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HomeMy WebLinkAbout20202129.tiff x..t COLORADO IllIF 44W":41 Department of Public RECEIVED Health&Environment JUN 1 5 2020 WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 June 10, 2020 Dear Sir or Madam: On June 11, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy Inc. - Seyler B10, B15 Econode T5N-R64W-S10 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I ,..TfF, , Jared Pais, Governor I Jill Hunsaker Ryan,MPH, Executive Director ,` r * ji Pu61 iC Re✓-eL.3 cc:Pc-CTP), o‘61M)H�(vs),PtJ(zM/ER/CH/GI() 2020-2129 c;. /t7/2o off/)1/2.42 ..rEv Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Noble Energy Inc. - Seyler B10, B15 Econode T5N-R64W-S10 L01 - Weld County Notice Period Begins: June 11, 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: Seyler B10, B15 Econode T5N-R64W-S10 L01 econode NWSW, Section 10, T5N, R64W Weld County The proposed project or activity is as follows: operator seeks permits for two separators at this oil and gas facility 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 19WE0566 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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 _ zy� COLORADO 1 '��� Department of Public a" Health&Environment y... COLORADO 4.. 44tri.i0 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0566 Issuance: 1 Date issued: Issued to: Noble Energy Inc. Facility Name: Seyler B10, B15 Econode T5N-R64W-S10 L01 Plant AIRS ID: 123 9CDA Physical Location: NWSW, Section 10, T5N, R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description LP 011 Five low-pressure separators Enclosed combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.cotorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at Page 1 of 10 CrY COLORADO 4101/4- 1 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Within one hundred and eighty days (180) after issuance of this permit, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator must monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 190 scf/bbl estimated in the permit application. 5. 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.) 6. 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 7. 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 LP 011 -- 0.8 12.5 2.7 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 10 rY. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 8. 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. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled LP 011 Enclosed combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) .A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point LP 011 Natural Gas Venting 7.62 MM scf 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 Page 3 of 10 COLORADO je. 444,40 Nitie Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 11. Upon installation of the flow meter, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 12. 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. 13. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 14. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 15. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 16. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 17. 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. 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and Page 4 of 10 zr, COLORADO Air Pollution Control Division Ntgil Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 19. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Part D, Sections II.B.2. and II.A.23) Periodic Testing Requirements ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per 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 Page 5 of 10 rYy.- COLORADO 40 4460 Air Pollution Control Division tie Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 22. 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 23. 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. 24. 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. 25. 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. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. 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. 27. 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. 28. 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. 29. 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: Kirk Bear OG Permits The Division Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy Inc. Page 7 of 10 , ,,‘,.......r,..,. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 2906 145 Toluene 108883 3810 191 Ethylbenzene 100414 110 5 LP 001 - Xylenes 1330207 974 49 n-Hexane 110543 23356 1174 224 TMP 540841 806 40 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: Uncontrolled Emission CAS # Pollutant Factors Source lb/MM scf NOx 196 AP-42 Page 8 of 10 C .. .,,v,,...,...... COLORADO 11.. Ilt0444461. Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Emission • CAS # Pollutant Factors Source lb/MM scf CO 703 AP-42 VOC 65490 HYSYS 71432 Benzene 382 HYSYS 108883 Toluene 501 HYSYS 100414 Ethylbenzene 15 HYSYS 1330207 Xylene 128 HYSYS 110543 n-Hexane 3067 HYSYS 540841 224 TMP 106 HYSYS 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAP, n-hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 9 of 10 " CrfM.- COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT . 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 C i COLORADO Air Pollution Control Division Department of Public Heatih&Environment CONSTRUCTION PERMIT Permit number: 19WE0567 Issuance: 1 Date issued: Issued to: Noble Energy Inc. Facility Name: Seyler B10, B15 Econode T5N-R64W-S10 L01 Plant AIRS ID: 123 9CDA Physical Location: NWSW, Section 10, T5N, R64W County: Weld County Description: ' Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control ID Point Description VRT 012 Two vapor recovery towers Enclosed combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphelair/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at Page 1 of 10 - COLORADO ii Air Pollution Control Division Department of Public Health&Environment www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) .A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type VRT 012 -- 0.4 4.7 1.0 Point 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. Page 2 of 10 C ,,,r ...r:m. COLORADO 40 ire, Air Pollution Control Division Department of Public Health&Environment 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Pollutants ID Point Control Device Controlled VRT 012 Enclosed combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point VRT 012 Liquid through-put 40,000 barrels 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 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. 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 Page 3 of 10 :ter COLORADO *lii_ Air Pollution Control Division Department of Public Health&Environment calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 11. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section 11.6.2. 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. 16. 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 17. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions Page 4 of 10 CrYy.. COLORADO >4 Air Pollution Control Division Department of Public Health&Environment to the 0EtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Part D, Sections II.B.2. and II.A.23) Periodic Testing Requirements ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or 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 Page 5 of 10 ,,�� COLORADO Air Pollution Control Division Department of Public Health b Environment • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution 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 Page 6 of 10 C ,, - ... COLORADO �/ Air Pollution Control Division �r Department of Public Health b Environment upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Kirk Bear 0G Permits The Division Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy Inc. Page 7 of 10 C :=� COLORADO 4.0.40 Air Pollution Control Division Nitie Department of Public Health&Environment 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) (ib/yr) Benzene 71432 1159 58 Toluene 108883 1421 71 Ethylbenzene 100414 38 2 VRT 012 Xylenes 1330207 339 17 n-Hexane 110543 9303 472 224 TMP 540841 307 15 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 C _7,7. COLORADO Air Pollution Control Division Department of Public Health b environment 5) The emission levels contained in this permit are based on the following emission factors: Uncontrolled Emission CAS # Pollutant Factors Source lb/bbl NOx 0.0178 AP-42 CO 0.0454 AP-42 VOC 4.6714 HYSYS 71432 Benzene 0.0290 HYSYS 108883 Toluene 0.0355 HYSYS 100414 Ethylbenzene 0.0010 HYSYS 1330207 Xylene 0.0085 HYSYS 110543 n-Hexane 0.0355 HYSYS 540841 224 TMP 0.0077 HYSYS 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, HAP, n-hexane PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.qov/ Part 60: Standards of Performance for New Stationary Sources Page 9 of 10 CCOLORADO _ii__ Air Pollution Control Division Department of Public Health&Environment NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Coloielizie Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Kirk Bear Package#: '.399158 Received Date: 5/10/2019 Review Start Date: 7/15/2015 Section 01-Facility Information Company Name: Noble Energy Inc. Quadrant Section Township Range County AIRS ID: 523 NWSV 10 sN 54 Plant AIRS ID: 9CDA Facility Name: Sevier 810,615 Econo re T 5ti-R54W-S10 LOS Physical Address/Location: County: Type of Facility: Exploration&Production Well Pad What industry segment?Oil&Natural Gas Prod,tior&Processing Is this facility located in a NAAQS non-attainment area? If yes,for what pollutant? ❑ Carbon Monoxide(CO) 0 Particulate Matter(PM) O Ozone(NOx&50C) Section 02-Emissions Units In Permit Application Emissions Self Cart Engineering AIRS Point# Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks Permit Initial 011 Separator Venting Yes 590250566 1. Yes Issuance Permit Initial 012 Separator Venting Yes 19WE0567 1 Yes Issuance Section 03-Description of Project permit ofthese units Section 04-Public Comment Requirements Is Public Comment Required? No 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? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0 0 ❑ 0 0 0 Title V Operating Permits(OP) ❑ 0 0 0 ❑ 0 ❑ 0 Non-Attainment New Source Review(NANSR) 0 0 IS this stationary source a major source? No If yes,explain what programs and which pollutants heriS02 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ 0 0 0 ❑ Title V Operating Permits(OP) 0 0 0 ❑ 0 ❑ ❑ 0 Non-Attainment New Source Review(MANSE) ❑ 0 Separator`v'eotng Emissions Inventors , 011 Separator Venting 'Facility AIRS ID: 123 SC. Cr, County Plant Point Section 02-Equipment Description Details Detaled Emissions Unit Descrption: the lost pre "'* ' - "° -Emission Control Device Description: enzlesed combustor p, l0M. ' - ` Requested Overall VOC&HAP Control Efficiency A. Limited Process Parameter Gas meter Section el-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 7.62 MMscf per year Requested Permit LimiThroughput= 7.62 MMscf per year Requested Monthly Throughput- _ MMscf per month Potential to Emit(PTE)Throughput= 7.62 MMscf per year Process Control(Recycling) Equipped with aVRU 9rcee neural 000niH on when the VRU V Hyp re^as volume rhetic rode;to rho.'at=) Is VRU Process equipment: � ,n;-Idv and en nrll d.m.tot yrRl _.ta{6.l,r_2qu�,ictl Lim t»r,-w-=_ tid_._,_<- Secondary Emissions-Combustion Device(s)for Air Pollution Control Separateness Heating Value: 2129 Btu/scf Volume of waste gas emitted per BBL of liquidsthroughput: ....,scf/bbl calculated from promax process streams Section 04.Emissions Factors&Methodologies LP gas produced(7631scf/day)per bbl produced at tanks(1.17 gal/min) Description $6. X . , ;•7"4*1 "'I"' 99 sc₹fbbiwxcaicu,.ated[tom e""'" G,. iD IMW I :-.3t.35lib/Ih-mot Displacement Equation Ex=Q•MW•Xx/C Weight A Helium ....J direct from promax model CO2 N2 / methane ethane :LC9 Propane 6obutane , n-butane sopentane n-pentane cyclopentane n-Hexane cyclohexane Other Octanes heptan methylcyclohexane ' 224-TMP 7.30 Benzene Toluene 047 Ethylbenzene 0.00 Xylenes 0:11 C8*Heavies 0.43 Total VOCWt% Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (Ib/MMsct) (Gas Throughput) (Gas Throughput) Benzene i, 4.3 Toluene i,_t .,� Ethylbenzene �.,+. 4.3 xvlene - nom. n-Hexane 224 TMP N _ _ "Wiia e, Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM20 PM2.5 ] ca '". 1* sox _ t Oia NOR .9.06811 Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested PermR Limits Requested Monthly Limns Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PMIO 0,0 C,C 0 C 0 00 PM2.S 0.0 C. {I.≥'. J.C. __ __ 0 SOx C C, v. ! NOR 0Z __ P, 9.a' 34 VOC 249.3 2,3 12H 239.1 12.5 2137 CO u.a .5 2.3 2 l" Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (nos/year) fibs/Year) (ibs/year) Ilbs/year) (Ibs/year) Benzene ___. 2906 .+ Talus 21, 2.222 3S12 '5'_ Ethylbenzene '0b — 109 xylene 9/1 .._ 43 973 49 n-Hexane 233,'1' :l;ve.'. 1167 2.S350 116.7 224 TMP 0/ aJ SCH .. 3 of K:\PA\2019\19WEO566.CP1 ,ctparaTorVenting Emissions Inventory .. Section 06-Regulatory Summary Analysis Regulation 3,Parts A,(3 Regulation 7,Section XVII.B,C Regulation 7,Section XVII.B.2.e :.,. —.6. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughputto Monitor Compliance Does the company use srtespecificemission factors based on ages sample to estimate emissions? This sample should representthegas outlet of the equipment covered underthis AIRS ID,and should have been collected within one year of the application secetoed date.However,if the faclllly has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to we an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct.emission factor analysis to demonstrate that the emission factors are less than or equalto the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equalto 90 tons per year? �'f .v,_;.s:l If yes,the permit will contain: -An"Initial Testing Requirement"to collects si0especificgas 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 analysisto demonstratethat the emission factors are less than or equal to the emissions factors established with this application on en 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? :_ $ 'WA kW, If yes,the permit will contain and Initial compliancetest condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling y+ .:f'(/MW al iiralEgigiii t ingin e hgEliinMEMMM � MENIME ` marrznr wry-r Section 08-Technical Analysis Notes section us-Inventory see coding and Emissions Factors Uicgnnrolled Emissions AIRS Point# Process# scc code Pollutant Factor Control%Units 011 01 =. PM10 0.00 b/OIL:,uC5 PM2.5 0.00 IWMPo?ttCF 500 0.00 C 'b/Mnl15Cp NOx 14..07 4 IbiceSsbl5CF VOC 55442.3e 9S Ih./MIl4SCF CO 654.94 e ilnJhntnoCF Benzene 351.33 tS lb/PAM5CF - • Toluene SO0.Oi 9s 14/t.3N0SCF Ethylbenzene 14.3? 35 Ib/MMbCP Kylene 12??0 no its/MMSCF n-Hexane 3395¢.25 OS Irc!nMSCF 224IMP 105.70 _,. IhoMMSCF • 4 of 8 K:\PA\2019\19WE0S66.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B-APEN and Permit Requirements • ATTAINMENT 1. Are uncontrolled.actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.0.1.a)7 Yes' Source Req 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10TPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.31? co Source Req ISeurce requires e NON-ATTAINMENT 1. Are uncontrolledemissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section ll.D.1.a)7 Sty. 'Source Req 2 Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section 11.0.2)? .4_ Source Req Colorado Regulation 7,Section XVII 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,20147 ye_:.'Source is ISoss.is not mbject to Regulation 7.Sec".n f411.8.2.G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 10/11.0-Emissions Control Alternative Emissions Control(Optional Radiant a. Is thisseparator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? `'1The control Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply toe 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. Separatrn vent mg Emissions Inventory 012 Separator Venting 'Facility AIRS ID: "^' County Plant S Section 02.Eoulnment Description Details • Detailed Emssons Unit Description: 17,,,,,, w+�max€rt ' y Emission Control Device Description: enclosed comb IVY ;" .. r • Requested Overall VOC&HAP Control Efficiency • Limited Process Parameter -_ t" cy • Section 03-Processing Rate Information for Emissions Estimates • Primary Emissions-Separator Actual Throughput= 40,066.0:Barrels lbbil per year Requested Permit Li mit Throughput= 40,,000,0 Barrels lbbl)per year Requested Monthly Throughput= ..s:% MMsof per month • Potential to Emit'PTE)Throughput= ,:.-OC Barrels(bbl)per year Process Control(Recycling) ' Equipped with aVRU No -.::. „y., is VRUprocesseq t:uiPmen -.....:<.a,...<va 'icn � Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2E:7 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: i scf/bbl Section 04-Emissions Factors&Methedoleeles Description 'k 9TM x w MW j4734 lb/Ib-mot Displacement Equadan Ex=Q"MW"%t/C Weight% Helium CO2 .' N2 4.H? methane ethane 15,DB prepare 31(36 bobutane n-butane ':17:7?. isopentane '4.03 n-pentane cyclopentane -"XS n-Hexane1i'9 cyclohexane ':4134 Other hexanes heptanes metllylcyclohexane . 224-TMP Benzene L Toluene Ethylbenzene 0CV %Vlenes 0:15 Coo Heavies Total VOC WI% Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (15/bbl) (Liquid Throughput) (Liquid Throughput) VOC 4.660:71 .. Benzene 0.029941 Toluene 0.035479 Ethylbenzene 0.004949 %ylene .0.008464 n-Hexane 0.23203] 224TMP cu:,Ye I. Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 d L}fY§ SOx /-TAY. NOx 0.0680 " Y" CO 03100 -,.. qt Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) PM10 0.0 Or PM2.5 0.0 2 _.- SOx 0 0 0.0 Cf."Cf." R -C NOx 02 0.2 L v.2 VOC 93.2 93.2 + .. CO 0.7 C,7 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (lbs/year) libs/year) Benzene 1158 11553 V. 1158 uU Toluene 1419 1419 71 1419 11 Ethylbenzene 38 38 - 38 Uylene 339 339 17 339 -- n-Hexane 9231 9231 46_ 9281 = 224 TMP 306 306 a 306 _- 6 of 8 K:\PA\2019\19W EOS66.CP1 Section Oe-Regulatory Summary Analys-s Regulation 3,Parts A,B Regulation 7,Section XVII.B,G Regulation 7,Section XVII.B.2.e ._,:�- < ., - - (See regulatory applicability worksheet for detailed analysis) Sectioi11 • i9 a 404S4g WWI&/rrr 1 r Le dye' /rwr" �€ z��r .44;.•i :TWA /TT r� yF4 v N � ,Fri 8 ,fir .l / ✓,� h d' 74 // ' i r ° / ✓ _ i_. r is / its! 'Y / ,� Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurizedliouid sample(Sampled upstream of the equipment covered under this Alps ID)and process simulation to estimate emissions? §g" This sample should have been collected within one year of the application received date.However,if thefecility has not been modified(e.g.,no new wells brought on-line),then R may heappropriate to use an older site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to collect a site.specific liquid sample 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. Does the company request a control device efficiency greater than 95%for a flare or combustion device? lives,the permit will contain and init1l compliancenwt condition to demonstratethe destruction efficiency of the combustion device hosed on inlet and outlet concentration sampling k OET blWA I1N< rs,.x »� - c- Y' *;,ir,T's Cwa. afyc rt.. xs, .fs ,�'• `k''' g` ta'`"5,z `"„ 'u'.r' i �'� rah � �•.��. �� t "���,�'�.�-� `� �"' '� �c��� s k. �,.v"�s =� ��:�xz'�,,�.�`'k� '�'... '�, L A .yy' 4 �5' :5,•, s' :.'N A :.fi .ft ,"C '�2 F�, § - '� Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# sCC Code Pollutant Factor Control%Units 01 PB/I10 • PM2.5 -0.. SOx 0 91 NOx VOC ' , .. - .. . CO 3n?? Ctiai Benzene Toluene Ethylbenzene .. Xylem n-Hex ?T.?of - 224TMP z ha 7515 K:\PA\2019\19WE0566.CP1 • Separator Venting Regulatory Analysis Worksheet • Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Facilityottainmeno-arca status Ass not boon established yet ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.at7 - Yes I5ource Rea 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,MOO greater than 10 TPY or CO emissions greater than leier(Regulation 3,Part B,Section 11.0.317 Yea Source Req NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY(Regulation 3,Part A,Section ll.D.1.a)7 Ye; Source Req 2. Are total faulty uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greaterthan 10 TPY(Regulation 3,Part B,Section 11.0.21? Yes Source Req I4 Colorado Regulation 7,Section%VII 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? I50 [Source is re S Fr_n]Sa RlcnllVllya,G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section AUG-Emissions Control Alternative Emissions 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? Wittiatrho control Il tx control do.uim thfs issrt sub,c-- cV.m t.11."u.2.e Section%VII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document-does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the•language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as'recommend,""may," 'should,"and"can,"is intended to describe APCD interpretations and recommendations"Mandotorytenninology 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. Seporioor`Iti'T!'p Emissions Inventory 012 Separator Venting 123 012 Facility AIRS ID: -uA County Plant Pont Section 02-Euuinment Description Details Detailed Emissions Unit Description: 1t 6 ' $ ayay° • Emission Control Device Description: 0ucd cemb NC '� � n yyk�1.,s. Requested Overall VOC&HAP Control Efficiency%. Limited Process Parameter '(.iq'Tadlbrou hp t ,,, 4,...051.55-0'00°'' Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 40,000.6,.Barrels(bbl)per year Requested Permit Limit Throughput= 40,000.0.Barrels lbbll per year Requested Monthly Throughput= 3397 MMscf per month Potential to Emit(PTE)Throughput= Barrels(bbl)Per Year Process Control(Recycling) Equipped with aVRU V. Is VRUprocessegoipme t Secondary Emissions-Combustion Devi®is)for Air Pollution Control Separator Gas Heating Value: 2627 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 4S.scf/bbl Section 04-Emissions Factors&Methodologies Des rit 47.B4Iib/Iamol Displacement Equation Ex=4aMW'Xx/C Weight% Helium il 0 0 CO2 9i N2 .. methane ethane Propane Bobutane n-butane 6opentane n-pen cycl0pen[ane -.. n-Hexane cyclohexane Other hexa, heptanes methylcycloh exane 224-TMP J,�13 Benzene Toluene ... Ethylbenzene 4 XYlenes CB.Heavies ..0., Total VOC Wt% Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant lib/bbl) (tb/bbl) (Liquid Throughput) (Liquid Throughput) Benzene !(' f Toluene .yy Ethylbenzene l/Hr%; " Xylene _..._ 1 n-Hexane 224 TMP Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/bbl Emission Factor Source (Waste Heat Co::. usted) (Gas Throughput) PM10 PM2.5 #+ay.�v NDx NOx 80 CO 0.3100 s ' iI4t4[L a Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Crleria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/pearl (tons/year) (tons/year) PIMA 0.0 e.0 9.0 0.0 0.0 PM2.5 0.0 _. 0.0 0.3 0_l SO5 0.0 j 0..0 0.0 NOx 0.2 ..-_• 02 0.2 0.2 VOC 23 2 93- 4.2 CO 9.1 ...7 _r Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (I bs/year) Iibs/year) (ibs/year) (lbs/year) (16s/year) Bentene "`_58 1.152, Toluene .> 1419 Ethylbenzene _3 38 XVlene _. 339 17 n-Hexane 9281 2.24 224 TMP 300 1 of3 • K:\PA\2019\19WE0567.CP1 • • Section O6-Regulatory Summary Analysis Regulation 3,Parts A,R a2 Regulation 7,Section)(VII.B,G .. Regulation 7,Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysts( Section 07-Initial and Periodic Sampling:and Testing Requirements . • . ... . a ,p Y j 9E I! f p 15 y7 i.�v j t f '' ,d ,,3't- k' ' het' '✓ .s iltlftlrhgrirkallrnrtalrarirjlrggiastrtasTgopRSf E rcr 7 S ( ...., MMEOMP 1 111 11149111111 Ili" 111411 311 „ , Using liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample(Sampled upstream of the equipment covered under-this AIRS ID)and process simulation to estimate emissions? Thu sample should have beer collected within one year pttke applicailon receivetl date.However,'ifthefacilgy has not been modified(e.g.,no new wets brought on-line(,then it may be appropriate to use en older sitespecNic sample. IP ns,the permit will contain an'Initial Compliance"testing requirementio collect a si[zspedFlc liquid sample and conduct an emission factor analysts to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company requests conVoldm100 eRiciency greeterthan 95%for a flare or combustion device? If yes,the permit will contain and Initial compitancetest condiDon to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 00-Technical Analysis Notes Section 09-Inventory5CC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process 0 5CC Cade Pollutant Factor Control%Unite 012 01 ., .. Gas Dt Sw.tar Ory -e/trq "-apa:ation PM1D ih/DDO0isb PM2.5 ,. ib/300tihb • 50x G-t:0 „ ih(1000bb NOx 0.1v ., ibf300Obb VOC 45,2C-`,7 S I/IDDObb CO 3:.su 6/1.000bb Benzene '.4S thj1000bb Toluene ,.-.1 HO ;b(1000bb Ethylbenzene 5.95 — ib71000hb • Xylene 3 Lec 35 ,h/uODDDb • n-Hexane 232.03 lb/1000N, 224 TMP 7-oS SS IF,j1006bb • 2 of 3 X:\PA\2019\19WEo567.CP1 • Separator Venting Regulatory Analysis Worksheet • Colorado Regulations Parts A and B-OPEN and Permit Requirements has es.Wishod yet ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section llOlal7 Yez =.I5 uce Req 2. Are total facility uncontrolled VOC emissions greaterthan5 TPY, greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)? bet• .•Source Req ISOu NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section ll.0.la)7 Yes --<Source Req 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NC*greaterthan 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)? Yes.:=*'.-:':Source Req Colorado Regulation 7,Section XVII 1 Was the well newly constructed hydraulically fractured, ecompleted on or after August 1,2014? INo '�:.ISource is no ISc tda., Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G-Emissions Control Alternative Emissions Control(Optional Section)a. Is this separator controlled bye back-up or alternate combustion device(i.e.,not the prm Iary control device)that is not enclosed? I _IThe control &vice r n rth.se.'ar e Rsguinnon 7,satticixVII.Ce . Section XVII.B.2.e—Altemative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply toe 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 Ail Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself •:v'i'lJ 1 p 1p19 •41/4 C°P"E Gas Venting APEN - Form APCD-211 Co +°' Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30,days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ( AIRS ID Number: 123 /9CDA/ / ' I i D i a''t_'i1 acs r' d d permit am; ^5 1 Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: SEYLER 810,B15 ECONODE T5N-R64W-S10 L01 Site Location Site Location: NWSW SEC10 T5N R64W Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Denver, CO 80202 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E-Mail Address2: a.satterfield@nblenergy.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. f 3'4915b 1 , ' Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 0 Add point to existing permit ❑ Change permit limit O Transfer of ownership's 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 a Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: LP gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 2/21/2014 For new, modified, or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS Q Yes O No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP) Emissions? ❑ Yes Q No Is this equipment subject to Colorado Regulation No. 7, 0 Yes O No Section XVII.G? . 2 " w• o Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 4 - Process Equipment Information Q 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? O Yes ❑✓ No Vent Gas 2 29 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Requested: 113 084 bbl/year Actual: bb(/year Process Parameters5 Molecular Weight: 38.351765 VOC (Weight%) 64.68% Benzene(Weight%) 0.38% Vented Gas Toluene(Weight%) 0.49% Properties: Ethylbenzene (Weight%) 0.01% Xylene (Weight%) 0.13% n-Hexane (Weight%) 3.03% 2,2,4-Trimethylpentane(Weight%) 0.10% Additional Required Information: ❑ Attach a representative gas analysis(including BTEX£t n-Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis(including BTEX l3 n-Hexane, temperature, and r pressure) 5 Requested values will become permit Limitations. Requested limit(s)should consider future process growth. 3I `� Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.41079, -104.54514 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec) (Feet) Leed Indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap El Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) 0✓ Circular Interior stack diameter(inches): Other(describe): Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes O No Pilot burner Rating: MMBtu/hr Pollutants Controlled: Other: Description: Requested Control Efficiency: Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. if multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOX NOX CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions 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) (tons/year) (tons/year) PM 7.6 Ib/MMscf AP-42 0.01 0.01 SOx 0.6 lb/MMscf AP-42 0.00 0.00 NOX 0.068, 100 IJMMBtu Ib/MMscf AP-42 0.21 0.21 CO 0.31,84 ,b/MMBN ib,MMs f AP-42 0.25 0.25 VOC 65.4876,0.0055 ibbb IbiMNIscf Model,AP-42 9.12 • 0.47 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions6 Number Basis Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.3816 lb/bbl Model/AP-42 106 5 Toluene 108883 0.5003 lb/bbl Model/AP-42 139 7 Ethylbenzene 100414 0.0144 lb/bbl Model/AP-42 4 0 Xylene 1330207 0.1278 lb/bbl Model/AP-42 36 2 n-Hexane 110543 3.0657 lb/bbl Model/AP-42 860 50 2,2,4- 540841 0.1058 Ib/bbl Model/AP-42 29 1 Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. �. _ 5 I , c.:-'. ''' Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. ^ + A 1� j 05/07/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name(please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 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 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.gov/cdphe/apcd � c v 6 1 hr.,_ MAY 1 0 2019 , , °P"E Gas Venting APEN - Form APCD-2114t1 , t,CO ;r.. Air Pollutant Emission Notice (APEN) and { Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www,colorado.gov/cdphetapcd. 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: /1W6---05-67 AIRS ID Number: 123 /9CDA/ C) 2- t avn blank un._, N D has already assigned a permit r:and/ORS it) Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: SEYLER B10,615 ECONODE T5N-R64W-S10 L01 Site Location Site Location: NWSW SEC10 T5N R64W Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadwa Suite 2200 (Include Zip Code) y, Denver, CO 80202 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E-Mail Address2: a.satterfield@nblenergy.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. 3' 9156 1 Permit Number: AIRS ID Number: 123 /9CDA/TBD /TBD Section 2 - Requested Action El NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) o Change fuel or equipment O Change company name3 ❑ Add point to existing permit o Change permit limit 0 Transfer of ownership4 O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info& Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: VRT gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 2/21/2014 For new, modified, or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS Q Yes O No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? ❑ Yes El No Is this equipment subject to Colorado Regulation No. 7, Q Yes ❑ No Section XVII.G? Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing O 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? O Yes ❑✓ No Vent Gas 2677 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput s Requested: 113,084 bbl/year Actual: bbl/year Process Parameters5: Molecular Weight: 47.8547997 VOC (Weight%) 82.08% Benzene(Weight%) 0.51% Vented Gas Toluene (Weight%) 0.62% Properties: Ethylbenzene (Weight%) 0.02% Xylene (Weight%) 0.15% n-Hexane(Weight%) 4.08% 2,2,4-Trimethylpentane(Weight%) 0.13% Additional Required Information: O Attach a representative gas analysis(including BTEX& n-Hexane, temperature, and pressure) El pressure) a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 3 i Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 5 - Stack Information Geographical Coordinates (Lotitude/Longitude or UTM) 40.41079, -104.54514 Discharge Height Operator Temp. Flow Rate Velocity Stack ID No. Above Ground Level (•F) (ACFM) (ft/sec) (Feet) Leed Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward O Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): ❑Other(describe): Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: 0 VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: Combustion u-1 Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: Ca CR%,r) �,_ _ 4 I Permit Number: AIRS ID Number: 123 /9CDA/TBD Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SO„ NO CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions 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 7.6 lb/MMscf AP-42 0.01 0.01 SOx 0.6 Ib/MMscf AP-42 0.00 0.00 NO 0.068, 100 ,b/MM8N lb%MMscf AP-42 0.20 0.20 CO 0.31,84 Ib/MMBm,Ib/MMscf AP-42 0.19 0.19 VOC 103.699,0.0055 ibrobi,IblMMscf Model,AP-42 3.42 0.18 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units 6 Basis (AP-42, Emissions Emissions Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.6435 lb/bbl Model/AP-42 42 2 Toluene 108883 0.7889 lb/bbl Model/AP-42 52 3 Ethylbenzene 100414 0.0212 lb/bbl Model/AP-42 1 0 Xylene 1330207 0.1882 lb/bbl Model/AP-42 12 1 n-Hexane 110543 5.1599 lb/bbl Model/AP-42 346 24 2,2,4- 540841 0.1702 lb/bbl Model/AP-42 11 1 Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 5 I Permit Number: AIRS ID Number: 123 19CDA I TBD Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 1' i(405/07/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name(please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance [�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 or(303)692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Qov/cdphe/apcd cd �a>ce Hello