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HomeMy WebLinkAbout20202328.tiff C. COLORADO *W Department of Public Health&Environment RECEIVED JUL 17 2020 WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 July 8, 2020 Dear Sir or Madam: On July 9, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy, Inc. - DP115 A34-14 ECO REVEILLE. 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator o1 t'°<a' 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe '$ , Jared Polis, Governor I Jill Hunsaker Ryan,MPH, Executive Director !tt ;* PUbI; G Rev:ecJ CC'.P(.(TP) {-IL(DS),PW(SM/ER/GH/ce 2020-2328 c)870 3/20 oG(aH) O7/17/,0 MYM Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Noble Energy, Inc. - DP115 A34-14 ECO REVEILLE - Weld County Notice Period Begins: July 9, 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: DP115 A34-14 ECO REVEILLE Oil and gas exploration and production SESW Sec 34 T6N R64W Weld County The proposed project or activity is as follows: The applicant is requesting to permit equipment at an existing oil and gas exploration and production facility. The source is requesting to route flash gas from various equipment onsite to an enclosed combustor and to permit fugitive emission leaks. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section tII.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0174 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: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 � COLORADO Department of Public 1 m I co>we Health Et Environment C •M�: d. COLORADO 4 Air Pollution Control Division 17i1 Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0174 Issuance: 1 Date issued: Issued to: Noble Energy, Inc. Facility Name: DP115 A34-14 ECO REVEILLE Plant AIRS ID: 123/A006 Physical Location: SESW Section 34, Township 6N, Range 64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control ID Point Description Condensate Flash gas venting from knock out tanks, Knockout 001 scrubbers, and other miscellaneous Enclosed Combustor Burners equipment onsite Fugitive emissions component leaks Fugitives 002 associated with the oil and gas exploration None and production facility This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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 Page 1 of 11 C �Y��,-� COLORADO t Air Pollution Control Division ,�• Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 III.G.2.) 3. 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. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator 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.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X Condensate Knockout 001 -- --- 6.8 - Point Burners Fugitives 002 --- --- 1.7 --- Fugitive Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 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. AIRS ID 002: The operator must calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended gas analyses, as required in the Compliance Testing and Sampling section of this permit. The operator must maintain records of the results of component counts and sampling events used to calculate Page 2 of 11 C �•My COLORADO _ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado actual emissions and the dates that these counts and events were completed. These records must be provided to the Division upon request. 9. 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.) Equipment AIRS Control Device Pollutants ID Point Controlled Condensate Knockout 001 Enclosed Combustor VOC and HAP Burners PROCESS LIMITATIONS AND RECORDS 10. 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 Equipment ID AIRS Process Parameter Annual Limit Point Total gas venting to enclosed Condensate combustor from knock out tanks, Knockout 001 scrubbers, and other miscellaneous 3.0 MMSCF/yr Burners equipment onsite 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. 11. AIRS Point 001: The owner or operator must continuously monitor and record the total volumetric flow rate of gas vented from the knock out tanks, scrubbers and other miscellaneous equipment onsite using the flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. 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. AIRS ID 001: The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion Page 3 of 11 CCOLORADO t'4/ Air Pollution Control Division Department of Public Heatth&Environment Dedicated to protecting and improving the health and environment of the people of Colorado device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. AIRS ID 001: The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. 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 commencement of operation 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. 15. AIRS ID 002: This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2. The following requirements were determined to be RACT for this source. Facility AIRS Pollutant RACT Equipment ID Point, Fugitives 002 VOC LDAR per Regulation 7, Part D, Section II.E 16. AIRS ID 002: Fugitive component leaks at this welt production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section I.L. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section I.C.1. 17. AIRS ID 002: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section II.E. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section II.B .B 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 19. AIRS ID 001: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&tM) plan and record keeping format approved by the Division, in Page 4 of 11 C .:'r- COLORADO I 4440 Air Pollution Control Division T tar Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. AIRS ID 001: 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 combined gas vented from the knock out tanks, scrubbers, and other miscellaneous equipment onsite in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane 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. 21. AIRS ID 002: Within one hundred and eighty days (180) after issuance of this permit, the permittee shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC)and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self-certification process to ensure compliance with emissions limits. 22. AIRS ID 002: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "gas service," "heavy liquid service," "light liquid service" and "water/oil". The operator shall submit the results to the Division as part of the self- certification process to ensure compliance with emissions limits. Periodic Testing Requirements 23. AIRS ID 002: On an annual basis, the permittee shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 24. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 5 of 11 C - COLORADO Air Pollution Control Division 1%0'44444.P Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 year, 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 APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 25. 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 26. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 27. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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. Page 6 of 11 �• x--yet. COLORADO 110 Air Pollution Control Division tie Department of Public Flealtn&Ennronment Dedicated to protecting and improving the health and environment of the people of Colorado 28. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 29. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 30. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 31. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 32. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issued to Noble Energy Inc. for: • Venting from knock out tanks, scrubbers, and Issuance 1 This Issuance other miscellaneous equipment onsite (AIRS ID 001) • Fugitive equipment leaks (AIRS ID 002) Page 7 of 11 »•Y•z. COLORADO Air Pollution Control Division Department of Public I fealtn&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 sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,698 85 Toluene 108883 1,383 69 Condensate Ethylbenzene 100414 993 50 Knockout 001 Xylenes 1330207 627 31 Burners n-Hexane 110543 9,060 454 2,2,4- 540841 967 48 Trimethylpentane Fugitives 002 n-Hexane 110543 44 44 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 following emission factors: Point 001: Emissions for Point 001 include venting of flash gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite to the enclosed combustor, combustion of flash gas at the enclosed combustor and combustion of pilot light gas for the enclosed combustor. Total emissions are based on the sum of emissions from all three activities. Page 8 of 11 C- , ..„,....» z.`� COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Venting of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite to Enclosed Combustor: Weight Uncontrolled Controlled Fraction Emission Emission CAS # Pollutant of Gas Factors Factors Source (%) (lb/MMscf) (lb/MMscf) VOC 78.0 90,207 4,494.9 HYSYS 71432 Benzene 0.5 564.98 28.249 HYSYS 108883 Toluene 0.4 460.25 23.013 HYSYS 100414 Ethylbenzene 0.3 330.50 16.525 HYSYS 1330207 Xylene 0.2 208.69 10.435 HYSYS 110543 n-Hexane 2.6 3,015.3 150.98 HYSYS 540841 . 2, 0.0. 3 321.67 16.084 HYSYS Trlmethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Combustion of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite: Combustion emissions from flash gas combusted at the enclosed combustor are calculated using the following emission factors and actual monthly volume of flash gas routed to the enclosed combustor. Uncontrolled Emission Factors CAS # Pollutant lb/MMscf Flash Gas Source NOx 167.35 AP-42, Ch 13.5' CO 762.91 AP-42, Ch 13.5 Permitted emissions are based on a heat content of 2,461 btu/scf. Combustion of Pilot Light: Combustion emissions from the pilot light are calculated using the following emission factors and most recent monthly volume of fuel to the pilot lights. The pilot light gas throughput shall be assumed to have a constant value of 0.04 MMBtu/hr for both burners. Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of operation. Uncontrolled Emission Factors CAS # Pollutant lb/MMBtu Source NOx 0.098 AP-42, Table 1.4-4 CO 0.0824 AP-42, Table 1.4-4 Permitted emissions are based on a heat content of 1,000 btu/scf. Point 002: The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil Water/Oil Service Page 9 of 11 ».:.. COLORADO Air Pollution Control Division 1 Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Connectors 5,922 588 1,938 1,148 Flanges 752 0 348 28 Open-ended Lines 6 0 0 0 Pump Seals 0 0 4 0 Valves 2,434 196 1,806 392 Other* 668 0 122 140 VOC Content (wt%) 40.0% 100% 100% 100% Benzene (wt%) 0. 10% 0.25% 0.25% 0.25% Toluene (wt%) 0.05% 0. 13% 0.13% 0.13% Ethylbenzene (wt%) 0.05% 0. 13% 0.13% 0. 13% Xylenes (wt%) 0.05% 0. 13% 0.13% 0. 13% n-hexane (wt%) 0.50% 1.25% 1.25% 1.25% 2,2,4- 0.05% 0. 13% 0.13% 0. 13% trimethylpen tone *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06' Pump Seals 3.5E-04 --- 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent extended gas analysis. 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 emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) AIRS ID 002: This source is subject to 40 CFR, Part 60, Subpart 0000a—Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Page 10 of 11 : t COLORADO Air Pollution Control Division Department of Public Health&Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD True Minor Source of: CO NANSR Synthetic Minor Source of: VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: 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 I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63:1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Coiorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Carissa Money Package#: 423655 Received Date: 12/26/20?9. Review Start Date: 6/24/2020 Section 01-Facility Information Company Name: Noble Energy,Inca Quadrant Section Township Range County AIRS ID: 123 SESW 34 69 64 Plant AIRS ID: AOC6 Facility Name: DP115 A 4-14[CO9E'E E Physical Address/Location: .. __.-:ship 6N,:' 64W County: Weld County Type of Facility: Exploration&Production Well Fad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? C--zone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit Initial 001 Separator Venting idensate Knockout Burr Yes 20WE0]24 =' yes Issuance Permit initial 002 Fugitive Component beaks Fugitives No 20ViiE0_74 Yes Issuance Section 03-Description of Project Noble is requesting to permit equipment at an exploration and production site that commenced construction 12/31/2020. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? - No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ O ❑ O O ❑Title V Operating Permits(OP) O O O El O O O O Non-Attainment New Source Review(NANSR) ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O O O O `o' Air Permitting Project • Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ ❑ Separator Venting Emissiuris Inventory Section 01-Administrative Information 'Facility AIRs ID: 123 A0C6 001 �g County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description: Venting of flash gas from monk out tanks,scrubbers and other miscellaneous equipment one to Emission Control Device Description: Enclosed combustor Requested Overall VOC&HAP Control Efficiency%: 95. S Limited Process Parameter Gas meter *"^ _ Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= MMscf per year Requested Permit Limit Throughput= 30 MMscf per year Requested Monthly Throughput= U.3 MMscf per month Potential to Emit(PTE)Throughput= _.5 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 24r1,S Btu/scf Volume of waste gas emitted per BBL of a , ; • liquids throughput: g scf/bbl Control Device • Pilot Fuel Use Rate: '41.66 sofh m.i MMscf/yr 0.04166 Pilot Fuel Gas Heating Value: 1000 Btu/scf Section 04-Emissions Factors&Methodologies Description Noble used flee pressurized liquid sample:from a similar site to model_missions.The prosper fired liquid sample is from WI State.WR03 fconode.cdiefted 6/8/201$from the HP separatoi,This,sample is used as the inlet to the knockout vessel in a€4Y5y5 model,In the rnodel the pressure is veered irom 342 psia to 16.12 esa:Noble used the stream corn-position of"Misr_yap to Burner 2 to estimate emissions,. MW _ 43.91b/Ib-mol Displacement Equation Ex=Q*MW*xx/C Weight Helium CO2 N2 '01 methane 7:4 ethane c r3:3 propane isobutane n-butane i19,0 isopentane "5.6 n-pentane 7:8 cyclopentane 2,3 n-Hexane .=o cyclohexane l0 Other hexanes heptanes Sot ' methylcyclohexane 224-TMP Benzene Toluene _ Ethylbenzene Xylenes CO*Heavies �.. Total VOC Wt 3 off C:\Users\cdmoney\Documents\Package 423555\20WE0174.CP1 • Se 3tor Ver.t, g Elm≤dons Inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 97272 Benzene 5673_ - jI1Ii Ethylbenzene 337>r 224 TMP 32,1434. _ Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0,00/5 _ AP-42 y 14 2(FM V.' 2 S PM2.5 0.0075 z k Jl.P tTa s4 2(• 500 0.0006 -Cab}e$:4 $ NOx 00580- 4FAIKh2 Eh4 '3'alndst4-#,F, (.#Fes k_ CO 0.3100 05-47 ClIn ,:0:.51ntiu0 a IFJ'yces( ._ _. Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 01. ._ � .2 et ---':4,1::,--- -, PM2.5 007._ 7 _. ;lk 4$),,,L SOx 0,5096 44 .4.'� NOx :t 93� 98.0392. avy„ ,. .e ,ai VOC 5.3422 �f, F` CO 0.,, 82.3524 ,.S..- Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled ' (tons/year) (tans/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 .3 0n - 0.0 0.0 0.C- 5 PM2.5 0-G 0.0 0.0 0_C 3.0 - 5 SOx 0.G 0,0 0.0 CU 0.0 0 NOx 0.3 0,0 0.0, 0.22 0.3 46 VOC 135.3 U.S 0.5 14_. ?.150 CO .2 0.0 0.5 1.7 a _._ 197 Potential to Emit Actual Emissions Requested Permit Limits Source's values Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 1702 0 0 s.. .. 1698 85 Toluene 3339 0 - 0 __ 1383 69 Ethylbenzene 300' 0 0 ,',', 993 50 Xylene 590 0 0 530 33 627 31 n-Hexane -303. 0 0 3032 42 9060 454 224TMP 973 0 0 973 45 967 48 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Part D,Section II.B,F Source is subject to Pegvlatlon 7.Part 0,Section IL D2,F Regulation 7,Part D,Section II.B.2.e 5,_o,,r3 de-lie tor epara- of sublect---Reenlation?,Part 0,SessIon'I.5.0 0 (See regulatory applicability worksheet far detailed analysis) 4 of 8 C:\Users\cdmoney\Documents\Package 423655\20WE0174.CP1 Separator Venting Emissions)nSent,ry Section 07-Initial and Periodic Sampling and Testing Requirements ,-Using Gas Throughput to Monitor Compliance 1 Does the company use site specific 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 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. eta y r Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? ' 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 affthis 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 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 initial and periodic compliance testing in accordance with PS Memo 20-02 17;2I1 l/y d/ I if;err .azr,a, U;e ' v r it keer I z 1 f ' '� s' f f,/i//o 'r n ", 1 1 , / l/ / .d .lu 00.:y 3,x3,/.r,s „U;,. ,"' ,a ,e, „ ,.+aa.:„°f,mss_ g o,�'lm:ovft*,,s,/— a,, ,4 Section 08-Technical Analysis Notes Noblemcruded a pas min pia of asnviarsap to Mow Yfi_r ydt.l rmssac care ecnsvirat.,_:fnes viz.gas senp-.,-,asvmslrbree,: ,rv' 3FAi_o a,9' and_v esl 12/1371G13. sd:npl..I-laie a love aud IitP,wen;-Man Me model.However,the source will std',fled to a'r an mi,fiai s re'specific sample In ensure the einissn,actors are appropriate. Noble also u,ed an older O&M plan that does not mcluce-a thrshol5sfoiserus:-„ ..However sane facility wide_missicnc are Lela, tpy.tl.e ca_r n. vria e_ O&M Plan- Section 09-SCC Coding and Emissions Factors(For Inventory Use Onlyl AIRS Point# Process It SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 001 01 a.5.0 :Mar.,. PM10 PM2.5 500 _. 0 lb/Nos�a:. NOx -. 0 lb/MN�SCr VOC -932733.0 95 Ib/MMSC€ CO 772.9 0 Haft/Ili/15U Benzene 5557.3 95 Ib/MI1:3SCf Toluene 463.1 95 lb/PatM5CF Ethylbenzene 3>5.0 95 Ib/MMSCP Xylene 196.8 95 lb/N1MSCF n-Hexane 33111,2 95 lb/MM5CF 224 TMP 524.2 95 •lb/MMSCP • 5 of 8 C:\Users\cdmoney\Documents\Package 423655\20WE0174.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Raeulletioa 3 Parts A and O-APEN and Permit Requirements Four.,5i he Nonn,ittainrnent 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,Non greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.31? Y you have ind€catod that source 3s:r.the 1Onw1t5u55v0nt Ai ea NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section Il.D.l.a)7 Yes n Source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2 TRY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.21? le_ Source Re nourc>:equates x permit Colorado Regulation 7,Part D,Section R 1. Was the well newly constructed,hydraulically fractured,orrecompleted on or after August 1,20147 YCOMMISource is: Innurce i-noble noblest to RegutaIinn 7,nart O,5551105 Section 11.8.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section 11 Section n.F-Control of emissions from well production Reclines Alternative Emissions Control(Optional Section( a. Is this separator controlled by a back-up or alternate combustion device tine.,not the primary control device)that Is not enclosed? er:5s'. The contra (The _tl,:_ 544.ratOr is not suhlacn to Rags amain`Pant Sa.e'en Section II.B.2.e—Aternative 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 note Rile 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 anyother 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 deserts 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 et-itself _. Fugitive E>,unions Inventory Semen 01-Aamtnslratbe Information 'Facility Allis ID: Co Poor,my Plant Semen 02-Equipment Oescripdon Dedih Detailed Emissions Unit Fugitive emission component leaks from compel associated with an errand gas -- Description: exploration and production facility Emssion Caniroi Device Description. Section 03-Processing Pate Information for Emissions Estimates Thts session is not appacabietn fugitive& • session 04.Emissions Factors&Methodologies Regulationuura:rmaGan pealing Hours: 8760 hoursryear Emssun Factor Source Scr ng EFs EPA433/R-95-017 Table24:. Control Enclnov Source .3, NonaSee Section 07 notes 1,2,63 for additional inssmallon Calculations Emission Factor(kg11- Service Component Type Count • source) I Control(%)Pollutant Mass Frac.O. Uncontrolled controlled Table 24 Table 24 Emissions(ipy) Emissions Itpy) GAS Conn.ors .11.590.0.,, 2.00E-04 1.00E-05 0.0% VOC 40.00% - 2.20E-05Ibnrrlswrce 0.100 . Flanges a 762 90E-04 5.70E-06 00% Benzene 0.1000% 1.26E-05 1Nhrhource 0.451 Open-Ended Lines fi 200E-03 1.50E'0 % Toluene 0.05% - .. 3.31E-05 1Nhr/source Pump Seals4.„,-, 2,40E-03 3.50E-04 0.0% Elhylbenzone .0.050% _ 7.72E-04 INhr/souroe Gas Feller valves include 5, Valves el?-234‘ece 450E-03 2.50E-05 00% Xylenes 0.06% 5.51E-05 lb/hr/sourss compresses seals) ON, ,L$3431.3" 0 0E-03 1.30E-04 0.0% nHexane 0.50% - 2,65E-04...our. RelielValvea pY8.80043 1.20E-04 0.0% 2,2,4-TMP 0060% 3113.10019, 2.65E-04 03/hr/source — — — — — Methanol — — — — — H2S — — — — Methyl Marmp,am ! 6 0 2,50E-00 7.50406 00% VOC 10000% -. • Flanges 03. 3.90E-07 390E-07 00% Benzene 0.26% Open-Ended Lines 1.40E-04 7,20E-06 00% Toluene 0.13% - TOTAL Pumps.Is 3,033.....3333reC.L.Al 0.000400 000E+00 00% Elhylben.ne 0.13% - 0.333 Heavy Oll Valves - 3.400436 040046 00% XYlenes 0.13% 0.604 Other :12.3...0—.L... 3.20E-05 .20E-05 00% nHexene 1.26% Relit:Walves — — — — 2,2,4-TMP 0.13% — _ — — Methanol 0.00% — — -- — --- H23 0.00% - — — — Methyl Mecca.. 0.00% LIQUID Conner gtg0M. 210E-04 9.70E-06 00% VOC 100.00% 2.14E-051berds0urce 0.153 Flanges r 1.10E-04 240E-06 00% Benzene 02500% 529E-06 INhr/source 0.153 Open£dad Lines 34333474i 1,40403 1.40E-05 0.0% Toluene 0.13% - - 309E-05 lb./source Pump Seals 3.433-17( 1.30042 510E-04 0.0% ElhOsenzene 0.130% - 1.12E-03 1041/snrce Lig.Oil Valves e'4B_ 250E-03 1.90E-05 0.0% Xylenes 0.13% - 047 419E-05 Ib/hr/source Other sty'{ 7,50E-03 1.10E-04 0.0% n Hexane 1.25% 0.00411, 2.43E-04 Rehr/source Relief Valves 750E-03 1.10E-04 0.0% 224TMP 0.13% - 0 006,1 31 2.43E-041h/hr/source — — — — — Methanol 0.00% — — — — — 9120 000% ._ — — — Methyl Mercaplar 0.00% Connectors- `!71 1.10E-04 1.00E-05 0.0% VOC 10070% - - Flanges `Let �I.-2.90E-05 2.90E-05 0.0% Benzene 0.260 Open...L SS ^2"" 2.50E-04 3.50E46 DA% Toluene :M39/3 Pump seals a� 2.40E-05 2.40E-05 04% Elhylbemmne 0.130% ware,,,, Valves ss332.33.4 9.80E-05 9.70E-06 00% Xylenes 0.13% Other '33331403;33, 1.40042 5.90E-05 0.0% n-Hexane Reli4Valves — — — — 2,2,4-TMP 0.13% — — — — — Methanol — — — — — H2S 0 _- — — _ ... Methyl MercaPtar:: 0 .. , Semen U5-Emissions Inventory Did opera.request a buffer? .z€ b. Lee Requested Buller(%1 Pollutant Uncontrolled Emissions Controlled Emssions Spume VOCScreening EFs-EPR453/R-95-017 Table 24 297 TPY Benzene --Ibryr INyr Screening EFs-EPR453/R-95-017 Table 2-8 436773 00043677 Toluene '(Nr I13. Screening EFs-EP/4453FR-97017 Table 24 000022317 00022317 Etssihen7.e a(Wu a IGNr Screening EFs-EPR463/R-954117 Table 24 0.0022317 0.0022317 Aden. t lb/yr 4 Ib/r Screening=Fs-EPR453/R45-017 Table 24 0.0022317 0.0022317 n-Herne lb%or et'b/yr •, Screening EFs-EPR453/R-95417 Table24 002183063 0.0214306 2,2,4-TMP - 4 bNr 1 lh/yr Screening EFs-EPR453/R-95-017 Tabie2-0 02022317 0.0022317 Methanol 401 lb/vr lb/yr Screening EFs-0PR453/R-95-017 Table 2-9 0 0 H25 4 G IbNr INyr Scr.ning EFs-EP/f453/R-05-017 Table 2-8 0 0 Methyl MercauMn DU lb/yr 1 lb/yr Screening EFs-EPR453IR-95-017 Table 24 0 0 Section.-6 elate Summa Ana s,z Reg.3 Review Regulation 3,Part B,Se0ion IlI.0.2 to delermmets RACT Is required? 3333Yea Reg.6 Reiiaw40 CFR,Part 60,Subpart KKK to determine rf applicable to this source? -Nip Review43 CFR,Part 60,Subpad 0000/delemine if Grimm and/or 5053851s applicable? ,a.,NP J-Subjeol to SOPS 0000a Re%7 Review section%VI.E.Eelemnes LEAR l6 appEwb,e? Add01ana1 Regulatory Considerations t-Except as provided in paragraphs 2 through 6 below,no comm or operas.-of source042r allow.- cause the into thealmosphare d any a bpo5N50000 lch is in 1cess of 20%o l3ronThis standard is 8352,,0001bas.on cennsnuln a opacity readhg6 taken et l5-second Intervals for six minutes.The epprwecl refers ll lest method for rvisibe emissions measurement Is l EPA Method 9(40 CFR,Pal 60,Append.A(July,1992))in all ....lions of Section II.A and B of this regulation. ' • Section IA-No person,wherever located,shall cause or allow the emission of morousair contaminants from any singlesource such a to result in delecleble odors which are measured in excess of the 10200ing Emits:For areas Regulafion2 used predominantly for reddenllal or commercial...pages it is a violation 0 odors are detected after the odorous air has been diluted with seen(7)or more volumes clod.-free air. Part A-APEN Requirements Criteria Pollutants:For criteria pollutants,Air Pollute,Emission Notices are required forsach Individual emission point in a nonahainmenl arewio uncontrolled acte emissions of one ion per year or roared any Individual criteria pollutant(p000rseta are not summed)for which the area Is non-ana-omae. Applicant Is required to file an APEN since emissions exceed 1 ton per year VOC Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than Me 2TPP threshold(003.9,Part l3) is this source located in an uncle nonunammnt area or attainment maintenance area? Ye. H yes,isthis source subject to leak 431ech01 n0 repair(LDAR)requirements per Regul3on 7,Section'NILE Regulation 3 XII.G or 40 CFR,Pad 60,Subparts 040 0000,orO000a? ES , '7 Part B,01.112-RACT requirements far new or mod0led minor sources This section al Regulation 3 requires RACT for new or modified minor sources lomted In nonatminment or athinment/maintenance areas.This source is Imam,in the 0-hour ozone mnattalnment area. The date of interest for dehfmining whether ihesource is new or modified Is theregore November 20,2007 (the date of the 0-810.81 ozone NA area designation).Since the fugttlyes will be in service after the date above,this source is considered"new or modified." - This facility is subject to NSP.00005 as well as Regulation 7,Section XVII.F.Following Me leak detection and repair program per Reg 7 sa5sifies the RACT requirements of Regulation 3.Tie permit will contain a cond.n reflecting this determination. • Fugizv Emissions'-n0=ntory is1M1is source el en onshore"natural gas processing plant"as defined In 40 CFR.Pad 60 631? "' " •. Did This source commences construction,reconstruction,or modification afterJanuary 20.1984.and on or before August 23,20111 This source Is not subject to NSPS KKK because the new equipment covered by thlsfugltive source Will commence construction after August 23 2n11 and Is not located at a natural gas processing N.V.... plantlsee technical analysis notes? • Did lisle source commences construction,reconstruction,or=Met,.alter August 23,2011 and on or befre "dam,r', September M.., - N Source M not subjectto NSPS 0000 because the new equipment covered by thisfuglave source will commence construction after September IS,2016. • Is this source located in an ozone non-attainment area or attainment maintenance areal is this seurce al an onshore"natural gas processing plant"as defined in 40 CFR,Pad 60.631? _ - Facility is not classified as a natural gas processing plant.Therefore,this source is not subject to Ronnie o,T RegulsIoh 7 Section MSG. Is the facility ctassi06d as await produW'ontacg8y or natural gasmmpressof station? Since this facility is classified as a well production facility,itis subject to Regulation 7 Section■0117. M this some at a ylatoml gas processing plant'as defined in 40 CFR Pan 63.761? .g5gflerW."� '�14 Is this facility considered e°mail),sour,of HAP as specifically dented In 40 CFR,Part 63.761 for sites that are r, , 0^J...Ion field facilities? }f '» Regulation 8 If you rep0nd?pelts both questions above,further review d the provisions of 40 CFR,P0163.760'Equipment Leek Standards'apply? Source Is not subject to MALT HH because the facility is classified as a synthetic minor source of HAPs. Did thins0urce commence construction reconsloollon or modification after September 18.2015? Ye !stills source al a well site compressor station or 06000,0"natural gas processing plant"as defined to 40 CFR Part 60.5430a? NSPS OOGOa Yes This facility meets the definition of well production facilityas donned by 40 CFR,Part 00.64600. Therefore,the 10310ve emissions at this facility are subject to NSPS 0000a. Section nl-Technical Analysis Notes The component counts are estbaudimated bd on engineering judgment.The gas compos tion s based on a sander sites and adiusted to be conservative(gas samplohon,Hddey H26-11A Econode,sampled e/13/2019).Asa result Me permit will contain an initial compliance test motoring that an actual hard count of components and an tni6al emended gas analysis.. As discussed above,this sow...Meat to WM 00003.However,Ibis NSPS has not yet been adopted,nto Colorado Regulation 5.Asaretrit,the conditmn referencing 11015 00003viiitbe addressed in the notes to rmt holder section of the per nit: The Many an ESP see ruhiect to Peculation',Section XVIIF as well es NSPS 0000a. Source is sing emission lactrsfrom table B(weenies factors)Nora EPA document Protocol for Equipment leak Emusmn Estimates.This ppopnato since components w lI be ored In accordance with Section XVIMNAP SeWlon Oft-Inventory SCCCodfng and Emissions Factors Uncontrolled AIRS Point,' Process# SCCCade Pollutant Emissions Factor Control% Source A } Vn Varies by Vanes by component 002 62 + �-,,,,. -;},-•gi J q,�y.,, k VO[ omperen 411e type Screening EFs-F11,03/R-95L17Tab1e2A c Varies by Varies by component Benzene c oMPonent type type Screening EFs-EPAA53/3-95-6I?Table 28 Varies by Varies by component Toluene component type type Screening EFs-EPA-453/1-95-01?Table 28 Varies by Varies by component EMylbemene component type type Screening EFs EPAA53/R-95-01?Table 2-8 Varies by Varies by component gylene component type type 5c 8 Screening EFs-EPA453/P-95-01?Table2 Varies by Varies by component n-Hexane component type type sic reening EFs-EPAA53/P-95-01?Table 2-e Varies by Varies by component 224TMP component type type Screening EFs-EPAA53/0-65-011 Table t-3 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy Inc. County AIRS ID 123 History File Edit Date 612412020 • Plant AIRS ID A0C6 Ozone Status Non-Attainment Facility Name DP115 A34-14 ECO REVEILLE Last Modified By: Carissa Money EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 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 New Facility-No Previous Total Previous Permitted Facilit total 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 0.0 001 20WE0174 Gas Venting 0.3 135.4 1.2 7.4 0.3 6.8 1.2 0.4 New paint 002 20WE0174 Fugitive Component Leaks 1.7 0.0 1.7 0.0 New point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 HP Heaters(13) 0.3 0.3 4.3 0.2 3.6 0.1 0.3 0.3 4.3 0.2 3.6 0.1 From Form APCD-102 0.0 0.0 _ 0.0 0.0 0.0 0.0 • FACILITY TOTAL 0.3 0.3 0.0 0.0 4.6 135.6 1.7 4.8 7.5 ' 0.3 0.3 0.0 0.0 4.6 7.0 1.7 4.8 0.5 VOC: Syn Minor(NANSR and OP) NOx:True Minor(NANSR and OP) CO: True Minor(OP and PSD) HAPS: True Minor Permitted Facility Total 0.0_ 0,0 0.0 0.0 0.3 135.4 1.7 1.2 7.4 0.0 0.0 0.0 0.0 0.3 6.8 1,7 1.2 0.4 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.0 0,0 0.0 0.0 0.3 6.8 1.7 1.2 Pubcom required for new syn minor limits Total VOC Facility Emissions(point and fugitive) 8.7 Facility is eligible far GP02 because<45 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 8.5 Project emissions less than 25 tpy Note 1 Note 2 Page 1 of 2 Printed 0/24/202(1 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-I-IAPs Company Name Noble Energy Inc. County AIRS ID 123 Plant AIRS ID ADC6 Facility Name DP115 A34-14 ECO REVEILLE Emissions-uncontrolled(lbs per year) POINTIPERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0174 Gas Venting 1698 1383 993 627 9060 967 7.4 002 20WE0174 Fugitive Component Leaks 9 4 4 4 44 4 0.0 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 HP Heaters(13) 154 0.1 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 0.9 0.7 0.5 0.3 4.6 0.0 0.5 0.0 0.0 7.5 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls(lbs per year) POINT'PERMIT (Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy) !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0174 Gas Venting 85 69 50 31 454 48 0.4 002 20WE0174 Fugitive Component Leaks 9 4 4 4 44 4 0.0 _ 0.0 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 HP Heaters(13) 154 0.1 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.5 2 123A0C6 6/24/2020 7.0 DEC t ; Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and G°P"E 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 will require re-submittal. Your APEN 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 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. 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: 20 Iota i 7y= AIRS ID Number: l 23 /A / 6O j Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: DP115 A34-14 ECO REVEILLE Site Location Site Location: SESW SEC34 T6N R64W Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadwa Suite 2200 (Include Zip Code) y� Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@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. 423652 > ® COLORADO egrcment el PUCK Heal.trEow,conmemt Permit Number: AIRS ID Number: 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 O Add point to existing permit ❑ Change permit limit O Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El 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: Gas venting for flash gas from knock out tanks, scrubbers and other miscellaneous equipment onsite Company equipment Identification No. (optional): Condensate Knockout Burners For existing sources, operation began on: N/A For new, modified, or reconstructed sources, the projected start-up date is: 12/31/2020 ❑� 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 weeks/year Will this equipment be operated in any NAAQS 0 Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is O Yes El No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, El Yes O No Section XVII.G? COLORA00 2 1 o ndu.° Permit Number: AIRS ID Number: Section 4 - Process Equipment Information El Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: 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? 0 Yes 0 No Vent Gas Gas Venting Heating Value: 2461 BTU/SCF Process Parameters: Requested: 3.00 MMSCF/year Actual: N/A MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters 5: Molecular Weight: 43.88 VOC (Weight%) 77.6292% Benzene (Weight%) 0.4879% Vented Gas Toluene(Weight%) 0.3975% Properties: Ethylbenzene(Weight%) 0.2854% Xylene(Weight%) 0.1802% n-Hexane(Weight%) 2.6041% 2,2,4-Trimethylpentane(Weight%) 0.2778% Additional Required Documentation: Q Attach a representative gas analysis(including BTEX&n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX&n-Hexane, temperature, and r pressure) 5 Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. COLORADO oey.av�,a se,K Permit Number: AIRS ID Number: Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.43701,-104.54033 ❑� Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator Temp. Flow Rate Velocity Above Ground Levet Stack ID No. ('F) (ACFM) (ft/sec) (Feet) Condensate Knockout 25.25 Variable Variable Variable Indicate the direction of the stack outlet: (check one) El Upward ❑ Downward O Upward with obstructing raincap o Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth(inches): O Other(describe): 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. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: 3.68 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: LEED EC48 ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2461 Btu/scf Constant Pilot Light: Q Yes ❑ No Pilot burner Rating: 0.0208 MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: % COLORADO Permit Number: AIRS ID Number: / / Section 7- Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No • If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SOx NO. CO VOC Enclosed Combustor(s) 100% 95% HAPs Enclosed Combustor(s) 100% 95% Other: From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM 0.9051 lb/MMscf AP-42 0.00 0.00 0.00 SOx .0O715 lb/MMscf AP-42 0.00 0.00 0.00 NO„ 179.2866 Ib/MMscf AP-42 0.27 0.27 0,27 CO 773.0466 Ib/MMscf AP-42 1.16 1.16 1.16 VOC 90,207.2960 lb/MMscf HYSYS/AP-42 6.75 135.52 6.75 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Q Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 564.9820 lb/MMscf HYSYS/AP-42 1,698 85 Toluene 108883 460.2485 lb/MMscf HYSYS/AP.42 1,383 69 Ethylbenzene 100414 330.5030 Ib/MMscf HYSYS/AP-42 993 50 Xylene 1330207 208.6947 lb/MMscf HYSYS/AP-42 627 31 n-Hexane 110543 3,015.2773 lb/MMscf HYSYS/AP-42 9,060 454 2,2,4-Trimethylpentane 540841 321.6711 lb/MMscf HYSYS/AP-42 967 48 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. ® COLORADO - 5jK Permit Number: AIRS ID Number: / / Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 12/20/2019 Sig Lure of Legally Aut orized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: J 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: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692-3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment ifik a* COLORA00 E nr :.er U6Gne -, 0O °` Fugitive Component Leak Emissions APEN CForm APCD-203 CDPHE 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 lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for fugitive component leak emissions only. If your emission source 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. 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: 24 l\T P7q AIRS ID Number: (23 /AVL/t(1Z., Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: DP115 A34-14 ECO REVEILLE Site Location: SESW SEC34 T6N R64W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Address:(Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessasalgado@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. 423653 COLORADO De{um COLOR A,urc 1 N¢.1,6 Grttc'.ne.n Permit Number: AIRS ID Number: Section 2 - Requested Action 0 NEW permit OR newly-reported emission source(check one below) -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change process or equipment O Change company name3 O Add point to existing permit O 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- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info 8 Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-10(5)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 Company equipment Identification No. (optional): Fugitives For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: 12/31/2020 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: hours/day days/week weeks/year Facility Types: 0 Well Production Facility ❑ Natural Gas Compressor Station ❑ Natural Gas Processing Plant O Other(describe): 5 When selecting the facility type,refer to definitions in Colorado Regulation No. 7,Section XVII. COLORADO i4rvNh 6Fnmm�mm Permit Number: AIRS ID Number: Section 4- Regulatory Information What is the date that the equipment commenced construction? 02/01/2020 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Will this equipment be located at a stationary source that is considered a ❑Yes No Major Source of Hazardous Air Pollutant(HAP)emissions? Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes ❑No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? 0 Yes ❑✓ No Is this equipment subject to 40 CFR Part 60, Subpart 0000? ❑Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart 0000a? 0 Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? 0 Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑ Yes El No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? 0 Yes ❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? 0 Yes O No Section 5 - Stream Constituents 0 The required representative gas and liquid extended analysis(including BTEX)to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight%content of each applicable stream. 2,2,4 VOC Benzene Toluene Ethylbenzene Xylene n-Hexane Stream Trimethylpentane (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Gas 40.00 0.10 0.05 0.05 0.05 0.50 0.05 Heavy Oil (or Heavy Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13 Light Oil (or Light Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13 Water/Oil 100 0.25 0.13 0.13 0.13 1.25 0.13 Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.43701, -104.54033 Attach a topographic site map showing location COLORADO ,. 3 DeP+Knxetd Mil!.e Permit Number: AIRS ID Number: Section 7- Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK 0 Monthly Monitoring- Control: 88%gas valve, 76%light liquid valve, 68%light liquid pump ❑Quarterly Monitoring- Control: 70%gas valve, 61% light liquid valve, 45% light liquid pump LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa 0 Monthly Monitoring- Control: 96%gas valve, 95%light liquid valve, 88%light liquid pump, 81% connectors Q LDAR per Colorado Regulation No. 7, Section XVII.F ❑Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. heitte COLORADO 4 H bCn anemP Permit Number: AIRS ID Number: Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑Table 2-4 was used to estimate emissions7. Table 2-8(< 10,000ppmv)was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑Q Estimated Component Count ❑Actual Component Count conducted on the following date: Equipment Type Service Open-Ended 9 Connectors Flanges Lines Pump Seals Valves Other Gas Count8 5,922 752 6 2,434 668 Emission Factor 1.00E-5 5.70E-6 1.5E-5 2.50E-5 1.20E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Heavy Oil(or Heavy Liquid) Count8 588 196 Emission Factor 7.50E-6 8.40E-6 Units kg/hr/source kg/hr/source Light Oil(or Light Liquid) Count8 1,938 348 4 1,806 122 Emission Factor 9,70E-6 2.4E-6 5.10E-4 1.90E-5 1.10E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Water/Oil Count8 1,148 28 392 140 Emission Factor 1.00E-5 2.90E-6 9.70E-6 5.90E-5 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the actual calendar year emissions below. 9 The"Other"equipment type should be applied for any equipment other than connectors,flanges,open-ended lines,pump seals,or valves. COLORADO 5 Mk Permit Number: AIRS ID Number: / / Section 9 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? 'V/~ Use the following table to report the criteria pollutant emissions from source: CAS Actual Annual Emissions Requested Annual Limit Limit(s)1° PermitEmission ( )10 Pollutant Number Uncontrolled Controlled" Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) voC 1.75 1.75 1.37 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 10 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes / No pollutants(e.g. HAP - hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Actual Annual Emissions Requested Annual Permit Chemical Name CAS Emission Limit(s)t°Number Uncontrolled Controlled11 Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4-Trimethylpentane 540841 Other: 10 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO ;=, Permit Number: AIRS ID Number: / / Section 11 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 6Yl(lR RA Salo 12/20/2019 Sig ature 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 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: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 APCD-SS-B1 OR 43OO Cherry Creek Drive South (303)692-3148 Denver, CO 8O246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment COLORADO 7 . flea. Env, � .• � - � NealubLnRrmrtaN Hello