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HomeMy WebLinkAbout20202326.tiff COLORADO Department of Public DM Health&Environment RECEIVED JUL 17 2020 Weld County Clerk to the Board WELD COUNTY COMMISSIONERS 1154 0 St PO Box 758 Greeley, CO 80632 July 8, 2020 Dear Sir or Madam: On July 9, 2020, the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy, Inc. - DP 124 125 BB47-14 ECO SLW RANCH ST BB07 BB18 T5N R63W S7 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,' \, Jared Polls,Governor I Jilt Hunsaker Ryan,MPH, Executive Director ,„ -„ '. PubI Co; Rev;eGs) cc:pi.trP), U-CDs),PWGTM/ER/CH/CK') 2020-2326 0%/03/20 o6(3m) ©7/2.7/20 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Noble Energy, Inc. - DP 124 125 BB07-14 ECO SLW RANCH ST BB07 BB18 T5N R63W S7 L01 - Weld County Notice Period Begins: July 9, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Noble Energy, Inc. Facility: DP 124 125 BB07-14 ECO SLW RANCH ST BB07 BB18 T5N R63W S7 L01 Oil and gas exploration and production facility SESW Sec 7 T5N R63W Weld County The proposed project or activity is as follows: The applicant is requesting to permit equipment at an existing oil and gas exploration and production facility. The source is requesting to route flash gas from various equipment onsite to an enclosed combustor and to permit fugitive emission leaks. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's arialysis, and a draft of Construction Permit 20WE0170 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 „.„.„.• COLORADO Department of Public 1 °PH' Health&Environment C,, .-•:•r- 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 CONSTRUCTION PERMIT • Permit number: 20WE0170 Issuance: 1 Date issued: Issued to: Noble Energy, Inc. DP 124 125 BB07-14 ECO SLW RANCH ST BB07 BB18 T5N Facility Name: R63W S7 L01 Plant AIRS ID: 123/A0C1 Physical Location: SESW Section 7 T5N R63W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS, Emissions Control ID Point Equipment Description Description Condensate Flash gas venting from knock out tanks, Knockout 001 scrubbers, and other miscellaneous Enclosed Combustor Burners equipment onsite Fugitive emissions component leaks Fugitives 002 associated with the oil and gas exploration None and production facility This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 11 -r„������-'''',,,����� COLORADO 410 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such • construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion,of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type Condensate Knockout 001 --- --- 5.6 --- Point Burners Fugitives 002 --- --- 1.7 --- Fugitive Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. AIRS ID 002: The operator must calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended gas analyses, as required in the Compliance Testing and Sampling section of this permit. The operator must maintain records of the results of component counts and sampling events used to calculate Page 2 of 11 xF:•z COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado actual emissions and the dates that these counts and events were completed. These records must be provided to the Division upon request. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Condensate Knockout 001 Enclosed Combustor VOC and HAP Burners PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and;made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point Total gas venting to enclosed Condensate combustor from knock out tanks, Knockout 001 scrubbers, and other miscellaneous 2.5 MMSCF/yr Burners` equipment onsite Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. AIRS Point 001: The owner or operator must continuously monitor and record the total volumetric flow rate of gas vented from the knock out tanks, scrubbers and other miscellaneous equipment onsite using the flow meter. The flow meter must be calibrated and maintained per the manufacturer's specifications and schedule. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. AIRS ID 001: The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion Page 3 of 11 C :< COLORADO Air Pollution Control Division +iii►-� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. AIRS ID 001: The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 15. AIRS ID 002: This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2. The following requirements were determined to be RACT for this source. Facility AIRS Pollutant RACT Equipment ID Point Fugitives 002 VOC LDAR per Regulation 7, Part D, Section II.E 16. AIRS ID 002: Fugitive component leaks at this 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. 17. AIRS ID 002: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section II.E. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section II.B B 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 19. AIRS ID 001: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in Page 4 of 11 ,. COLORADO Air Pollution Control Division Department of Public Health&Envtrorrnent Dedicated to protecting and improving the health and environment of the people of Colorado order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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. AIRS ID 001: The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the combined gas vented from the knock out tanks, scrubbers, and other miscellaneous equipment onsite in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site- specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 21. AIRS ID 002: Within one hundred and eighty days (180) after issuance of this permit, the permittee shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC)and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self-certification process to ensure compliance with emissions limits. 22. AIRS ID 002: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "gas service," "heavy liquid service," "light liquid service" and "water/oil". The operator shall submit the results to the Division as part of the self- certification process to ensure compliance with emissions limits. Periodic Testing Requirements 23. AIRS ID 002: On an annual basis, the permittee shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 24. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 5 of 11 ,_ ,,,,f..... COLORADO Air Pollution Control Division OPF1£ Department of Public Health&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, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 25. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 26. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 27. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. Page 6 of 11 C _ ,,,,,,....:1 COLORADO 410 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 28. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 29. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 30. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator,or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 31. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 32. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issued to Noble Energy Inc. for: • Venting from knock out tanks, scrubbers, and Issuance 1 This Issuance other miscellaneous equipment onsite (AIRS ID 001) • Fugitive equipment leaks (AIRS ID 002) Page 7 of 11 •r,•:�Y- 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. Seer https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,411 71 Toluene 108883 1,149 57 Condensate Ethylbenzene 100414 825 41 Knockout 001 Xylenes 1330207 521 26 Burners n-Hexane 110543 7,528 377 2,2,4- 540841 803 40 Trimethylpentane Fugitives 002 n-Hexane 110543 43 43 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emissions for Point 001 include venting of flash gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite to the enclosed combustor, combustion of flash gas at the enclosed combustor and combustion of pilot light gas for the enclosed combustor. Total emissions are based on the sum of emissions from all three activities. Page 8 of 11 C ����•YYYY•,,r��- COLORADO 4^ Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Venting of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite to Enclosed Combustor: Weight Uncontrolled Controlled Fraction Emission Emission CAS # Pollutant of Gas Factors Factors Source (%) (lb/MMscf) (lb/MMscf) V0C 78.0 90,207 4,495.3 HYSYS 71432 Benzene 0.5 564.98 28.249 HYSYS 108883 Toluene 0.4 460.25 23.013 HYSYS 100414 Ethylbenzene 0.3 330.50 16.525 HYSYS 1330207 Xylene 0.2 208.69 10.435 HYSYS 110543 n-Hexane 2.6 3,015.3 151.02 HYSYS 540841 2, 0.0. 3 321.67 16.084 HYSYS Trimethylpentane Note: The controlled emissions factors br this point are based on a control efficiency of 95%. Combustion of Flash Gas from knock out tanks, scrubbers, and other miscellaneous equipment onsite: Combustion emissions from flash gas combusted at the enclosed combustor are calculated using the following emission factors and actual monthly volume of flash gas routed to the enclosed combustor. Uncontrolled Emission Factors CAS # Pollutant lb/MMscf Flash Gas Source N0x 167.35 AP-42, Ch 13.5 CO 762.91 AP-42, Ch 13.5 Permitted emissions are based on a heat content of 2,461 btu/scf. Combustion of Pilot Light: Combustion emissions from the pilct light are calculated using the following emission factors and most recent monthly volume of fuel to the pilot lights. The pilot light gas throughput shall be assumed to have a constant value of 0.04 MMBtu/hr for both burners. Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of operation. Uncontrolled Emission Factors CAS # Pollutant lb/MMBtu Source 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 002: The emission levels contained in this permit are based on the following emission factors: Component Gas Service Heavy Oil Light Oil Water/Oil Service Page 9 of 11 Cdirvz ! COLORADO . Air Pollution Control Division �l Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Connectors 5,891 500 1,954 1,185 Flanges 716 0 342 29 Open-ended Lines 6 0 0 0 Pump Seals 0 0 4 0 Valves 2,355 167 1,806 405 Other* 660 0 119 145 VOC Content (wt%) 40.0% 100% 100% 100% Benzene (wt%) 0.10% 0.25% 0.25% 0.25% Toluene (wt%) 0.05% 0. 13% 0. 13% 0. 13% Ethylbenzene (wt%) 0.05% 0. 13% 0. 13% 0.13% Xylenes (wt%) 0.05% 0. 13% 0. 13% 0.13% n-hexane (wt%) 0.50% 1.25% 1.25% 1.25% 2'2'4 0.05% 0. 13% 0. 13% 0. 13/° trimethylpentane *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches,instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): il Component Gas Service Heavy Oil Light Oil Water/ Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E-04 --- 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent extended gas analysis. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) AIRS ID 002: This source is subject to 40 CFR, Part 60, Subpart 0000a—Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Page 10 of 11 C�r��:•z.,� AOLORADO Air Pollution Control Division �i�� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: https://www.gpo.gov/fdsys/pleq/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, NOx PSD True Minor Source of: CO NANSR Synthetic Minor Source of: VOC, NOx 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 Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A- Subpart Z MACT 63.600-63.1199 Subpart AA- Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Colorado Air.Permitting ng Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Carissa Money Package#: 423666 Received Date: 12/26/2019 Review Start Date: Section 01-Facility Information Company Name: Noble Energy Inc' - Quadrant Section Township Range County AIRS ID: 123 SESW 7 5'a 63 Plant AIRS ID: A0C1 Facility Name: DP 124 125 6507-14 ECO S_. RANCH ST BB07 6518 T5N R63W S7101 Physical Address/Location: County: Weld County Type of Facility: Exploration&Production-Weil Pad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit:n=tiai 001 I Separator Venting idensate Knockout Burr Yes 20WE0170 1 Yes Issuance Permit₹nit,al 002 Fugitive Component Leaks Fugitives No 20`,VE0170 1 Yes issuance Section 03-Description of Project Noble is requesting to permit equipment-at an exploration and production site that commenced o tionl'-C/2019. Sections 04,05 8,06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? - No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOOv CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(P5D) Title V Operating Permits(OP) w J J ❑ Non-Attainment New Source Review(NANSR) '' J Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Colorado Air Permitting Project Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) _ Non-Attainment New Source Review(NANSR) • Seprator Venting Emissions inventory T Section OS-Administrative Information 'Facility AIRs ID: 123 AOCI. 001 County Plant Point Section 02-Equipment Description Details Venting of flash gas from knock out tanks,scrubbers and other inisiellun_ons equipment on site,: Detailed Emissions Unit Description: Enclosed, - - - - Emission Control Device Description: _ Requested Overall VOC&HAP Control Efficiency%: Limited Process Parameter !M.461:,� - x0"`Tt Gas meter �+%lRF< Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= MMscf per year Requested Permit Limit Throughput= 2S MMscf per year Requested Monthly Throughput= 0.2 MMscf per month Potential to Emit(PTE)Throughput= ->MMscf per year Secondary Emissions-Combustion Device(s)far Air Pollution Control Separator Gas Heating Value: 2461.0 Btu/scf Volume of wastegas emitted rvi f'r per BBL of, t'� � .liquids throughput: �� "5ss." scfi/bbl Control Device Pilot Fuel Use Rate: 40:0;scfh MMscf/yr 0.04166 • Pilot Fuel Gas Heating Value: gr(�*..:.1.000 Btu/sof Section 04-Emissions Factors&Methodologies Description Noble used one pressurized lipoid sample from a similar site to model emission„Ti_pressurized_liquid sample is labeled WR State WROS Econode,collected 6/8/2018 from the tiP separator.This sample is used as the inlet to the knockout vessel in a HYNIS model.In the model the_essay._is reduced keno 332 Asia to 16,12 psia.Noble used The stream composition of'Misc Vap to Burner 2'to estimate emissions. MW �"Ib/Ib-mol Displacement Equation Ex=Q*MW*Ex/C Weight Helium CO2 N2 methane ethane propane <,r isobutane 6 2 n-butane i93 isopentane ,.., n-pentane _ cyclopentane n-Hexane cyclohexane 1.2 Other hexanes heptanes methylcyclohexane 224-TMP C.3 Benzene C Toluene Ethylbenzene Xylenes CB+Heavies Total VOC Wt% 3 of8 K:\PA\2020\20WE0170.CP1 Separator Venting Emissions;rlvenror Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC Benzene .: _ H 5115 Toluene ..,53.1:;5 < . w' Ethylbenzene "73 .:1, 7i r.n-Hexane .._.,-3 _ 224 TMP 1, _— Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu( lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0£u55 14.336,1 3,..; ,.(. i ,„y w 3 PM2.5 0.9075 10.33x9 *-WritIVAlikePitti„),11ett.WW.,,mrpxr., SOx 0 0005 L4.476 ` NOx 0.0680 1.67.34.2B 'At 42 ,c t e:*1111V):,, , CO 0.3100 7,2 s 3 AR-44,14,W60 .l,7, Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput)PM10 G.ter A �."�;i _ 'FX', c3.4-2.(FM10/P 0°-I -4 PM2.5 0.577, .. SOx 0.:t:)C.5 $yk: YOrt,t . NOx '?SSr a�A-.- ,a a VOC 0,0Q5,4 5.3- CO 0,032- 8z 3^25 111..,,, 't, a 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) (lbs/month) PM10 _,.3 0_„ 0.3 ..., 0.1 a PM2.5 0,0 e3.0 0 r 3.0 0,9 4 SOx 0.=5 0-0 0.0 0.0 5 3 0 NOx ...t 0.0 7 0,23 0.2 3S VOC 1-'2,8. 3.0 0.0 112.8 5.5 953 CO 0.-3 u._ 0.97 1.0 165 Potential to Emit Actual Emissions Requested Permit limits Source's Values used it permit Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (Ibs/year) Benzene 147,8 0 0 1413 71 1411 71 Toluene 1158 0 _ 1110 58 1149 57 Ethylbenzene 34.- 0 339 42 825 41 Xylene 3-92 0 C 392 2> 521 26 n-Hexane 75.2f.: 0 4 7.551, 376 7528 377 224 TM air 9 E 810 ,_ 803 40 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B 5uurcz rentre a Jerrca Regulation 7,Part D,Section 11.6,F co . e i,burled to 3-ee1rAion 7,Part D,SecC,0.0.2,F Regulation 7,Part D,Section 11.8.2.e The cone el d_.,-re€r::7,i,,eparator is not sot ect to Regulation 7,Ps-'D S.c.,_' ."2,e (See regulatory applicability worksheet for detailed analysis) 4 of 8 K:\PA\2020\20WE0170.CP1 Separator Venting Emissions inventory Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gassample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-widepermitted emissions of VOC greater than ore equal to 40 tons ty- g q per year in the ozone nonattainment area OR are emissions greaterthan or equal to 90 tons per year in the ozone attainment area? 3 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 meta installed and operational upon startup of this point? If no,the permit wil 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 wil contain initial and periodic compliance testing in accordance with P5 Memo 20-02 rr A c >` : ¢, itli ✓ l n '3 i 4L r 4 c Ac x� r jz ' ici ,')4 ,, o /, ,,2 , CSoie Section 08-Technical Analysis Notes gas gas composition-vas'labeled"SLW BB07 Combilstor'and sampled 12/13/0__.Th,s sample did have a lower Noble included a sample n3 a similar site to show the model emissions are c,.,..=s,sa..� similar �_ U � ,._...d NAP wt%than'hF model.However,the scarce will still need to take an initial sit specific gas sample to enst.re the emission factors are appropriate. Noble also used an older O&M pfan that does not incia-d,e the thresholds for serious NAA.However,since facility wide emissions are below 40 fpy,the correct monitoring freque,,is id_rifled in the O&M Plan, Si Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) AIRS Point it Process 0 5CC Code Pollutant Uncontrolled Emissions Factor Control% Units 001 01 1i1..J0'V-»0 Hares PM10 19.4 0 Iw'yalisirscy PM2.5 19.4 500 1.5 .1 ibi MM6cF NOx .181.7 0 lb;MMScF VOC 90273.2 95 lb/MMSCP CO 774.9 0 Ib/MMSCF Benzene 567.3 95 Ids/₹,iMSC Toluene 463.1 9" lb/MMSCF Ethylbenzene 355.9 95 lb/MM5-t Kylene 196.8 95 lb/rulMscF n-Hexane 109.0,2 95. lb/MMSCS 224 TMP ,324.2 95 Ib/rv?s=_CF 5 of 8 K:\PA\2020\20 W E0170.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. 1 Colorado Regulation 9 Parts A and B-APEN and Permit Requirements is in the Non-Atyn.mane Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.a(? u�✓,dfl✓�ry', 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.3)2 Yea hour indicated taut s uces Is 1g the Non-Attainment Ares 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 Yes I Source Re 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,N0x greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)? .-s. Source Re ISau ce iequhosa perm!? Colorado Regulation 7,Part D.Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? )yes- (source Is! rggurgg is stlbloct Is iivgeiatcsc,7,Pont?,Soctloo 11,1,2,F Section 11.8.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section) a. Is this p t r controlledby a back-up or alternate combustion device(i.e.,not the primary control device)thetis not enclosed? Ihe:' 'The contr. I' • • ',..a for is n_t subject tc,Ra,.a-on Pa, Sce len Section 11.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.Mandatory terminology such as."must"and"required"are intended to describe controlling requirements wader 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. .:_dons:nvpnt:rry Section DI-Adminstrathe Information 'Facility AIRS IIIr�AOC Point002 onnryPlant Section 02 Eouloment Description Details Dossier,Emissions Unit Fugitive component leaks from components associated with an ell and gas Descriptor exdoration andpoductie facility Emission Control Device • Descripton°: Rion 3 ulna Pate Information trr Emissions Ertimates Thfs section Is notapplkabl tu fugitives. Section 04-Eml..Factors&Melhodoledes Regulation 7InormaPon Operating Hours: ::_EI_t hours/year Emss,mFacl4r Source Scree mg E.EPlu453AF43SU17Yabk20 Control Efficiency Soda: Hone. Sston 07 notes 1,2,3 3 far additional informa.n Calculations Emission Factor 0X931,- . Service - Component Type Count I source) -Control(%)Pdgrtant Mass Fraction Uncontrolled Controlled Table 24 Table 2.0 Emissions lipyl Emissions ltpy) GAS Connsslors 66911 00E-04 1,00E-05 0.0% VOC 40.00% - 2.20E-05 lb/lir/source 0.177 Flanges 716 .90E-04 5.70E-06 0.0% Benzene 0.1000% 1.26E-05 Iblhrls0urce 0.443 Open-Ended Lines 6 2.00E-03 1.50E05 0.0% Toluene 0.05% 3.31E-05 lbdr/source Pump Saab 0 .50E-04 0.0% Elhylbenzene "0.050% - 0.090,37':= 7.72E-04 din/source Gas(Relief valvesn01u215 Valves 2355 4,50E-03 2.50E-05 0.0% 404750 0.05% 3.0004'71 i7 5.51E-05.Iblhr/source comprssur seals) Other 660 .80E-03 1,20E-04 0.0% .Hexane 0.50% 0.0447711E- 2.85E-04 10/61/0001 e Relief Valves .80E-03 1,20E-04 0.0% 22,4-TMP' 0.050% 6700071 2.65E-0411/61/source — -- — — — Melhenol - _- -- — — — 1)25 — — — — -- Methyl MeoPlen Connectors 500 750E-02 7.50E-06 00% VOC Flanges — 3.90E-07 3.90E-07 0.0% Benzene 0,25% -. Open£nded Lines 7.20E-06 0.0% Toluene 0.13% -.. - TOT, ...Seals 00E. 0.0,400 0.0% Ebylbenzene 0.19% _ 0.330 Heavy Oil Valves 167 0.40E-06 0.40E-06 0.0% Xy6nes 0.13°e 0.596 Other ,;..i4.-,,.. .20E33 3.20E-05 0.0% n4l2nne 1.25% Relief Valves — — — — 2.2.4-TMP 0.13% .. — — — — — Methanol 0.00% — — — — 0.00% — — — Methyl Meopta, 0.00% LIQUID Connectors _ti/j6#iz 210E-04 9.70E-06 0.0% VOC 10030% .. 2.14E-05Iblhrlsoutce 0.153 Flangss 342"d 110E-04 2-40E-06 00% Benzene 0.2500%. - 529E-05 I015400urce 0,153 Open-Ended Li .0 1.40E-05 00% Toluene 0.13% 309E-05 lhfnrlsource Pumps v 4 5.10E-04 04% Elhylbenzene 0.130% - 1.12E-03 Ih/hr/sexed Light Oil Valves .₹6 - 2.503433 1.90E-05 0.0% Xylenes 0.13% - 4.19E-D5 IhMr/source Other Y(Y 750E-03 1.10E04 0.0% .Hexane 1.25% 2.43E-04 W./source Reiss-Valves `%6.... 7,50E03 1.10E-04 00% 22,4-TMP 0.13% 243E-04 ibssr/source / — — — — — Methanol 0.00% — — — — — H2S 0.00% — — — — — Methyl Mew prat 0.00% Connectors '9'319.80E-04 300E-05 00% VOC 10030% Flangs .2d"}°: 90E-06 2.90E-03 00% Benzene 0.2500% - • Open-Ended Lines 4.09.CE 230E-04 350E-06 00% Toluene 0.13% Pump al »6 r 240E-05 240E-05 00% Ehylbenzene 0.130% water/Oil Valves -29,4034, 9,80E-05 9.70E-06 00% Xylenos 0.13% — OIM1er //54Y;,- 1.40E-02 5,90E-D5 00% nHexane 1.30% -.... ReildValves — — — -- 2243MP 0.13% — — — — — Mehanol — — — — — H25 — — — — — Mebyl Meopta, 0 Section 05-Emission , Did derebrrequesl a buffer? Z s c'- ':_ Requested..(%) POIlntanl Uncontrolled Emissions Condolled Emisdons Source VOC by lb Screening EFs-EPA453R-93017 Table 2-8 291 TPY Benzene 3 bN IWyr r 3 Screening EFs-EP453IR-95-017Teb/e2-8 0004327 0.0043272 Toluene a bNr 4 Iblyr Screening EFs-EP2453IR-93017 Table 2-8 0.0022112 0.002211 Ethylbenzene s 03/yr -;'bNr Screening EFs-EPA4 7 3/R-95-01Table2-2 0.0022112 0.002211 Wanes 0 bNr 4 INvr Screening 6..61,45336..61,45333.954317017 Table 2-8 0.0022112 0,002211 - n-Hexa 0-6.02ne 14,bNr 13 lb/yr Screening EFs.EPPASS/R3S-017 Table 22 0.0216359 032163 2,24Th1F b/r 1 ibNr Screening EFs-EPA453R25-01722 0.0022112 0.002211 Methanol f_5 b/yr 4 p4r, Screening EFs-EPA-053Rd 4206 5-017 Tatia22 H2S 33e tr/yr =)Iblvr Screening EFs-EPA453R-03617 Table2-8 Methyl Merced. E.09 bhr 4Iblvr Screening EFs-EPA-4334935017 Table 22 Section 06-Reulato Summa Anal sts Reg. Review Regulation 3,P5/I Section IllD2 to riderminas RACT is rag,it04 Yak` -"l Reg6 Review 40 CFR.Pad 60,Subpart KKK to detell if....eta this source? 70 Review 40 CFF Pad 60,Subpart 0000/o cletemnef 605380 and/or 605381 Is app able? S11M1 .Subject to NSPS 00002 2., Peg.7 651/80 Sedan MEP lodel.-tinesLOAR1sapplicable? etre'V_ Aaanlonal Requlatoryeonsiaerations Section 11.0.1-Except as provided In paragraphs 2lhrough 6 below,no Monet or derail,of a source shall allow or cause the emission into the atmosphere of any air pollutant which kiln excess 0120%opacity.This standard is Regulation 1 based on 24 0Ansecullve opacity readings taken al 15.secon4 intervals for six minutes.The approved 15lerence lest method for visible emissions n,easuremenl is EPA Method 9(40 CFR,Part 60,Append..(July,1092))in all , subsections of Section II.Aand B of...Mahon. Section IA-No parson,wherever located,shall cause 0r allow,.emission 0l odorous Mating limits: any single source...to1 to result ft detectable odors which are measured In excess of the 005030 ng limits:Far areas R52260l00 usedyr1dominan0y far residenfal 0rmmmerdal pureesss It is a violation P..aretl i..after the odorous aft has been diluted with seven(7)or re..trot otle..air. Part AAPEN Requirements Calera Pollutant:Forcntsa pollutants,Be Pdlulent Emission Meanders required for,each individual emission point in a nonalainma,l ard.M1 uncontrolled.ual emissions of one ton peryar or more ofany individual cnteaa pollutant(pollutants are not summed)for which the area is non-attainment. - Applicant is required to file an APES since emissions exceed 1 tan per year VOC Part B—Construction Permit Exemptions Applicant Is required t0 obtain a permit since uncontrolled VOC emissions from this facility are greater Nan the2 SPY threshold(Reg.3,Part B) Is this source located in an ozone non-attainment areaor attainment maintenance area? If yes,is III source sublec4 b leak detection and repair ILDOR)requirements...ration 7,Session.I.F Regulation XII.G or 90 CFR,Pad 60,Subparts KKK,0000,or-0000a? mss; Part B,III.02-RACT requirements for new or modified minor sources This section of 1eg216tion 3 requires RACT for new 0r modified minor sources lasted in nonattsinment or attainment/maintenance areas.This source Is located In the 8-hour inane nonanalement area. The date of interest for determining whether the source Is new 0r modified is therefore November 20,2007 (the dale of the BAour ozone NA area designation).Since the fugitives will 6,6.5,510181.11524515 above,Mis source is considered"new or modified." This facilk is subject to NSPS 00006 as well as Regulation 7,Section)(VILE.Riming the teak detection and repair program per Reg 7 sa057es the RACT fequiremenis of Regulation 3.The permit will contln a cond.reflecting this determination. Is this source at an on2ore T3uml gaspmeessing plant-asdefnxl in 40 CFR.Pad MS31? '''NO' Old ba source cumm200200300=0243on,reconstruce00 or modification IS January 241984,and en or before August 23.2011? This source is not subject to NSPS KKK because the new equipment covered by this fugitive source will Regulation commence construction after August23,2011 and Is not located at a natural gas processing plant(see D'N?his seum000 120nces condors-lion,reconstruction,or modification aerAugust 23,2011 end on or before September 18,2015? No Source is not subject to NSPS 0000 because the new equipment covered by this fugitive source will commence construction after September 18,2015. Is this source baled in an ozone non-attainment area or attainment maintenance area? Yes Is this source al an onshore"natural gas pwoeaing plant"as damned in 40 CFR,Pad 60.631? No Facility is not classified as a natural gas processing plant Therefor,this source Is not subject to Regulation 1 Regula0onP Section OILS. Is the fear',claaOed as awell production facility of natural gas mmpressot station? Yes Since Es facil000 ciassl0ed as a well production facility,it is subject to Regulation?Section XVII.F. Is this source at a esaturd gas processing plan!"as defined in 40 CFR,Pad 53.761? No Is this facility considered a"major source"of HAP as specifically damned to 40 CFR,Pad 63.761 for sites kat are Ogl production field tacilhios? No Regulation 8 If you repand'You'la both questions above,further review if the provisions 0140 CFR,Pad 63 763"Equipment Leak Standards"apply? Source Is not subject to MALT HH because the facility Is classiged as a minor source of HAPs. DN this source commenceconsloclbn reconstruction,or modification alter September 10,2015? Yes Is This sourced a well etc,compras0r dation or onshore-natural gas proressing pian3 as defined to 40 CFR.Part NSPS 0000a fi0.5430a? >Yea This faIlity meets Me definition 0(a well production facility as defined by 40 CFR,Part 60.6430a. Therefore,the fugitive emissions at this facilely are subject t0 NSPS 0000, Secikno?-Technical Analysis Notes The component counts re estimated based on enGrteeringudgment The gas composition is based on a similar sites ondadjusted to be conseieative(gas sample from Hurley H 6110.Econode;sampled 8/13/2019)As a result,the permit ill containan initialcomplance test requiring that at...aid count of components and an real extended gas analysee As discussed above,this source Is subject to NSCS 0000a.However,this N5 P5 has not yet been edoptedrito Colorado Regulation 6.Ala result,the condition referencing NSPS 0000a will be addressed in the notes to permit holder section of the permit. The f ditty is an LOP site so itis subject to Regulation7,Section le/11.2 es well as MPS 0000a. Source.,using emission factors from table 2-e Nereening factorsjfrom EPA document Protocol for Equipment teak Emission Estimates.This is appropriate since components will be monitored In accordance with Section Nil EO0,. Section 08-inventory SCC Ceding and Emissions factors Uncontrolled AIRS Point# Processp SCC CodePolloknt Emmons Fatter Control It ,ounce 664.61164 Mk.'.' - tZ Varies by Varies by 002 01 ae, a 1 VOC component type component type Screening Eh-EPA-453/0-95-017 Table 2-8 Varies by Varies by Benzene\ component type component type Screening EF-EPA-453/8-9,017 Table 2-8 Varies by Varies by Toluene component type component Nee Screening EF-EPA-453/415,017 Table 2-8 Varies by Varies by Ethylbenzene component type component type Screening fins-EPA-453/8-95.017 Table 2-8 Varies by Varies by Xylene component type component type Screening EFs-EPA-053/0.-95-017 Table 2-8 Varies by Varies by miersoe component type component type Screening EF-EPA-053/0.-95-017Table2-8 Varies by Varies by 224-TRAP component type component Nee Screening EF-EPA-453/R-95-017 Table 2-8 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy,Inc County AIRS ID 123 History File Edit Date 6/23/2020 Plant AIRS ID AOC1 Ozone Status Non-Attainment Facility Name DP 124 125 BB07-14 ECO SLW RANCH ST BB07 BB18 T5N R63W S7 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 VOC HAPs VOC HAPs ID 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 20WE0170 Gas venting from knockout tanks, 0.2 112.8 1.0 6.1 0.2 5.6 1.0 0.3 New point 002 20WE0170 Fugitives 1.7 0.0 1.7 0.0 New point 003 GP02 .,380 bhp Cummins KTAI9GC 0.3 0.3 47.0 3.4 22.4 0.3 0.3 0.3 3.7 2.6 7.3 0.3 New GP02 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 FACILITY TOTAL 0.3 0.3 0.0 0.0 47.2 116.2 1.7 23.4 6.5 0.3 0.3 0.0 0.0 3.9 8.2 1.7 8.3 0.7 VOC: Syn Minor(NANSR and OP) NOx:Syn Minor(NANSR and OP) CO: True Minor(PSD and OP) HAPS: True Minor • Permitted Facility Total 0.3 0.3 0.0 0.0 47.2 116.2 1.7 23.4 6.5 0.3 0.3 0.0 0.0 3.9 8.2 1.7 8,3 0.7 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.3 0.3 0.0 0.0 3.9 8.2 1.7 8,3 Public comment required for new syn minor limits Total VOC Facility Emissions(point and fugitive) 9.9 Facility is eligible for GP02 because<45 tpy (D)Change in Total Permitted VOC emissions(point and fugitive) 9.9 Project emissions less than 25/50 tpy Note 1 Note 2 • • Page I of 2 Printed 6/23/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Noble Energy,Inc County AIRS ID 123 Plant AIRS ID A0C1 Facility Name DP 124 125 8807-14 ECO SLW RANCH ST BB07 BB18 T5N R63W 57 L01 Emissions-uncontrolled(lbs per year) POINT PERMIT 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 20WE0170 Gas venting from knockout tanks,scrubbers and other miscellaneous equipme 1411 1149 825 521 7528 803 6.1 002 20WE0170 Fugitives 9 4 4 4 43 4 0.0 003 GP02 380 bhp Cummins KTA19GC compressic 367 75 71 43 82 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.2 0.0 0.0 0.7 0.6 0.4 0.3 3.8 0.0 0.4 0.0 0.0 6.5 'Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0170 Gas venting from knockout tanks,scrubbers and other miscellaneous equipme 71 57 41 26 377 40 0.3 002 20WE0170 Fugitives 9 1 4 4 43 4 0.0 003 GP02 380 bhp Cummins KTA19GC compressic 367 75 71 43 82 0.3 ' 0.0 0.0 0.0 0.0 0.0 0n 0.0 0.0 0.0 TOTAL(tpy) 0.2 0.0 0.0 0.1 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.7 2 123A0C l 6/23/2020 4'6'C'26 Zp19 .z.:43,„C Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and CDPHE Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENS will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 24)IV E.:0 170 AIRS ID Number: /2_3 /A4)c I /oe I Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: DP124 125 8807-14 ECO SLW RANCH ST 8807 8818 T5N R63W S7 L01 Site Location: SESW SECT T5N R63W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadwa , Suite 2200 (Include Zip Code) y Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@nblenergy.com ' Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 423662 COLORADO I Permit Number: AIRS ID Number: Section 2 - Requested Action NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name3 0 Add point to existing permit O Change permit limit 0 Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info 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: Gas venting for flash gas from knockout tanks, scrubbers and other miscellaneous equipment onsite Company equipment Identification No. (optional): Condensate Knockout Burners For existing sources, operation began on: 12/06/2019 For new, modified, or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS nonattainment area? Yes 0 No Is this equipment located at a stationary source that is considered a Major Source of(HAP) Emissions? ❑ Yes No Is this equipment subject to Colorado Regulation No. 7, 0 Yes 0 No Section XVII.G? II, COLORADO L I NrMJ,6Bn„ t Permit Number: AIRS ID Number: Section 4 - Process Equipment Information I 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? El Yes O No Vent Value: Gas 2461 BTU/SCF Gas Venting Heating Value: Process Parameters: Requested: 2.5 MMSCF/year Actual: N/A MMSCF/year -OR- Liquid Throughput Process Parameters: Requested: bbl/year Actual: bbl/year Molecular Weight: 43.88 VOC (Weight%) 77.6292% Benzene (Weight%) 0.4879% Vented Gas Toluene(Weight%) 0.3975% Properties: Ethylbenzene(Weight%) 0.2854% Xylene(Weight%) 0.1802% n-Hexane(Weight%) 2.6041% 2,2,4-Trimethylpentane(Weight%) 0.2778% Additional Required Documentation: ❑ Attach a representative gas analysis(including BTEX& n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX& n-Hexane, temperature, and r pressure) 5 Requested values will become permit limitations or 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- 3 I : ''. �.� �� NealNb£�rrunment Permit Number: AIRS ID Number: / / Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.40885,-104.4837 ❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator Temp. Flow Rate Velocity Stack ID No. Above Ground Level (•F) (ACFM) {ft/sec) (Feet) Condensate Knockout 25.25 Variable Variable Variable 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): 48 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other(describe): 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: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: 3.68 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: LEED EC48 ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NSA Waste Gas Heat Content: 2461 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: 0.0208 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: % COLORADO 4 Permit Number: AIRS ID Number: / / Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes 0 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 Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SOX NO5 CO VOC Enclosed Combustor(s) 100% 95% HAPs Enclosed Combustogs) 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 1.0893 lb/MMscf AP-42 0.00 0.00 000 SOX 0.0860 lb/MMscf AP-42 0.00 0.00 0.00 NO. 181.7103 lb/MMscf AP42 0.23 0.23 0.23 CO 775.0825 lb/MMscf AP-42 0.97 0.97 0.97 VOC 90,207.2960 Ib/MMscf HYSYS/AP42 5.61 112.61 5.61 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 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 Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 564.9820 lb/MMscf HYSYS/AP-42 1,411 71 Toluene 108883 460 2485 lb/MMscf HYSYS/AP-42 1,149 57 Ethylbenzene 100414 330.5030 lb/MMscf HYSYS/AP-42 825 41 Xylene 1330207 208.6947 lb/MMscf HYSYS/AP-42 521 26 n-Hexane 110543 3.015.2773 lb/MMscf HYSYS/AP-42 7,528 377 2,2,4-Trimethylpentane 540841 321.6711 lb/MMscf HYSYS/AP-42 803 40 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. COLORADO .. newnn.m m rums Permit Number: AIRS ID Number: / / Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. ftUAcn S 12/20/2019 g ature of Legally Authori ed Person(not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 APCD-SS-B1 OR 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 1"ASSN COLORADO Fugitive Component Leak Emissions APEN Form APCD-203 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or locks 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-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)webste. 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.1. See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 2PoiEofro AIRS ID Number: rZ3 /Act cr /ot . Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: DP124 125 B807-14 ECO SLW RANCH ST B807 BB18 T5N R63W S7 L01 Site Location: SESW SECT T5N R63W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Address' 1625 Broadway, Suite 2200 (Include Zip Cade) 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 wilt require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided, 423663 �, ....O1 j r,===. Permit Number: AIRS ID Number: Section 2 - Requested Action O NEW permit OR newly-reported emission source(check one below) -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change process or equipment O Change company name3 O Add point to existing permit O Change permit limit ❑ Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source O 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. '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: 12/06/2019 For new or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Facility Types: 0 Well Production Facility ❑ 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. +2 COLORADO 2 • �w armx Permit Number: AIRS ID Number: Section 4 - Regulatory Information What is the date that the equipment commenced construction? 12/20/2018 Will this equipment be operated in any NAAQS nonattainment area? 0 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 0 Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? 0 Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? D Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑Yes No Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? ❑r Yes ❑ 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 livid 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. VOC Benzene Toluene Ethylbenzene Xylene n-Hexane 2,2,4 Stream (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Trime(wt%)ntane (wt%) Gas 40.00 0.10 0.05 0.05 0.05 0.50 0.05 Heavy Oil (or Heavy Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13 Light Oil (or Light Liquid) 100 0.25 0.13 0.13 0.13 1 .25 0.13 Water/Oil 100 0.25 0.13 0.13 0.13 1.25 0.13 Section 6- Geographical Information Geographical Coordinates (Lotitude/Longitude or UTM) 40.40885, -104.4837 Attach a topographic site map showing location 3 ccCOLORADO w. R, �e Permit Number: AIRS ID Number: Section 7- Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑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 ❑Monthly Monitoring- Control: 96%gas valve, 95% light liquid valve, 88%light liquid pump, 81% connectors ❑Q LDAR per Colorado Regulation No. 7, Section XVII.F ❑Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. i/ip. COLORADO MaJMb GnnmTen Permit Number: AIRS ID Number: Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑Table 2-4 was used to estimate ennissions7. ❑Table 2-8(< 10,000ppmv)was used to estimate emissions. Use the following table to report the component count used to calculate emissions.The component counts listed in the following table are representative of: El Estimated Component Count ❑Actual Component Count conducted on the following date: Equipment Type Service Open-Ended 9 Connectors Flanges Lines Pump Seals Valves Other Gas Counts 5,891 716 6 2,355 660 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 OH(or Heavy Liquid) Counts 500 167 Emission Factor 7.50E-6 8.40E-6 Units kg/hr/source kg/hr/source Light Oil(or Light Liquid) Counts 1,954 342 4 1,806 119 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 1,185 29 405 145 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 '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 tines, pump seals,or valves. 5 COLOR n.o..a.mmm wburADO Noa�N b 6nriwnmm. Permit Number: AIRS ID Number: / / Section 9 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: Actual Annual Emissions Requested Annual Permit Emission Pollutant CAS Limit(s)t° Number Uncontrolled Controlled" Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) voC 1.73 1.73 1.73 t°Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 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-criteriaO Yes D No pollutants(e.g. HAP - hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Actual Annual Emissions Requested Annual Permit Chemical Name CAS Emission Limit(s)t° Number Uncontrolled Controlled" Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (ibs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 2,2,4-Trimethylpentane 540841 Other: to 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 5 I rw7 NxW,bb 6n�,ran,m+t Permit Number: AIRS ID Number: / / Section 11 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. #(8.0441 12/20/2019 Sig ature of Legally Auth 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: E Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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-B 1 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 Hello