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Home My WebLink About20110362.tiff STATE OF COLORADO Bill Ritter,Jr.,Governor Martha E. Rudolph,Executive Director • �oF•Co.zo Dedicated to protecting and improving the health and environment of the people of Colorado y`�,; o 4300 Cherry Creek Dr.S. Laboratory Services Division r Denver,Colorado 80246-1530 8100 Lowry Blvd. 1876 s Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment January 28, 2011 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: The Air Pollution Control Division will publish a public notice for the Noble Energy, Inc. This public notice will be published in The Greeley Tribune on February 4, 2011. Thank you for assisting the Division by making the enclosed package (includes public notice, preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review and comment. It must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please forward any comment regarding this public notice to the address below. Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Jacquie Barela Regards, Jacqueline N. Barela Public Notice Coordinator Stationary Sources Program Air Pollution Control Division ti,bb � P�, 2011-0362 ezu (�� a - ii ;� 7/ NOTICE OF REQUEST FOR SYNTHETIC MINOR PERMIT FOR NATURAL GAS COMPRESSOR STATION BY Noble Energy, Inc. CONTENTS 1 . PUBLIC NOTICE 2. PRELIMINARY ANALYSIS 3. AIR POLLUTANT EMISSION NOTICES 4. DRAFT PERMIT PREPARED BY: STUART SIFFRING COLORADO DEPARTMENT OF PUBLIC HEALTH & ENVIRONMENT 4300 CHERRY CREEK DRIVE SOUTH, APCD-SS-B1 DENVER, CO 80246-1530 STATE OF COLORADO Bill Ritter,Jr.,Governor pF co Martha E.Rudolph,Executive Director o qp 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. .1876` Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado of Public Health http://www.cdphe.state.co.us and Environment Released to: The Greeley Tribune on January 28, 2011; published February 4, 2011 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT The Colorado Air Pollution Control Division declares the following proposed construction activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment hereby gives NOTICE, pursuant to Section 25-7-114.5(5), C.R.S. of the Colorado Air Quality Control Act that the Division received an application for an air pollution emission permit on the following proposed project and activity: Noble Energy, Inc. proposes to modify a natural gas compressor station known as the Grover Compressor Station. This source has been designed to process 20 MMSCF per day of natural gas and is located approximately 0.5 miles southeast of Grover via County Road 390, Section 4 of Township 10 North, Range 61 West in Weld County. The source would be considered a major source of air pollutants subject to Prevention of Significant Deterioration (PSD)and Maximum Achievable Control Technology (MACT) requirements if the operator did not install emissions controls and accept Federally enforceable emissions limits in the proposed permit. Since the operator will accept emissions limits less than 250 tons per year for each criteria pollutant and less than 10 tons per year any single hazardous air pollutant (HAP) and 25 tons per year total combined HAP, this source will be considered a synthetic minor source not subject to PSD or MACT review. As such, this permit is subject to public comment per Regulation 3, Part B, Section III.C.I.d. Copies of the draft permit and preliminary analysis are available for review in the public comment package. The Division hereby solicits and requests submission of public comment concerning the aforesaid proposed project and activities for a period of thirty (30) days from the date of this publication. Any such comment must be submitted in writing to the following addressee: Stuart Siffring Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B 1 Denver, Colorado 80246-1530 Within thirty (30) days following the said thirty(30)-day period for public comment, the Division shall consider comments and, pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant with conditions, the emission permits. Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the subject project and activity by affected persons. A copy of the applications for the emission permits, the preliminary analysis of said applications, and accompanying data concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld County during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of Public Health and Environment,4300 Cherry Creek Drive South, Denver, Colorado. Summary of Preliminary Analysis COMPANY'S NAME: Noble Energy,Inc. PERMIT No. 09WE0574 REVIEW ENGINEER: Stuart Siffring AIRS ID: 123/7695/002 SUPERVISING ENGINEER: Christopher Laplante REVIEW DATE: 11/8/2010 ACTION TAKEN: Construction Permit Issuance 2 FACILITY DESCRIPTION: NWNW Section 4,T10N,R61W FACILITY LOCATION: Weld County(Attainment) PUBLIC COMMENT: YES POINT DESCRIPTION'. TEG Dehydrator Emissions SUMMARY OF FACILITY CRITERIA POLLUTANT EMISSIONS(tons per year): EMISSIONS DESCRIPTION PM10 TSP SOx NOx VOC CO TOTAL HAPs EXISTING FACILITY PTE EMISSION POINT PTE 298.00 CONTROLLED ACTUAL POINT 14.90 UNCONTROLLED ACTUAL POINT 298.00 ACTUAL FUGITIVE ATTAINMENT STATUS(N or A) A A A A A NET CHANGE IN FACILITY EMISSIONS'. SUMMARY OF POINT HAZARDOUS AIR POLLUTANTS(pound per year): HAP'S NAME: Benzene n-Hexane Toluene Xylene Ethylbenzene total tons Uncontrolled Emissions: 34,858 7,703 47,195 33,529 8,484 131,769.00 66 Controlled Emissions: 1,743 385 2,360 1,676 424 6,588.00 3 PROPOSED CONTROLS a EFFICIENCY 95%flare to control still vent emissions. Flash tank emissions to be re-routed to station inlet seperator and recompressed. POINTS CLASSIFICATION'. Syn.Minor REGULATORY APPLICABILITY: COMMENT/NOTES'. See history file at K:History11237695.xIs for total facility emissions. The Division requested information from the applicant to assess the proximity and dependence of commonly owned emission sources within the region of this site. Based on this information the Division believes this stationary source is properly defined. Summary of Preliminary Analysis - NG RICE Company Name Noble Energy, Inc. Permit No. 10WE1669 Facility Name Grover Compressor Station AIRS 123/7695/004 Facility Location NWNW S04 T10N R61W Review Date 11/17/2010 Facility Equipment ID ENG2 Permit Engineer Stuart Siffring Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Caterpillar or Waukesha, Model To Be Determined, Serial Number To Be Determined, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at 1680 horsepower at 1200 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control (if lean burn engine is chosen) OR non-selective catalytic reduction (NSCR)system and air-fuel ratio control (if rich burn engine is chosen). This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 96.00 Requested(mmscf/m) 8.15 Fuel Heat Value(btu/scf) 1200 BSCF (Btu/hp-hr) 7755 Emission Factor Sources Uncontrolled Controlled NOx worst case senario from manuf. worst case senario from manuf. VOC worst case senario from manuf. worst case senario from manuf. CO worst case senario from manuf. worst case senario from manuf. Formaldehyde worst case senario from manuf. worst case senario from manuf. SOx AP-42;Table 3.2-3(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-3(7/2000);Natural Gas No Control PM10 AP-42;Table 3.2-3(7/2000);Natural Gas No Control PM2.5 AP-42;Table 3.2-3(7/2000); Natural Gas No Control Other Pollutants Describe EF sources- HAPs etc. Describe EF sources- HAPs, etc. Point Summary of Criteria Emissions (tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 228.7 19.4 228.7 94.0% VOC 10.8 5.4 10.8 50.0% CO 185.8 32.4 185.8 85.0% SOx 0.0 0.0 0.0 0.0% TSP 1.1 1.1 1.1 0.0% PM10 1.1 1.1 1.1 0.0% PM2.5 1.1 1.1 1.1 0.0% Total HAPs* 0.0 0.0 0.7 0.0% *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 fIb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 10660 5330 10660 0.0% Methanol 0 0.0% Acetaldehyde 767 383 767 0.0% Acrolein 471 300 471 0.0% Benzene 180 180 180 0.0% 1,3-Butadiene 0 0 0 0.0% Toluene 0 0 0 0.0% `Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Source is not required to model based on Division Guidelines/No NAAQS violations expected (see Ambient Air Impacts details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB over 500 HP located at a(n) Area Source Reg &XVII.E NOx: NA CO: NA VOC: NA Standards (g/hp-hr) Reg 7 XVI.B(Ozone NAA No requirements)applies? NSPS JJJJ Note: JJJJ requriements are not currently included as permit conditions while the reg is not yet adopted into Reg 6 Comments/Notes APEN requested that there be 4 different engine options in the permit. The Division requested information from the applicant to assess the proximity and dependence of commonly owned emission sources within the region of this site. Based on this information the Division believes this stationary source is properly defined. Summary of Preliminary Analysis - NG RICE Company Name Noble Energy, Inc. Permit No. 10WE1670 Facility Name Grover Compressor Station AIRS 123/7695/005 Facility Location NWNW S04 T10N R61W Review Date 11/17/2010 Facility Equipment ID ENG3 Permit Engineer Stuart Siffring Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Caterpillar or Waukesha, Model To Be Determined, Serial Number To Be Determined, natural gas-fired, turbo- charged, 4SRB reciprocating internal combustion engine, site rated at up to 1680 horsepower at 1200 RPM. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control (if lean burn engine is chosen) OR non-selective catalytic reduction (NSCR) system and air-fuel ratio control (if rich burn engine is chosen). This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 96.00 Requested(mmscf/m) 8.15 Fuel Heat Value(btu/scf) 1200 BSCF (Btu/hp-hr) 7755 Emission Factor Sources Uncontrolled Controlled NOx worst case senario from manuf. worst case senario from manuf. VOC worst case senario from manuf. worst case senario from manuf. CO worst case senario from manuf. worst case senario from manuf. Formaldehyde worst case senario from manuf. worst case senario from manuf. SOX AP-42;Table 3.2-3(7/2000);Natural Gas No Control TSP AP-42;Table 3.2-3(7/2000); Natural Gas No Control PM 10 AP-42;Table 3.2-3(7/2000); Natural Gas No Control PM2.5 AP-42;Table 3.2-3(7/2000);Natural Gas No Control Other Pollutants Describe EF sources- HAPs etc. Describe EF sources- HAPs, etc. Point Summary of Criteria Emissions (tpy) Uncontrolled Controlled Proposed Control Requested Requested PTE Efficiency NOx 228.7 19.4 228.7 94.0% VOC 10.8 5.4 10.8 50.0% CO 185.8 32.4 185.8 85.0% SOx 0.0 0.0 0.0 0.0% TSP 1.1 1.1 1.1 0.0% PM10 1.1 1.1 1.1 0.0% PM2.5 1.1 1.1 1.1 0.0% Total HAPs* 0.0 0.0 0.7 0.0% *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 flb/yr) Uncontrolled Controlled Proposed Control HAP Name Requested Requested PTE Efficiency Formaldehyde 10660 5330 10660 0.0% Methanol * 0 0.0% Acetaldehyde 767 383 767 0.0% Acrolein 471 300 471 0.0% Benzene 180 180 180 0.0% 1,3-Butadiene 0 0 0 0.0% Toluene 0 0 0 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Source is not required to model based on Division Guidelines/No NAAQS violations expected (see Ambient Air Impacts details of modeling analysis) Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB over 500 HP located at a(n) Area Source Reg &XVII.E NOx: NA CO: NA VOC: NA Standards (g/hp-hr) Reg 7 XVI.B(Ozone NM No requirements)applies? 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II II II II II 4 EE.'O i, y ti s0. d C G U w R II C7 cr,N W GQ p m 4 C. tt ra Q ° o m U p, W W C4 Ll n rl .a .7 .a y o u iy � Z, el d a °� 7. s „ u co'" m ati o C run E i, a I" J ® C a b ° O .X L 0. ci, o ° 0000000 . i ro o E d o u O D U U U U U v � dcsp �] A v ® E o L a Vi Vl v� v] vi Vl v� CO v " O L u > v c o I- ` o a Z Z Z Z Z Z Z. P, c _ .. d c o u o .L. 0E R '❑ v II ooII�� II cCll II FyII�� II b E Q 5 a 2 r« .. -0„ @ 0.0 (C.... E w > m C C C4 a C d `u' o o I 'EN^, c u C 0 6-11 O C X.°a °o c r a °3 ON y q v t cy o Z z o r.'T Ur O .u. o a4 G�, 0 Q a O p'E CC zi N U N y y v) coC Ca u N W �. O] E ,7 `� ,CC CO E m a i' .,ry u O O O u 0 0 0 0 .2. N CJ O v U N R' e ° v t o C n°. c o c E cn II II rn cn up cn cr v a • d '-' ro-m m m o ° o L 0 a m CO 02 0 Cl CO XI �, °' - ..1 '6 v'� o a m u U a ,.a a s �a ra .a r' V C Y u E �C C r„w v on C I 'E 5 o in O ,o Fn N c Tao Cu Q O a CO o O E c o V x x U o 0 'd N 0 45 A 5 ❑ E ��Q L s c W o W o F- G R 0 0 0 F ° v o A .0 x .0 .0 R C < D] C O W u ❑A — __. — .— _ _ cn cn STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION * TELEPHONE: (303)692.3150 . „�y *1696 CONSTRUCTION PERMIT PERMIT NO: 09WE0574 Issuance 2 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Grover Compressor Station, located in the NWNW of Section 4, Township 10 North, Range 61 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) Triethylene glycol (TEG) natural gas dehydration unit (make: to be determined, model: TBD, serial number: TBD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with either one (1) Kimray model 45015 or two (2) model 21015, gas-glycol pump(s) with a design capacity of 7.5 gallons DENY 002 per minute. This unit is equipped with a reboiler, still vent and flash tank. Emissions from the still vent are controlled by a combustion device achieving minimum 95% control efficiency. Emissions from the flash tank are recycled to the station inlet. Stripping gas may be injected into the reboiler to enhance water removal from glycol. 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. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee'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). 2. 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 AIRS ID: 123/7695/002 Page 1 of 9 Dehy Version 2009-1 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 3. The manufacturer model number and serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operation. This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E) 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 AIRS Tons per Month Emission Type Equipment ID Point VOC Benzene DEHY 002 1.25 0.08 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point VOC Benzene DENY 002 14.9 1.0 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 yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility 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 (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 monthly emissions and keep a compliance record on site, AIRS ID: 123/7695/002 Page 2 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN, at this facility. 6 Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values(including gas throughput, lean glycol recirculation rate. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc. 7. This unit shall be configured such that the flash tank vapors are routed to the station inlet separator and recompressed and still vent vapors are routed to the flare. The flare shall be capable of reducing uncontrolled emissions of VOC from the TEG dehydration unit to the emission levels listed in Condition 5, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) 8. 100% of emissions that result from the flash tank associated with this dehydrator shall be recycled to station inlet separator and recompressed. PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual natural gas throughput rate 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 AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID DENY 002 Natural gas throughput 7300 620 MMscf/yr MMscf/month During the first twelve(12) months of operation,compliance with both the monthly and yearly natural gas throughput limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the yearly natural gas 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 monthly natural gas throughput and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. This source shall be limited to a maximum lean glycol recirculation pump rate of 5.0 gallons per minute. The owner or operator shall maintain weekly records of the actual lean glycol recirculation rate and make them available to the Division for inspection upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. 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) 12. Emissions from combustion device shall have no visible emissions during normal operations, and be designed so than an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the AIRS ID: 123/7695/002 Page 3 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 Division, determine whether it is operating properly. (Reference: Regulation No. 7, Section XVII.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No. 7, Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG) separator(flash separator or flash tank), if present, shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7, Section XVII. 15. This source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the following: • §63.764 - General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (c)(1) and (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). • §63.764 (e)(1)(ii) —The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. • §63.772-Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). • §63.772(b)(2) -The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. • §63.772(b)(2)(i)—The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc T"", Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TMTechnical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or AIRS ID: 123/7695/002 Page 4 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 • §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. • §63.774 - Recordkeeping Requirements o §63.774(d)(1)-An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. • §63.774(d)(1)(i)—The actual annual average natural gas throughput(in terms of natural gas flowrate to the glycol dehydration unit per day) as determined in accordance with §63.772(b)(1), or • §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING & MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the applicant shall follow the 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. Periodic Testing Requirements 18. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per Condition 6. ADDITIONAL REQUIREMENTS 19. All previous versions of this permit are cancelled upon issuance of this permit. 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 AIRS ID: 123/7695/002 Page 5 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 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. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equal or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 22. Prevention of Significant Deterioration (PSD) requirements 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 PSD threshold will require a full PSD review of the source as though,construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 23. 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 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 Subpart HH. (Reference: Regulation No. 8, Part E). 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 AIRS ID: 123/7695/002 Page 6 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 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. 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 �� Stuart Siffring/7 Permit Engineer Permit History Issuance Date Description Issuance 2 This Issuance Modification of TEG dehydrator at a synthetic minor source AIRS ID: 123/7695/002 Page 7 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cd phe.state.co.us/req u lations/ai rregs/100102agcccom mon provisionsreq.pdf. 3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS # BIN (lb/yr) reportable? Rate (Ib/yr) Benzene 71432 A 34,858 YES 1743 Toluene 108883 C 47,195 YES 2360 002 Ethylbenzene 100414 C 8,484 NO 424 Xylene 1330207 C 33,529 YES 1676 Hexane 110543 C 7,703 YES 385 4) The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of rive years. Tile five-year term for this APEN expires on June 3, 2015. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source NOx, VOC PSD Synthetic Minor Source NOx, VOC MACT HH Area Source Requirements: Applicable MACT ZZZZ Area Source Requirements: Not Applicable 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: 123/7695/002 Page 8 of 9 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 09WE0574 Air Pollution Control Division Issuance 2 http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ— Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 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/oilgaspermitting.html AIRS ID: 123/7695/002 Page 9 of 9 STATE OF COLORADO .of Cot,. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 -. • X876,i CONSTRUCTION PERMIT PERMIT NO: 1 OWE1669 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Grover Compressor Station, located in NWNW SO4 T1 ON R61 W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar 3516 lean burn engine equiped with oxidation catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo-charged, rated at 1340 HP at 1400 rpm. This emission unit is used for natural gas compression. OR One (1) Caterpillar 3516 ultra lean engine burn equiped with oxidation catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo-charged, rated at 1380 HP at 1400 rpm. This emission unit is used for natural gas compression. ENG2 004 OR One (1) Waukesha 7042 rich burn engine equiped with non-selective catalytic reduction catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo- charged, rated at 1480 HP at 1200 rpm. This emission unit is used for natural gas compression. OR One (1) Waukesha 7044 rich burn engine equiped with non-selective catalytic reduction catalyst and air-fuel ratio controller. serial number: TBD, natural gas-fired, turbo- charged, rated at 1680 HP at 1200 rpm. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar 3516 or Waukesha 7042 or Waukesha 7044 engine in accordance with the permanent replacement provision of the Alternate AIRS ID: 123/7695/004 Page 1 of 16 NGEngine Version 2009-1 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Operating Scenario (AOS), included in this permit as Attachment A. Any permanent engine replacement completed per this AOS provision must be limited to an identical make and model of engine originally installed under the authority of this permit. 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 APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the permittee'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, III.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; (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. Within thirty days (30) after commencement of operation of this point the permit holder shall submit to the Division a complete Air Pollution Emission Notice (APEN) requesting to modify this permit to reflect the actual equipment constructed and remove the engine options not installed. 6. The manufacturer, model number, and serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operation. This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 7. 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 AIRS ID: 123/7695/004 Page 2 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 8. 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 AIRS Tons per Month Equipment ID Point Emission Type N0x V0C CO ENG2 004 1.6 0.5 2.8 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO, V0C CO ENG2 004 19.4 5.4 32.4 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 yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility 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 (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 monthly emissions 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 emission units, requiring an APEN, at this facility. 9. The catalyst system for the below engine options shall be capable of reducing uncontrolled emissions of NOx, VOC, CO, and HAPs from the unit to the emission levels listed in Condition 8, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) Engine Controlled Model Control Device Manufacturer Emissions Caterpillar 3516 LB Oxidation catalyst and air/fuel ratio CO, V0C's and controller formaldehyde AIRS ID: 123/7695/004 Page 3 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Caterpillar 3516 ULB Oxidation catalyst and air/fuel ratio CO, VOC's and controller formaldehyde Waukesha 7042 Non-selective catalytic reduction (NSCR) NOR, CO and air/fuel ratio controller Waukesha 7044 Non-selective catalytic reduction (NSCR) NOR, CO and air/fuel ratio controller PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual consumption rate 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 AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID 96.00 8.15 ENG2 004 Consumption of natural gas as a fuel MMscf/yr MMscf/month During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the yearly consumption 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 monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable). 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for natural gas-fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas-fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below AIRS ID: 123/7695/004 Page 4 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Maximum Engine Construction or Emission Standard in g/hp-hr HP Relocation Date NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 ≥500HP July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Note: Per Regulation No. 7, Section XVII.B.4, internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT) limit, or a New Source Performance Standard under 40 CFR Part 60 are not subject to this Section XVII. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the applicant shall follow the 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 16. A source initial compliance test shall be conducted to measure the emission rate(s) for NOx, CO and Formaldehyde in order to demonstrate compliance with the emissions limits contained in this permit. 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) Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. 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: AIRS ID: 123/7695/004 Page 5 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tDns 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. 19. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equal or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 20. Prevention of Significant Deterioration (PSD) requirements 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 PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 21. 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: 22. 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. 23. 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 AIRS ID: 123/7695/004 Page 6 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 r^sult 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 iffifiv if Stuart Siffring Permit Engineer Permit History _ Issuance Date Description Issuance 1 This Issuance Engine at natural gas compression facility AIRS ID: 123/7695/004 Page 7 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/requlations/airregs/100102agcccommonprovisionsreq.pdf. 3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS # BIN (lb/yr) reportable? Rate (lb/yr) Formaldehyde 5000 A 10660 Yes 5330 Methanol 67561 C 0 No 0 Acetaldehyde 75070 A 767 Yes 383 004 Acrolein 107028 A 471 Yes 300 Benzene 71432 A 180 Yes 180 1,3-Butadiene 106990 A 0 No 0 Toluene 108883 C 0 No 0 4) The emission levels contained in this permit are based on the following emission factors: Point 004: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.4264 1.5000 0.4264 1.5000 CO 0.5686 2.0000 0.5686 2.0000 VOC 0.1166 0.4100 0.1166 0.4100 5000 Formaldehyde 0.1064 0.4000 0.0532 0.2000 67561 Methanol 0.0031 0.0108 0.0031 0.0108 75070 Acetaldehyde 0.0028 0.0084 0.0014 0.0042 107028 Acrolein 0.0026 0.0093 0.0026 0.0093 71432 _ Benzene 0.0016 0.0056 0.0016 0.0056 106990 1,3-Butadiene 0.0007 0.0023 0.0007 0.0023 108883 Toluene 0.0006 0.0020 0.0006 I 0.0020 AIRS ID: 123/7695/004 Page 8 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7755 Btu/hp-hr, a nameplate horsepower value of 1680, and a fuel heat value of 1200 Btu/scf. Emission factors vary depending on make/model chosen. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx worst case senario from manuf. worst case senario from manuf. CO worst case senario from manuf. worst case senario from manuf. VOC worst case senario from manuf. worst case senario from manuf. 5000 Formaldehy worst case senario from manuf. worst case senario from manuf. de 67561 Methanol AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 75070 Acetaldehyd AP-42; Table 3.2-3 (7/2000); No Control e Natural Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 106990 1,3- AP-42; Table 3.2-3 (7/2000); No Control Butadiene Natural Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (ARC'N) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on June 2, 2015. A revised APEN shall be submitted no later than 30 days before the five-year t^rm expires. 6) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf 7) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Ermines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hn located at r r sources have not yet been incorporated into Colorado Air Quality Control Commi;_sion's Regi r n No. 8. A copy of the complete subpart is available on the EPA website at: http `sww.epa ;, r .o/a'w/area/fr18ja08.pdf Additional information regarding area source standards crr be four .,.. the EPA website at: http://www.epa.qov/ttn/atw/area/arearules.html 8) This facility is classified as follows: Applicable Status Requirement Synthetic Minor Source Operating Permit CO (if 4SRB used), NOx (if 4SRB used), VOC PSD Synthetic Minor Source CO (if 4SRB used), NOx (if 4SRB used), VOC MACT HH Area Source Requirements: Not Applicable AIRS ID: 123/7695/004 Page 9 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 MACT ZZZZ Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A— Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ— Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ— Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 10) 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/oilgaspermitting.html AIRS ID: 123/7695/004 Page 10 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES December 10, 2008 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines 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, Port D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it h boon found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. A.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days 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 engine is in operation. If the engine operates only part of a day, that day shall count as a sinn,e day towards the 90-day total. The compliance demonstrations and any periodic, monitoring rentiir d t.v this AOS are in addition to any compliance demonstrations or periodic monitoring required by thi on not. All replacement engines are subject to all federally applicable and state-only re's, rerents 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 NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, morel number, horsepower, and serial number of the engine(s) that are replaced during the term of this o trmit, and r .111n l`aaturer, model number, horsepower, and serial number of the replacement en_ m.'_ In additiL a to M. the permittee shall maintain a copy of all Applicability Reports required undo tion A.1.2 . ad 'n . m available to the Division upon request. A.1.1 The permittee may temporarily replace an existing compressor engine 'hat I subject to the emission limits set forth in this permit with an engine that is of i.e. ;:..me roams,..,:rc model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the emissions from the temporary replacement engine comply with the emission limitations for the existing permitted engine as determined in section A.2. Measurement of emissions from the temporary replacement engine shall be made as set forth in section a_ A.1.2 The permittee may permanently replace the existing compressor engine with an engine that is listed in the table below (A.3.6) without modifying this permit so lone as the e ... dons 'rem the permanent replacement engine comply with 1) the permitted a i emissio aa as for the existing AIRS ID: 123/7695/004 Page 11 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10W16C9 Air Pollution Control Division Issuance 1 engine, 2) any perrnittuc. sn. rt-term emission limitations for the existing permitted engine, and 3) the applicable emission lirnitaLicns as set forth in the Applicability Report submitted to the Division with the Air Pollutant Emissions No: ' \PEN) for the replacement engine (see http://www.cdohe.statn r'n , `;p/oilgaspermittinq.html for example applicability report formats). Measurement of emissions Horn the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section A.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercisin an alterna.lve operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdphe.state.co.us/a0/oilgaspermittinq.html. This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of the source indicating that "eased on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used icr permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not s.,bject to emission limits. The permittee 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 engine replacement. A.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirement' 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 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 permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: http://www.cdphe.state.co.us/apiclown/portanalyzeproto.pdf 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. AIRS ID: 123/7695/004 Page 12 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 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 engine 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 engine 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 engine 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 engine is taken offline. A.3 Applicable Regulations for Permanent Engine Replacements A.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit 0f NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CF Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. A.3.2 Control Requirements and Emission Standards: RegOntion No. 7, Ser--.os '"I. and XVII.E (State-Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI. as specified below: Rich burn engines with a manufacturer's design rate gr .c'er than 500 hn shall use a non- selective catalyst and air fuel controller to reduce emirs ^n. AIRS ID: 123/7695/004 Page 13 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10`VE16o. Air Pollution Control Division Issuance 1 Lean burn cr..: ' ies . ',th a manufc.., .rer's design rate greater than 500 hp shall use an oxidation catalyst to iL i. _a ,;scions. The above emission cocar iuipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition A.1.2. Emission Standards: Sec:. onXVII.E— Stale-only requirements Any permanent engine Ihar. is either constructed or relocated to the state of Colorado from another state, after the date listed in the • ole below shah operate and maintain each engine according to the manufacturer's written ins't. ctions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves tke emission standards required in the table below: instruction Emission Standards in G/hp-hr Max Engine Hi' .location Da.a NOx CO VOC January 1, 2006 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 July 1, 2007 2.0 4.0 1.0 500≤Hp July 1, 2010 1.0 2.0 0.7 The source shall submit c os of the relevant Applicability Reports required under Condition A.1.2 A.3.3 NSPS for spark ig:,,con internal coinoustion engines: 40 CFR 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engine _treater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn encInes greater than or equal to 500 hp and less than 1,350 hp are subject 40 CFR 60, Subpart JJJJ. An analysis of a: pi: l'. 'e monitoring , recordkeeping, and reporting requirements for the permanent engine replacement shit to included in the Applicability Reports required under Condition A.1.2. Any testing required by the NSi 7 is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division, rcc_tided that such test is conducted within the time frame specified in Condition A.2. Note that und..r th , v, a of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Col ado into the State of Colorado is considered to be a new source, subject to the requirements of Reguh., 'n No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of November I, 2008 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional ste o added to the determination of the NSPS. Under the provisions of Regulation No 6, Pad 8, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Co/cp ado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. A.3.4 Reciprocating in: n.1 combust:c, engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/7&35/7,0-, Page 14 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 A.3.4.1 Area Source for HAPs A permanent replacement engine located at an area source that commenced construction or reconstruction after June 12, 2006 as defined in § 63.2, will meet the requirements of 40 CFR Part 63, Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition A.2. A.3.4.2 Major source for HAPs A permanent replacement engine that is located at major source is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ as follows: Existing, new or reconstructed spark ignition 4 stroke rich burn engines with a site rating of more than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4 stroke lean burn engines with a site rating of more than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a site rating of greater than or equal to 50 but less or equal to 500 hp and were manufactured on or after 1/1/08 are subject to the ;uirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/05) 2 stroke lean burn or 4 stroke rich burn engines with a site rating of 500 hp or less will moot the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a site rating of less than 250 hp wi:: mr:,t the requir; m: etc of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60 Subpart JJJJ. An analysis of the applicable monitoring, recordkeep.:),;. d reporting quep -. nts h-.r the permanent engine replacement shall be included in the F R-ports required under Condition A.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can se,.ve the testing regt!ir a by this AOS under Condition A.2, if approved in advance by the l v'�ci'r, provided Het _e n test is conducted within the time frame specified in Condition A.2. A.3.5 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not"routine replacement" of an existing un,t. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be uses! Vr additional nn" emission feints for any site; an engine that is being installed as an entirely new r-, - m poin. ann n • as part of an AOS- approved replacement of an existing onsite engine has to go , Jh the e,:prr ,� .: Construction/Operating permitting process prior to installatic.. A.3.6 List of approved replacement engines AIRS ID: 123/7695/004 P: ge 15 of 16 Noble Energy, Inc. Colorado Department of Public Health and Environment Permit No. 10WE1669 Air Pollution Control Division Issuance 1 Manufacturer Model Type BHP Controls Caterpillar G3516LE 4SLB Turbo 1340 AFRC w/Oxicat Caterpillar G2516ULB 4SLB Turbo 1380 AFRC w/Oxicat Waukesha L/042 4SRB Turbo 1480 AFRC w/NSCR Waukesha L7044 4SRB Turbo 1680 AFRC w/NSCR AIRS ID: 123/76.,0,X04 Page 16 of 16 STATE OF COLORADO ov.Cow COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION *' TELEPHONE: (303) 692-3150 ,aa6* CONSTRUCTION PERMIT PERMIT NO: 10WE1670 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the Grover Compressor Station, located in NWNW S04 T10N R61W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One (1) Caterpillar 3516 lean burn engine equiped with oxidation catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo-charged, rated at 1340 HP at 1400 rpm. This emission unit is used for natural gas compression. OR One (1) Caterpillar 3516 ultra lean engine burn equiped with oxidation catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo-charged, rated at 1380 HP at 1400 rpm. This emission unit is used for natural gas compression. ENG3 005 OR One (1) Waukesha 7042 rich burn engine equiped with non-selective catalytic reduction catalyst and air-fuel ratio controller, serial number: TBD, natural gas-fired, turbo- charged, rated at 1480 HP at 1200 rpm. This emission unit is used for natural gas compression. OR One (1) Waukesha 7044 rich burn engine equiped with non-selective catalytic reduction catalyst and air-fuel ratio controller. serial number: TBD, natural gas-fired, turbo- charged, rated at 1680 HP at 1200 rpm. This emission unit is used for natural gas compression. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar 3516 or Waukesha 7042 or Waukesha 7044 engine in accordance with the permanent replacement provision of the Alternate AIRS ID: 123/7695/005 Page 1 of 16 NGEngine Version 2009-1 Noble Energy, Inc. Col do pe mek o Public Health and Environment 7 Permit No. 10WE1670 f „Ain-: Dx Air Pollution Control Division Issuance 1 20, r __ J Operating Scenario (AOS), included in this permit as Attachment A. Any permanent engine replacement completed per this AOS provision must be limited to an identical make and model of engine originally installed under the authority of this permit. 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 APCD no later than fifteen days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of 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 on this permit shall be demonstrated to the Division. It is the permittee'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, III.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; (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. Within thirty days (30) after commencement of operation of this point the permit holder shall submit to the Division a complete Air Pollution Emission Notice (APEN) requesting to modify this permit to reflect the actual equipment constructed and remove the engine options not installed. 6. The manufacturer, model number, and serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operation. This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 7. 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 AIRS ID: 123/7695/005 Page 2 of 16 Noble Energy, Inc. Col do p e o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 8. 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 AIRS Tons per Month Emission Type Equipment ID Point NO, VOC NO, ENG3 005 1.6 0.5 1.6 Point Monthly limits are based on a 31-day month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO ENG3 005 19.4 5.4 32.4 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 yearly emission limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the synthetic minor status of this facility 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 (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 monthly emissions 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 emission units, requiring an APEN, at this facility. 9. The catalyst system for the below engine options shall be capable of reducing uncontrolled emissions of NOx, VOC, CO, and HAPs from the unit to the emission levels listed in Condition 8, above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3, Part B, Section III.E.) Engine Controlled Model Control Device Manufacturer Emissions Caterpillar 3516 LB Oxidation catalyst and air/fuel ratio CO, V0C's and controller formaldehyde AIRS ID: 123/7695/005 Page 3 of 16 Noble Energy, Inc. q Col do D.. p rime. of Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 Caterpillar 3516 ULB Oxidation catalyst and air/fuel ratio CO, VOC's and controller formaldehyde Waukesha 7042 Non-selective catalytic reduction (NSCR) NOR, CO and air/fuel ratio controller Waukesha 7044 Non-selective catalytic reduction (NSCR) NON, CO and air/fuel ratio controller PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual consumption rate 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 AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID ENG3 005 Consumption of natural gas as a fuel 96.00 8.15 MMscf/yr MMscf/month During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required. Compliance with the yearly consumption 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 monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable). 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This equipment is subject to the control requirements for natural gas-fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas-fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below AIRS ID: 123/7695/005 Page 4 of 16 Noble Energy, Inc. Col do `p; ` e o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 Maximum Engine Construction or Emission Standard in g/hp-hr HP Relocation Date NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and January 1, 2008 2.0 4.0 1.0 <500HP January 1, 2011 1.0 2.0 0.7 ≥500HP July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Note: Per Regulation No. 7, Section XVII.B.4, internal combustion engines that are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT) standard under 40 CFR Part 63, a Best Available Control Technology ("BACT") limit, or a New Source Performance Standard under 40 CFR Part 60 are not subject to this Section XVII. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the applicant shall follow the 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 16. A source initial compliance test shall be conducted to measure the emission rate(s) for NOx, CO and Formaldehyde in order to demonstrate compliance with the emissions limits contained in this permit. 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) Periodic Testing Requirements 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 18. 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: AIRS ID: 123/7695/005 Page 5 of 16 Noble Energy, Inc. Col ,do p e of Public Health and Environment Permit No. 10WE1670 aiThAir Pollution Control Division 7' Issuance 1 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. 19. Operating Permit (OP) requirements shall apply to this source at any such time that the facility wide potential to emit equals or exceeds the major source level. Once the facility wide potential to emit equal or exceeds the major source level a Title V operating permit application shall be submitted in accordance with the requirements in Regulation No. 3, Part C. 20. Prevention of Significant Deterioration (PSD) requirements 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 PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4) 21. 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: 22. 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 'LB upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. 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 AIRS ID: 123/7695/005 Page 6 of 16 Noble Energy, Inc. Col do p rt e of Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 24. 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. 25. 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. 26. 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. 27. 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. 28. 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: Stuart Siffring Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Engine at natural gas compression facility AIRS ID: 123/7695/005 Page 7 of 16 • Noble Energy, Inc. N Col do D pir riie of Public Health and Environment Permit No. 10WE1670 7 Air Pollution Control Division Issuance 1 Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.cdphe.state.co.us/requlations/airreqs/100102agcccommonprovisionsreq.pdf. 3) The -following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (lb/yr) Formaldehyde 5000 A 10660 Yes 5330 Methanol 67561 C 0 No 0 Acetaldehyde 75070 A 767 No 383 005 Acrolein 107028 A 471 No 300 Benzene 71432 A 180 No 180 1,3-Butadiene 106990 A 0 No 0 Toluene 108883 C 0 Yes 0 4) The emission levels contained in this permit are based on the following emission factors: Point 005: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant Ib/MMBtu g/bhp-hr Ib/MMBtu g/bhp-hr NOx 0.4264 1.5000 0.4264 1.5000 CO 0.5686 2.0000 0.5686 2.0000 VOC 0.1166 0.4100 0.1166 0.4100 5000 Formaldehyde 0.0532 0.2000 0.0532 0.2000 67561 Methanol 0.0031 0.0108 0.0031 0.0108 75070 Acetaldehyde 0.0028 0.0098 0.0028 0.0098 107028 Acrolein 0.0026 0.0093 0.0026 0.0093 71432 Benzene 0.0016 0.0056 0.0016 0.0056 106990 1,3-Butadiene 0.0007 0.0023 0.0007 0.0023 108883 Toluene 0.0006 0.0020 0.0006 0.0020 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7755 Btu/hp-hr, a site-rated horsepower value of 1680, and a fuel heat value of 1200 Btu/scf. AIRS ID: 123/7695/005 Page 8 of 16 Noble Energy, Inc. ColA do •p e o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 r� Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx worst case senario from manuf. worst case senario from manuf. CO worst case senario from manuf. worst case senario from manuf. VOC worst case senario from manuf. worst case senario from manuf. 5000 Formaldehy worst case senario from manuf. worst case senario from manuf. de 67561 Methanol AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 75070 Acetaldehyd AP-42; Table 3.2-3 (7/2000); No Control e Natural Gas 107028 Acrolein AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 71432 Benzene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 106990 1,3- AP-42; Table 3.2-3 (7/2000); No Control Butadiene Natural Gas 108883 Toluene AP-42; Table 3.2-3 (7/2000); No Control Natural Gas 5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years. The five-year term for this APEN expires on June 2, 2015. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting —effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http.//www.epa.qovittn/atw/areaffr181a08.pd This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines c 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.aov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.ciov/ttn/atw/area/arearules html 8) This facility is classified as follows: Applicable Status Requirement Synthetic Minor Source Operating Permit CO (if 4SRB used), NOx (if 4SRB used), VOC PSD Synthetic Minor Source CO (if 4SRB used), NOx (if 4SRB used), VOC MACT HH Area Source Requirements: Not Applicable MACT ZZZZ Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: AIRS ID: 123/7695/005 Page 9 of 16 Noble Energy, Inc. Col do p e o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 http://ecfr.g poaccess.goy/ 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 M—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 10) 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/apioilgaspermitting.html AIRS ID: 123/7695/OO5 Page 10 of 16 Noble Energy, Inc. Col do ; p a of Public Health and Environment Permit No. 10WE1670 . _ Air Pollution Control Division Issuance 1 ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES December 10, 2008 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines 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 engine replacement performed in accordance with this AOS, and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. A.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days 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 engine is in operation. If the engine 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. All replacement engines 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 NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the permittee shall maintain a copy of all Applicability Reports required under section A.1.2 and make them available to the Division upon request. A.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the emissions from the temporary replacement engine comply with the emission limitations for the existing permitted engine as determined in section A.2. Measurement of emissions from the temporary replacement engine shall be made as set forth in section A.2. A.1.2 The permittee may permanently replace the existing compressor engine with an engine that is listed in the table below(A.3.6)without modifying this permit so long as the emissions from the permanent replacement engine comply with 1) the permitted annual emission limitations for the existing AIRS ID: 123/7695/005 Page 11 of 16 Noble Energy, Inc. Col do p e of Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3) the applicable emission limitations as set forth in the Applicability Report submitted to the Division with the Air Pollutant Emissions Notice (APEN) for the replacement engine (see http://www.cdphe.state.co.us/ap/oilgaseermittinq.html for example applicability report formats). Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section A.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdohe.state.co.us/ap/oilgaspermittina.html. This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of the source indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permittee 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 engine replacement. A.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 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 permittee 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 permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf 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. AIRS ID: 123/7695/005 Page 12 of 16 Noble Energy, Inc Col tdo p y e o Public Health and Environment Permit No. 10WE1670 = j Air Pollution Control Division Issuance 1 . .. ,. . For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine 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 engine 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 engine 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 engine is taken offline. A.3 Applicable Regulations for Permanent Engine Replacements A.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. A.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. AIRS ID: 123/7695/005 Page 13 of 16 Noble Energy, Inc. Col k do •4/pa e ;Public Health and Environment '. Permit No. 10WE1670 1 : t4 � ; Air Pollution Control Division Issuance 1 Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition A.1.2. Emission Standards: Section XVII.E— State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Construction or Emission Standards in G/hp-hr Max Engine HP Relocation Date NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition A.1.2 A.3.3 NSPS for spark ignition internal combustion engines: 40 CFR 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject 40 CFR 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition A.2. 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 manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of November 1, 2008 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 123/7695/005 Page 14 of 16 Noble Energy, Inc. Co do I p e: o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 s A.3.4.1 Area Source for HAPs A permanent replacement engine located at an area source that commenced construction or reconstruction after June 12, 2006 as defined in § 63.2, will meet the requirements of 40 CFR Part 63, Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition A.2. A.3.4.2 Major source for HAPs A permanent replacement engine that is located at major source is subject to the requirements in 40 CFR Part 63 Subpart ZZZZ as follows: Existing, new or reconstructed spark ignition 4 stroke rich burn engines with a site rating of more than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4 stroke lean burn engines with a site rating of more than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean burn or 4 stroke rich burn engines with a site rating of 500 hp or less will meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ. New or reconstructed (construction or reconstruction commenced after 6/12/06)4 stroke lean burn engines with a site rating of less than 250 hp will meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition A.2. A.3.5 Additional Sources The replacement of an existing engine with a new engine 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; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. A.3.6 List of approved replacement engines AIRS ID: 123/7695/005 Page 15 of 16 I Noble Energy, Inc. A; Col '.do • p " e o Public Health and Environment Permit No. 10WE1670 Air Pollution Control Division Issuance 1 • Manufacturer Model Type BHP Controls Caterpillar G3516LE 4SLB Turbo 1340 AFRC w/Oxicat Caterpillar G3516ULB 4SLB Turbo 1380 AFRC w/Oxicat Waukesha L7042 4SRB Turbo 1480 AFRC w/NSCR Waukesha L7044 4SRB Turbo 1680 AFRC w/NSCR AIRS ID: 123/7695/005 Page 16 of 16 Hello