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Home My WebLink About20200882.tiffCOLORADO Department of Public Health Er Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 February 24, 2020 Dear Sir or Madam: RECEIVED MAR 0 5 2020 WELD COUNTY COMMISSIONERS On February 25, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy Inc. - ROHN STATE LD04 ECONODE T9N-R58W-S4 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 Et 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 Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pub1:C Rev:ec.J 03/1812.0 Cc : PL(TP)HL-4.10, PcJ((n/ER /c H /cif ), 060A) 03/12, /2r> 2020-0882 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy Inc. - ROHN STATE LD04 ECONODE T9N-R58W-S4 L01 - Weld County Notice Period Begins: February 25, 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: ROHN STATE LD04 ECONODE T9N-R58W-S4 L01 Exploration Et Production Well Pad NESE S4 T9N R58W Weld County The proposed project or activity is as follows: This facility has a gas stream from a Vapor Recovery Tower (VRT) which requires a permit. The facility is located in the attainment area and is a synthetic minor facility for VOC, NOx, CO, n -hexane, and total HAPs. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE1017 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: Lauraleigh Lakocy 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 PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE1017 Issuance: 1 Date issued: Issued to: Noble Energy Inc. Facility Name: ROHN STATE LD04 ECONODE T9N-R58W-S4 L01 Plant AIRS ID: 123/9C84 Physical Location: NESE Section 4 T9N R58W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description. Emissions Control Description VRT 021 Vapor Recovery Tower (VRT) 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 this specific general terms and lconditions, included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days 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. 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 III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NONO),VOC CO VRT 021 - --- 16.1 2.2 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 Page 2 of 10 COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) Equipment ID AIRS Point Control Device Pollutants Controlled VRT 021 Emissions from the VRT are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime 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 Equipment ID AIRS Point Process Parameter Annual Limit VRT 021 Natural Gas Venting 4.48 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. 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 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 11. 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) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 13. 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 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, 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 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. 14. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. (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 Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recentoperating and maintenance (O£tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O£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 16. 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 this emissions unit 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 Page 4 of 10 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" 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. 17. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Part D, Section II.B.2. and II.A.23) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30 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 NO,t 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 Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 20. 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 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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.; 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 Page 6 of 10 a'Ml�SN vto COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy Inc. Page 7 of 10 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 sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT 021 Benzene 71432 2,170 109 Toluene 108883 2,040 102 Ethylbenzene 100414 285 14 Xylenes 1330207 1,090 55 n -Hexane 110543 19,723 987 2,2,4- Trimethylpentane 540841 2,337 117 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 230.96 230.96 AP -42, Chapter 13.5 CO 992.37 992.37 VOC 143,428.8 7,172.3 ProMax simulation based on site - 71432 Benzene 483.9 24.20 108883 Toluene 454.8 22.74 100414 Ethylbenzene 63.65 3.18 1330207 Xylene 243.1 12.16 specific sampling taken 10/29/2015 110543 n -Hexane 4,398.1 220.2 540841 2,2,4 Trimethylpentane 521.1 26.06 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 separator temperature of 100°F and separator pressure of 16.122 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 emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, and Total HAPs PSD Synthetic Minor Source of: VOC, NOx 8) 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 Page 9 of 10 aM!y!M vt., COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 10 of 10 Coiorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Laaaaligfttai�acy.. Package#: 421 01 � i�<• ;Received Date: :15/28/201 Review Start Date: 2/6/2O2Q Section 01-Facility Information Company Name: Noble Ehergy Quadrant Section Township Range County AIRS ID: ,NESW :-"4 -"--4N ', Plant AIRS ID: Facility Name: R0HN STATE L004.EC:ORME N-NSS U 4iLD1 , - Physical Address/Location: NESW quadrant of Section 4,Township RN,Range 58W County: WeidCounty Type of Facility: !„.Weld aucti � What industry se ment?Oil&Ngr LP:EI:�;cr1 exsis g I'°a g � .,.,,, tea, Is this facility located in a NAAQS non-attainment area? "No If yes,for what pollutant? , Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit 7t AIRS Point ffi 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) ., .. Ermitleittal .,,.PSepa Trig' , V&"li a gtream... Yes 1NWETOS7 1 Yes issuance Section 03-Description of Project Upon an evalu2 6t NotteEnergy r ( . � e VRTsfr ode gas to an enclosed combustion device requires a permit The.Source began , Operators 1213/2013-..- t This sout`ee is located i i the sttainmentarea*nr ! it ietic mltTorf Q Cn€ lIex ape and total HAPs f/ �� ' r Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Ye „_ Min If yes,why? Pye�tj„�Nb,��`CheTr�h+tin�sr Pernsrt Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Nd... 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? Is this stationary source a synthetic minor? Yes w: If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) J -/ -/ © ❑J Non-Attainment New Source Review(NANSR) Is this stationary source a major source? 30 If yes,indicate programs and which pollutants: 5O2 NOx CO_VOC PM2.5 PM10 TSP HAPs • itle VPrevention Operating a iSng rt Deterioration(PSD) _ ❑ El Title V Operating Permits(OP) L�-I IN—I Non-Attainment New Source Review(NANSR) Separator Venting Emissions Inventory Section 01-Administrative Information Facility Allis ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description: d Enc#sued CofnhU tiuluE1duaou _ --, ",": f��'.. Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: 95 Limited Process ParameterRidiSAME ±±YY Gas meter "x541. Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput=,,, ,r,.,.,,.,...' ..�. 'V! MMscf per year Requested Permit Limit Throughput= MMscf per year Requested MonthlyThroughput= 0.4 MMscf per month Potential to Emit(PTE)Throughput= 4,5 MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: Btu/scf Volume of waste gas emitted per BBL of f ,„/� liquids throughput: .. h.,9, scf/bbl f Control Device Pilot Fuel Use Rate: 4 lSR4433533.1 seth 0.0 MMscf/yr Pilot Fuel Gas Heating Value: ,. h,.YP17I'.Btu/scf rn,ateiNo Section 04-Emissions Factors&Methodologies Description the source l(ected sacs specif?c sumtslesfram the 2-htgh pressure separator oar Ys on saL. S26 and 2310 petThe source,ihe,mntractor uses!else 2 i0"samp2 f tithe model us'this represented the nuwplethatsvuu moat`, folly gturatest This maybe under esbmating the airns53bhs=uhab)e to Yest 7ntePnaIly;Is w y r because tin saurca acing has tl 0 Sliput theywi33 ba:require4 En C Se an isdh`at sample to dsmonst ote coonplbance nth ttfe,l MW .S.a;3 lbJlb-mol Displacement Equa5oe Ex=Q*MIN*Xx/C Weight% Helium CO2 N2 G methane 0:2 ethane 5,22 propane isobutane "�f 'Rd n-butane isopentane n-pentane 44 cydopentane _.., 4,2 n-Hexane .-5,12 cyclohexane Other hexanes .-�40 heptanes ,5,1' methylcyclohexane 224-TMP y, Benzene ,?- Ltd Toluenez4,31 Ethylbenzeee Xylenes CB+Heavies Total 14:0.2 VOCWt% St-s 2 of 8 K:\PA\2019\19WE1017.CP1 Separator Venting Emissions inventory EMMENZSEEM Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) 483.6551 ® 3.1808 242.9660 rmIstimemazsm 219.7589 Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) 0,0075 m:4*-41Tabfe i4 2',( r'1:---,::;' 00075 AP-42Tabiel., ' .. MIMINEIMII 0.0006 ss zr L f AP,442£a53 b • 0.0680 §ZEIMMIllr,g4iii r � e -.�' 1 ` 0.3100 Crf:'. s®.f -CS.' t _ l Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) 04075 .-Y`lubfel4€-2{: IIMMZEI 0.0075 t AP 4ZT`8tao1.4-2;x'4 0.0006 : `sWfj 4.0600 68.0000 , 0 i - , -,0.3100 310,0000 1�4✓�, 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) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0.1 0,0 11.0 0.1 0,1 0 PM2.5 0.1. 11.0 0.0 0.1 0.1 9 SOx 0.0 0.0 3.0 0.0 0.0 1 NOx 0.5 0.0 0.0 0.5 0.5 82 VOC 321,1 0,0 0,0 321.1 16.1 2727 CO 0.0 0.3 0.0 2.2 3.2 ' 372 Potential to Emit Actual Emissions Requested Permit Limits , Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) pbs/year) (lbs/year) (Ibs/year) (Ibs/year) Benzene 2167 0 0 2167 108 Toluene 2036 0 0 2036 102 Ethylhenzene 285 0 0 285 14 Xylene 1000 0 0 1066 54 n-Hexane 19090 0 0 19090 985, _224 TMP 2333 0 0 2333 117 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B • Source requires a permit Regulation 7,Section XVII.B,G Source is Subject to Regulation 7,Section XV11.8,7,G Regulation 7,Section XVII.B.2.e The control desire for this separator is not to Regulation 7,Section XV11,0.2.o (See regulatory applicability worksheet for detailed analysis) • • • • 3 of 8 . K:\PA\2019\19WE1017.CP1 • Separator Venting Emissions Inventory 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 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 may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a sitespecific as 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 greaterthan or equal to 90 tons per year? :y, 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 poin?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 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 95/6 for a flare or combustion device? If yes,the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 'Puu haen inlet V.; te4 above That the manitared}traces'yarameter is naturaI gas uented.The fol€owing quest;,enn�s/clo net:erive an answer. � 4 / �� 9G h ,%,,,:4 #0,41A,;,, r (-/ � i S� aY yet %'� 1 . /i .d 1. ,,,--7 46 / / Y'%l t x a. , / 9 %1/� r Section 08-Technical Analysis Notes Emission fo44cltsted m the noteotopermitholner(mcluding the controlled emission factors)represent those requested by the sovice.There are sam hghtdrffer n s,p srbly du for undtng comrenttans 6 �',c1, alA yf C Y i >a wed ,,/� T Thesionf.oxfactgr and ea)gb(at,tut pksepfed on the APEN forPMand Son are slightly different than those listed above however begausethey are poRh6jtit hie-base vs both calculation method"ologies sohls'i5r'. asifSaI di)t`erm s °,t4-agr nl t y H `' ' i a r a y ° f tom'` y r. ,.''.:.„..LW�° .tea¢, ..u/.zwuL„� '° ,,.a., n3,��r "N.,w..«u,5� ...e„�:acw 9.m'r�i.»,w.c�` - ..,�.3a�₹ aR,�"> wder S ection 09-Inventory SCC Coding and Emissions Factors AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control 0% Units 021 01 3-10-001-60 Flares PM30 23.5 0 ffi(MM5CF SCC coding withpilot PM2.5 23.5 0 fib/MMSCF emissions in lbs divic SOx 1.9 0 01/909.45C8 NOx 214.7 0 €b/mxiscF VOC 95 ibjMRt5CF 143343.2 CO 978.7 9 . ib)Mi SCF Benzene 483.7 95 ih(fiftstCF Toluene 454.6 95 lb/MMSCF Ethylbenzene 03.6 95 fb/P.iNfSCF Xylene 343,0 95 IbiMMSCF n-Hexane 4395.2 95 lb/MMiCP 224 TMP 579.0 95 lh/no sC:F • • 4 of 8 K:\PA\2019\19WES017.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. • [Colorado Re ulatlon Spares Aend B-APEN and Permit Requirements Souse is in the Attainment Arne ATTAINMENT I. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.0)7 ..I: Source Re 2. Are total facility uncontrolled VOCemissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,PartB,Section 11.0.3)7 Yvi ,A'Source Re 'Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,PartA,Section 11.0.1.0)7 2. 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)7 of Sun have Indicated that source 3s in the Attainment Area Colorado Regulation 7,Section XVII • 1. Was the well newly constructed,hydraulically fractured,or remmpleted on or after August 1,2014? %,1 Source rce is. 'Source is suhiest to Regaiation 7,Section XVR.0 2,G • Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Settles XVII.G-Emissions Control Alternative Emissions Control(Optional Section) a. Is this separator controlled by a backup or alternate combustion deuce(i.e,not the primary control device)that is not enclosed? Nfl 'The contra 'The control device;or?nu separator is ootsub)ect to Regulation 7,Section kltI.B.2.e Section XVI1.B.2.e—Altemative 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 fads 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 of non-mandatory language such as'recommend,"may,"'should,"and Man,"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. • • • • 0 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 2/20/2020 Plant AIRS ID 9C84 Ozone Status Attainment Facility Name Rohn State LD04 Econode T9N-R58W-S4L01 Last Modified By: Lauraleigh Lakocy • 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 VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 2.2 2.2 0.0 0.2 262.1 1,216.5 1.2 214.9 30.5 2.2 2.2 0.0 0.2 26.2 75.6 1.2 49.4 1.8 From Aug 2019 Previous Permitted Facility total 1.7 1.7 0.0 0.0 256.3 1,215.9 0.0 206.0 30.5 1.7 1.7 0.0 0.0 20.4 75.0 0.0 40.5 1.7 001 GP01 Thirty-six(36)Condensate Tanks with a total capacity of 910.0 11.6 39.0 0.6 Source converted to GP01,Approved Dec 2017, 27,000 bbl updated emissions front Form'102 002 14WE0501 Twelve(12)500 bbl and Two(2)60 bbl Produced Water 131.0 14.5 6.6 0.7 Tanks 003 14WED501 One(1)Truck Condensate Loadout operation 160.0 2.4 8.0 0.1 0.0 0.0 Point Cancelled-Cancellation request received :004 14WE0501 One(1)Natural Gas Venting from Separator 08/04/2015.Emissions are,below APEN reporting, - - thresholds. i 1.2 0.0 - '„ 1.2 "0'A. Point Cancelled-Cancellation request received 005 14W00501 Fugitive CoMpnrent Leaks 04/30/2015.Emissions are below APEN reporting - thresholds:. 006 14WE0501 Caterpillar G35166 RICO(StC:JEFD2156). •, 0A 0.0'. Cancelled 911112019:No Longer Exists 007 :14W00501 Caterpillar/236168 RICE(SINE JEF02168) - 0.0 0.0 Cancelled 8/20/2019,No Longer Exists 0.0 0.0 Point Cancelled-Cancellation request received 008 14WE0501 .Caterpillar G3408TA RICE ' 05/19/2015.Source no longer exists at the facility.(SN:6N555118) 0.0 0,0 Point Cancelled Cancellation request received 009 14WE0501 Caterpillar G3408TA RICE 06/15/2015,Source no longer exists at the facility.(SN:6NB05120) 010 14WE0501 Gummins7.4L RICE , 0.0 0.0 Point Cancelled as of 01/2812016.(SN: ,• - _ '.. - :_005676751 011 • 14WE0501• Dooean 0140L RICE(SN:EEZ0G100147) 5.0 0.0.'Cancelled:12/06/2019 No Longer Exists 012 14W50551 Cummins OSB7G6 RICE(diesel-fired.274 hp 0.0 0:5 Cancelled 12/05/2018,No Lopoor Exists 0.0 0,0 Point Cancelled-Cancellation Request received 013 14W00551 RICE GM 7.4L 40R6(110HP): 08/24/2016.Source no longer exists at the facility.(SN:S0299021 0.0 0:0 -Point Cancelled-Cancellation request received 014 16WE0503,CN RICE Kubota DF972-E24SR824HP 09/01/2016.Source no longer:exists at the facility.(SN:5P0887) 0.0 0.0 Point Cancelled-Cancellation request received 015 16WE0504.CN RICE Kubota::0F672-E24SRB 24HP 09/01/2016.Spume no:longer exists at the facility.(SN:6C4494) 016 :GP02 RICE CAT G3304NA 4SRB(95HP)(SN;N4F01853) 0,0 ._ 0.0 Cancelled 4/25/2019,No Longer Exists 017 GP02 RICE Caterpillar G3304NA 4SRB(95HP) 0.1 0.1 12.0 0.7 12.0 0.1 0.1 0.1 2.6 D.7 4.4 0.1 (SN:N4F02570) 018 GP02 RICE Bucks 5,7L GM 4SRB 92HP 0.1 0.1 12.4 0.7 9.8 0.1 0.1 0.1 2.5 0.7 43 0.1 (ON:10CHMM405270096) 019 GP02 RICE Bucks 5.7L GM 4SRB 92HP 0.1 0.1 12.4 0.7 9.8 0.1 0.1 0.1 2.5 0.7 4.3 0.1 (SN:10CHMM410160039) 020 GP02 Waukesha 1900h0 L7044GSI S5 SN:5283705929 1.5 1.5 219.4 12.8 - 174.5 1.7 1.5 1.5 12.8 12.8 27.5 1.7 021 19WE1017 VRT Gas Stream Venting 0.1 0.1 0.5 321.6 2.2 13.8 0.1 0.1 0.5 16.1 2.2 0.7 Newly Requested Point - XA 5 MMatu/hr Heater Treater 2.8 0.2 2.3 0.0 2.8 0.2 2.3 0.0 APEN Exempt/Insignificant Source - XA Light Towers 0.2 0,9 1,1 5,5 0.2 0.9 1.1 0.0 APEN Exempt/Insignificant Source - XA Separator Heaters 0.1 0.1 1.3 0.1 1.1 0.0 0.1 0.1 1.3 0.1 1.1 0.0 APEN Exempt/Insignificant Source - XA VOC Burners 0.4 0.4 0.8 0.3 4.4 0.0 0.4 0.4 0.8 0.3 4.4 0.0 APEN Exempt/Insignificant Source FACILITY TOTAL 2.3 2.3 0.0 0.2 262.6 1,538.1 1.2 217.1 44.3 2.3 2.3 0.0 0.2 26.7 85.2 1.2 51.6 4.1 VOC:Syn Minor(PSD and OP) NOx:Syn Minor(OP and PSD) CO:Syn Minor(OP),True Minor(POD) HAPS:Syn Minor n-Hex&Total Permitted Facility Total 1.8 1.8 0.0 0.0 256.8 1,537.5 0.0 208.2 44.3 1.8 1.8 0.0 0.0 20.9 84.6 0.0 42.7 4.1 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.1 0.1 0.0 0.0 0.5 9.6 0.0 2.2 Public Comment is required for Point 021 because it is requesting a new synthetic minor limit. Total VOC Facility Emissions(point and fugitive) 86.4 Facility is eligible for GP02 because u 90 tpy (4)Change in Total Permitted VOC emissions(point and fugitive) 9.6 Project emissions less than 50 tpy Note 1 Note 2 Page 6 of B Printed 2/20/2020 COLORADO DEPARTMENT OFPOLLUTI PUBLICON HEALTHDIVISION AND ENVIRONMENT AIR FACILITY EMISSION SUMMARY-HAPs Company Name Noble Energy,Inc. County AIRS ID 123 Plant AIRS ID 9C84 Facility Name Rohn State LD04 Econode T9N-R58W-S4L01 Emissions-uncontrolled(lbs per year) POINTIPERMIT (Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Thirty-six(36)Condensate Tanks with 2711 1055 99 648 16866 1821 11.6 a total capacity of 27,000 bbl 002 14WE0501 Twelve(12)500 bbl and Two(2)SD 7000 22000 14.5 bbl Produced Water Tanks 003 14WE0501 One(1)Truck Condensate Loadout 473 184 17 136 4045 2.4 operation 004 141VE05A1 One(1)Natural Gas Venting from , Separator_ ,' 0 0 005 141WE0501 - Fugitive Component Leaks " 0 0 0006 114WE05D1 Caterpllar;G3516B RICE(SN 0 0 J,EF0216B) . 007 14WE0501 CaterpillarG3516B RICE(SN: 0.0 JEF02168) _ 008 14WE0501 Caterpillar G3408TA RICE 0.0 009 >;14WE0501 Caterpillar G3408TA RICE 0.0 010 14WE0501 Cummins 7.4L RICE 0 0 011: 14WED501 pposan D14EL,RIICE(SN: 0.0 012' 14WE0501=''' Cummins"OSBTGS RICE(diesel, 0.0 fired).-274 hp 013 14WE0501 RICE GM 7.4i 4SRB(11 OHP) 0.0 014 -16WEO503.CN RICE Kubota DF972-E2 4SRB 24HP " 0 0 015 16WE0504.CN RICE Kubota 1DF972-E2 4SRB 24HP, D,0 016 GP02` RICE GAT fl33D4NA 45R6(95HP) 0 0 (Silt N4F01653) 017 GPO; RICE Caterpillar G3304NA 4SRB 134.3 183 17.2 10.4 20 0.1 (95HP) 018 GP02 RICE Bucks 5.7L GM 4SRB 92HP 148,7 20.2 19.1 11.5 22.2 0.1 22.2 0.1 019 GP02 RICE Bucks 5.7L GM 4SRB 92HP 148.7 20.2 19.1 11.5 020 GP02 Waukesha 1900hp L7044GSI S5 SN: 1835 418 394 237 458 1.7 5283705929 2170 2040 285 1090 19723 2337 021 19WE1017 VRT Gas Stream Venting 13.8 - XA 5 MMBtu/hr Heater Treater 0.0 - XA Light Towers 1 1 1 0.0 - XA Separator Heaters 0.0 - XA VOC Burners 8 0.0 TOTAL(tpy) 1.1 0.2 0.2 6.3 1.6 0.2 0.9 31.3 0.3 2.1 0.0 0.0 44.3 "Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls(lbs per year) 7 19WE1017.CP1 2/20/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Noble Energy,Inc. County AIRS ID 123 Plant AIRS ID 9C84 Facility Name Rohn State LD04 Econode T9N-R58W-S4L01 POINTI PERMIT IDescription Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Thirty-six(36)Condensate Tanks with 136 53 5 33 844 92 0.6 a total capacity of 27,000 bbl 002 14WE0501 Twelve(12)500 bbl and Two(2)60 350 1100 0.7 bbl Produced Water Tanks 003 14WE0501 One(1)Truck Condensate Loadout 24 9 1 6 202 0.1 operation 004 14WE0501` One(1)Natural Gas Venting from 0.0 Separator 005 14WE0501 Fugitive Component Leaks 0.0 006 14WE0501 Caterpillar G35168 RICE(SN: 0.0 JEF_02156) 007 -.14WE0501' Caterpillar G3516B RICE(SN: 0.0 JEF02168) 008 14WE0501 Caterpillar G3408TA RICE 0,0 009 14WE0501 Caterpillar G3408TA'RICE 0,0, 010 14WE0501 Cummins 7.4L RICE' 0.0 011 14WE0501 Doosan O146L RICE(SN: 0.0 EEZDG100147) 012 14WE0501 Cummins QS8706 RICE(diesel- 0.0 fired),1274 hp 013 14WE0501 RICE GM 7.4L 4SRB(110HP) 0.0 014 16WE0503.CN RICE Kubota DF972-E2 4SRB 24HP' 0.0 015 16WE0504.CN RICE Kubota DF972-82 4SRB 24HP 0,0 O16 GP02 RICE CAT G3304NA4SRB(95HP) 0.0 (SN:N4F01853)'s 017 GP02 RICE Caterpillar G3304NA 4SRB 134.3 18.3 17.2 10.4 20 0.1 (95HP) 018 GP02 RICE Bucks 5.7L GM 4SRB 92HP 148.7 20.2 19.1 11.5 22.2 0.1 019 GP02 RICE Bucks 5.7L GM 4SRB 92HP 148.7 20.2 19.1 11.5 22.2 0.1 020 GP02 Waukesha 1900hp L7044GSI S5 SN: 1835 418 394 237 458 1.7 5283705929 021 19WE1017 VRT Gas Stream Venting 109 102 14 55 987 117 0.7 XA 5 MMBtu/hr Heater Treater 0.0 - XA Light Towers 1 1 1 0.0 - XA Separator Heaters 0.0 XA VOC Burners 8 0.0 0.0 TOTAL(tpy) 1.1 0.2 0.2 0.4 0.1 0.0 0.0 1.6 0.3 0.1 0.0 0.0 4.1 8 19WE1017.CP1 2/20/2020 ED ACT 282019. Gas Venting APEN — Form APCD-211 st�,iic�ts' ��€irces 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 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.govlcdphe/aocd. 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: AIRS ID Number: 123 /9C84 f 621 [Leave blank unless APCD has already assigned a permit (I and AIRS ID] Section 1 Administrative Information Company Name': Noble Energy Inc. Site Name: ROHN STATE LD04 ECONODE T9N-R58W-S4 LO1 Site Location: NESE SEC4 T9N R58W Mailing Address: 1625 Broadway, (include Zip Code) Suite 2200 Site Location County: Weld NAICS or SIC Code: 1311 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@nblenergy.com I 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. 4216 Form APCD-211 - Gas Venting APEN - Revision 3/2019 ._._. _.....___Altar C.0 ................... . 1 Permit. Number: AIRS ID Number: 123 /9C84/ [Leave blank unless APCD ;as already assigned a permit k 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 o 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 & 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: For new, modified, or reconstructed sources, the projected start-up date is: 12/3/2013 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 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 APCD-211 - Gas Venting APEN - Revision 3/2019 days/week weeks/year ❑ Yes ❑✓ No ❑ ' Yes ❑✓ No ❑✓ Yes O No COLORADO 2 1 Ay ,m:,�.. Pao.Ms..t. fi. Permit Number: AIRS ID Number: 123 /9C84/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ 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? ❑✓ Yes Gas Venting Process Parameterss: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 3 i 57 BTU/SCF Requested: 4.48 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 56.3290 VOC (Weight %) 96.45% Benzene (Weight %) 0.33% Toluene (Weight %) 0.31% Ethylbenzene (Weight %) 0.04% Xylene (Weight %) 0.17% n -Hexane (Weight %) 2.96% 2,2,4-Trimethylpentane (Weight %) 0.35% Additional Required Information: ❑ Attach a representative gas analysis (including BTEX it n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 31 Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO Permit Number: AIRS ID Number: 123 19084/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latituclettori&itude or'UTM) 40.777, -103.8615 t?pert€r ;�' Stack iD No,y��cf Discharge ti4 Level i/ % f �� Flow l e f & old Indicate the direction of the stack outlet: (check one) QQ Upward O Horizontal O Downward Other (describe): Indicate the stack opening and size: (check one) Q Circular O Other (describe): Interior stack diameter (inches): Ei Upward with obstructing raincap Section 6 - Control Device Information El 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:. Type: Enclosed Burner(s) Make/Model: MMBtu/hr Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: El Yes O No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-1.11- Gas Venting APEN - Revision 3/2019 41 Benzene 7.6 lb/MMscf AP -42 Permit Number: AIRS ID Number: 123 /9C841 [Leave blank unless APCD has already assigned a permit If 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 Methods) Overall Requested Con€rol Efficiency ( reduction in emissions) PM SO,' NO,' CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A ollutant Emissions Invento. Annuat Emissiai Uncontrolled Emissions (tons/year) trailed • xissions6 tonslyear)> Uncontro(1 Emissions (tons/year) Controlled Emissions, (tons/year)" PM 0.00 0.00 SOx 0.6 Ib/MMscf AP -42 0.00 0.00 NO,1 230.9609 lb/MMscf AP -42 0.52 0.52 CO 992.3746 1b/bbi' °"i `" `` "AP -42 2:23 2.23 VOC. 143,428.7535 lb/bbl HYSYS, AP -42 I 1 321.61 16.08 n -Criteria Reportable Pollutant Emissions invent° Chemical Abstract /ice (CAS) Number Uncontra Basis Emission Factor YObl Source (AP -42, Mfg., etc.). at, Uncontrolled Emissions (pounds/year). nual Emissions ontroiled Emissionss (pounds/year) 71432 483.9150 HYSYS/AP-42 2,170 109 Toluene 108883 454.8363 HYSYS/AP-42 2,040 102 Ethylbenzene 100414 63.6532 Xylene 1330207 243.1046 Ib/66rf`" HYSYS/AP-42 285 14 HYSYS/AP-42 1,090 55 n -Hexane 110543 4,398.0707 ib/Mill "HYSYS/AP-42 19,723 987 2,2,4- Trimethylpentane 540841 521.1312 lu�r. HYSYS/AP-42 2,337 117 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 3/2019 51A to i0 C ADa Permit Number: AIRS iD Number: 123 19C84f [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. OMLIWA Signs ure of Legally Authorized. Per (not a vendor or consultant) 10/23/2019 Date Janessa Salgado Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: (�✓ Draft permit prior to issuance 12 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 APED -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.cotorado.gov/cdphe/apcd' Form APCD-211 Gas Venting APEN - Revision 3/2019 6I 4 COLOR Ai xy ac an 2/13/2020 State.co.us Executive Branch Mail - Noble Energy Rohn State LD04 Econode VRT Permit Request STATE OF COLORADO Lakocy - CDPHE, Lauraleigh <tauraleigh.lakocy@state.co.us> Noble Energy - Rohn State LD04 Econode VRT Permit Request Janessa Salgado <Janessa.Salgado@nblenergy.com> To: "Lakocy - CDPHE, Lauraleigh" <lauraleigh.lakocy@state.co.us> Hey Lauraleigh, Below are responses to your questions in red. Thanks! Janessa From: Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us> Sent: Thursday, February 6, 2020 3:31 PM To: Janessa Salgado <Janessa.Salgado@nblenergy.com> Subject: EXTERNAL: Noble Energy - Rohn State LD04 Econode VRT Permit Request Dear Janessa, Wed, Feb 12, 2020 at 7:39 AM I am currently reviewing the permit application for the VRT gas at the Rohn State LD04 Econode (AIRS ID: 123-9C84- 021) and had a few quick questions for you: • Included in the application package were 2 pressurized liquid samples, one labeled "Rohn 03/04 Econode HP 2510 Pressurized Liquid" and the other "Rohn 03/04 Econode HP 2310 Pressurized Liquid". It appears that the "2510" sample was used in the ProMax simulation - what is the 2310 sample for? Was that from the same unit? The two samples represent two different HP separators. We had a contractor perform this modeling and it appears they used the sample that had the lowest percent % (the sample that most fully saturated), which was sample 2510. • On the APEN, the emission factors for PM and SOx are listed in lb/MMscf, but I believe they are actually lb/MMBTU. May I make that redline change? Does that change your emission calculations? Can we leave the unit as lb/MMscf and list the EF as calculated (PM= 1.2371 and SOx= 0.0977)? • For CO,''VOC and all of the HAPs, It looks like you have also come up with the emission factors in lb/MMscf, but they are all labeled "lb/bbl". May I redline the APEN to reflect the lb/MMscf units? Yes • In reviewing the Form APCD-102, it appears that points 001, 002, and 003 are controlled; however, no combustion emissions are listed. Can you please provide the combustion -related emissions for these points? The combustion related emissions are captured in the "APEN Exempt/Insignificant Sources" section of Form 102. This is a result of how those points have been permitted in the past. On the permit checklist, you did select that you were not requesting a facility -wide permit. Our login staff did give this point a new permit number, but since there appears to be another permit that covers multiple points at this facility (14WE0501), I did want to validate that it was your intention for this point to have its own permit. Let me know. Correct, I would like this point to be on its own permit. !Quoted text hidden] https //mail.google.com/maiUu/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1658342203874264594&simpl=msg-f%3A16583422038... 1/1 Hello