.05 (n -hexane)
0.13
Section 7 — Non -Criteria / Hazardous Air Pollutants
Pollutant
CAS #
BIN
Uncontrolled
Emission Rate
ilb/yr)
Are the
emissions
reportable?
Controlled Emission
Rate (Ib/yr)
Benzene
71432.
A
1463
Yes
73
Page 2
n -Hexane
110543
C
2190
Yes
110
Toluene
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.
108883
C
1463
Yes
73
Section 8 —Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory
standard?
Yes
X
No
Section 9 — Source Classification
Is this a new previously un-permitted source?
X
Yes
No
What is this facility classification?
True
Minor
X
Synthetic
Minor
Major
Classification relates to what programs?
X
Title V
X1
PSD NA NSR
X
MACT
Is this a modification to an existing permit?
Yes
X
No
if "yes" what kind of modification?
Minor
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)?
Yes
X
No
For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)?
Yes
X
No
For Reg. 3, Part B. 1II.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)?
Facility is above modeling threshold for NOR.
X
Yes
No
AIRS Point I
Section 12 — Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
009
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. (Reference: Regulation No. 1, Section HI.A.1. & 4.)
Regulation 2 — Odor
009
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.
Page 3
Regulation 3 -. APENs, ConstructionPermits Operating Permits PSD
009
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
each individual emission point in an attainment area with uncontrolled actual emissions of
two tons per year or more of any individual criteria pollutant (pollutants are not summed) for
which the area is attainment.
(Applicant is required to file an APEN since emissions exceed 2 tons per year VOC)
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this
facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section ll.D.3.a)
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 not located in the 8 -hour
ozone nonattainment area.
Since source is in attainment, RACT is not required. However, operator is using 0.6
saturation factor, which does satisfy RACT requirements.
Regulation 6 - New Source Performance Standards
009
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 - Volatile Organic Compounds
009
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum
liquid storage and distribution facility that has a daily average throughput of more than
76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
009
MACT EEEE:
Not subject because minor source of HAPs
Section 13—Aerometric Information Retrieval System Coding Information
Process
Point Process throughput
Description
Process/
Limit
Emission
Factor
Pollt
Pollutant /
CAS #
Fugitive
Fu 9
(Y/N)
Emission
Factor
Source
Control
(%)
009
01
Truck Condensate
Loadout
730,000
BBUyr
4.07
lb/1,000
gallon ,
throughput
VOC
No
AP -42
95
01
Truck Condensate
Loadout
730,000
BBL/yr
0.048
lb/1,000
gallon
throughput
Benzene
No
AP -42
95
01
Truck Condensate
Loadout
730,000
BBUyr
0.048
lb/1,000
gallon
throughput
Toluene
No
AP -42
95
01
Truck Condensate
Loadout
730,000
BBL/yr
0.071
lb/1,000
gallon
throughput
n -Hexane
No
AP -42
95
SCC
40600132: Crude Oil: Submerged Loading (Normal Service)
Page 4
Section 14 —Miscellaneous Application Notes
AIRS Point
009
Truck Condensate Loadout
Units
Basis
S
0.6
Submerged loading:
dedicated normal service
based on source's
description/drawings
Based on EPA TANKs run
P
4.2
Psia
M
66
Lb/lb-mole
Based on EPA TANKs run
T
510
Deg R
Based on source's
knowledge of bulk liquid
temperature
L
4.06
Lb/10^3 gal
0.171
Lb/bbl
AP -42: Chapter 5.2
Equation 1
L = 12.46*S`P`M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psia]
M = molecular weight of vapors [lb/lb-mole]
T = temperature of bulk liquid loaded [deg. R]
Page 5
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
13WE1744
Issuance 1
DATE ISSUED:
ISSUED TO: Noble Energy Inc
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Keota Gas/LNG Plant, located in the NW of Section
21, Township 9N, Range 61W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
TL CND
009
Truck loadout of condensate. Emissions from the loadout are
controlled by an 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 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
AIRS ID: 123/9B29/009 Page 1 of 9
f:
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (H) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
III.F.4.)
o Public Health and Environment
Air Pollution Control Division
4. 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
5. 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
VOC
TL CND
009
527
Point
(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
TL CND
009
3.1
Point
ee "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 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.
AIRS ID: 123/9B29/009
Page 2 of 9
0
Public Health and Environment
Air Pollution Control Division
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.
6. All condensate loading operations shall occur in vapor balance service, such that all
tanker truck vapors are routed to and controlled by the combustor. The vapor return
hose shall be connected at all times during loading operations. (Reference: Regulation
No. 3, Part B, Section III.E.)
7. 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
TL CND
009
Combustor
VOC
GREENHOUSE GAS (GHG) REQUIREMENTS
8. Conditions 9-10 in this section shall apply until any such time that this facility becomes a
true minor source for GHG emissions and a cancellation request for permit 13WE1736 is
received by the Division. If the facility is true minor for GHG emissions and a
cancellation request for permit 13WE1736 has been received, the CO2eq emission limits
do not apply and only GHG emission calculations specifically required by 40 CFR Part
98 are necessary.
9. Emissions of greenhouse gases shall not exceed the following limitations (as calculated
in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section
I I.A.4)
Monthly Limits:
Facility Equipment
ID
AIRS Point
Tons per Month
Emission Type
CO2e1
TL CND
009
18
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
Annual Limits:
Facility
Equipment
ID
AIRS
Point
Tons per Year
Emission
Type
CO2e1
TL CND
009
208
Point
AIRS ID: 123/9B29/009
Page 3 of 9
limits.
or Public Health and Environment
Air Pollution Control Division
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
CO2e is carbon dioxide equivalent in tons per year. CO2e is the total sum of the mass of each
greenhouse gas emission multiplied by global warming potential for each greenhouse gas. The
greenhouse gas emissions in this inventory include OO2, CH4 and N2O.
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.
10. The owner or operator shall calculate OO2, CH4, and N2O emissions from the
combustion of waste gas in the enclosed combustor, on a monthly basis, using
equations and procedures outlined in 40 CFR Part 98, Subpart W 98.233(n)(4-6) along
with estimated monthly emissions and the emission factors in 40 CFR Part 98, Subpart
C. The minimum combustion efficiency of this unit is assumed to be 95%.
PROCESS LIMITATIONS AND RECORDS
11. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate 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
Annual Limit
Monthly Limit
(31 Days)
009
Condensate Loading
730,000 BBL
62,000 BBL
The owner or operator shall calculate monthly process rates based on the calendar
month.
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.
AIRS ID: 123/9629/009
Page 4 of 9
do p e of Public Health and Environment
Air Pollution Control Division
12. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference:
Regulation 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
13. 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, III.E.) (State only enforceable)
14. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & MAINTENANCE REQUIREMENTS
15. 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
16. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For 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.
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
AIRS ID: 123/9629/009 Page 5 of 9
eft of Public Health and Environment
Air Pollution Control Division
e. No later than 30 days before the existing APEN expires.
18. The exhaust stack for this point shall vent emissions at a point greater than or equal to
15.24 meters above the ground.
19. This facility shall be completely enclosed by a fence line and posted with no trespassing
signs that preclude public access to this site as described in the modeling analysis for
this facility. This requirement is imposed as a result of the modeled ambient air NOx and
CO impacts that result from the facility operations. (Reference: Regulation No. 3, Part B,
Section II1.B.5)
20. 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:
21. 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.
22. 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.
23. 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.
24. 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.
25. 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
AIRS ID: 12319B29/009 Page 6 of 9
Public Health and Environment
Air Pollution Control Division
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
26. 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.
27. 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:
Peter Armington
Permit Engineer
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Noble Energy Inc
AIRS ID: 123/9B29/009 Page 7 of 9
of Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these .
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 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:
http://wwvv.cdphe.state.co. us/requlations/airregs/100102agcccommonprovisionsreq. pdf.
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.
AIRS
Point
Pollutant
CAS #
BIN
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
009
n -Hexane
110543
C
2190
Yes
110
Benzene
71432
A
1460
Yes
73
Toluene
108883
C
1460
Yes
73
5) The emission levels contained in this permit are based on the following emission factors:
CAS
Pollutant
Emission Factors-
Uncontrolled
lb/BBL loaded
Source
Emission Factors —
Controlled
Lb/BBL loaded
Source
VOC
0.171
AP -42
0.0086
AP -42
110543
n -Hexane
0.003
AP -42
0.00015
AP -42
71432
Benzene
0.002
AP -42
0.00010
AP -42
108883
Toluene
0.002
AP -42
0.00010
AP -42
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 4.2 psia
M (vapor molecular weight) = 66 Ib/Ib-mol
T (temperature of liquid loaded) = 510 °R
AIRS ID: 123/9629/009
Page 8 of 9
j k{r I
Col do Dlrimet of Public Health and Environment
Air Pollution Control Division
.1
_
. 'f
The uncontrolled non -criteria reportable air pollutant (NCRP)= emission factors were calculated by
multiplying the mass fraction of each NCRP in the liquids by the VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95%.
GHG emissions from combustion are based on the assumption that vapors have an average of
five carbon atoms and molecular weight of 66.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, GHG, HAP
PSD
Synthetic Minor Source of: VOC, GHG
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 j
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
9) An Oil and Gas Industry Construction Permit Self -Certification Form is included with this permit
packet. Please use this form to complete the self -certification requirements as specified in the permit
conditions. Further guidance on self -certification can be found on our website at:
http://www.cdphe.state.co.us/ap/oilqaspermittina.html
AIRS ID: 123/9B29/009
Page 9 of 9
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