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Home My WebLink About20202331.tiff C �X•:�►. COLORADO 'tagDepartment of Public Health&Environment RECEIVED JUL 2 2 2020 Weld County - Clerk to the Board WELD COUNTY 1150 O St COMMISSIONERS PO Box 758 Greeley, CO 80632 July 15, 2020 Dear Sir or Madam: On July 16, 2020, the Air Pollution Control Division wilt begin a 30-day public notice period for Noble Energy, Inc. - DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 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 & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator o.,A-:-..,P 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe ,,` ��' Jared Polls, Governor I Jilt Hunsaker Ryan,MPH, Executive Director I ,*, ,,,„1 F(.11O1,1; C Rev;ew cc:PL(TP),NL(os),Pw(aM/ERJci/cK), 2020-2331 o$/oS/2o o(lTM) 07/25/20 Air Pollution Control Division 41' Notice of a Proposed Project or Activity Warranting Public GDPHE Comment Website Title: Noble Energy, Inc. - DP416/417/418/419 D25-04 ECO GUTTERSEN - Weld County Notice Period Begins: July 16, 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: DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 L01 Oil and gas exploration and production facility NENW Sec 25 T3N 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 permit four produced water storage tanks, venting of gas from the heater treater and surge drum and fugitive emission leaks. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0172 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 GDPHE DepaYl[nent of Public 1 Health&Environment --x,"z- COLORADO tiD Air Pollution Control Division Department of Pubhc Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0172 Issuance: 1 Date issued: Issued to: Noble Energy, Inc. Facility Name: DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 L01 Plant AIRS ID: 123/AOC3 Physical Location: NENW Section 25 T3N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Produced Four (4) 500 bbl fixed roof produced water Water 001 storage vessels connected via liquid Enclosed Combustor manifold Heater Venting from two heater treaters and two Treater and 002 surge drums during vapor recovery unit Enclosed Combustor Surge Drum (VRU) downtime Fugitive emissions component leaks Fugitives 003 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. 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. ov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. 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 Page 1 of 12 �-4�� COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) F.4.) 3. 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.) 4. 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 5. 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 Produced 001 5.5 19.7 25.0 Point Water Heater Treater and 002 "' 8.4 Point Surge Drum Fugitives 003 2.2 --- Fugitive 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. 6. 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. Page 2 of 12 Air Pollution Control Division C Department of Public Health&Envkronment Dedicated to protecting and improving the health and environment of the people of Colorado 7. AIRS ID 003: 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 actual emissions and the dates that these counts and events were completed. These records must be provided to the Division upon request. 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 AIRS Control Device Pollutants ID Point Controlled Produced 001 Enclosed Combustor VOC and HAP Water Emissions from two heater treaters and two Heater surge drums are routed to an enclosed Treater and 002 combustor during Vapor Recovery Unit (VRU) VOC and HAP Surge Drum downtime 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 Process Parameter Annual Limit Point Produced Water 001 Produced water throughput 3,000,000 bbl/yr Gas venting from two heater treaters Heater Treater 002 and two surge drums to enclosed 2.5 MMSCF/yr and Surge Drum combustor during VRU downtime 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. AIRS Point 002: The owner or operator must continuously monitor and record the total volumetric flow rate of gas vented from two heater treaters and two surge drums to the enclosed combustor 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. Page 3 of 12 C, _ .,(......,.v.fCOLORADO Air Pollution Control Division tZtf Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.)I.E.) (State only enforceable) 12. AIRS ID 001: This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping,„ monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 13. AIRS ID 001 and 002: 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 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 storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. AIRS ID 001: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. AIRS ID 002: 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. 17. AIRS ID 003: This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Page 4 of 12 CC •r..:tz- COLORADO - —.r Air Pollution Control Division Department of Pubic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 003 VOC LDAR per Regulation 7, Part D, Section II.E 18. AIRS ID 003: 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 I.L. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section I.C.1. 19. AIRS ID 003: 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 20. 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 £t MAINTENANCE REQUIREMENTS 21. AIRS ID 001 and 002: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) 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 OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 22. AIRS ID 003: 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 23. 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 12 ,, ,,e....-rvl COLORADO 0 woo, Air Pollution Control Division Department of Public 1Ieattn&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 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 • 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. 24. 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 25. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 26. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation 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 12 C0 .1, COLORADO 0 YY Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 27. 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. 28. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 29. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issued to Noble Energy Inc. for: • Four (4) 500 bbl fixed roof produced water Issuance 1 This Issuance storage vessels (AIRS ID 001) • Venting from two heater treaters and two surge drums (AIRS ID 002) • Fugitive equipment leaks (AIRS ID 003) Page 7 of 12 C _, ,,,, ....r,...-,:t - COLORADO Air Pollution Control Division Department of Public Health b 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) Produced Benzene 71432 21,000 1,050 001 Water n-Hexane 110543 66,000 3,300 Benzene 71432 1,167 58 Toluene 108883 932 47 Heater Ethylbenzene 100414 90 4 Treater and 002 Xylenes 1330207 815 41 Surge Drum n-Hexane 110543 7,132 357 2,2,4 540841 69 3 Trimethylpentane Fugitives 003 n-Hexane 110543 84 84 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: Page 8 of 12 C �r, "�';r�• COLORADO t j Air Pollution Control Division �� Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Point 001: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0037 0.0037 CDPHE CO 0.0167 0.0167 CDPHE VOC 0.2620 0.0131 CDPHE 71432 Benzene 0.0070 0.0004 CDPHE 110543 n-Hexane 0.0220 0.0011 CDPHE Point 002: Emissions for Point 002 include venting of gas from two heater treaters and two surge drums to the enclosed combustor, combustion of heater treater and surge drum 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. Venting of Heater Treater and Surge Drum Gas to Enclosed Combustor during VRU downtime: Weight Uncontrolled Controlled Fraction Emission Emission CAS # Pollutant of Gas Factors Factors Source (%) (lb/MMscf) (lb/MMscf) VOC 94.4 134,782 6,739.1 Gas sample 71432 Benzene 0.4 466.88 23.344 HYSYS 108883 Toluene 0.3 372.71 18.636 HYSYS 100414 Ethylbenzene 0.03 35.905 1.7952 HYSYS 1330207 Xylene 0.3 326.00 16.300 HYSYS 110543 n-Hexane 2.3 2,853.0 142.65 HYSYS 540841 0.02 27.560 1.3780 Gas sample Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Combustion of Heater Treater and Surge Drum Gas: Combustion emissions from heater treater and surge drum gas combusted at the enclosed combustor are calculated using the following emission factors and actual monthly volume of heater treater and surge drum gas routed to the enclosed combustor. Uncontrolled Emission Factors lb/MMscf Heater Treater and CAS # Pollutant Surge Drum gas Source NOx 210.28 AP-42, Ch 13.5 CO 958.65 AP-42, Ch 13.5 Permitted emissions are based on a heat content of 3,092 btu/scf. Page 9 of 12 C •r.-.T. COLORADO _ Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 0.39 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 N0x 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 003: The emission levels contained in this permit are based on the following emission factors: WComponent Gas Service Heavy Oil Light Oil Service Connectors 3,648 0 3,571 848 Flanges 1,307 0 1,451 479 Open-ended Lines 0 0 0 0 Pump Seals 0 0 9 0 Valves 1,327 0 1,774 514 0ther* 837 0 597 139 VOC Content (wt%) 34.73% 100% 100% 100% Benzene (wt%) 0. 12% 0.36% 0.36% 0.36% Toluene (wt%) 0.06% 0. 18% 0.18% 0. 18% Ethylbenzene (wt%) 0.01% 0.03% 0.03% 0.03% Xylenes (wt%) 0.02% 0.07% 0.07% 0.07% n-hexane (wt%) 0.67% 1.92% 1.92% 1.92% 2,2,4- 0.01% 0.03% 0.03% 0.03/° trimethylpentane *0ther equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents T0C 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 Page 10 of 12 C . . COLORADO Air Pollution Control Division COP H£ Department o€Pubhc Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 003: This source is subject to 40 CFR, Part 60, Subpart OOOOa-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 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, HAP 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 Page 11 of 12 . COLORADO Air Pollution Control Division COPN£ Department or Public Heath&Envtronment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 12 of 12 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Ceiisse Money Package#: 5,22650. Received Date: 26,:2.13 Review Start Date: z;r}>2? Section 01-Facility Information Company Name: enrolee Energy,lee Quadrant Section Township Range County AIRS ID: COlm ee Plant AIRS ID: 3' Facility Name: 25.5.51,3 422 025 e ECO GUTTERSEN .__255 25lOO'547.-5252 LOCO Physical Address/Location: i. !F. Tom., >, _ ..,3 County: Weld County Type of Facility: oraf s3L What industry segment?Ari9 f Is this facility located in a NAAQS non-attainment area? If yes,for what pollutant? a .l Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point if 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) 2 C(J1 = ' I . rCi72 Yes- sitne aE Section 03-Description of Project P...1e r,� C �rF`C rt ss k� �..,. l,. a,,,si * 1/3,‘,12.020, .Ions To,7,�a062 x',`3003 c rccc: ed 7'2/2020 RI aa_ - perm,t:U ts.-„ rr,. Sections 04,OS&06 For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? If yes,why? Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? 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? 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 Title V Operating Permits(OP) O O O Q O O O Q Non-Attainment New Source Review(NANSR) O 121 Is this stationary source a major source? If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Co orac3o Air Permitting Project - Prevention of Significant Deterioration(PSD) O O O O O O Title V Operating Permits(OP) O © O O O O 0 0 Non-Attainment New Source Review(NANSR) O O Section 01-Administrative Information 'Facility AIRs ID: -123 AVC" tt0" County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Ta)yt#4 l3Utttci((Cdnagdpyocuced Old£6rstordgyvevsels bcnnnvtoct,15 Ii414d"manifold Description: Emission Control Device Enclosod;ombUstor Description: Requested Overall VOC&HAP Control Efficiency H: Limited Process Parameter >r.. Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) • Actual Throughput= Barrels(hbl)per year 'Requested Permit Limit Throughput= 3,(30,00U.^"Barrels(hbl)per year Requested Monthly Throughput= ca1va.S Barrels(bbl)per month Potential to Emit((PTE)Condensate Throughput= ( 3,000,000=O Barrels(ball per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 1496,0•Btu/scf Volume of waste gas emitted per BBL of liquids produced= 36.4 scf/bbl Actual heat content of waste gas routed to combustion device= _1 MMBTU per year • Requested heat content of waste gas routed to combustion device= _501::MMBTU per year ' Potential to Emit(PTE)heat content of waste gas routed to combustion device= _v.,._ 9 MMBTU per year • Control Device Pilot Fuel Use Rate: '21/1•11 .t scfh ..C MMscf/yr 'Pilot lignt erruss.0,a-elnctUded With.AIRS ID 002 Pilot Fuel Gas Heating Value: .., Btu/scf 660 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (Ib/hhl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) r Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) 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) (tans/year) (Has/month) PM10 0.5 0.0 -..v C.: 02�_ PM2.5 y.v C,0 .,.., _... _ 1722 50x 0 0 0.0 110 0.7 _3 NOx S S v 0-'u 5.5 -_ .0202. .0 VOC _. ,, 10 3530 33.2 27,8 CO v 3 L20.0 <5 3 4273.9 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 21G07.3 0c 0,0 2L300 1,350 Toluene _3 h 0.7 • C Ethylbenzene 0,0 i.. 0 0 3 C 3 of 13 C:\Users\cdmoney\Documents\Package 423650\20W E0172.CP1 Storage T-inks)Emissions Inventory • Xylene 0.0 5._ 0.0 0 0 n-Hexane 60000.0 0.0 0.0 60000 0300 224 TMP 0.0 0.0 0.0 0 0 • • • 4 of 13 CA Users 423650\20W E0172.CP1 Stir i?ak ;) r i5si rs!nvelitory Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Not_n_ r,c, Regulation 7,Part D,Section LC,D,E,F Stasnio 7ar•c s u!,lest t:.. '.,.. Pa..' . Regulation 7,Part D,Section I.G,C ..., - ,-e.;s not sanioot co iistenstion.5ertafil ., Regulation 7,Part D,Section II.B,Cl,, C.3 --,' to , tat-neat to Rain lat:-n;ns i O. ..,. +';S r 3 Regulation 7,Part D,Section II.C.2 Storage .tan's,.0 set-risen to Reg,:-anon,7 par:77.-.. ,r. -._ Regulation 7,Part D,Section II.C.4.a.(i) Sic'gs-la+',is not 550,0t a,:: Regulation 7,Part D,Section II.C.4.a.(ii) Stor.xg-"0,05 is 001,os,r-r is '',.. ue,.o r......a..rt.,.•, Regulation 6,Part A,NSPS Subpart Kb Stooge Tara o not;,avers to:505 an Regulation 6,Part A,NSPS Subpart OOOO 5.0.no t.eSc is not s;.;e,r:o'4o05.7.4330 NSP5 Subpart 0OOOa oireirage rank is not sealers tore:RS OCOOa. Regulation B,Part E,MACT Subpart HH .-ad,...o Water St rage•oat nat xrb;e_t to'vl-SC!.•r (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to estimate emissions? fay \t If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80tpy? td" If yes,the permit will contain an"initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. rt Does the company use a site specific emissions factor to estimate emissions? f lk If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,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 Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? �t If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes C entailed Janessa Salgado With.ftobleaboutthe operations of these tanks.She stated the tanksoniycoliect water from wells's aTed at this site.She alsasaidthe,un:s were constructed 3/22/2,,13. • • Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions • AIRS Point If Process it SCC Code Pollutant Factor Control% Units �Gt 01 $`-s PM10 9__ C lb/1,000 gallons Produced Water throughput PM2.5 1 lb/1,000 gallons Produced Water throughput 5Ox 9 lb/1,000 gallons Produced Water throughput NOx 9 lb/1,000 gallons Produced Water throughput VOC -. - na lb/1,000 gallons Produced Waterthroughput CO :4.6 0 lb/1,000 gallons Produced Water throughput Benzene -5 lb/1,0W gallons Produced Water throughput Toluene t"i., 45 lb/1,000 gallons Produced Water throughput Ethylbenzene ,i.00 35 lb/1,000 gallons Produced Water throughput Xylene '70 95 lb/1,000 gallons Produced Water throughput n-Hexane :a Si 45 lb/1,000 gallons Produced Water throughput 224 TMP 1.00, 45 lb/1,000 gallons Produced Water throughput 5 of 13 C:\Users\cdmoney\Documents\Package 423650\20WE0172.CP1 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B.APED and Permit Reguiremems the Nn1, ._.t_-1.3ree ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2155(Regulation 3,Part A,Section 11.D.l.a)? 2. Produced Water Tanks have no grandfathering provisions 3. Aretotalfacility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than lO TPY(Regulation 3,Part 8,Section 11.531? NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from the individual source greater than l TPY(Regulation 3,Part A,Senior E.0.1.a)7 Source Requires an APED.Go to • 2 Produced Water Tanks have no grandfatherng provisions 3. Aretotal facility uncontrolled VOC emrssons greater than J TPY,NOx greater.than 5TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.5.217 „'rs;„='Source Requires a permit Colorado Regulation i,Part O,Section I.C-F& 1. Is this storage tank located In the 0-hr ozone control area or any ozonenomattainment area or attainment/maintenance area(Regulation 7,Part D,Section LA.1)? cm Continue.You have Indicated th 2. Is this storage tank located at nil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant)Regulation 7,Part D,Section 1A.1)? Fen Continue-You have indicated th 3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part D,Section 1.0)7 .-o Storage Tank is not subject to Re 4. Does this storage tank contain condensate? 5. Does thisstorage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,pert 0,Section I.G.2)? 6. Are uncontrolled actual emissiansof this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section 1,0.3.a(ii))? IStara-ehrth.l•.subc ._?_3 R Part 0,Section I.C.1-General Requirements forAir Pollution Control Equipment-Prevention of Leakage Pen 0,Section I.C.2-Emission Estimation Procedures Part 0,Section 1.D-Emissions Control Requirements Part D,Section I.E-Monitoring Pert 0,Section IS-Recordkeeping and Reporting Pert 0,Section I.G.2-Emissions Control Requirements Part D,Section I.C.1.a and b-General Requirements for Air Pollution Control Equipment-Prevention of Leakage Colorado Regulation 7,Part O,Section I1 I. Isthis storage tank located at a transmission/storage facility? N, Continue-You have indicated th 2. Is this storage tank'located at an ail and gas exploration and production operation,well production facility',natural gas compressorstationa or natural gas processing plant'Igegulation 7,Part 0,Section AC)? Go to the next question-You ha 3. Does this storage tank have aflxed roof(Regulation?,Part D,Section II.AIO)? Nik,,:pgil Go to the next question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2.tans per year VOC(Regulation 7,Part 0,section ACT.op YPsw a'z,:'..Source is subject to parts of Reg. I,R, I , !I, Part D,Section 11.0 Provisions for AirPollution Control Equipment and Prevention of Emissions Part 0,Section II.C.1-Emissions Control and Monitoring Provisions Peal), on IIC3 RecordkeepingRq 5 Does thestorage tank contain only"stahilizecrliquids(Regulation 7,Part D,Section ll.C:2.bl7 rx" -SJSource u subject to all provision, Part D,Section 110,2 Capture d M -g f Storage T ks fitted with Air Pollution Control Equipment Is the controlled storage tankl d at a wellp d i facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on or after May 1,2020,such 6. that an additional controlled storage vessel is constructedto receive an anticipatedincrease in throughput of hydrocarbon liquids or produced water(Regulation 7,Part 0;Section ll.C4.a.()? a. ]Storage Tanks not subject to.Rs I h Idled g kI di t II ood t f I'Y Ig p orstation ornatural gas procersng plantconstrunedonorafarlanuary1,2021on locatedat aftcllitythat was modified on or after January 1, z� 7, 2021 suchthat add tonal con ed storage ve I rted tone an[cpated ncrease nthroughpulashydrocarit liqu dsor pro ducedwater IRegulaton?Part OSec[lon 11C4a.(/7 i3 40 CFR,Part-60 Subp_Kb Standards of P r! ce for V tl Ogan cliqud Storage Vessels 1. Is the individual storage vessel capacitye t han or equal t 75 cubic meters(m)1-472 BBLs](40 CFR 60.110b(a))? ,i-1-10 Go to the next question 2. Does the storage vessel meet the followngexemptton in 60,111b(d)(4)7 '`N'Storage Tank is not subject NSPc_ a.Doesthe vessel has a design capactty less than or equal to 1,589.074 in°r10,000 BBL)used for petroleum'or condensetestared,processed,untreated prior to custody transfer'as defined in 60.11167 3. Wastho storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after luly 23,1954(40 CFR 60.1106(3))? 4. Does the tank meet the definition of"storage vessel.'In 60.1116? 5. Does the storage vessel store a'volatile organic liquid(VOL)"sas defined In 601116? R". 6. Does the stoage vessel meet any one ofihe fallowing additional exemptions: - Ea a.Is the storage vessel a presure sel designed to opera.In excess of 204.9 kPa M29.7 psi]and without emissions to theatmosphere lest b(d)(2)I?;or ' b.The design capacity greater than or equal to 151 ms("950 BBL]andstoree a liquid with a maximum true vapor pressure less than 3.5 kPa(60.110b(b))?,or v.. °Xsc[r: c.The design capacity Is greater than or equal to 75 Ms MA72 BBL]but lessthan 151 ms 1-950 BBL]and stores a liquid with a maximum true vapor pressure'less than 150 kPa(60.11ob(bl)? ` k 7. Does the storage tank meet either one of the following exemptions from control requirements: ?Y Jiib a.The desgn capacity Is greater than or equal to 151 m5 I"950 BBL]and stores a liquid with a maximum true vapor pressure-greater than or equal to.35 kPa but less than 5.2 kPa7;or 5uR.lkye b.The design capacity is greaterthan or equal to 75 Mt["472 BBL]but less than 151 ma 1-950 BBL)and stores a liquid with'maximum true vapor pressure greater than or equal to 15,0 kPa but less than 27.6 Oa? Moms,Minh 6 not ,NSP,Kb 40CFR.Part 60,Subpart 0000/OOOOa Standards of Performance for Crude Oll and Natural was Prodvctlon,Transmissien and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Continue-You have Indicated th 2 Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September IS,20157 Nq'...'}?;x 'Storage Tank is not subject 55P5 3. Was this storage vessel constructed,reconstructed or modified(see definitions 40 CFR,60.2)after September 18,20157 irefw,.¢P, Go text ori` question 4, Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? Idf"e Storage Tank Is not subject NSPS 5. Does this storage vessel meet the definition of"storage vessel'per 60.5430/60.5430x? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40CFR Pan 63 Subpart HH? :-6i,_-:'s.'t�' [Note:If a storage vessel Is previously determined to be subject to MOPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,It should remain subject to NSPS 0000/0000a per 60.5365(e)(2)/60.5365e(e((2)even if potential VOC emissions drop below 6 tons per year] 40 CFR,Pen63,Subpart MAC1 HH.Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: I".as (Continue-You have Indicated th a.A facility that processes,upgrades or stares hydrocarbon liquids'(63.760(a)l2)l;OR b.A facility that processes,upgades or stores natural gas prior to the print at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.760(a)(3))? 2. H the tank looted at a facility that is major'for HAPs? ' Storage Tank Is not subject MAC. 3. Does the tank meet the definition of"storage vessel'in 63.7617 4TRAS 4. Does the tank meet the definition of storage vessel with the potential for flash emssons'per 63.761? 5. Is the tank subject to control requirements under do CFR Part 60,Subpart Kb or Subpart 00007 IFrvaiced Wete Storm, IAr;T 1111 Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards §63.773-Monitoring §63.774-Recordkeeping §63.775-Reporting RACT Review • RACE review is required if Regulation 7 does not apply AND If the tank Is in the nomattainmea area.If the tank meets both criteria,then review RACT requirements. Disclaimer • This document assists operators with determining applicability ofrertain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not rule.or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts end circumstances.This document does not change or substitute for any lees,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.""rosy,""should,"and'en,"is intended to describe APCD interpretations end 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. • • • • • • • • • Section 01-Administrative Information Facility Allis ID: - 123- - ApIC3 flU County Plant Point Section 02-Equipment Description Details - - Detailed Emissions Unit Description: Venting fromosiheater treater anti one surge drum daring vapor recovery unto(VRtz)doeuitleue Emission Control Device Description: Enclosed cra0hustor Requested Overall VOC&HAP Control Efficiency OE: - 90, 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= -2.S MMscf per year Requested Monthly Throughput= 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: 3442,#Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device 1 Pilot Fuel Use Rate: 390 scfh ..<MMscf/yr Pilot Fuel Gas Heating Value:. 1000 Btu/scf Section 04-Emissions Factors&Methodologies Description €n the My 2624 submittal,tlobie used esirspacific Ares...MEW liquid sample from the outlet of the heater theater to model emissions.The Wes-Anted liiERMM rare pie.tr 352615020 5rd',5 lcd Cat._rsys D23 Heater Treater at ppeo0 r=4t 2513 pop and temperature of 122 deg C.This sample is used es the Min to the surge dram in a 4USy5mordel.ht the model,the pressure€s r5ducod from 57.42 p_15 to 5,12 p i5 S ace the heater treater and surge dram streams are combined and then metered And routed tq=laaet E;obte t£snd l-srrco:n composition of the surge drum tea be Ca,eieaiv Gerretapiy,thasvrga drum comp::5RKr has Maher VOC than the heater treater stream Amble also co€fected a gas sample of the eotnbitted stream;sample vol vote 12f28/2029,labeled Guttemen D25:04;SREC tt;ocisui)robin used the Willer ive between 5115 model aedgas. Sam pin to estimate Hntisulooe Volt smtisIons are based outfit as pied gun a#aym elsonpmoftiioor to estimate Smisof000 shtca it had a h`€gher r,S_€,.:r,:ea..-ztito compared ttd5 tre2tt 5551pas€tutee a,za;,'se rn ott£F'..d ccrge deem stream r`sGU,G%hywtV#3C and the combined gas stream sample Es 9§.%by wt 10(0 approprfrth to osethe 5ampie gas steers conaposith,n.HArr'ep based ou the mode bieh had slightly tugher'wt.*excel for 224 TMP, - - MW I 54.1 Ib/Ib-mol Displacement Equation Ex=Q•MW Weight% 7/2020 Model-Surge Drum _- . •_ '.12/2019 Model-Heater Treater Vapors to VIM Helium CO2 0.1 • ,S- N2 1.1 methane 0.00, " 4 ethane d.4 ..: toy ..- propane REM.. - 255..7 isobutane 1111. 96' 1111 8,3 n-butane - 31,7 - 29,1 -.-. isopentane 32 8.1 .. n-pentane 1G.9 s.7 cyclopentane 0.5 - 3v n-Hexane S - • 3354 cyclohexaoe G.4 1:0 Other hexanes 2.4 heptanes - - 2,9 methylcyclohexane `r.1 224-TMP LEA Benzene D 2 - Toluene Oct -- -S _ Ethylbenzene Xylenes COO Heavies 0€S .. 1.6 Total .-.. -. VOC Wt% ..- 8 of 13 C:\Users\cdmoney\Documents\Package 423650\20WE0172.CP1 separator venting Emissions!nye-t Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC Benzene Toluene Ethylbenzene Xylene c_ n-Hexane 224 IMP 22.5598 1,2,00 5420004143541. Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf- Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0075 23,0415 5 . __ PM2.5 J.Ca', 2020416 SOx 00e?6 1.3191 NOx 0,O530 210.2846 a CO 0,0,100 050.6002 n ., --- Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 je.4-047514Xiq;4C-.1n-lalk'',ZaiV14-t;W:tet4.; PM2.5 '..1i414.4-W/4/"...'A71515 SOx 910 0V4 0.5882 NOx '4.i t:;.-471.41,71.4, 95 1.;:41 x CO x '31;4$2 x°gi 52.3529 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 J-0 0 0 0M 0,0 / PM2.5 0.3 0.3 .. 3.0 ...,. SOx 0.3 0.0 -.. C.0 C., NOx 0.4 0,3 0-43 OA :r3 . VOC 168.5 31 4.. 103.1 '1.3 1332 CO 1.23 __. 0.0 ,.34 1.3 F_. • Potential to Emit Actual Emissions Requested Permit Limits Source's values Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/yearl (Ibs/year) (Ibs/year) (Ibs/year) (Ibs/year) (lbs/year) Benzene . _. t: 0 1180 _ 59 1167 58 Toluene 0 , 331 07 932 47 Ethylbenzene . 0, 0 .3 X 90 4 Xylene G J :.._ 4-0 815 41 n-Hexane 0 0 ..C.07 7132 357 224TMP 8 J v_ 3 69 3 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B 5o:arce..e9.vres=i:era,at Regulation 7,Part D,Section II.0,F Source 0,00...0,',30,03'0-30-., _scat 3,0 2, Regulation 7,Part D,Section ll.8.2.e a-_.a.ti-,l dm i,:.= ti-.a_e--a.., ,s ..s t ,. ,,.'a €. D,Section 31.22.E (See regulatory applicability worksheet for detailed analysis) 9 of 13 C:\Users\cdmoney\Documents\Package 423650\20 W E0172.CP1 Sepal-a„.,i'Venting?iraiis5i;"=n c 7.ry,ari*o,'sr 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 he appropriate to use an older site-specific sample., If no,the permit will contain an"Initial Testing Requirement"to collect a site-specificg_as sample from the equipment being permitted and conduct an emission factor analysia to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 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 of this point? 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 Lcq -- d aqo,tbet giogiggred`rewc a_S Ede-b1F t�,Th <J=%C - — +_.?-�a�_'. '≥r s .AW/#40,10t0t0Ple,09* 47*.° '9l" i pt Section 08-Technical Analysis Notes :7S 2.019 af....lrl„L+}',„tJJie tined threec,..:-__ no.',a I.,Yxg., ,. The pw,g_atedlicNri s,orge, .o:,eg,0-_tterser°glate Ciutler,ggi Stgte 3. god ,_aet Stag.. -754ao;f were each ew ,. d./5/2g19.These gaggal + a.t,',,.ail ...2f r.. s d ` 1 ''-n__ww, iP,ir-as_g.R2s',wigged r; ) .E(L-a v31,17 aer at The go % ..._ ers. , 11,pegs,r,v5,,-educed dg.-rt aa5''E surge.drum fo, 37 3 2 >'t.t,.l-- p,,a_The geggergreater ggg,--r_g: are...rgr,_-.g�-e, t, _rt„__u'a ., .t�.,# ,z.e;c?� .._arr_!`posgo:�.c,.'+ of drum--t_a__..as.at„e.,crc, ed_I: Gem; e €omposit;ans _ Iwhs,, t.,3,.., „t VOC_4.sthe wrgg s VCCt 5 ggc.1..,gng the stgge gtrearn ccw.,wsgw.g,t.,,.-h 1,Aggthe sow ca.,,r aweaicss: 0.0253.,_/beg:.ur,.z.gs,drum gas suiycc,. ,9to-s&"Ll._ oto, ggaw _e.,irt 4_o }-0.S, ^gg„d•'eo is tl_,O-ibut„e-_ ..E_ _ ,z2 .MP,o'i?0le ho.,,t Wita draft permit to finf,5in0,6/auj=p Nogg.,o grgWed re, gti ego ,t. n ;.2_ t, a_ -il =tesag,r_t egg and.Aa ?', ,.o, Sego_.: gbt_, :he ig,y2020 sabrr.d£ a,raoltesg...fc„ao>, 2 it=.l.' a -tee. e...�cc -.,_t2,.i eIe w,t=,gGgetetf ffi€a g,, ,. Asd, _S ed„ ,. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only( AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions FactorControl% Units 002 01 _,_ y_Hares PM10 33.2 P M2.5 a3.2 ,=.°_CF SOx _ ..., NOx 3:i;�5 C V0C CO Benzene 4!?.7 .. 2Prt CC Toluene Ethylbenzene 3�.S I`•i,'M vz5,} Xylene .'Z3.5 3`, it'!','clb''.i n-Hexane .. 9w lb;Oilt45'r 224 TM _4 '?.tl;^f.F 10 of 13 C:\Users\cdmoney\Documents\Package 423650\20WE0172.CP1 • Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permin�uirements Scurce is In tha Non,Atimtunant Ares 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 V0C emissions greater than 5 TPY,Not greater than us TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.0.3)? You have rndicztod Si:,cooae,c n rho Nan,Attamment NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY(Regulation 3,Part A,Section 11.0.1.3)7 yes- Source Re 2. Are total facility uncontrolled V0C emissions from the greater than 2 TPY,Nov greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)7 fipby-; Source Re ',..,r,r_u 0 P»rm.t Colorado Regulation 7,Part D,Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? ) itrandsource is: to Regulation Z,nor:D,Sxction 11 0.Z F Section 11.6.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities AltematiAe Em6ssions Control(Optional Section) a. is this separator controlled by a back-up or alternate combustion device(i.e.not the primary control device)that is not enclosed? • *'.. The contra T he 000iroi.'.evi[a,or thnrnl,.:ra-_r=s not sublactta Reguat en:nsrry y....on0.9_.e Section 11.0.2.0—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act.,its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. section 01-Admfnstrative Information IFaN!.Alf.ID: -. County 063 u Plant Point Section 02-Equipment Description Details Detuled...ens Unit Nugol omp'unenficaks from N.M.'.5'5°Pet"w6h an oflaod gas Description: exploration and prodo.ction facility Emission Control Device None Descriptions: Section 03-Processing gate Information for Emissions Es..Ms Th1ss 0(onisnoteppl(cable to fggtees: ' Section -Emissions Factors.Methodologies Regulation06- ]Information Operating Hours 8]60 hoe',Near Emission Sector Source Screening,a i EPA-3•43/R-95-01]Table x$ Coniml Efficiency source. :,None'_.,.,. '..See Section 07 netos 1.2,83 for additional information Calculations Emission Factor(Irg/hm Service Component Type countsource) 0.00,DA)Pollutant Mass Proton Uncontrolled Controlled Table 2.4 Table 28 Emissions Roy) Emissions(197) GAS Connectors 3648 2.00E-04 1.00E-05 0.0% VOC t 34.73°! 1517.9us5 359516.8.1 2.20E-05 lblhr/source 0,136 Flanges 34361 3.90E-04 5.10EO6 0.0% Benzene &4t4 1:'•:99r ;9Y. 1.26E05 Ibhr/source 0,391 Open-Ended Lines 0„ 2.00,03 1.50E-05 0.0% Toluene 12;,,0626%. e1.'- .31E-05 Iblin/sourse Pump Sods •O 2.402.03 3.5.04 0.0% Elhylbenzene .0,02191% 7.12E-04 Ib/hr/source Gas(Relief valves include 5 Valves 1827 4,50E-03 2.50E-05 0,0% 04400s 4.0744% .. > 5.51E-05100rls0urce c p ..seals) Other 837' 8.80E-03 1.20E-04 0.0% nHesarte Ube% •• • '•r 2.65E-04 bar/source Relief Valves 8.80003 1.20,04 0.0% 24-TMP O)%i% • 2.65E-041bfirlscume — — — — — Methanol — — — — — H25 — — — — — Methyl Meroptan ' Connectors 0 1.50E.. 7.50E-06 0.0% VOC 10000% Flanges 3.90E-07 3.90;07 Benzene0.30% a Open-Ended Lines — 1.40E-04 7.20E-06 00".5 Taluoe 0.18% L TOTAL Pump Seals -.. 0.00E+00 0.00E+00 0.0% Elhylbenzene 0.09% 4 0.449 Heavy Oil Valves 0 8,40E-06 8:40,06 00% Xylenes 0.07% 3 0.705 Other 3.J.OE-05 .20,05 00% n-H00373 1.92% . 901124 Valves — -- --- — 2,2,4-TMP 0.03% — — -- — -- Methanol 0.00% — — — — — 725 4.00% - — — — — — Methyl Merrap1* 0.00% 1(000 Connecters 35]4 2.10E-04 9.]0,06 0.0% 000 100.00°/ .. _ : _4 2.14E-05 Ibhr/source 0.313 Flanges 1461 1.10,04 0.0% Beene 0.36% 5,29E-06I6lhrlsource 0313 Open-Ended Ones 0 1.4UE-03 1.40405 0.0% Toluene 0.10% .. 3.09E-0S Mr/source Pump Seals 9 1.30602 5.10E-04 0.0% Elhylbenzene 0.03% _.__. 112E-03Ib0iYlsource Light Oil Valves 1774 2.50E-03 1.90E-05 0.0% Xylenes 0,07% - -.-: 4.19E-05Iblhrlscurce Other 597 7.50E-03 1,10E-04 0.0% 021303ne 1.92% 2.43E-04 Iblhrlsaurce Relief Volvos 0 7.50E-03 1.10E-04 0,0% 22,4-TMP 0.03% _ . 243E-04 Ibmr/snrce — — — -- — Methanol 0.00% _ -- — -_ — — H25 0;00°4. — -- -- — Methyl Mercaplat •0,00% — 06,1080(010 046 1.10E-04 1.00E-05 0.0% VOC .100,0004 Flanges 479 2.90E-06 2,90906 0.0% Benzene 0,36% Open-Ended Lines 0 2,50E-04 3.50E-06 0.0% Toluene 0.18% - PumpSeals 0 2.40E-05 2,40E-05 0.0% 0199100,13,e 0.03% - "' Water/Ort Valves 514 9,00E-05 9.70E-06 DR% Xylanes 007% ; Other 139 1.40E-02 5,90E-05 00% n wane 1.92% Relief Valves — -- — -- 22,4-TOP 0.03%. s - ..- - — — — — Methanol 0.00°/.. - — — — 1425 0,00% • —- -- — — — Methyl Mercaplar 6.00% . Section OS-Emissions Inventory uu&r Did operator request a buffer? k ,t,4q gg4 Requested Buffet(%). - - Pollutant Uncontrolled Emissions Controlled Emissions Source VOC - 474 2 Ipy screening EFs'EPA-455/P-95-017 Table 20 372 TPY Benzene a IbNY :a(4/27 Screenng EFs-EPA-4531R-95-0ST Table 28 000765972 0.0078597 Toluene 4 Ibhr I lb/yr Screening EFs-EPA-453/R-95-017 Table 28 0.00393843 0.0039384 Ethylbenzene •Ibhr Ibryr Screening EFs-EPA-453/985-057 Table 2-8 00006344 00006344 %vans 1 lb/yr :10,441 Screening EFs-EPA-053/P-95-017 Table28 0.00151053 0.0015105 n-H53440 'a lb/yr 71 INN eenmg EFs-EPA-053/FA5-0d7 Ta502.8 0.04203166 0.0420317 P Ibry044 r I 11 Screening EFs-EPA-453/RSOTT STable 28 0.0005]041 0066704 Methanol 6.Ibhr 0 IlawS.eening EFs-EPA-45345-95-051 Table2-8 0 0 J14 Ibhr 'Ib(r .Screening.EFs-EPA-0531R-95-017 Tab.22 0 Methyl00+44lan _33 IbNI '•lb/yr S.eening EFs-EPA-453IRAs-017 Table 28 0 0 Seaton 06-Re:ulmo Summa nal 1s Reg.3 Ravlmer Regulation 3,Pan El,Section 111.0.2 to determine is.ACT is required? Y03 , 952.6 R0iew 40 CFR,.M160 Subpart KKK 10 determine Ifapplicable to this source? Mg R020040 CFR,Pad 60,Subpart 000014 determine if 00.5360 and/or 005385 is applicable? N4 'Subject to NSPS 00008 Reg,7 Realm/SectionXVIIFto determine is LIAR is applicable? Yes Addgl3nal Regulatory Considerations Section IIA,1-.col as provided in paragraphs 2 through 6 below,no nester or operator of a source snail atowa cause the emission into iho atmosphere ofany air pollutant which is in extras of 20%°goo...ibis standard rs 66321851001 beset on24consec4ive opacity readings taken a115son intervals for six minutes,The appraaedrerereno test method for visible emissions measurement is B.O.'.9((40 CFR,Pan 60.Appendix A(July.1992))in all subsections or Section O Antl B of this regulation Section(.A-No person,wherever located,shall cause.allow the emission of odorous...mina.from any single source such as to result In delectable odors which are measured in excess of I.following limits.For areas Regulation2 used prodominantty(dr residential or commercial purposes 6 f is if are doted.after the odorous air has been diluted with seven(7)or mare volumes orator flee air. Part RAPER Requ*ements p6101'Pollutants:Forcnleri3 pollutants.Air Pollutant Emission Nmicesare required for each individual emission point m a non-attainment area with uncontrolled actual emismns None ton peryear a more Noy individual Maeda pollutant(pollutants are not summed)for which the area is non-attainment Applicant is required to fie an APEN since emissions exceed 1 ton per year VOC Part 8—e0nnruction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this 540009 are greater - than the 2 TRY threshold(Reg.3,Port B) IS lids source located in an ozonenonatlainmont area or attainment maintenance aeon? 4&e • dyes,is this source subject to leak detection and repair CEDAR)requirements per Regulation 7,Section XVILF. Regulation3 XII..40 CFR,Part 50,Subparts KKK,0000,or 000052 Yes Part B,IIL01-RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or mociMen Mar sources located In nonattainment or attainment/maintenance areas.This source is located in I.8-hour ozone nonattainment area. The date al Interest for determining whether the source is new or modified',therefore November 20,2007 (the date.of the,-hour ozone NA area designation).Since the fugitives will be In service after the date above,this source is considered"new or modified.' This facility is subject to NAPS 0000a as well as Regulation 7,Section XVII.F.Following tfe leak detection and repair program per Reg 7 satisifies the RACT requirements of Regulation 3.The permit will contain a carnation refleetirg lM1is determination. ',this source at an onshore"natural gas processing plan'asst..in 40 CFR,Parl.631, No Did this source commences construction,reconstruction,or nwdificetion Mr./wary 20,1984,and on orberore August 23,2011? No This source is not subject to NSPS RRR because the new equipment covered by the fugitiVe source will 6nstruction afer August 23,2011 and is not located at a natural gas processing plant Ise Regulation technlcalanalysis ndest Did MS source commences consimcton,reconstrMon,or modRcadon after August 23.2011 and on or before Septeismm ber 18,2015? Na Source is not subjectto NAPS 0000 because the new equipment covered by this fugitive source will commence construction after September 16,4016. Is this source located In an ozone non-attainment area ar attainment maintenance era? Y."Y Is this source at an onshore"nalurA gas pmressirrg plant.as defined in 40 CFR,Pad 60.631? 'Nq Facility is not classified as a natural gas processing plant.Therefore,this source is not subjectto Regulation? Regulatton 7 Section XII.G. Is the facility classified as a well production facility or natural gas compressor station? Yes Since this facility Is classified as a well production facility,it is subject to Regulation n 5ectlon XVII.F. Is this sourceat a Materel gas processing plant"e500tined In 40 CFR,PM 83.761? No Is Ns tamlity considered a"major source"of HAP as specifically defined In 40 CFR,Part 63.]11 for sites'halm. production field facidaaa? No Regulatton 6 goon repond"yes"re INN questions above,further review if the provisions of 40 CFR,Part 63.789'Equipment Lak Standards'.apply? Source is not subject to MGT HH because the facility Is classified as a synthetic miner source of HAP,. Did this source comment construction,reconstruction,or modification after Septemher 16.2015? Yes Isihls soumeat a well site,compressor station orpnshore'5raluml gas processing plant"asafinetl In 40 CFR,Pad totes 0000a 80.5430x? Yes • This facility meets the definition of a well production facility as defined by 40 CFR,Pad 60.6430a. Therefore,the fugitive emissions at this facility are subject to NIPS 0000a. Section 07-Technical Analysis Notes In the Dec 2014 sub al,the Component estimated tiesedOil eng eaC judarnentand then...composition was based on asimiars tee an 0 4(2 tedto he consemet.(gas'sample fi tom Hurley H2EFt Econode,sampled 3/13/2.019).As ayes.thepermtor Rcoma xarr'ri tcomplientemst requiring thetan actualh5cdcdunt of comment..aa rat extended gas nahgw, I sent a deaft gamin to the source on 5/13/2820 and ib..roe prove.revised emission estimates a response.the draft n7/ z2oIn the nty;2020 std.t)Noblest,.they Fad c.c.s.a si tespecifln 00Sem,.(1411 ed 2/28,020 and labeled GuttersenD25O4sele gen);updated this A based or the revisedes composition.Noble alsosta€e7 they condintedasdespacific coulpaMtltcdunibut also plan to guild an.. al 10 swells et(Mite Thus,the 7/2/20sibmitMl rP dth@conlpotet counts based.the actualsomponen untandscaledfor the additional wells.The PAaod per tare based on the 7/2/2020 submittal. As a result,thepermirw t not remote an initial ex(xitded gas analysis.Also,en'till comper000neuniwlli nett,required.Noble mustupdate the component coignesthe,leis modified. Ps domed above h oassubjeenln NSP50000a,Howe?.this NhPS has rwtyet been adnpted into Mars.gegulation 6.Asaresult,the coedit,....easing NSPS 0000a will haaddressedln the.eat.Or permit herder wain,pfthe permit The hciltty Is an FAPade so Nis subject to Regulation 7,Secfionkoll,Fas,wellas NSPS 000. - Section 06-Inventory SY W ding and Emissions Factors Uncontrolled AIRS Point# Process# SCCMode Pollutant Emissions Factor Carrrol% Source Vafie,Mt Varies by component 003 01 VOC component type type Screening ER-EPA453/BAS-017 Table LB Varies by Varies by component Benzene z om ne pont type type Screening Efs-EPA-053/RAS-011 Table 2-e Varies by Varies by component Toluene component type type Screening EM-EPA-453.95-017 Table 2A Varies by Varies by component Ethylbenzene component type type Screening EFs-EPA-453/8.95-017 Table 2-e V Varies by Varies by component Xylene component type type Screening EFs EPA453/R-95-017 Table 2-8 Varies by Varies by component n-Hexane component type Sc 45 type reening Efs-EPA- 3/R-95017 Table 2-8 Varies by Varies by component 224 TINP component type type Screening Fes•EPAA-53/R-Ps-omahle2-e COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT MR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Enemy,Inc. County AIRS ID 123 History File Edit Date 6/8/2020 Plant AIRS ID A0C3 Ozone Status Non-Attainment Facility Name DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 L01 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 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 0.0 001 20WE0172 Four 500 bbl Produced Water Storage 0.6 0.6 5.5 393.0 • 25.0 43.5 0.6 0.6 5.5 19.7 25,0 2.2 Using state default EF 002 20WE0172 Heater treater and surge drum venting 0.4 168.5 1.3 5,1 0.4 8.4 1.3 0.3 New point 003 20WE0172 Fugitive equipment leaks 2.2 0.1 2.2 0.1 004 20WE0222.XP 34.4 hp Diesel Engine 1.9 1,9 1.4 0.0 1.9 1.9 1.4 0.0 based on APEN 0.0 0.0 Two Heater Treater Heaters and 2 HP 0.9 0.9 0.1 12.3 0.7 10.3 0.0 0,9 0.9 0.9 0.1 12.3 0.7 10.3 0.0 Based on Form 102 Heaters 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 FACILITY TOTAL 1.5 1.5 0.0 0.1 20.1 564.1 2.2 38.0 48.7 1.5 1.5 0.9 0.1 20.1 30.7 2.2 38.0 2.5 VOC: Syn Minor(NANSR and OP) NOx:True Minor(NANSR and OP) CO: True Minor(PSD and OP) • HAPS: Syn Minor Permitted Facility Total 0.6 0.6 0.0 0.0 5.9 561.5 2.2 26.3 , 48.7 0.6 0.6 0.0 0,0 5.9 28.1 2.2 26.3 2,5 Excludes units exempt from permits/AFENs (A)Change in Permitted Emissions 0.6 0.6 0.0 0.0 5.9 28.1 2.2 26.3 Pubcom required based on change in emissions and requesting syn minor limits Total VOC Facility Emissions(point and fugitive) 32.9 Facility is eligible for GP02 because VOC<45 tpy (D)Change in Total Permitted VOC emissions(point and fugitive) 30.3 Project emissions greater than 25/50 tpy Note 1 Note 2 Page I oft Printed 7/14/20211 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 A0C3 Facility Name DP416 418 O25-04-A ECO GUTTERSEN D23 O25 T3N-R64W-S25 L01 Emissions-uncontrolled (lbs per year) POINT I PERMIT I 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 20WE0172 Four 500 bbl Produced Water Storage Tanks 21000 66000 43.5 002 20WE0172 Heater treater and surge drum venting 1167 932 90 815 7132 60 5.1 003 20WE0172 Fugitive equipment leaks 16 3 1 3 34 1 0.1 004 20WE0222.XP 34.4 hp Diesel Engine 0.0 0.0 Two Heater Treater Heaters and 2 HP Heaters 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 11.1 0.5 0.0 0.4 36.6 0.0 0.0 0.0 0.0 48.7 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text uncontrolled emissions<de minimus Emissions with controls(lbs per year) POINT I PERMIT I 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 20WE0172 Four 500 bbl Produced Water Storage Tanks 1050 3300 2.2 002 20WE0172 Heater treater and surge drum venting 58 47 4 41 357 3 0.3 003 20WE0172 Fugitive equipment leaks 16 8 1 3 84 1 0.1 004 20WE0222.XP 34.4 hp Diesel Engine 0.0 0.0 Two Heater Treater Heaters and 2 HP Heaters 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 0.6 0.0 0.0 _ 0.0 1.9 0.0 0.0 0.0 : 0.0 2.5 I 123A0C3 7/14/2020 6 `hdlg Produced Water Storage Tank(s) APEN Form APCD-2O7 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-20O) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website. 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: Z&(,VE 0/71 AIRS ID Number: 17 /4c ,/ Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: DP416/417/418/419 D25-04 ECO GUTTERSEN Site Location Site Location: NENW SEC25 T3N R64W County: Weld 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: janessa.salgado@nblenergy.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any 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. 423647 COLORADO Permit Number: AIRS ID Number: / / Section 2 - Requested Action ® NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 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: Produced Water Storage Company equipment Identification No, (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 01/31/2020 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: Q Exploration Es Production(EUP)site 0 Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? Q Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ❑ Yes 0 No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes ❑✓ No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? ❑ Yes 0 No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑ No 805 series rules?If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑ Yes Q No emissions≥6 ton/yr(per storage tank)? COLORADO Permit Number: AIRS ID Number: / / Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Produced Water Throughput: N/A 3.000,000 From what year is the actual annual amount? N/A Tank design: ✓❑ Fixed roof 0 Internal floating roof ❑ External floating roof Storage it of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) PW Tanks 4 2,000 01/2020 01/2020 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well • SEE ATTACHED ❑i 0 O 0 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 The E&P Storage Tank APEN Addendum(Form APCD•212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.20223,-104.50455 ❑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. Operator Stack Discharge Height Above Temp. • Flow Rate Velocity ID No. Ground Level(Feet) (CF) (ACFM) (ft/sec) Enclosed Combustor(s) 30 Variable Variable Variable Indicate the direction of the stack outlet: (check one) 0 Upward 0 Downward O Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 13.5 ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Permit Number: AIRS ID Number: Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Mode(: O Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr hr Type: Enclosed combustor(s) Make/Model: Zeeco, HREC ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NIA Waste Gas Heat Content: 1496 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: N/A MMBtu/hr Description of the closed loop system: O Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7- Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —300,25,3 psig Describe the separation process between the well and the storage tanks: Liquids from the wells go to HP separators, LP separators (heater treaters), and surge drums and all feed into the produced water storage tanks. Note, the enclosed combustor pilot emissions are accounted for in the heater treater/surge drum APEN because the combustors are shared. , COLORADO 4 Permit Number: AIRS ID Number: Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O 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): Pollutant Control Equipment Descri Non Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustor 100% 95% NOx CO HAPs Enclosed Combustor 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 Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions$ Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tans/year) (tons/year) VOC 0.2620 lb/bbl CDPHE 19.65 393.00 1965 NOx 3.66E-3 Ibibbl AP-42 5.49 5.49 5.49 CO 1.67E-2 lb/bbl AP-42 25.04 25.04 25.04 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 alt APENs,including APEN updates. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14.03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes O 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 Source Uncontrolled Controlled Service(CAS) Uncontrolled Units Basis (AP-42, Emissions Emissions8 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.0070 lb/bbl CDPHE 21,000 1,050 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0220 Ibibbl CDPHE 66.000 3,300 2,2,4-Trimethylpentane 540841 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. cOLO RAOO -. 5 ✓ NcaINbY eu..nen�. Permit Number: AIRS ID Number: / / Section 10- Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. MOO 12/20/2019 Sig ature of Legally Aut rized 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 QQ 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. with $ i Send this form along and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303) 692-3150 Make check payable to: Colorado Department of Public Health and Environment .1"_ Alapt COLORAoo = APEN Form 212 Addendum Company Name: Noble Energy, Inc. Source Name DP416/417/418/419 D25-04 ECO GUTTERSEN API NUMW Name a - Newly Reported Weil? 05-123-48845 GUTTERSEN D23-711 Yes 05-123-48635 GUTTERSEN D25-715 Yes 05-123-48634 GUTTERSEN D25-724 Yes 05-123-48637 GUTTERSEN D25-734 Yes 05-123-48636 GUTTERSEN D25-743 Yes 05-123-48628 GUTTERSEN D25-753 Yes 05-123-48631 GUTTERSEN D25-762 Yes 05-123-48627 GUTTERSEN D25-772 Yes 05-123-48630 GUTTERSEN D25-781 Yes 05-123-48621 GUTTERSEN STATE D23-721 Yes 05-123-48623 GUTTERSEN STATE D23-731 Yes 05-123-48624 GUTTERSEN STATE D23-741 Yes 05-123-48598 GUTTERSEN STATE D23-751 Yes 05-123-48596 GUTTERSEN STATE D23-761 Yes 05-123-48595 GUTTERSEN STATE D23-771 Yes 05-123-48597 GUTTERSEN STATE D23-781 Yes 05-123-48619 GUTTERSEN D35-720 Yes 05-123-48620 GUTTERSEN D35-730 Yes 05-123-48622 GUTTERSEN D35-740 Yes 05-123-48587 GUTTERSEN D35-750 Yes 05-123-48592 GUTTERSEN D35-760 Yes 05-123-48593 GUTTERSEN D35-770 Yes 05-123-48588 GUTTERSEN D35-780 Yes 05-123-48843 GUTTERSEN STATE D35-790 Yes 05-123-48842 GUTTERSEN STATE D36-714 Yes 05-123-48633 GUTTERSEN STATE D36-724 Yes 05-123-48639 GUTTERSEN STATE D36-733 Yes 05-123-48638 GUTTERSEN STATE D36-743 Yes 05-123-48625 GUTTERSEN STATE D36-752 Yes 05-123-48632 GUTTERSEN STATE D36-762 Yes 05-123-48629 GUTTERSEN STATE D36-771 Yes 05-123-48626 GUTTERSEN STATE D36-781 Yes .rrex. Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and CDPHE 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. 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: 20WE01 72 AIRS ID Number: 123 /A0C3 /002 [Leave blank unless APCD has already assigned a permit C and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy Inc. Site Name: DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 L01 Site Location Site Location: NENW SEC25 T3N R64W Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@nbIenergycom 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. COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 1 j ice Depantrter. Puhlw,� Permit Number: 20W E0172 1 72 AIRS ID Number: 123 /AOC3/002 [Leave blank unless APCD has already assigned a permit#and AIRS ID} Section 2 - Requested Action 0 NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) O Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit O Change permit limit 0 Transfer of ownership' 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 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: Heater treater and surge drum gas streams- combustion during VRU downtime Company equipment Identification No. (optional): For existing sources, operation began on: 01/30/2020 For new, modified, or reconstructed sources, the projected start-up date is: ❑r 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 nonattainment area? ❑ Yes ❑ No Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Yes ❑ No Section XVII.G? Ag++►► COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 2 I allI! =r z.",'""" Permit Number: 20WE0 1 72 AIRS ID Number: 123 i A0C3/002 [Leave blank unless APCD has already assigned a permit and MRS 1D] Section 4 - Process Equipment Information ID 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? ❑✓ Yes ❑ No Vent Gas BTU/SCF Gas Venting Heating Value: 3092.42 Process Parameters5: Requested: 2.50 MMSCF/year Actual: NSA MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5 Molecular Weight: 54.12(gas),47.0859(model) VOC (Weight%) 94.3874% Benzene (Weight%) 0.3758% Vented Gas Toluene (Weight%) 0.3000% Properties: Ethylbenzene(Weight%) 0.0289% Xylene(Weight%) 0.2624% n-Hexane(Weight%) 2.2964% 2,2,4-Trimethylpentane(Weight%) 0.0193% Additional Required Documentation: ❑✓ Attach a representative gas analysis (including BTEX ft n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX It n-Hexane, temperature, and pressure) 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. COLORADO Form APCD-21i - Gas Venting APEN - Revision 12/2019 3 smif Ilea.bc"'""'° x mn n.ronment Permit Number: 20W E0172 172 AIRS ID Number: 123 /A0C3/002 [Leave blank unless APCD has already assigned a permit 4'and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.20223,-104.50455 ❑✓ 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 Operates Sta Temp date FIoW , V�ty Above Ground Level ck iD�o � �(•� �/sect, !Feet) Enclosed Combustor(s) 30 Variable Variable Variable Indicate the direction of the stack outlet: (check one) ❑✓ 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): 13.5 o Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): 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. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: % Pollutants Controlled: VOC, HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: Zeeco, HREC ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NSA Waste Gas Heat Content: 3092.42 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0.195 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 4 H 'm Permit Number: 20WE0172 AIRS ID Number: 123 /A0C3/002 [Leave blank unless A jai}has already assigned a permit!+and AIRS ID] 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? ❑✓ 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): Description Collection Efficiency Control Efficiency Pollutant Control Equipment p (%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 SOx NO. CO 1,071.1904 lb/MMscf AP-42 1.34 1.34 1.34 VOC 134,782.2187 Ib/MMscf HYSYS/AP-42 8.42 168.48 8.42 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 0 Yes 0 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 Abstract Source Uncontrolled Controlled Chemical Name Uncontrolled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg-,etc-) (lbs/year) (lbs/year) Benzene 71432 466.8834 lb/MMscf Gas Sample 1,167 58 Toluene 108883 372.7116 Ib/MMscf Gas Sample 932 47 Ethylbenzene 100414 Xylene 1330207 325.9984 lb/MMscf Gas Sample 815 41 n-Hexane 110543 2,852.9831 lb/MMscf Gas Sample 7,132 357 2,2,4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. yo2► coLoRAoo Form APCD-21 i - Gas Venting APEN - Revision 1212019 5 1111W4&-- Permit Number: 20WE0 1 72 AIRS ID Number: 123 ,A0C3/002 [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. liS 07/02/2020 gnature 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: ❑✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: 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 liekAW,_COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 6 I illIhreW I 1=7Zrubh',. Fugitive Component Leak Emissions APEN Y:4 Form APCD-203 COME Air Pollutant Emission Notice (APEN) and r. 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: 20WE0172 AIRS ID Number: 123 / AOC3 /003 [Leave blank sinless,nrnCC;i`as already'assigned a permit a and MRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: DP416 418 D25-04-A ECO GUTTERSEN D23 D25 T3N-R64W-S25 L01 Site Location: NENW SEC25 T3N R64W Site Location Weld County: NAICS or SIC Code: 1311 M(il ing d Co 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any 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. CC COLORADO Form APCD 203 - Fugitive Component Leak Emissions APED Revision 07'2020 1 COLORADO AetUh 6 Entieanrt Permit Number: 20WE0172 AIRS ID Number: 123 /Aoc3/003 [Leave blank unless APCD has already assigned a permit d and AIRS ID] Section 2 - Requested Action El 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 ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 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 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: 1/30/2020 ❑✓ 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 Facility Types: O Well Production Facility o Natural Gas Compressor Station ❑ Natural Gas Processing Plant ❑ Other(describe): 5 When selecting the facility type, refer to definitions in Colorado Regulation No.7,Section XVII. ]COLORADO Form APCD-2O3 - Fugitive Component Leak Emissions APEN - Revision 07/2020 2 I Permit Number: 20WE0172 AIRS ID Number: 123 /Aoc3/003 [Leave blank unless ARCD has already assigned a permit d and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? 02/18/2019 Will this equipment be operated in any NAAQS nonattainment area? El Yes ❑ 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 i Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? ✓❑Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? O Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? 0 Yes O No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ✓❑Yes ❑ 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. V0C Benzene Toluene Ethylbenzene Xylene n-Hexane 2,2,4 Stream (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Trimethylpentane (wt 90 Gas 34.7328% 0.1236% 0.06323% 0.0091% 0.0230% 0.6658% 0.0122% (or Heavy Liq Heavy Oiluid) 0.03%100% 0.36% 0.18% 0.07% 1 .92% 0.03% Light Oil 100% 0.36% 0.18% 0.07% 0.03% (or Light Liquid) 0.03% 1 .920�0 Water/Oil 100% 0.36% 0.18% 0.03% 0.07% 1.92% 0.03% Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or`-UTM) 40.20223, -104.50455 Attach a topographic site map showing location .COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Pension sion 07/2020 3 t '.HeaNh 6 Emironmene Permit Number: 20WE0172 AIRS ID Number: 123 /Aoc3/003 [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: 0 LDAR per 40 CFR Part 60, Subpart KKK ❑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 ❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 07/2020 4 <ro'�� Permit Number: 20WE0172 AIRS ID Number: 123 /Aoc3/003 flea'-marl'unless A?CD has already assigned a herein r`and AIRS ID] 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: ❑ Estimated Component Count ❑✓ Actual Component Count conducted on the following date: 3/5/2020 Equipment Type Service Open-Ended 9 Connectors Flanges Pump Seals Valves Other Lines Gas Counts 3,648 1,307 1,327 837 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) Counts Emission Factor Units Light Oil(or Light Liquid) Counts 3,571 1,451 9 1,774 597 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 Counts 848 479 514 139 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. iiie*AmNICOLORADO Form APCD1-203 - F:gitive Component Lek Emissions APED Repsicn 07,20203 5 x �L, Permit Number: 20WE0172 AIRS ID Number: 123 /Aoc3/003 [Leave blank unless APCD has already assigned a permit-land AIRS ID] 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? Use the following table to report the criteria pollutant emissions from source: CAS Actual Annual Emissions Annual Requested AL t(sermit Emission 1° Pollutant Number Uncontrolled Controlled11 Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) voc 2.19 2.19 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. 11 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 El 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)t0 Number Uncontrolled Controlled11 Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) abs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 11 543 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. 11 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO Form APCD-2O3 - Fugitive Component Leak Emissions APEN - Revision 07,2020 6 Permit Number: 20WE0172 AIRS ID Number: 123 I Aoc3/003 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 11 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. qamumk. s 07/09/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $216.00 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 COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 07/2020 7 I islW Hut. E�:oor�., Hello