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Home My WebLink About20200424.tiffCOLORADO Department of Public Health Es Environment Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 January 6, 2020 Dear Sir or Madam: RECEIVED JAN 10 2020 WELD COUNTY COMMISSIONERS On January 7, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy Inc. - Eagle Reliance Seneca Tahoma Econode T6N-R65W-S14 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health £t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692.2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pulp I : G Re v;Gt,J CC : PL.(TP)i Ht -0-x), P W (Srt feR/GK/cv), I (/2o o60M) t/(3/20 2020-0424 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy Inc. - Eagle Reliance Seneca Tahoma Econode T6N-R65W-S14 L01 - Weld County Notice Period Begins: January 7, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Noble Energy Inc. Facility: Eagle Reliance Seneca Tahoma Econode T6N-R65W-S14 L01 Exploration IL Production Well Pad SWSW Quadrant of Section 14, Township 6N, Range 65W Weld County The proposed project or activity is as follows: The Eagle Reliance Seneca Tahoma Econode is an existing facility that processes wellhead liquids. Noble Energy Inc. (Noble) submitted this application requesting to decrease throughput and permit limits for condensate storage and condensate loadout. In addition, Noble has requested to permit Low Pressure Gas Venting and Vapor Recovery Tower Venting during Vapor Recovery Unit downtime. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 15WE0039.CP3 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: COLORADO Department of Public Health @ Envlranrnent James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO. Department of Public Health & Environment COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 15WE003 9 Date issued: X Issued to: Noble Energy Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 3 Eagle Reliance Seneca Tahoma Econode T6N-R65W-S14 L01 123/9D74 SWSW Quadrant of Section 14, Township 6N, Range 65W Weld County Well Production Facility Equipment or activity subject to this permit: Desccription AIRS Point Equipment Description Emissions Control Description Condensate Loadout 005 ' Loadout of condensate by submerged fill, from storage vessels into tank trucks Enclosed Combustor Produced Water Storage 006 One (1) above ground atmospheric produced water storage tank with a total capacity of 3,348 barrels (consisting of Six (6) storage vessels liquid manifold together). Enclosed Combustor Condensate Storage 007 One (1) above ground atmospheric condensate storage tank with a total capacity of 9,684 barrels (consisting of eighteen (18) storage vessels liquid manifold together). Enclosed Combustor LP Gas Venting 011 Low Pressure Gas Separator(s) - Gas Venting during VRU Downtime Enclosed Combustor VRT Gas Venting 012 Vapor Recovery Tower(s) (VRT) - Gas Venting during VRU Downtime Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. Page 1 of 17 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 Points 011 and 012: YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Points 005, 007, 011 and 012: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form.. and guidance on how to self -certify ! compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section IILG.2.) 3. Points 005, 007, 011 and 012: This permit must 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. (Regulation Number 3, Part B, Section III.F.4.) 4. Points 005, 007, 011 and 012: The operator must complete an initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self - certification process. (Regulation Number 3, Part B, Section III.E.) 5. Points 005, 007, 011 and 012: The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Page 2 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: Desccription AIRS Point Tons per Year Emission Type NO. VOC CO Condensate Loadout 005 -- 1.0 -- Point Produced Water Storage 006 -- 2.7 -- Point Condensate Storage 007 -- 5.0 -- Point LP Gas Venting 011 1.4 23.5 4.7 Point VRT Gas Venting 012 -- 10.5 1.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 3 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Desccription AIRS Point Control Device Pollutants Controlled Condensate Loadout 005 Enclosed Combustor VOC and HAP Produced Water Storage 006 Enclosed Combustor VOC and HAP Condensate Storage 007 Enclosed Combustor VOC and HAP LP Gas Venting 011 Enclosed Combustor VOC and HAP VRT Gas Venting 012 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Desccription 005 AIRS Point Control Device Pollutants Controlled Condensate Loadout Condensate Loaded 140,014 barrels Produced Water Storage 006 Produced Water Throughput 401,500 barrels Condensate Storage 007 Condensate Throughput 140,014 barrels LP Gas Venting 011 Natural Gas Venting 11.94 MMSCF VRT Gas Venting 012 Natural Gas Venting 3.26 MMSCF Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Points 011 and 012: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. Page 4 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 11. Points 005, 006, 007, 011 and 012: This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Points 006, 007, 011 and 012: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. Point 005: No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 14. Point 005: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 15. Point 005: All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 16. Point 005: The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 17. Point 005: For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Page 5 of 17 COLORADO Air Pollution Control Division Department of Pubitc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. 18. Point 007: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 19. Points 006, 007, 011 and 012: The combustion ` device covered by this permit is` subject to Regulation Number 7, Section XVII.B.2. General' Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and-. be designed so that 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 Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 20. Points 006 and 007: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 21. Point 006: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation No. 7, Section XVII.C.2. This storage tank shall be operated without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and Page 6 of 17 atm- COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado equipment. The owner/operator must develop, certify, and implement a documented STEM plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet these requirements. Compliance is required on the following schedule: o A storage tank constructed on/after May 1, 2014 must comply and implement a STEM Plan within 90 days of the storage tank commencing operation; o A storage tank constructed before May 1, 2014, must comply and implement a STEM Plan by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase -In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 - Storage Tank Inspections Phase -In Schedule Threshold: Storage Tank Uncontrolled Pt Actual VOC Emissions' (tpy) Approved Instrument Monitoring Method ("AIMM") Inspection Frequency 6 and < 12 Annually January 1, 2016 >12and <50 Monthly July 1, 2015 > 50 January 1, 2015 The owner/operator shall maintain records in accordance with Regulation No. 7, Section XVII.C.3. and make them available to the Division upon request. The owner or operator shall maintain records of STEM, including the plan, any updates, and the certification, for the life of the storage tank. The owner/operator will maintain records of all required inspections and monitoring for a period of two years. 22. Points 011 and 012: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING 8 MAINTENANCE REQUIREMENTS 23. Points 005, 006, 007, 011 and 012: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format Page 7 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0 tm plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 24. Point 007: The owner or operator must complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate from the vapor recovery tower(s) that are routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to the Division as part of the self - certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 25. Point 011: The owner/operator must complete aninitial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from the low pressure separator(s) in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 26. Point 012: The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from the vapor recovery tower(s) in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Page 8 of 17 COLORADO Air Pollution Control Division Department of FhOolic'Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 27. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 28. All previous versions of this permit are cancelled upon issuance of this permit. 29. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C. • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides ' sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per yeas a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APENr is less, above the level reported on the ; or '' For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more whichevE last APEN submitted; or For any non -criteria reportable pollutant: if the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 30. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS Page 9 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 31. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 32. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of. 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 33. This permit is issued in reliance ; upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the'activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations o.r activity specifically identified on the permit'. 34. 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. 35. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 36. 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. 37. 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. Page 10 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 July 2, 2015 Issued to Noble Energy, Inc. Issuance 2 August 18, 2016 Final Approval including removal of cancelled point 002 fugitives Issuance 3 This Issuance Issued to Noble Energy, Inc. • Point 003: Removed • Point 004: Removed • Points 005: Modified • Point 006: No Changes • Point 007: Modified • Point 011: Added, New Point • Point 012: Added, New Point Page 11 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible,but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set, forth in Part II. E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Points 005: Condensate Loadout AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Are the emissions reportable? Controlled Emissions (lb/yr) 005 Benzene 71432 106 No 5 Toluene 108883 205 No 10 Ethylbenzene 100414 4 No <1 Xylenes 1330207 43 No 2 n -Hexane 110543 637 Yes 32 2,2,4-Trimethylpentane 540841 31 No 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 12 of 17 1b► COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Points 006: Produced Water Storage AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Are the emissions reportable? Controlled Emissions (lb/yr) 006 Benzene - - - 71432 2,811 Yes 141 n -Hexane 110543 8,833 Yes 442 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Points 007: Condensate Storage AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Are the emissions reportable? Controlled Emissions (lb/yr) 007 Benzene 71432 630 Yes 32 Toluene 108883 1, 213 Yes 61 Ethylbenzene 100414 23 No 1 Xylenes 1330207 257 Yes 13 n -Hexane 110543 3,780 Yes 189 2,2,4-Trimethylpentane 540841 187 No 9 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Points 011: Low Pressure Gas Venting AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Are the emissions reportable? Controlled Emissions (lb/yr) 011 Benzene 71432 3,447 Yes 172 Toluene 108883 8,712 Yes 436 Ethylbenzene 100414 335 Yes 17 Xylenes 1330207 2,677 Yes 134 n -Hexane 110543 21,747 Yes 1,104 2,2,4-Trimethylpentane 540841 1,440 Yes 72 Page 13 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Points 012: VRT Gas Venting AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Are the emissions reportable? Controlled Emissions (lb/yr) 012 Benzene 71432 2,081 Yes 104 Toluene 108883 4,911 Yes 246 Ethylbenzene 100414 183 No 9 Xylenes 1330207 1,460 Yes 73 n -Hexane 110543 12,602 Yes =<63 2,2,4-Trimethylpentane 540841 786 Yes 39 Note:' All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.'` 5) The emission levels contained in this permit are based on the fo lowing emission factors: Points 005: Condensate Loadout CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- NOx 3.22 x 10-4 3.22 x 10"4 AP -42 Chapter 13.5 Industrial Flares -- CO 1.47 x 10"3 1.47 x 10"3 -- VOC 2.81 x 10"1 1.40 x 10"2 HYSYS and TANKS 4.0.9d 71432 Benzene 7.59 x 10"4 3.79 x 10"5 108883 Toluene 1.46 x 10-3 7.30 x 10-5 100414 Ethylbenzene 2.81 x 10-5 1.40 x 10"6 1330207 Xylene 3.09 x 10"4 1.55 x 10"5 110543 n -Hexane 4.55 x 10-3 2.28 x 10"4 540841 2,2,4-Trimethylpentane 2.25 x 10"4 1.12 x 10"5 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: Page 14 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 7.6324 psia M (vapor molecular weight) = 60 lb/lb-mot T (temperature of liquid loaded) = 511.8 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in condensate storage tank flash vapors as modeled in HYSYS by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Points 006: Produced Water Storage CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- VOC 2.62 x 10"1 1.31 x 10"2 CDPHE, State Approved 71432 Benzene 2.20 x 10"2 1.10 x 10-3 110543 n -Hexane 7.00 x 10"3 3.50 x 10"4 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Points 007: Condensate Storage CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- NOx 2.91 x 10"3 2.91 x 10"3 AP -42 Chapter 13.5 Industrial Flares -- CO 1.14 x 10.2 1.14 x 10"2 -- VOC 1.41 x 10° 7.07 x 10"2 HYSYS (Flash) and AP -42 (WEtB) 71432 Benzene 4.50 x 10"3 2.25 x 10-4 108883 Toluene 8.67 x 10"3 4.33 x 10"4 100414 Ethylbenzene 1.67 x 10"4 8.33 x 10"6 1330207 Xylene 1.83 x 10"3 9.17 x 10"5 110543 n -Hexane 2.70 x 10"2 1.35 x 10-3 540841 2,2,4-Trimethylpentane 1.33 x 10"3 6.67 x 10"5 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 15 of 17 le COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Points 011: Low Pressure Gas Venting CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source -- NOx 240.17 240.17 AP -42 Chapter 13.5 Industrial Flares -- CO 782.77 782.77 -- VOC 78,747.43 3,941.76 HYSYS modeled gas stream of the low pressure separator using pressurized liquid inputs 71432 Benzene 288.70 14.44 108883 Toluene 729.76 36.49 100414 Ethylbenzene 28.03 1.40 1330207 Xylene 224.22 11.21 110543 n -Hexane 1,821.59 92.51 540841 2,2,4-Trimethylpentane 120.63 6.03 Note:The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled low pressure separator temperature of 130°F and separator pressure of 42.12 psia. Points 012: VRT Gas Venting CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source - NOx 356.94 356.94 AP -42 Chapter 13.5 Industrial Flares -- CO 1055.04 1055.04 -- VOC 128,180.72 6,417.08 HYSYS modeled gas stream of the vapor recovery tower using pressurized liquid inputs 71432 Benzene 639.26 31.97 108883 Toluene 1,508.17 75.41 100414 Ethylbenzene 56.06 2.80 1330207 Xylene 448.45 22.42 110543 n -Hexane 3,870.43 196.15 540841 2,2,4-Trimethylpentane 241.26 12.06 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled low pressure separator temperature of 120°F and separator pressure of 16.12 psia. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 16 of 17 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be foundat the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix 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 Page 17 of 17 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It: Received Date: Review Start Date: Jam€s: Ricci 403694 8/5/2019 10/9/2019 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Location: County: Type of Facility: What industry segment? Noble Energy Inc 123. 9074 Eagle�Reliance Seneca'T.a homa.Econode T9N-R6,511,\,/,914 L0I SWSW Quadrant of Section 14, Township 6N, Range 65W Weld County Ekploratian &,Pr atura1Gas;p6oduc5io Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? DCarbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) Quadrant Section Township Range Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 005 Liqu d ) 43dtng -." ' Yes 15WE0039 - 3 Yes at Modificaon 007 Condensate Tar lt, .:_ !,;. Yes 15WE0039 3 y � Permit Modifigtioni, 011 Separatorventing Yes 15WE0039 3 y PeemCf Iabdin' 012 I Seentmg - 15WE0039 3 yes ,..=�M Pam dification'. Section 03 - Description of Project The Eagle Reliance Seneca Tahoma Econode is an existing facility that processes wellhead liquids. Noble Energy Inc. (Noble s permit limits for condensate storage andcondensate loadout. In addition, Noble has.requested`to permit Low Pressure Gas Ventingand Vapor Recovery Tower Venting during Vapor Recovery Unit downtime, Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ubmitted this application requestingto decrease throughput arid, et h' d: Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? " N If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. pi inPittainrh nt ea Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No SO2 NOx CO V0C PM2.5 PM10 TSP HAPs PM2.5 PM10 TSP ❑ ❑✓ HAPs ❑ ❑ Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading 'Facility AIRS ID: County Plant Pain Section 02 - Equipment Description Details Detailed Emissions Unit Desbription: Emission. Control Device Description: Is this laadout controlled? Collection Efficiency: Control Efficiency: Requested Overall VOC & HAP Control Efficiency 56: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating= 4 Barrels (bbl) per year Barrels (bbl) per year Requested Monthly Throughput = 11602 Barrels (bbl) per month Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2662 93 ,;;Btu/s6 Volume of waste gas emitted per year= 248600 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation 1= 12.46'5°P"M/T 304 MMBTU per year 662 MMBTU per year 662 MMBTU per year ed drocarbon liquid sample is valid for developing site specific emissions factors. Factor- Meaning Value Units Source S Saturation Factor 3.6 yy ' *`�;, , 'Sj 6•;;f ' "<`'a` P True Vapor Pressure 7.6324r: psi. "From Tanks 4.0)9d, accepted smce it closley matches AP -42 Tab e 7.1-2for a RVP-15 fluid M Molecular Weight of Vapors 60 ,s,,7; Ib/Ib-mol AP 42 Table 71 7 fora RVP 1S flitV T liquid Temperature 5118 W,..?3 Rankine S1 797S deg F.: m Applicant _e ,o the average D_m,ertemperature) L Loading Losses 6.6094 lb/1000 gallons 0.2810 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene :6 0027 0.000759 lb/bbl 125Y5, Mass Fraction of Condensate flash vapors (H ghei;.than State EF). Toluene „„ tlo 0052 " "';.: 0.001461 lb/bbl "675Y5" Mass Fraction of Condensate flash vapors Ethylbenzene .�. ,)(rart0,0001 "" " 6.000028 lb/bbl HYSY5, Mass Fraction of Condensate flash vapors Xylene e f ,,,4I 0.0011 0,000309 lb/bbl HYSYS Mass t`. action of Condensate flash vapors n -Hexane T 0,0162 0.004561 lb/bbl HYSY5, Mass Fraction of Condensate flash vapors (Higher Than State F1)` 224TMP ""0.0008 0.600225 lb/bbl HYSYS, Mass Fraction: of Condensate flash vapors Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled controlled (Ib/bbl) (Ib/bbl) (Volume Loaded) (Volume Loaded) 1.40E-02 3.79E-06 7.30E-05 1.40E-66 1.55E-06 2.266.04 1,12E -OS VOC 2.81E-01 7.59E-04 1.46E-03 2.61E-05 3.09E-04 4.55£-03 2,25E-04 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) (Volume Loaded) 3.12E-05 3.52E-05 2.78E-06 3.22[:-04 1.47E-03 (waste heat combusted) Emission Factor Source PM10 PM2.5 6,0075._.,.. 0.0075 0.0006 5ox NOx CO 4g .0.0680 •f`„ -- 0.3100 Emission Factor Source 2 of 18 H:\World\Working\Noble Eagle, Reliance,Tahoma & Seneca\15WE0039.CP3 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.0 0.0 0,0 0,0 0.0 0 0,0 0.0 0,0 0.0 0.0 0 0,0 0,0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0,0 4 10.7 9.0 0.0 19.7 1.0 107 0.1 0.0 0.0 0.1 0,1 17 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 106 49 2 106 1 205 94 5 205 10 4 2 0 4 0 43 20 1 43 2 637 292 15 637 32 31 14 7. 31 2. Section 06- Regulatory Summary Ana sis Source requires a permit Regulation 3, Parts A, 8 RACT- Regulation 3, Part R, Section III.D.2.a The loadout must operate with submerged fill and laadout emissions must he routed to flare to satisfy RACE. (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Values from -AP -42 Table 7.1-2a ndTAN conservativebased on the. predicted:RVPt than the state approved'enrtnslnnfatgots Section 09- Inventory 5CC Coding and Emissions Factors AIRS Point it 005 Process 0 01 s Equation terdevelop emission factors for tin source All the input values assumed a liquid with RV)" ef.i5, This valueseemed to be mAPI OraviEyto RVP Using theequationfound in PS Memo1d-03 (10.2)_ Based no theappgtcantuassgmptaons,.emission factors greater :anserva2lve RVP assumption and"tMxmissioo factors heing greater than the state approved ane$3#re applicant's -«r.mpfiotrswere accepted, I_ 5CC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 Il lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 6.7 95 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.02 95 lb/1,000 gallons transferred Toluene 0.0.3 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.01 95 lb/1,000 gallons transferred n -Hexane 6.11 95 lb/1,000 gallons transferred 224 TMP 0.07. 95 lb/1,000 gallons transferred 3 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca \15WE0039.CP3 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re . ulatlon 3 Parts A and B - APEN and Permit Requirements rsoun:e Is in the Nan-Aiteinrnent Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.O.1.a)? 2. Is the laadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.11? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs( of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOCemissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greaterthan 10 TPY (Regulation 3, Part 8, Section 11.0.3)? you hove indicated that source is in the ioon:Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, PartA, Section li.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.1.1.1)7 3. Is the loadout operation loading less. than 10,000 gallons (238 Bats( of crude oil per day on an annual average basis? 4. Is the laadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? (Source requires a permit 7. RACT Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part e, Section 111.0,2.2)? sitiwzo (The loadout stool operate with submerged Miami boatload a der:lanc most be routed to flare to satissy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular s3uation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Qualify Control Commission regulations, the language of the statute erregulation will control. The use of non -mandatory language such as "recommend,""may,"should," and 'can," is intended to describe APCO interpretations and recommendations. Mandatory terminology such as 'must' and 'required" are intended to descnbecontrolling requirements under the teens of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to next. Go to then Go to next Go to next. Go to next . The loadou Condensate Storage Tank(s) Emissions inventory 007 Condensate Tank (Facility AIRS ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device •Endo ed€ mbu Description: Requested Overall HOC & HAP Control Efficient -y%: Section 03- Processing Rate information for Emissions Estimates Primary Emissions - Storage Tanks) Actual Condensate Throughput Requested Permit Limit Throughput= Potential to Emit (PTE) Throughput= rer6uaranteed Conner Ertaie Barrels (hbl) per year Barrels (bhl) per year Barrels (bhp per year Secondary Emissions -Combustion Device(s) Heat content of waste gas= %:1663si₹.,s0' Waste gas/bbl of liquids produced= Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas muted to combustion device = PTE heat content of waste gas routed to combustion device = Pilot Gas Volume MMBTU/day Number of Burner 4: ,.... ;' Heat Content of Pilot Gas --_SOCO00 ��''': Btu/scf 0.730 MMSCF/yoar NOx Pilot Light EF -- 104.001' x., lb/MMSCF CO Pilot Light EF bAUU- . :C; lb/MMSCF Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? /sct bbl - Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput = 11092 Barrels (bbl) per month From HYSYS HYSyS Speciation and Displacement Equation 2,207 MMBTU per year 4,943 MMBTU per year 4,943 MMBTU peryear Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC Benzene Toluene F30.50E-03 __......... ';.... Ethylbenzene `;;.4,5''004„ Xylene n -Hexane 224 TMP =0. 3E -D3 Pollutant Control Devl0 Uncontrolled Uncontrolled (Ib/MMBm) (lb/bbl) (waste heat (Condensate combusted) Throughput) PM10 PM2.5 NOx CO 0.OD75 0.0075 0,0103 0.0003 2.91E-0:3 1.14E-02 i.. 0.3100 Emission Factor Source Section OS- Emissions Inventory Ei%Sd 2 6. j Barrels (Will per year Mass Fraction (From HYSYS) W&e Qb/year) From TANKS 4.0 Flash gh/year) From HYSYS lb/bbl 0.8486 198031.8503 0.0000 1.4144 0.0027 630.0801 0.0000 0.0045 0.0052 1213.4877 0.0000 0.0087 0.0001 23.3363 0.0000 0.0002 0.0011 256.6993 0.0000 0.0018 0.0162 3780.4808 0.0000 0.0270 0.0008 186.6904 0.0000 0.0013 Criteria Pollutants Potential to Emit Uncontrolled (tons/Year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) HOC PM10 PM2.S NOx CO ' 93.0 45.4 2.3 99.0 5.0 841 0,0 0.0 0.0 0,0 0.0 3 Q.0 0.8 0,0 0,0 0.0 42 0.1 0.1 0,2 0.2 35 0,8 0.4 0.4 0.8 - 0.8 135 Hazardous Air Pollutants Potential to Emit Uncontrolled )ibs/year) Actual Emissions Uncontrolled Controlled (Ras/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled Ohs/Year) (lbs/year) Benzene Toluene Ethylhenzene Xylene 5 -Hexane 224 TMP 630 209 14 630 32 1213 557 26 131.3 61 23 11 1 I 25 1 37 118 6 257 13 3780 1734 87 j 3780 189 14'7 06 4 I 18'7 - 9 section 06- Regulatory Summary Analysis. Regulation 3, Parts A, B Source requiresa permit Regulation 7, Section XII.C, 0, E, F Storage tank is subject to Regulation 7, Section 08I.C-F Regulation 7, Section 811.6, C Storage Tank in not .subject to Regulation 7, Section TIL0 Regulation 7, Section MI.5, C1, CS Storage tank is subject so Regulation 7, Snotion 808, 6, C.0 &C.3 Regulation 7, Section XVll.C.2 Storage Took b not subject to Regulation 7, Section XVli.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank isnot subject to SOPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tankis not cubjectto NSPS-000O Regulation 8, Part E, MACE Subpart HH Storage Took is nog subject to MACT HO (See regulatory applicability worksheet for detailed analysis) 0.003181711 5of18 H:\Worid\Working\Noble Eagle, Reliance, Tahoma & Seneca\SSWEUO39.CP3 Condensate Storage Tank(s) Emissions Inventory Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? lives, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? • If yes, the permit will.contain en "initial Compliance" testing requirement to develop a -site specific emissions factor based on guidelines in P5 Memo 05-01. Does the company use a site specific emissions factorto estimate emissions? if yes and if there are flap) emissions, are the emissions factors based one pressurized liquid sample drawn at the facility being permitted?This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., none wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain en "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% far a flare or combustion device? If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis No Corldensatestnr g? fir. muddy th iRrrinafarf 217 pill sa 82ldecl Section 09 - Inventory SCC Coding and Emissions Factors afized} ouid-samples were input into ilt$y$and mixei 124degF.9fter existing the VRT rte7iquidweSRi0d7 Hashemissons to occur. Nobl confirmedihetthi mmt uonb,ftni II be Torn W&e losses-et II bti Is In at the VRT xouerifytuflashemisslons.wt�I Uncontrolled Pollutant Emissions Factor PM10 0.01 PM2.5 0.01 NOx 0.07 VOC 33.7 CO 037 Benzene 0.11 Toluene 0.21 Ethyibenzene 0.00 Xylene 0.04 n -Hexane 0.64 224 TMP 0.03 tatfons assomingwt[did with RVP OF35.0. ohstra'e odiui comloilarlce In thloperrnit.' Control% Units O b/1,000 gallons condensate throughput O 6/1,000 gallons condensate throughput O b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput O b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 95 b/1,000 gallons condensate throughput 6 of 18 H:\W arld\Working\Noble Eagle, Reliance, Tahoma & Senea\15WE0039CP3 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B -APEN and Permit Requirements (Sour. is in the Nan-Attoioment Area ATTAINMENT 1, Are uncontrolledactual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A,Section 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, 500 greater than 10 TPY or CO emissions greater than 10 TRY (Regulation 3, Part B,Section 11.0.3)? IVOS have indicated that suurce is in the No's-A4taimnent Arae NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)7 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 far additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation3, Part B, Section 11.0.2)? 'Sorlve inquires a poorciit Colorado Regulation 7,Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tar& located upstream of a natural gas processing plant? Yes Yes 'Stamp tanh is subject to Regulation 7. Sentinn 3ll,C F Section XILC.1 -General Requirements for Air Pollution Control Equipment -Prevention of Leakage Section XII.C.2- Emission Estimation Procedures Section 811.8- Emissions Control Requirements Section 811.0 - Monitoring Section XII.F- Recordkeeping and Reporting Colorado Regulation], Section 811.6 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2, Is this storage tark located ate natural gas processing plant? 3. Does this storagelank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year SOC7 Yes No IStamgo Trash is not subject to Rog:dation 7, Section 111,0 Section X11.8.2 - Emissions Control Requirements Section X11.0.1 -General Requirements for Air Pollution Control Equipment- Prevention of Leakage Section XII.C.2- Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed root storage tank? 4. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC? No at Section XVII.B- General Provisions for Air Pollution Central Equipment and Prevention of Emissions Section 0011.0.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? (Storage Tank is not subject to Reguation 7, Section 50111,1,7 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters Ira') (-472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does he vessel has a design capacity less than or equal to 1,589.874 ma [-10,000 BBL] used for petroleum` ar condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meat the definition of"storege vessel"' in 50.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL["s as defined in 60,111k? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M5 ["472 BBL] but less than 151 m' ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? ?fly NAN f,''raAFS Source Req Go to next Source Req Continue-' Continue-' Source is sic Continue -' Storage Tar Continue-' Gone the n Go to then Source is sic Got then Storage Tar Storage Tank Is not suhleat to 4506 Kb Subpart A, General Provisions §60.1126- Emissions Control Standards for VOC §60.1136- Testing and Procedures §60.1156- Repargng and Recordkeeping Requirements §60.116k- Monitoring of Operations 40 CFR. Part 60, Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensatestorage vessel located ate facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 20152 3. Are potential VOCemisslons' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Yes mom WOW IStoraae Tank is not sublets to 45950000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395- Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements .§60.5416(c)- Cover and Closed Vent System Monitoring Requirements §60.5417 -Control Device Monitoring Requirements [Note: H a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC en the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below Stens per year] 40 CFR, Part 63, Subpart MAR HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria, a. Afacilly that processes, upgrades or stores hydrocarbon liquids' (63.760(')(2)); OR b. A faciliy that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))7 2. Is the tank located at a facility that is major' for HMIs? 3. Does the tank meet the definition of"storage vessel.' in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Yes N.R•' IStoraa Tank is no-3ubjentto MAC' HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766- Emissions Control Standards 063.773 - Monitoring 063.774-Recordkeeping §63.775 -Reporting -04OO Continue -' Go to then Storage Tar ontinue-' Storage Tar RACT Review RACT review Is required If Regulation 7 does not apply AND If the tank Is In the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators oath determining applicability of certain requirements of the Clean Air Act, its implementing regulations,. and AirQuality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. Tits document does not change or substitute for any law, regulates, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean. Air Act„ its Implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,"should,"and "can,"is intended to. describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and °required" are intended to describe controllingrequirements under the terms of the Clean Air Act and Air Quality Control Commission regulatidns, but this document does not establish legally binding requirements in and of itself. Separator Venting Emissions Inventory 012 Separator Venting 'Facility AIRs ID: County Plant deiglaiaigeZiei Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: MMscf per year MMscf per year Requested Monthly Throughput = .94 MMscf per year 1.95 MMscf per month Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Waste gas/6bl of liquids produced 2298:00 ' ', Btu/scf Pilot Gas Volume 3.50 MMBTU/day Number of Burners 8 00 Heat Content of Pilot Gas _1000.00_-. __.:' Btu/scf 10.220 MMSCF/year NOx Pilot Light Emission Factor 100.00 i Ib/MMSCF CO Pilot Light Emission Factor ............. 84.00.-^ !, Ib/MMSCF Section 04- Emissions Factors & Methodologies Ste specific pressurized liquid wmples methods used to develop emission factors#ased on MW Std Vapor Volumetric Flo 41 0500 6.1040 Ib/Ib-mol MMSCFD H From HYSYS From HYSYS Mole %(HYSYS) Molecular Weight Weight %(talc) Weight % (HYSYS) lb/hr (HYSYS) Helium 0 00'. 4.00 0.00 0 00 4 0 00 CO2 192 44.01 2.06 . 2.064 967 N2 0.12 28.01 0.08 0:08 0 39 methane 21.59 16.04 8.44 .:8.44 39.63 ethane :22.91 30.06 16.78 - 16:78 r 78.81 propane 25:66 44.09 27.56 2756:' 129.46 isobutane 4:70 58.12 6.65 665-: 31.24 n -butane 2.54 58.12 17.75 t 7.76 : 83 41 isopentane 3.13 72.11 5.50 :5.09 25.81 n -pentane 3.67: 72.11 6.45 6 41- - 30 28 cyclopentane 600 70.13 0.00 0'00 0 00 n -Hexane 0.80 86.18 1.68 1.68 7 91 cyclohexane 0.00 84.16 0.00 _:0.00' -- 0.00 - Other hexanes 1 1. 86.18 2.48 2.49:. 1168 heptanes 0 71 100.21 1.73 1.74 8.16 me thylcyclohexane ' 0.00 98.19 0,00 0,00- - 0 00 224-TMP 0.04 114.23 0.11 .:0:10 0.49 Benzene 0.14 78.12 0.27 0.27 1 28 Toluene : 0.30 92.15 0.67 0,67 3.13 Ethylbenzene 001' 106.17 0.03 002.:. 011 Xylenes 0 08: 106.17 0.21 0.20 0 94 C8 0:24 114.23 0.67 0:67 318 C9 0.03 128.20 0.09 0.10:. 0 46 C10 : 0.23 142.29 0.80 0 79 3.70 Total VOC 1_0.111) 100,00 (;{;.;;0 449.69 ..:3.4£• 72.65 <- 343.20 Ib/MMSCF Emission Factor Method —> Mole %(HYSYS) —> Weight % Weight %from HYSYS lb/hr from HYSYS Applicant VOC 78,686.28 78,677.36 78,738.32 'S;;":n- ',9,8,747.43 Benzene 288.57 292.44 296.52 ;s:: X288.69 Toluene 729.42 725.69 721.89 ;" x:729.76 Ethylbenzene 28,01 21.66 25.87 - ===28.03 Xylene 224.11 216.62 216.92 I K:. X224:22 n -Hexane 1,819.10 1,819.63 1,824.67 ._ ................._....5 �Rf:�;��,f,821:59 224TMP 120.56 108.31 11331 i -- 1i�12063 9 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca\15WE0039.CP3 Separator Venting Emissions Inventory Pollutant Separator Venting Uncontrolled Controlled 1=IMM=tMgM MIME= 28.03 MEME EEM =MM. Pollutant Primary Control Device Uncontrolled Uncontrolled (Waste Heat Combusted) 0.0075 0 COOS 0.0006. 0.0680 (Gas Throughput( Emission Factor Source Emission Factor Source 10 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca\15WE0039.CP3 Separator Venting Emissions Inventory Section 05 - Emissions inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 sox NOx VOC CO 0.1 0,1 0.1 0.1 0.1 17 0.1 0,1 0.1 0.1 0.1 17 0.0 0.0 0,0 0.0 0.0 1.4 1.4 1.4 1,4 1.4 244 470.1 470.1 23.5 470.1 23.5 3997 4,7 4,7 4.7 4.7 4.7 794 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 3447 3447 172 3447 172 0712 8712 436 8712 436 335 335 17 335 17 2677 2677 134 2677 134 - 21747 01747 1.104 21747 1104 1448 1440 72 1440 72 Section 06-R gulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 0, Section XV0,8.2. The control device for this separator is not subject to Regulation 7, Section XVII,ti,2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use sitespecific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e .g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gm sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? .ey, If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissionsfactors established with this application, -A "Periodic Testing Requirement" to collect a site -specific gm sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 100 days). This condition will use the °Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Y above that the monitored oess parameter is natu al gas vented. the following questions do not rewire 11 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca\15WE0039.CP3 Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes Noble is requesting to permit ventingof the low pressure separator gas while the (Vapor Recovery Unit) VRU is down, assumed to be 5% of the time. This is newly reported emission source at this facility. Four pressurized liquid samples were supplied with this application. The Sample name, sample date, sample pressure and sampietemperature can be found below. Tahoma E22-69-11 10/31/2014 217 peg 82 deg F Seneca E15-72-1.HH Reliance E23 -79 -FIN Eagle E2.4-79HN 10/31/2014 0/31/2014 10/31/2014 218 psig 219 psig .:.219 psig 78 deg 80 deg JY-, 77degF The four pressurized liquid samples were input into-HYIPS and mixed (equal parts). The pressurized liquid was modeled;througha LP Separator operation at 42. of the LP separator to estimate emission factors forthis point. degF (added heat). HY&YS was<able to made) the flash -Ste Emission factors can be derived three d₹fferentweys, as seen above. Mole%from 49515 can be converted to Weight %, Weight:%can be taken directly from HYSYS or a lb/hr estimation foreachcomponentcan betaken directlyfrom 59505. All three methodsresulted in very similar results. There are limitations of rounding/Sig figs from pulling thesevalued from a PDF'd UNITS report as well as differences m molecularweightsassomptions. Sincefhe applicant`s calculations also closely matched-all three methadsabove, their emission factors were accepted:A site specific gas sample wi ll he required Indus permit to demonstrate initial compliance with the modeled emission factors. Noble confirmed thatgas meters are already installed to measure the gas bypassed to the combustor. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # Process # 5CC Code 011 01 • 3-10-001-80 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 ].7.12 0 lb/MMSCF PM2.5 17.12 t₹ lh/MMSCF 105 1.35 0 Ib/MMSCF NOx 240.17 0 ₹b/MMSCr VOC 78747.43 95 lb/MMSCF CO 782.77 0 lb/MMSCF Benzene 288.70 95 Ib/MMSCF Toluene 779.75 95 Ib/MMSCF Ethylbenzene 08.03 95 lh/MMSCF Xylene 774.22 - 95 Ib/MMSCF n -Hexane 182.1,59 95 lb/MMSCF 224 TMP 120.63 95 lb/MMSCF 12 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma&Seneca \15WE0039.CP3� Separator Venting Regulatory Analysis Worksheet Colorado Re: elation 3 Parts A end B-APEN and Permit Requirements fSOF0cc is in the Non-Attaitnrout Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation3, Part B, Section 11.0.31? IYou have indicated that source isle the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 0.0.l.e)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOa greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part 0, Section 11.0.2)? ISotroe requires, permit Colorado Regulation 7, Section )(VII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1,2014? source is sub{act to Regulation 7, Section XVB.a.2, G Section 0011.0.2— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 01111.0 - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (.e., not the primary control device) that is not enclosed? ITheoontrol device forthfs separator is not cabjent to Regulation 7, Section XV11.0.2.a Sedan XVII.B,2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of carton requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is nota rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regelation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"'may,"'should,"and 'can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req Source Req -NThe control Separator Venting Emissions Inventory 012 Separator Venting Facility AIRS ID: County Plan Poin Section 02 - Equipment Description Details Detailed Emissions Unit Description: ,Vlpol Emission Control Device Description: ;EndbsodC Requested Overall VOC & HAP Control Efficiency °h: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: th.98% Manufacturer Guarani: e Cohtrcl Efficiency MMscf per year MMscf per year Requested Monthly Throughput= 3.26 MMscf per year 0.277 MMscf per month Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gasvolume that is routed to the flare) Secondary Emissions- Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Waste gas/bbl of liquids produced = 2966:00 li Btu/scf scf/bbl p From HYSYS Pilot Gas Volume 3,50 ,%; -.- MMBTU/day Number of Burners Heat Content of Pilot Gas 1000100 , Bt./.f 5.110 MMSCF/year NOx Pilot Ught Emission Factor w,,,,,; ;:,1,00.00 Ib/MMSCF CO Pilot Ught Emission Factor EMAR4.00 lb/MMSCF Section 04 - Emissions Factors & Methodologies Displacement Equation Ex = Q • MW • Xx / C MW Std Vapor Volumetric Flow Ib/Ib-mol MMSCFD From HYSYS From HYSYS Male % (HYSYS) Molecular Weight Weight % (tale) Weigh t%(HYSYS) lb/hr (HYSYS) Helium 0:00'-;... 4.00 0.00 ` 0.00. 0.00 CO2 064 44.01 0.53 0.52 0.81.. N2 801 28.01 0.01 000'' 001..: methane 3.47 16.04 1.04 104; 164` ethane 13.33 30.06 7.51 7.1 /. propane 30.58 J 44.09 25.26 25.26 78.90 isobutane 7.78 58.12 8.47 8.47.: 3:85 n -butane -JI 22.41 58.12 24.40 - 24.40 37 57[ isopentane h(3S 72.11 8.58 8 58. 19.21 n -pentane /.57 72.11 10.23 10 24 15 /6 J cyclopentane '0(00 - 70.13 0.00 0.00 r 0100 n -Hexane Y.70 86.18 2.74 2.75. n.74 0 00 84.16 0.00 0.00; 7,00 ,yyclohexane Other hexanes 2.52 86.18 4.07 4.07'. 6 heptanes 1.49 100.21 2.80 2.79--30 methylcyclohexane :7100 98.19 0.00 0.00 0.00 224TMP --7.08 114.23 0.17 0.17 0.76. Benzene 0 1 78.12 0.45 0.451 • 0.69 Toluene 0,62 92.15 1.07 1.08 166 Ethylbenzene 0.02 I 106.17 0.04 0.041 6.06, Xylenes 3x16 106.17 0.32 0,31 0,48 CO 0,49 114.23 1.05 1.04 1.61 C9 0 06 128.20 0.14 0.15:'. 0 22 C10 0,43 142.29 1.15 1.14! 175 Total VOC ;.02 100.02 .00::;1 154.00 82.57 90.94 98.94 140.02 Ih/MMSCF Emission Factor Method-> - _ Mole %(HY5Y5) —> Weight % Weight %from HYSYS lb/hr from HYSYS Applicant VOC 128,078.73 128,083.83 128,165.68::.. 128,18072 Benzene 638.98 633.80 634.05 639.26. Toluene 1,507.47 1,52112 1,518.54 1508 17 Ethylbenzene 56.03 56.34 52.72 " 56.06 Xylene 448.21 436.62 437.89 448,45 n -Hexane 3,865.59 3,873.22 3,876.52 3,870.43 224TMP 241.12 239.44 237.89 ;.{241.26 14 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca \15WE0039.CP3. Separator Venting Emissions Inventory Pollutant Separator Venting Uncontrolled (Ih/MMscf) Controlled (Ib/MMscf) 128,180.72 6,417,118 EMMEEMIEM 211E Pollutant Primary Control Device Uncontrolled Uncontrolled (Waste Heat Comhusted) 0.0075'E 0,0075 .0006 0.0680 0:3100 (Gas Throughput) MMISIEM MEIZZ Emission Factor Source Emission Factor Source 15 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca \15WE0039.CP3 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions - Requested Permit Limits Requested Monthly Limits Uncontrolled (tons/year) Controlled (tons/year) Uncontrolled (tons/year) Controlled (tons/year) Controlled (lbs/month) PM10 PM2.5 sox NOx VOC CO 0.0 0.0 0.0 0.0 0.0 6 0.0 0.0 0.0 0.0 0.0 6 0.0 0.0 0.0 0.0 0.0 0 0.6 0.6 0.6 0.6 0.0 89 208.7 208,7 10.4 208.7 10.5 1778 1.7 1,7 1.7 1.7 1.7 291 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2081 2081 104 2081 104 4911 4911 246 4911 246 183 103 9 183 9 1460 1460 73 1460 73 12602 12602 639 12602 639 786 786 39 786 39 Section 06 - Regulatory Summer Analysis Regulation 3, Parts A, B Regulation 7, Section XVILB, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVfl.B.2, G The control device for this separator is not subject to Regulation 7, Section XVI€.8.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gel sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the fadlity has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Ye, If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 16 of 18 H:\World\Working\Noble Eagle, Reliance, Tahoma & Seneca \15WE0039.CP3 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Noble is requesting to permmt venting of the Viti(Vapor Recovery Tower) gas whilo the 553 (Vapor Recovery Unit) is down„ assumed to be 5% of the time. This is a newl four pressurized liquid samples were supplied with this application. The Sample name, sample date, samplepressure and sampletemperature can be found below. Tahoma E22 -69 -HC 10/31/2014 10/31/2014 10/31/2814 217 psig 218 psig 219 psig 82 deg 78 deg 80 deg Seneca E15-72-1 HN: Reliance 823.79-HN Eagle E14.79HN 10/31/201.4 219 psig 77 deg F The four pressurized liquid samples were input into HYSYSandmixed (equal parts). --I he pressurized liquid was modeled .: and 120 deg F. HYSY5 was able to model the flash stream of the VRT to estimate emission factors forthis point, ougha LP Separator oper 4212 psia and 130 deg F (added: heat) then through a VRToperating at 16,12 psig: ys, as seen above, Mole%from'HYSYS can be converted. to Weight %, Weight %can be taken directly from HYSYS or a lb/hr estimation for each component can betaken directly from 03811.': All three methods resulted in very similar results. There are imitations of rounding/sigfigs from pulling these valued Promo'PDF'd HYSYS report as well as differences in molecularweights assumptions. Since the applicant's calculations also closely matched all three methods above, their emission factors were accepted. A site specific gas sample will be required inthis permit to demonstrate initial compliance with the modeled emission factors -. Noble confirmed that gas meters are Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point II 012 Process 0 SCC Code 01 3-t0-001-00 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 22.10 0 Ib/MMSCF PM2.5 23.10 0 lb/MMSCF SOx 1.74 0 Ib/MM5CF NOx 35534 0 ib/MMSCF VOC 128189.72 95 Ib/MMSCF CO 1455.04 0 Ib/iv1MSCF Benzene 639.26 95 Ib/tvtMSCF Toluene 1508,17 95 Ib/MMSCF Ethylbenzene 55.06 95 lb/11/IMSCF Xylene 448.45 95 ib/MMSCF n -Hexane 1870,43 95 Ib/MMSCF 224 TMP 241.26 95 lb/MMSCF 17 of 18 H:\World\Working\ Noble Eagle, Reliance, Tahoma&Seneca \15WE0039.CP3 Separator Venting Regulatory Analysis Worksheet Colorado Re illation 3 Parts A and B-APEN and Permit Requirements Source is in the Non-Atteinntent Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.13.1.07 2. Are total facIlIty uncontrolled VOC emissions greater than 5 TPY, NOn greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)7 You have inAicatedthat source is In the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section 11.0.1.a)7 2. Are total facility uncontrolled UDC emissions from the greater than 2 TPY, Non greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)e' I5ource requfras a permit - Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,20147 'Source Is sublect to Regulation 7, Section HVFI.B.2, G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVI I.G - Emissions Control Altemadve Emissions Control (Optional Section). a. Is this separator controlled bye back-up or alternate combustion device (i.e., not the primary control device) that Is not enclosed? The control device for this separator is not subject is Ragulailon 7, Section XV13.S.2.e Section XVII.t.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use ofnon-mandatory language such as 'recommend," 'may," 'should," and 'can,"is • intended to describe APCD interpretations and recommendations. Mandatary terminology such as 'must" and 'required" are intended to describe controlling requirements under the terms af the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself 2'c S 7ea_._ Sourcece RReq eq illiiiigiskirilsourre is si The control SUI(1} SE �1 Sew tf��.�� ►PEN r�_ 1 G AUG 5 2019 A p ALA., kte 1403-, 1612111`1 Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Noble Energy Inc. Site Name: Eagle, Reliance, Tahoma & Seneca Econode Site Location: SWSW SEC14 T6N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 403691 Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I AV COLORADO Dcpartznen: of PvRic HIa!IA c Enniciv7a 1 Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑✓ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name3 9 Change permit limit O Transfer of ownership4 O Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: to 140,000 bbl/yr Modification to decrease throughput from 1,168,000 bbl/yr 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck Loadout Company equipment Identification No. (optional): For existing sources, operation began on: 9/9/2014 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? SI Yes ■ No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • IS Does this source load gasoline into transport vehicles? Yes No ■ 12 Is this source located at an oil and gas exploration and production site? Yes No O ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annualES average? Yes No • Does this source splash fill less than 6750 bbl of condensate per year? Yes No SI ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No • SI Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2 I AY COLORADO Department of RM. Permit Number: 15VVE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: El Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 140,000 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: 68,727 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 60 °F True Vapor Pressure: 7.88 Psia ® 60 °F Molecular weight of displaced vapors: 60 lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO Emu -amen, °t P;Nc Permit Number: 1 5WE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4798, -104.6382 Discharge Height Above! :- Temp. F (� ) Flow Rate Velocity ' (ft/sec '' — ) Operator ; Stack ID No ;, -- Ground Level (feet) — ACFM) ( — Leed/Cimarron Variable Variable Variable Indicate the direction of the stack outlet: (check one) ❑r Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ❑ Circular o Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enclose Flare Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: CI Yes O No Pilot Burner Rating: MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I COLORADO Department o cw^ Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the 0 Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Enclosed Burner 95% HAPs Enclosed Burner 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory Pollutant Emission Factor — — Requested Annual Permit — Emission Limit(s)5 Actual Annual Emissions Uncontrolled — Basis _ _. Units — _ Source _ (AP -42, M etc. ' fg.,_ ) Uncontrolled Emissions (tons/year) Controlled Emissions 6 ---- / r (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/yew_; PM 7.60 Ib/MMscf AP -42 0.00 0.00 0.00 0.00 SOX 0.60 lb/MMscf AP -42 0.00 0.00 0.00 0.00 NO. 0.068 lb/MMBtu AP -42 0.01 0.01 0.02 0.02 CO 0.310 Ib/MMBtu AP -42 0.05 0.05 0.10 0.10 VOC 0.2950 lb/bbl AP -42 10.14 0.51 20.65 1.03 Non -Criteria Reportable Pollutant Emissions Inventory - Chemical Name Chemical Abstract Service (CAS) Number _ Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 0.0017 lb/bbl AP -42 119 6 Toluene 108883 0.0090 lb/bbl AP -42 618 31 Ethylbenzene 100414 0.0016 lb/bbl AP -42 108 5 Xylene 1330207 0.0135 lb/bbl AP -42 929 46 n -Hexane 110543 0.0087 lb/bbl AP -42 597 30 2,2,4- Trimethylpentane 540841 0.0014 lb/bbl AP -42 95 5 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I AvCOLORADO n of Pub. Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration'yfor coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance` with each condition of General Permit GP07. 07/24/2019 Signature of Legally Authorizederson (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 61 COLORADO �.- ': f:.af�1.-Env:euvrrnr Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit ALL sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly,' is missing information, or tacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does notfall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General ADEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution. Control Division (APCD) wehsite at: www.cotorado.gov/cdphe/apcd. This emission notice is valid for five (5) years.: Submission of a. revised APEN is required 30 days prior to expiration of the five/ear term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, 1I.C. for revised APEN. requirements. Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 005 [Leave bunk unless APCD has airaedyassig e d a permit e'an£i.A'IRS ID] Section 1 Administrative Information Company Namei.-- Noble Energy Inc; Site Name: EAGLE RELIANCE SENECA TAHOMA ECONODE TON-R65W-314 L01 Site Location: SWSW SEC14 T6N R65W Mailing Address.. (Include zip code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County:. Weld NAICS or:SIC ..Code: 1311. Contact Person: .:Jartessa,Salgado Phone Number: 303-228-4196 E-mail Address2: jenessa.salgado@nblenergy.com Use thefull, legal company name registered with the Colorado Secretary of State. This is the company name that: will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided: tAPEN _ �.. Permit Number: 15WE0039 [Leave bail,. us AIRS ID Number: 123 / 9D74 /005 z-5 APCD hats aticady.as5igned. a permit and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name3 ✓❑ . Change permit Limit ❑ Transfer of ownership4 O Other (describe below) -OR- APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Modification to throughput 3 For company name change, a completed Company Name Change Certification Form. (Form APCD-106) must be submitted. 4For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Truck Loadout Company equipment identification No. (optional): For existing sources, operation began on: 06/05/2019 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? 12 Yes ■ No Is this equipment_tocated at a stationary source that is considered a Major Source of (HAP) emissions? Yes E No ■ Does this source toad gasoline into transport vehicles? Yes 0 No ■ Is this source located at an oil and gas exploration and production site? ❑✓ Yes No ■ if yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average?. Yes No © ■ Does this source splash fill less: than 6750 bb[ of condensate per year? 0 Yes No ■ Does this source submerge fill less than 16308 bbt of condensate per year? Yes No ■ p Revis.an 312019. bbl/year ft3/truckload Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 005 a. e bla tIt ulll s Apo.) already ass gr.'d a permit # and AIRS 1DII Section 4 - Process Equipment Information Product Loaded: ❑ Condensate 0 Crude Oil 0 Other: ifthis APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 140,014 bbl/year This product is loaded from tanks at this facility into:. (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: 64,21 0.84 bbt/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: �. Average temperature. of bulk liquid loading: .�9rJ °F True Vapor Pressure: 7. 324 Psia @ 60 °F Molecular weight of displaced vapors: ( tb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading. Lines, complete the following: Requested Volume Loaded5: Product Density: Load Line Volume: bbt/year tb/ft3 ft3/truckload Actual Volume Loaded: Vapor Recovery Line Volume: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 4PC 7:08 - i 1. . ,carl zt. ` icu d L': adin? F.€ [N I e is o 1 / 2019 Permit Number: 15WE0039 AIRS lD Number:. 123 / 9074 / 00.5 [Leave- blank unless A?CO.. has already a -s gr:ed e permit r and AIRS ID Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UM) .- 40.4798, -104.6382 Operator Staek ID No Discharge Height Above Ground level (feet) Temp ( Fj Flow Rate 'CF ° Velocity (ftlsec) Indicate the direction of the stack outlet: (check one) Upward El Horizontal Q. Downward ❑ Other (describe): indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other(describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information Check this box _ if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Flare Make/Model: _ ❑ Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 9$ % Minimum Temperature: "F Waste Gas Heat Content: Btu/scf Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: MMBtu/hr Pollutants Controlled: Description: Requested Control Efficiency:. t"P r wym.. ;�Y"l1 t;rt.�_,a.,• 1'IYc11'2Cazun.Clyi(� L �}� 3 ;(i Revision 312019 e a t n R A. rai 41 Permit Number: 15WE0039 AIRS ID Number: 123 / 90741005 [Leaveblank u t as A.?C D has already , _i ned a permit AI arld AIRS ID; Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control- methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency f% reduction in emissions) PM SOX NOx CO VOC Enclosed Burner .95% HAPs Enclosed Burner 95% Other: D Using State Emission Factors (Required for GP07) O Condensate ❑ Crude VOC 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/B8L Frorn:what year is the following reported actual annual emissions data?. is eria Pollutant Emissions Inventory, PM Emission Factor -Uncontrolled_ Basis IbIMMsef • Source T1AP 42 • Mfg , etc;) Actual Annual Emissions Requested Annual. Per Emission Limit(s)5 Uncontrolled -Emissions (tons/year), Controlled. Emissions6 (tans/year) Uncontrolled Emission (tons/year) £ontrolled Emissions' (tons/year). 7;60 AP -42 0.00 0,00 0.00 0.00 SOx 0.60 Ib/MMscf AP -42 0.00 0.00 0.00: 0.00 NO„ 0.068 lb/k/IMBtu AP -42 0.01. 0.01 0.02 0,02. CO 0.310 IbIMMetu AP -42 0.05 0.05 0.90 0.10 VOC 0.2810 Iblbbl AP -42 9.02 0.45 19.67. 0.98 Non -Criteria Reportable Pollutant Emissions Inventory. Chemical Name Chemical Abstract Service (CAS) Number ., Emission Factor', Actual Annual Emissions; Uncontrolled Basis Units Source (AP -42, klis., etc.) Uncontrolled. Emissions (pounds/year) Controlled. Emissions& (pouncislyear.) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene n -Hexane 1330207 110543 0.0046 lb/bbl AP -42 292 15 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s). should consider future: process: growth. 6 Annual emissions fees will be based on actualcontrolled emissions. reported, If source has not yet started operating, leave blank. 'PC€D £ :2. Hydrocarbon Liquid Lon s APE _s; r. 3/2019 • Permit Number: 15WE0039 AIRS ID Number: 123 19074 / 005 leave blank iuites APCO has already a ned ,a permit. # and AIRS ID] Section 8 Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct: If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of. General Permit GP07. 10/24/2019 Signature of Legally Authorized Person (not a vendor or consultant) Janessa Salgado Date Environmental. Engineer Name (print) Title Check the appropriate box to request a copy of the: []✓ Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of thefive/ear term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See. Regulation No. 3, Part A, II.C, for revised APEN'requirements.. Send this form along with $191.13 and the, General Permit registration fee of $312.50,. if applicable, to:. Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make' check payable. to: Colorado Department of.Pubtic Health and Environment For more information or assistance call: Small Business Assistance. Program (303) 692-3175 or (303) 692-3148. APCD Main Phone Number (303) 692=3150 Or visit the APCD website at: httos://www.colorado.gov/cdphe/apcd �irocar b 3 I._t_;u d i r7 -PEN, rye ' ' n .3/2?019. 6l Av cos xac3 4 06 47078 Sv\PERSEbE6 : ci-H--kLet APE -k/ Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 /9D74/007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: Eagle, Reliance, Tahoma & Seneca Econode Site Location: SWSW SEC14 T6N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Allison Satterfield 303-228-4137 a.satterfield@nblenergy.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 403690 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 1 I ®, _� e=wR�m: or A:nm HUWfi v£.�s�ew,mnnf Permit Number: 15WE0039 AIRS ID Number: 123 / 9D741007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP01 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) 0 Change in equipment O Change company name3 9 Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: to 140,000 bbl/yr Modification to decrease throughput from 1,168,000 bbl/yr 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Tank Battery 09/09/2014 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year El Exploration Et Production (EEtP) site 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? MI Yes ■ No Are Flash Emissions anticipated from these storage tanks? IS Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes M No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No U D Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • D Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2I COLORADO ° , En Ilten� nwn Vl Permit Number: 15WE0039 AIRS ID Number: 123 I 9D74 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year)' ;Condensate Throughput: 68,727 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 66.797 degrees ❑ Internal floating roof Tank design: El Fixed roof 140,000 RVP of sales oil: 13.735 O External floating roof Storage Tank ID - -- ---- # of Liquid Manifold Storage Vessels in Storage Tank - - -- - Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in ' or- Storage Tank (month/year) Date of First Production - (monthlyeor) Tanks 18 9,684 05/2014 05/2014 Wells Serviced by this Storage Tank or Tank Battery6 (EEP Sites Only) API Number Name of Well ' I Newly Reported Well - No new wells since initial application ■ - - M - ■ _ ■ ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4798, -104.6382 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Leed/Cimarron Variable Variable Variable Indicate the direction of the stack outlet: (check one) ID Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I COLORADO D.C.111.711ernot wem Permit Number: 15WE0039 AIRS ID Number: 123 /9D74/007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion r Device: Pollutants Controlled: VOC and HAPs Rating: Type: Enclose Flare Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: 95 % 98 Waste Gas Heat Content: Constant Pilot Light: El Yes 0 No Pilot Burner Rating: Btu /scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —4 psig Describe the separation process between the well and the storage tanks: Liquids go from well to HP separators, then to LP separators, then to the VRT, then to tanks. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I COLORADO o,Pubn Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the nol efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95% NOx CO HAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor — .-__-_ . Actual Annual Emissions Requested Annual Permit_ Emission Limit(s)5 Uncontrolled Emissions ---- ---- (Tons/year) Controlled Emissions 8 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled — Emissions (Tons/year) Source Uncontrolled Basis Units _ (AP 42, Mfg. etc)_ VOC 1.1506 lb/bbl HYSYS 39.54 1.98 80.54 4.03 NOx 0.068, 100 Ib/MMBtu, Ib/MMscf AP -42 0.55 0.55 1.1 1.1 CO 0.31, 84 Ib/MMBIA Ib/MMscf AP -42 2.38 2.38 4.8 4.8 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical _Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled _,_ - Basis Units - Source (AP -42, Mfg. etc) Uncontrolled Emissions -- -. - (Pounds/year) Controlled Emissions8 - - -- ----- (Pounds/year) Benzene 71432 0.0023 lb/bbl HYSYS 158 8 Toluene 108883 0.0036 lb/bbl HYSYS 247 12 Ethylbenzene 100414 0.0001 Xylene 1330207 0.0008 lb/bbl HYSYS 53 3 n -Hexane 110543 0.0135 lb/bbl HYSYS 928 46 2,2,4- Trimethylpentane 540841 0.0007 lb/bbl HYSYS 48 2 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 1 COLORADO Cc,artaeno of ttbac Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 /007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 07/24/2019 Signature of Legally Auth sized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado. Rov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 Ay COLORADO 6 1 Fr,_,..: IM;" M1 R.Lt4',4,)L - k°1-°( Condensate Storage Tank(s) APEN Form APCD-205 AifPolltitant Emission Notice (APEN) and Application ;for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN. updates.. Incomplete APENswill be rejected and wilt require re -submittal. YourAPEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment fora new filing fee. This APEN is: to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.): In addition, the General. APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A List of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at www.colorado.p,ov/pacific/cdnhe/air-oermits. This emission notice is valid for five (5) years. Submission: f a revised APEN is required 30 days prior to expiration of thefive-year term, or when a reportable change is made (significant, emissions increase„ increase production, new equipment, change in fuel type., etc.). See Regulation No. 3, Part A, II.C.. for revised APEN requirements. Permit Number:. 15WE0039 AIRS ID Number: 1.23 ! 9D74 / 007 [Leave blank unless APCD h: s_already a signed a permit # and AIRS ID] Section_1-Administrative_Information _ --- Company Name1: Noble Energy Inc. Site Name: EAGLE RELIANCE SENECA TAHOMA ECONOOE T6N-R65W-514 LD1 Site Location; SWsw SEC14 T6N R65W Mailing Address: (Include Zip Code) 1 625 Broadway, Suite 2200 Denver, CO 80202 Site Location: County: We'd NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address: janessa,salgado@nblenergy.com. 1 Use the full, legal company name registered with the Colorado Secretary of State.. This is the company name that will appear on all documents issued by the APCD. Any changeswill require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form.APCD-205•C 71 ? 7__ Store Tank(s) APEN. Revision 317019 1. I . <<� "s`. tu.a�r��, v.r�. Permit Number: 15WE0039 AIRS ID Number: 123 i 9D74/ 007 ( n a ?)lank urtie,3sAP :D has already asGigned a permit n -.a and AIRS 101 Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GPO8 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑✓ Change in equipment O Change company name3 O Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Modification of throughput and emission factors. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General InformationGeneral description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Tank Battery 09/09/2014 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 0 Exploration £x Production (EEtP) site 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? IS Yes ■ No Are Flash Emissions anticipated from these storage tanks? O Yes 0 No Is the actual annual average hydrocarbon liquid throughput a 500 bbliday? O Yes ❑✓ No If "yes", identify the stock tank gas -to -oil ratio: m3/titer Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes / No • Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ yes 0 No € o m ,t` CL _2i)_ rond,aocate Str,ragP Tadis) .?_., r. til ic•n >„7019 2 COSORa,OO Di Upward. O Horizontal Permit Number: 15WE0039 AIRS ID Number: 123 /9D741007 [Leave, c'Mnk tintess APCD has e ready -assigned a. permit and AIRS ID Section 4 - Storage Tank(s) Information Actual Annual Amount (bbt/year) Requested Annual Permit Limits (bbUUyear) Condensate Throughput: 64,210.84 140,014 From what year is the actual annual amount? ANerage API gravity of sates oil: 66.62 degrees Tank design: 0 Fixed roof 0 Internal floating roof RVP of sales oil: Modeled at 15 ❑ External floating roof Storage Tank.ID .. #'of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank. (bb(y insta..ltation Date.of Most Recent Storage Vessel.. in Storage Tank (month/year) Date of First Production (month/year) Tanks 18 9,684 09/2014 09/2014 API Number Wells Serviced by this Storage -Tank or Tank 8attery6 (EffP:Sites-On y) Name of Well Newly Reported Weit No new: wells since initial applicaiton 0 5Requestedvaiues witibecome permit imitations. _ Requestedlimit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form, Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) -= 40.4798, -104.6382 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM): Velocity (ft/sec). Indicate the direction of: the stack outlet: (check one) ❑ Downward O Other (describe): Indicate the stack opening and size: (check: one) El Circular CI Square/rectangle Other (describe):. O Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): interior stack depth (inches): co L.7RAQ APCD-2.05. - C..in'_'..,ils.=±NSr.rFl r? iFi::..i>t EN 2011 Permit Number: 15WE003,g AIRS ID Number: 1 23 t 9D74 t 007 t4 ear`£ a .k LinLess.APCD has- a[; "7y 7ssAn d a permit # and AIRS 101 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑•Combustion Device: Pollutants Controlled: VQC and HAPs Rating: MMBtu/hr Type: Enclosed Flare Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: gg Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: 0 Yes O Na Pilot Burner Rating: Btu/scf MMBtu/ hr O ___Closed Loop p System Description of the closed loop system: - ❑ Other: Pollutants Controlled: Description: - Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 4 psig Describe the separation process between the welt and the storage tanks: Liquids go from well to HP separators, then to LP separators, then to VRT, then to tanks. COLORADO r.Isi ADEN • R .is:0in _ /2019 Permit Number: 15WE0039 AIRS iD Number: 120 / 9D74 /007 [Leave a an9 unless APCD has already astst ned a permit and r :S IDI Section 8 Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall or combined) control efficiency (% reduction): Pollutant Description of Control Method{s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95% NOx ,CO KAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions inventory Pollutant Emission Factor. Actual Annual. Emissions... Requested Annual : Permit Emission Limit(s)5 Uncontrolled Basis -: Units Source (AP -42, Mfg_, etc.) Uncontrolled Emissions (tons/year) Controlled £missions$ (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (toms/year) VOC 1.4144 lb/bbl HvsYsrrarzksa:o9d 45.41. 2.27 99.02 4.95 N0x - 0.0029 Ib/bbl —AP-42— —0.09 -0.09 - -- 0.20 - 0.24 CO 0.0114 ib/bbl AP -42 0.37 - 0.37 0.80 0.80 Reportable -.Pollutant; Non Criteria Emissions inventory Chemical Name Chemical Abstract Service (CAS) Number. Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.( Uncontrolled Emissions (pounds/yeorj Controlled Emissions$ (poundslyear) Benzene 71432 .0.0045 lb/bbl rtYsysnene4.e9a 289 ' 14 ' Toluene . 108883 - 0.0087 - lb/bbl yYsysdsn s4:o9d 557 ..:� _ 28 s.. - Ethylbenzene 100414 Xylene 1330207 0.0018 Ib/bbl HYSYStrankcd-99c.. 118. 6 n -Hexane 110543 0.0270 lb/bbl HYSYSrr nks4:99d 1,734 - 87 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo .14-03: a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. F fir r,5 r,a...S_j ii'l-a1AP-E1:1 i, - n 3 12.09 • Permit Number: 15WE0039 AIRS ID Number: 123 /9D74/007 [Leave blank yhte.:.> APCD has al X1.3 .:>Pg,hed a permit , anci AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, trued and correct If this is a registration for coverage under General Permit G.P01 or GP08, I further certify that -- this -source ,;is and will be operated in full compliance with each condition of the applicable General Permit. 10/24/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance ® Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change infuel type; etc.). See Regulation No. 3, Part A, II.C_ for revised APEN requirements: Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to:. Colorado Department of Public Health and Environment Air. Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment for more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/aPCd SAP EK.S LI sue- +k.fckD • Clda(rnutv1w\ f*c/tt,/a0 IZ1I i Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 /9D74 I •. D 1( [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information company Name': Noble Energy Inc. Site Name: Eagle, Reliance, Tahoma & Seneca Econode Site Location: SWSW SEC14 T6N R65W Mailing Address: 1625 Broadway,Suite 2200 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 403688 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I eaCOLORADO E.o.m.:. Of Putiic Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info It Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: LP gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 9/9/2014 For new, modified, or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year ❑r Yes ❑ No ❑ Yes 0 No O Yes ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AV COLORADO t ntofPublic Ha.:In E,:n.m,m.,,, Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: 0 Yes ❑✓ No Vent Gas Heating Value: 2196 BTU/SCF Requested: 15.13 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 39.0479117 / VOC (Weight %) 69.59% Benzene (Weight %) 0.15% Toluene (Weight %) 0.43% r Ethylbenzene (Weight %) 0.01% ✓' Xylene (Weight %) 0.10% v n -Hexane (Weight %) 1.49% V 2,2,4-Trimethylpentane (Weight %) 0.08% `/ Additional Required Information: O Attach a representative gas analysis (including BTEX It n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) El 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I AY COLORADO rdF¢tl Fulih E FnW rafm�n� ❑✓ Upward ❑ Horizontal Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4798, -104.6382 Discharge Height;' Temp Flow Rate l , Velocity Operator ' AboveeGGround Level Rt Stack ID No ds H :j-"' ( �. F)_ ACFM ( ) t/sec j ; (f ) i (Feet) Leed Variable Variable Variable Indicate the direction of the stack outlet: (check one) 0 Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: % Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 4 I AV. imYLR fr Enwrmmxe� Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM Overall Requested Control Efficiency (% reduction in emissions) SOX NO,, CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant; PM Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis 7.6 Ib/MMscf Source (AP 42r :.. Mfg,etc,1 AP -42 Uncontrolled_ • Emissions (tons/year)' Controlled Emissions6 (ton-ns/year) Uncontrolled Emissions (tons/year)_ 0.04 Controlled Emissions tons/year) I' 0.04 SOX 0.6 Ib/MMscf AP -42 0.00 0.00 NO,, 0.068, 100 Ib/MMBtu, Ib/MMscf AP -42 1.64 1.64 CO 0.31, 84 IbIMMEtts Ib/MMscf AP -42 5.58 5.58 VOC 71.73943, 0.0055 Ib/MMscf, Ib/MMscf Model, AP -42 542.9 27.17 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS _ NUmbef i Emission Factor Actual Annual Emissions uncontrolled Basis -- - Units Source (AP -42, Mfg., ' etc.) Uncontrolled Emissions (Pounds/year) Controlled _� Emissions , (Pounds/year)' Benzene 71432 0.15831 Ib/MMscf Model/AP-42 2396 120 Toluene 108883 0.43877 Ib/MMscf Model/AP-42 6641 332 Ethylbenzene 100414 0.01005 Ib/MMscf Model/AP-42 152 8 Xylene 1330207 0.10333 Ib/MMscf Model/AP-42 1564 78 n -Hexane 110543 1.53432 lb/MMscf Model/AP-42 23240 1179 2,2,4- Trimethylpentane 540841 0.08520 Ib/MMscf Model/AP-42 1 290 64 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I A. COLORADO Lcpet Puthc Neal. EnrltcnmmI Permit Number: 15WE0039 AIRS ID Number: 123 /9D74/TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. s),0 7/24/2019 Signature of Legally Author ✓Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (please print) Title Check the appropriate box to request a copy of the: ❑.. Draft permit prior to issuance ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6I AY COLORADO Haaith E EBviecnmant Gas Venting APEN Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed forboth new and existing facilities, including APEN'. updates, Incomplete APENs will be rejected and will require re -submittal. Your APEN. will be rejectedif it is filled out incorrectly, is missing information, or lacks payment for thefiling fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine, sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition; the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Qov/cdphe/aped This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A,. II.C, for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 /9D74 /011 [Leave blank unless APCD has already assigned a permit I and AIRS IDj Section 1 - Administrative. Information Cot iPany Narnel Noble Energy Inc. Site Name:- EAGLE -RELIANCE SENECATANOMA.ECONODE T6N-P65W-514. Lit Site Location: SWSW SEC14 T6N R65W Mailing Address: ing Ad ) (fn1625 Broadway, Suite 2200 Code) . Denver, CO 80202 Site Location County: Weld NA1CS or SIC Code: 1311 Contact Person: ,1enessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@nbienergy:com 1 Use the full, legal company namee registered. with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APED via e-mail to the address provided. coLc5-e.no 211 Gas Venting APEN R Ioi312019 Permit Number: 15WE0039 AIRS iD Number: 123 /9O74/O11 (Leave bank unless APCO has already ass!sned a permit -, and AIRS D] Section 2 Requested Action ❑ NEW permit OR newly -reported emission source - OR • MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name3 ❑ Add point to existing permit. ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL. PERMIT ACTIONS ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional info ft Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 General Information General description of equipment and purpose: LP gas stream Company equipment Identification No: (optional): For existing sources, operation began on; 09/09/2014 (7 4 For new, modified, or reconstructed sources, the projected start-up date is: \\a\\‘'s Checkthis box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: %\ti,Normal Hours of Source F• hours/day Os Operation: Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7,. Section XVILG? evi ors 3/2019 days/week weeks/year Permit Number: 15WEQ039 AIRS iD Number: 123 /9D74 /011 [Leave blank u€.less AP -CD has already assigned a permit > and AIRS ID] Section 4 Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial #: ❑ Compressor Rod Packing Make: Model: # of Pistons: ❑ Blowdown Events # of Events/year: Volume per event: O Other Description: Capacity: Leak Rate: gal/min Scf/hr/pist MMscf /event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Q Yes Gas Venting Process Parameters5: ❑ No Vent Gas Heating Value: 2750 BTU/SCF Requested: 11 94 MMSCF/year Actual: MMSCF/year Liquid Throughput Process Parameters5: Vented Gas Properties: Requested: bbl/year Actual: bbl/year MolecularWeight: 41.05 VOC (Weight %) 72.65 / Benzene (Weight %) 0.27% r Toluene (Weight %) 0.67% / Ethylbenzene (Weight %) 0.03% / Xylene (Weight %) 021% / n -Hexane (Weight %) 1.68% ✓ 2,2,4-Trimethylpentane (Weight%) 0.11% ✓ Additional Required Information: ❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attacha representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. r rm APCD•2 i l . v .,n 312919 31 COLC%A.D T. ❑✓ Upward O Horizontal Permit Number: 15WE0039 [Leave btank unless APCD has a AIRS ID Number: 123 /9D74/011 ready assigned a permit =' and MRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4798, -104.6382 operator StaclS lil No Discharge Height Above Ground Level (Feet) Temp ( , S `' Flow ate L ACFM} : Velocity (fl sec) Indicate the direction of the stack outlet: (check one) ❑ Downward O Other (describe): indicate the stack opening and size: (check one) E Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section .6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: rm Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu / hr Type: Enclosed Combustor(s) Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas. Heat Content: Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: .ormAPCD•21i G -Vent m. APEPI Rc ri ; p /2019 },rte, G3LLSN �17� 4 I J Permit Number: 15WE0039 ' AIRS ID Number: 123 19D74 /01 1 (Leave blank unless APCD has atr ady 'assJtneci a permit ." and Ai RS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description. of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOX CO VOC VOC Burner 95% NAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant. Source. {AP -42:,. Mfg., etc.). Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Uncontrolled Emissions {tons/year) Controlled Emissionsb (tonslyear) Uncontrolled Emissions (tons/year).. Controlled. Emissions (tans/year) PM 76 Ib/MMscf AP -42 0.04 - -0:04 Sox. 0.6 lb/MMscf AP -42 0.00 0.00 NOx 240.1668 Ib/MMscf AP -42 1:43 1.43 CO 782.7722 Ib/MhrJlu,Ib(MMsd AP -42 4.67 4.67 VOC 78,747.4276 Ib/MMscf HYSYS, AP -42 470.07 23.53 Non -Criteria:, Reportable Pollutant Emissions Inventory Chemical Abstract Service CAS { ) Number Emission Factor Actual Annual Emissions Chemical Name Source Uncontrolled Uncontrolled Basis! Units (AP -42, Mfg., etc) Emissions {paundslyear) Controlled Emissions6 (pounds/year) Benzene 71432 288.6936 ) lb/MMscf HYSYS/AP-42 3,447 172 Toluene 108883 729:7580 lb/MMscf HYSYS/AP-42 8,712• 436 Ethylbenzene 100414 11. OA $1PArvic ii 5J AP -1L 3 SS 1-} Xylene 1330207 224.2226 Ib/MMscf HYSYS/AP-42 2,677 134. . n -Hexane 110543 1,821.5880 Ib/MMscf HYSYS/AP-42 2_1, 3-'n- I ,1 fly Trimeththylpentane ylp 540841 10,6290 .Ib/MMscf HYSYS/AP-42 1,440 72 Other: 5 Requested values will become permit limitations. Requested lirnit(s):should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.' If source has not yet started operating; leave blank. o ,, APC )-_'il r.. . r Revision /2019 5( or' Ste 1111-241.0 • Permit Number: 15VVE0039 AIRS ID Number: 123 '9D74/O11 [Leave blank .,mess APCG has already assicmcd a permit . and AIRS ; ] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, _true,. and, correct. 10/24/2019 Si nature of Legally Authorson not a vendor or consultant) g ( Janessa Salgado Date Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.).: See Regulation No. 3, Part A, II:C. for revised APEN requirements: Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-55-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of. Public Health and Environment }i.. no.-APEN - Fevisin 3.1701g For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148; APCD Main Phone Number (303)692-3150 Or visit the APCD website at: httos://www.colorado.Rovicdohe/apcd coL9,aans • 6 Mrt 1/2/2020 State.co.us Executive Branch Mail - APEN Review: Mods at the Eagle, Reliance, Tahoma & Seneca Econode, AIRS ID 123-9D74 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Mods at the Eagle, Reliance, Tahoma & Seneca Econode, AIRS ID 123-9D74 Janessa Salgado <Janessa.Salgado@nblenergy.com> Mon, Dec 30, 2019 at 8:47 AM To: "Ricci - CDPHE, James" <james.ricci@state.co.us> Hey James, For point 011 I am also calculating 21,747 lbs uncontrolled and 1,104 lbs controlled. The draft shows 1,087 lbs controlled, can this be updated to 1,104? This makes the controlled EF 3941.76 Ib/MMscf. For the EF for points 011 and 012 I request the match my calculations. Point 011: Pollutant Uncontrolled Controlled NOx 240.17 240.17 CO 782.77 782.77 VOC 78,747.43 3,941.76 Benzene 288.70 14.44 Toluene 729.76 36.49 Ethylbenzene 28.03 1.40 Xylene 224.22 11.21 n -Hexane 1,821.59 92.51 224 120.63 6.03 Point 012: Pollutant Uncontrolled Controlled NOx 356.94 356.94 CO 1,055.04 1,055.04 VOC 128,180.72 6,417.08 Benzene 639.26 31.97 Toluene 1,508.17 75.41 httos://mail.qooqle.com/mail/u/0?ik=5517734b80&view=Pt&search=all&permmsgid=msg-f%3A1654360195393089816&simpl=msg-f°/03A16543601953... 1/2 1/2/2020 State.co.us Executive Branch Mail - APEN Review: Mods at the Eagle, Reliance, Tahoma & Seneca Econode, AIRS ID 123-9D74 Ethylbenzene 56.06 2.80 Xylene 448.45 22.42 n -Hexane 3,870.43 196.15 224 241.26 12.06 Thanks! Janessa Thanks Janessa. I attached the draft permit and PA to this email for your review. After you review, I will send this permit for public comment. Please let me know if you need additional time past January 3rd to provide comments. Also, I am still calculating different n -hexane values for LP venting (point 011), even with the 18 lbs difference described above. The APEN lists 8,712 lbs uncontrolled / 436 lbs controlled but I calculated 21,747 lbs uncontrolled / 1,104 lbs controlled. Thanks, [Quoted text hidden] https://mai I.goog le.com/mai I/u/0? i k=5517734b80&view=pt&sea rch=a II&permmsg id=msg-f%3A1654360195393089816&sim p I=msg-f%3A16543601953... 2/2 11 : see_ c+�-,4c,4 NP6N S ? �'� '1 t aUWpn�lun� f t Le; Jed. 1O1 ZA I (A Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 /9D74 / O/2. [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: Eagle, Reliance, Tahoma & Seneca Econode Site Location: SWSW SEC14 T6N R65W Mailing Address: 1625 Broadway,Suite 2200 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterrield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 403689 COLORADO Dp„ nt o, Put, Hxa. b Rn+renman� Permit Number: 15WE0039 AIRS ID Number: 123 /9D74/TBD [Leave blank unless APCD has already assigned a permit !t and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info ft Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: VRT gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 9/9/2014 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? ❑✓ days/week weeks/year Yes Yes Yes Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I ❑ No ❑✓ No ❑ No COLORADO orn�:eo«�ae a�w� Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator o Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,' you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? O Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Value: Heating Valuue:: 2744 BTU/SCF Requested: 3.23 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 48.8685053 I VOC (Weight %) 86.49% Benzene (Weight %) 0.21% ✓ Toluene (Weight %) 0.54% / Ethylbenzene (Weight %) 0.01% ✓ Xylene (Weight %) 0.12% 1 n -Hexane (Weight %) 2.01% / 2,2,4-Trimethylpentane (Weight %) 0.11% 1 Additional Required Information: O Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) 0 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I COLORADO Hoh En U:rcmmmi AIRS ID Number: 123 /9D74 / TBD Permit Number: 15WE0039 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4798, -104.6382 Discharge Height --- 4 'Above _bove Ground Level Temp ('F) -- - - - -- T Flow _ Rate — t T Velocity Operator Stack ID No. , -- — -- --- -, - (ACFM) —. — — - (ft/sec)` -- _ (Feet) a Leed Variable Variable Variable Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr hr Type: VOC Burner Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: 'arm APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO Permit Number: 15WE0039 AIRS ID Number: 123 /9D74 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the uction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor - - --- — -- — Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis - ----etc.) Units Source (AP -42_.. Mfg., Uncontrolled Controlled Uncontrolled Emissions' (tons/year) _ — Controlled _ Emissions - -- _.,_(tons/year) ,. Emissions - t-- (tons/year) _ Emissions 6 (tons/year) PM 7.6 Ib/MMscf AP -42 0.02 0.02 SOX 0.6 lb/MMscf AP -42 0.00 0.00 NO. 0.068, 100 Ib/MMBtu.Ib/MMscf AP -42 0.56 0.56 CO 0.31, 84 Ib/MMBtu,lb/MMscf AP -42 1.59 1.59 VOC 111.587119, 0.0055 ILYMMscf, lb/MMscf Model, AP -42 179.97 179.97 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP 42, Mfg., etc.); Uncontrolled Emissions (pounds/year)_! Controlled Emissions 6 (pounds/year) Benzene 71432 0.26659 lb/MMscf Model/AP-42 860 43 Toluene 108883 0.69029 lb/MMscf Model/AP-42 2226 111 Ethylbenzene 100414 0.01498 lb/MMscf Model/AP-42 48 - 2 Xylene 1330207 0.15354 Ib/MMscf Model/AP-42 495 25 n -Hexane 110543 2.59371 lb/MMscf Model/AP-42 8375 427 2,2,4- Trimethylpentane 540841 0.13820 lb/MMscf Model/AP-42 446 22 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5I COLORADO Depu calm of M:tic Rua.ue _. sv.ieresrt. Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 I TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 1 C , Signature of Legally Authorize l'erson (not a vendor or consultant) Date Allison Satterfield 7/24/2019 Environmental Scientist Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 61 yCOLORADO -t Lt*, el ,1.-`\\ \°\ Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates.. Incomplete APENs will be rejected and wilt require re -submittal. Your APEN will be rejectedif it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee, This APEN is to be used for gas venting only. Gas venting includes emissions from gas/tiquid separators, well head casing,: pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs.,A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www;colorado.govlcdphe/aped. This emission notice is valid for five (5) years.. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel. type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE0039 AIRS ID Number: 123 /9D74 /012 [E Pet e blank unless APCD has :already a permit # and MRS ID] Section 1 - Administrative Information Company Namei::Noble.. Energy Inc. A. Site NameEAGLE REIIANCE:SENECATAHbMAECON00c TEN-R65wS14 Ld9-- Site Location: SWSW SEC14 T6N R65W Mailing Address: 1625 Broadway, Suite 2200 flmlude zip code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Janessa. Salgado Phone Number:' 303-228-4196 E -Mail Address2: jenessa.saigado@nbienergy.cony l Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD, Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. f nts APCD-211 i EI] W.2nting ;^ L,l Revision _120119 I iT 'Ji.9'�S ,4'JJ Permit Number: 15WE0039 AIRS ID Number: 123 /9D741012 [Leave blank unless :!,PCD has already assipm d -a permii and AIRS ID] Section 2 Requested Action NEW permit OR newly -reported emission source -OR- ❑ MODIFiCATION. to existing permit (check each box below that applies) • Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR • APEN submittal for update only (Note blank APENs wilt not be accepted) - ADDITIONAL PERMIT ACTiONS.- ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name. Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: WRT gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 09/09/2014 For new, modified, or reconstructed sources, the projected start-up date is: O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to: Colorado Regulation No. 7, Section XVIi.G? Form t iP,...D 21't Gas Venting. ADEN. . Revision 312019 • Q Yes ❑ Yes • Yes weeks/year No ❑✓ No Permit Number: 15WE0039 AIRS ID Number: 123 / 9D74 / 012 [Leave blank. unless APCO has already ass geed a p. rmtt ,^„ A iS �] Section 4- Process Equipment Information Q Gas/ Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min. # of Pistons: Leak Rate; Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: O Yes No Vent Gas. Heating Value: 2986 - BTU/SCF Requested: 3.26 MMSCF/year Actual:. MMSCF/year Liquid Throughput Process Parameters5: Vented Gas Properties: -OR- Requested: bbl%year Actual: bbilyear Molecular Weight: 53.38 VOC (Weight %) 90.92% Benzene (Weight %) 0.45% .i Toluene (Weight %) 1.07% e Ethylbenzene (Weight %) 0,04.% Xylene (Weight %) 0.32% ✓ n -Hexane (Weight %) 2.74% a 2,.2,4-Trimethylpentane (Weight %) 0.17% Additional. Required Information: Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature,and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 2P _2; 1 r APE, . Re 3/2019 rCi� • �..� .� i � �::_ �.c.z.�lii'•� APEN ,. ^S':}Fi ❑✓ Upward O Horizontal Permit Number: 15WE0039 AIRS ID Number: 123 /9074/012 [Ldxe-bias Lint.ess APCD has a.ready ass. ne' a perm : and AIRS ID] Section 5 - Stack Information Geographical. Coordinates (Latitude/Longitude or UTM) ___ 40.4798, -104.6382 Operator k lQ Stacflit Discharge Height Above Ground Level jt evil Temp Flow Rate Velocity tACrM) i l Indicate the direction of the stack outlet: /check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular 0 Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: % % ❑ Combustion Device: Pollutants Controlled: VOC, HAPS Rating: MMBtu/hr hr Type: Enclosed Combustar(s)Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 at % Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtulhr. Other: Pollutants Controlled: Description: Requested Control Efficiency: APCD-211 . as r''.r It a /PEN # evis':c:n 3? 41 COLOTi :5OO Permit Number: 15WE0039 AIRS ID Number; 123 /9D74/O12 lLeave blank un1es APB: D his a re,a dy-assigned a per mil.= and. AIRS ID) Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested. Control Efficiency {% reduction in emissions) PM SOX NO. CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant: Source:: (AP -4a Mfg., etc.) Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Uncontrolled Emissions itans/Year) Controlled Ernissions6 (tons/year) Uncontrolled Emissions (tons/year) • Controlled: Emissions (tons/year} PM 7.6 ib/MMscf AP -42 0.02 0.02 SOX 0.6 ib/MMscf AP -42 0.00 0.00 NO. 356.9240 Ib/MMscf AP -42 0.58 0.58 CO 1,055.0415 Ib/MARIN, IbIMMscf AP -42 1.72 1.72 VOC 128,180.7155 lb/MMscf HYSYS, AP -42 208.68 19.45 Non -Criteria. Reportable. Pollutant Emissions Inventory :.. Chemical Name Chemical Abstract .. Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis units Source (AP -42; Mfg., etc.) Uncontrolled Emissions oundsl ear (P y 1 Controlled Emissions s {pounds/year) Benzene 71432 639.2555 lb/MMscf HYSYS/AP-42 2,081 104 Toluene 108883 1,508.1659 lb/MMscf HYSYS/AP-42 4,911 246 Ethylbenzene 100414 Xylene 1330207 448.4452 lb/MMscf HYSYS/AP-42 1,460 73 n -Hexane 110543 3,870.4338 Ib/MMscf HYSYS/AP-42 32,602 639 2,2,4- Trimethylpentane 540841 2441.2'5580 Ib/MMscf HYSYS/AP-42 786 39 Other: s Requested values wilt become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees willbe based on actual controlled emissions reported. If source has not yet started operating, leave blank. AvCOLORADO Permit Number 15WE0039 AIRS ID Number: 123 /9D74/012 [Leave {ve blank, uatess APCD has' a ready assialned a pes'ntlt. = and AIR- ID] Section 8 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10124/20.19 Signal ire of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to. issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production,. new equipment, change in fueltype, etc.). See Regulation. No. 3, Part A, 11.C. for revised APEN requirements. Send this form along with $191.13.to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado. Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303.).692-3175 or (303) 692-3148 APCD Main Phone Number (303)692-3150: Or visit the APCD website at:. httos://www.colorado.gov/cdphetapcd E C'w.A-D D Foil. APCD =11 Gas Venting APEN evi5iO 31.2019 Hello