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Home My WebLink About20202138.tiff w COLORADO Department of Public Health Es Environment RECEIVED Weld County - Clerk to the Board MAY 182020 1150OSt PO Box 758 WELD COUNTY Greeley, CO 80632 COMMISSIONERS May 7, 2020 Dear Sir or Madam: On May 8, 2020,the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy, Inc - LD07-01 Econode. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe (, ), Jared Polls,Governor Jill Hunsaker Ryan,MPH, Executive Director I Fob l;C Rev;e j CC:PL(TP),HL(LK),PW(SMIER/CH/CK), 06(sK} 2020-2138 07/2 /20 o7/is/2o Mt.M,1, Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CD HE Comment Website Title: Noble Energy, Inc - LD07-01 Econode - Weld County Notice Period Begins: May 8, 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: LD07-01 Econode Oil and gas exploration and production facility NENE Sec 7 T9N R58W Weld County The proposed project or activity is as follows: Noble is requesting to permit two 500 bbl off-spec condensate storage tanks, sixteen 500 bbl produced water storage tanks, hydrocarbon loadout and venting from the heater treater/surge drums at a new oil and gas exploration and production 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 20WE0119 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 1 Department of Public I asHealth it Environment C D P H E Condensate Storage Tank(s) APEN '74' Form APCD-205 CO dr•, 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 wilt be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, 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 and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at:www.colorado.gov/pacific/cdphe/air-permits. 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: 20WE0119 AIRS ID Number: 123 /A0B7/008 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Noble Energy Inc. Site Name: LD07-01 ECONODE T9N-R58W-S7 L01 Site Location Site Location: NENE SEC7 T9N R58W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@nblenergy.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. COLORADO Form APCD-205-Condensate Storage Tank(s)APEN- Revision 3/2019 1 I •Y „ , Permit Number: 20WE0119 AIRS ID Number: 123 /AOB7/008 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Tanks (Off-Spec Tanks) Company equipment Identification No. (optional): N/A For existing sources,operation began on: 10/03/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: Exploration it Production(EftP)site O Midstream or Downstream(non E€tP)site Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? O Yes 0 No Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? ❑ Yes 0 No If"yes", identify the stock tank gas-to-oil ratio: N/A m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑✓ No 805 series rules?If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual ❑ Yes i No emissions≥6 ton/yr(per storage tank)? COLORADO Form APCD-205- Condensate Storage Tank(s)APEN - Revision 3/2019 2 I M ��"'�`"""�` tfna2lnb E:Nino+nmY Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/00$ [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbi/year) Condensate Throughput: N/A 464,645 From what year is the actual annual amount? N/A Average API gravity of sales oil: 36.07 degrees RVP of sates oil: 5.335(Modeled 0 9) Tank design: ❑✓ Fixed roof 0 Internal floating roof ❑ External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) Tanks 2 1,000 10/2019 10/2019 Wells Serviced by this Storage Tank or Tank Batten/6(EBEP Sites Only) API Number Name of Well Newly Reported Well SEE ATTACHED ❑ - - ❑- - ❑ 0 5 Requested values wilt become permit limitations. Requested limit(s)should consider future growth. 6 The EEtP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.7704, -103.9016 Operator Stack Discharge Height Above Temp. Flow Rate " Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) No Modeling Required N/A N/A N/A N/A Indicate the direction of the stack outlet: (check one) El Upward ❑Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) p Circular Interior stack diameter(inches): N/A ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): _. _. A r COLORADO Form APCD-205- Condensate Storage Tank(s)APEN - Revision 3/2019 3 I Ai& mow , Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/OO8 [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model:Zeeco, H R E C Combustion lLI Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2710.60 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: N/A MMBtu/hr Description of the closed loop system: 0 Closed Loop System Pollutants Controlled: 0 Other: Description: Control Efficiency Requested: Section 7- Gas/Liquids Separation Technology Information (EaP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3.18 psig Describe the separation process between the well and the storage tanks: Liquids go from well to HP separators, then to LP separators (heater treaters), then to surge drum, then to LACT. These tanks only take off-spec oil rejected from the LACT. Note,the enclosed combustor pilot emissions are accounted for in the heater treater/surge drum APEN because the combustors are shared. COLR Form APCD-205-Condensate Storage Tank(s)APEN - Revision 312019 4 ��''K. OADO Permit Number: 20WE0119 AIRS ID Number: 123 /AOB7/008 [Leave blank unless APCD has already assigned a permit ft and AIRS ID) Section 8 - 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 Control Pollutant Description of Control'Method(s) Efficiency (%reduction in emissions) V0C Enclosed Burner 95% NOx CO HAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s) Pollutant 5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units 1AP-42, Emissions Emissionse Emissions Emissions oasis Mfg.,etc.) (tons/year) (tons(year) (tons/year) (tons/year) VOC 0.2449 Ib/bbl HYSYS/AP-42 56.90 2.84 NOx 4.08E-4 lb/bbl AP-42 0.09 0.09 CO 1.86E-3 lb/bbl AP-42 0.43 0.43 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units 8 Number Basis (�4z, Emissions Emissions Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 1.13E-3 525 26 Toluene 108883 9.55E-4 444 22 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 5.6E-3 lb/bbl HYSYS/AP-42 2,600 130 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form APCD-205- Condensate Storage Tank(s)APEN - Revision 3/2019 5 I Alf' n m.su,w�ex+a.eni Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/008 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 04/29/2020 Signature of Legally Authorized Person(not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: Q 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 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-205- Condensate Storage Tank(s)APEN - Revision 3/2019 6 I A�`N. >�` CDPHE Produced Water Storage Tank(s) 11 APEN - Form APCD-207 CO to• Air Pollutant Emission Notice(APEN)and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks,condensate storage tanks, hydrocarbon liquid loading,etc.). In addition,the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. 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: `7.rP In/ 0/ t ci AIRS ID Number: / 'Alpe 71£>O [Leave uet ss APCD has areal awTer:rd a permit w amd AIRS ID] Section 1 -Administrative Information Company Name: Noble Energy Inc. Site Name: LD07-01 ECONODE T9N-R58W-S7 L01 Site Location Site Location: NENE SECT T9N R58W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.saigado@nblenergy.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes 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. /qtiv COLORADO Permit Number: AIRS ID Number: A?CD BSsi3 .1 a Goat z T a!'l AiRS!D} Section 2 - Requested Action 0 NEW permit OR newly-reported emission source 0 Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 O GP08 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership4 O Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info fc Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD•104)must be submitted. Section 3 -General Information General description of equipment and purpose: Produced Water Storage Company equipment Identification No. (optional): For existing sources,operation began on: 10/03/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration Et Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? O Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Are these storage tanks located at a commercial facility that accepts oil production ❑ Yes 0 No wastewater for processing? Do these storage tanks contain less than 1%by volume crude oil on an annual average basis? O Yes 0 No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) ❑ Yes 0 No 805 series rules?If so,submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual ❑ Yes 0 No emissions≥6 ton/yr(per storage tank)? CGt ORa OG .., .-.. .. .,�_.. {'._- .,,.. �_ 2 ) m _. Permit Number: AIRS ID Number: ,' 3;atre a c,,,i;ired a p,-.,r IT rt »aoc1 HP5(D, Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbllyear) Produced Water Throughput: N/A 3,000,000 From what year is the actual annual amount? N/A Tank design: Q Fixed roof O Internal floating roof 0 External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) PW Tanks 4 2,000 10/2019 10/2019 Temp Tanks 12 6,000 10/2019 10/2019 Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well - - SEE ATTACHED 0 0 0 0 s Requested values will become permit limitations.Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 -Stack Information Geographical Coordinates (Latitude/Longitude or 1/TM) 40.7704, -103.9016 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) (°F) (ACFM) (ft/sec) No Modeling Required N/A N/A N/A N/A Indicate the direction of the stack outlet:(check one) 0 Upward O Downward ❑Upward with obstructing raincap ❑Horizontal ['Other(describe): Indicate the stack opening and size: (check one) a Circular Interior stack diameter(inches): N/A ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): Permit Number: AIRS ID Number: [ �,s u ,ss APO t a,ahotdi ,:`:Z1 AP, Section 6 -Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed(emissions vented): Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model:Zeeco, H REC O Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 1496 Btu/scf Constant Pilot Light: ci Yes ❑ No Pilot Burner Rating: N/A MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7- Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —300,25,3 psig Describe the separation process between the well and the storage tanks: Liquids from the wells go to HP separators, LP separators (heater treaters), and surge drums and all feed into the produced water storage tanks. Note, the enclosed combustor pilot emissions are accounted for in the heater treater/surge drum APEN because the combustors are shared. �� C{Ji 33 aa0 Permit Number: AIRS ID Number: / / ADCD ha d::/assn ed i.. and..F'y ID Section 8 - 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 Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) V0C Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)s Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions8 Emissions Emissions Mfg.,etc.) (torts/year) (tons/year) (tons/year) (tons/year) VOC 0.2620 lb/bbl CDPHE 393.00 19.65 NOx 3.66E-3 lb/bbl AP-42 5.49 5.49 CO 1.67E-2 Ib/bbl AP-42 25.04 25.04 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Basis Units (AP-42, Emissions Emissions8 Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 21,000 1,050 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0220 lb/bbl CDPHE 66,000 3,300 2,2,4- 540841 Trimethylpentane 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 7 Attach produced water laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. 237 ._2 at r ,s; �,� 5 ( �Ny ci�aaoo c Permit Number: AIRS ID Number: / ! Wan.tity!.S5 APCD h7,1'r Ir ':1., ID; Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and wilt be operated in full compliance with each condition of the applicable General Permit. atiflakk 12/06/2019 Signature of Legally Auth: 'zed Person(not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: 0 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 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd ICZ10qADO C D P H E Hydrocarbon Liquid Loading APEN Form APCD-208 CO I' Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. 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,glycol dehydration unit, condensate storage tanks,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.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: 20WE0119 AIRS ID Number: 123 /A0B7/ 010 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Noble Energy Inc. Site Name: LD07-01 ECONODE T9N-R58W-S7 L01 Site Location Site Location: NENE SECT T9N R58W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E-Mail Address2: janessa.salgado@nblenergy.com ' 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. pp COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 I keg =V= Permit Number: 20WE0119 AIRS ID Number: 123 I A067/010 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly-reported emission source El Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Truck Loadout Company equipment Identification No. (optional): For existing sources,operation began on: 10/03/2019 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? O Yes El No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes ❑✓ No emissions? Does this source load gasoline into transport vehicles? ❑ Yes ❑✓ No Is this source located at an oil and gas exploration and production site? ❑✓ Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annualEl Yes O No average? Does this source splash fill less than 6750 bbl of condensate per year? ❑✓ Yes O No Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes El No MI COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 2 I AV 17.1== Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/010 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ✓❑ Condensate O Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 464,645 bbl/year Actual Volume Loaded: N/A bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions,complete the following: Saturation Factor: Average temperature of 51 .7925 of •6 bulk liquid loading: True Vapor Pressure: Asia C�W °F Molecular weight of G 7 lb/lb-mol 4.2957 displaced vapors: V If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 3 IeM M "„"n, Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/010 [Leave blank unless APCD has already assigned a permit/#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UM) 40.7704, -103.9016 Discharge Height Above Operator, Temp „ � )=lov+tRate Velocity Ground`-Level Stac�C ID No � ('F) (A-c-EM) No Modeling Required N/A N/A N/A N/A Indicate the direction of the stack outlet: (check one) O Upward ❑ Downward O Upward with obstructing raincap O Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): N/A ❑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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: q Used for control of: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model:Zeeco, H REC Combustion ❑ Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A °F Waste Gas Heat Content: 2710.60 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: N/A MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: % szaoa Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 3/2019 4 I cos,c"`°`p°" w ems caw,�nroe�s Permit Number: 20WE0119 AIRS ID Number: 123 /Aos7/010 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SOX NOx CO VOC Enclosed Burner 95% HAPs Enclosed Burner 95% Other: ❑ Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s) Pollutant 5 Source Uncontrolled Controlled Uncontrolled Controlled UncontrollediUnits (AP-42,; Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM 0.00 lb/bbl AP-42 0.00 0.00 SOx 0.00 lb/bbl AP-42 0.00 0.00 NOx 1.84E-4 lb/bbl AP-42 0.04 0.04 CO 8.40E-4 lb/bbl AP-42 0.20 0.20 VOC 0.1766 lb/bbl AP-42 41.02 2.05 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled. Service (CAS) Uncontrolled (AP 42 6 Units Emissions Emissions Basis Number Mfg.,etc-) (pounds/year) (pounds/year) Benzene 71432 7.08E-4 lb/bbl AP-42 329 16 Toluene 108883 5.98E-4 Ib/bbl AP-42 278 14 Ethytbenzene 100414 Xylene 1330207 n-Hexane 110543 3.50E-3 lb/bbl AP-42 1,627 81 2,2,4- Trimethylpentane 540841 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. vsriCOLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 3/2019 5 I Z,===' Permit Number: 2OWEO119 AIRS ID Number: 123 /A0B7/010 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 04/29/2020 Signature of Legally Authorized Person(not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance 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 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd ANT COLORADO Form APCD-208- Hydrocarbon Liquid Loading APEN- Revision 3/2019 6 I .: „==. 44, CDPHE 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. 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, btowdown events,among other events. If your emission unit does not fall into this category, there may be a more specific APEI%1 for your source(e.g.amine sweetening unit, hydrocarbon liquid loading,condensate storage tanks,etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.cotorado.Rov/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: 20WE0119 AIRS ID Number: 123 /A0B7 /011 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': Noble Energy Inc. Site Name: LD07-01 ECONODE T9N-R58W-S7 L01 Site Location: NENE SEC7 T9N R58W Site Location Weld County: NAICS or SIC Code: 1311 Hosting 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@nbienergy.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. COLORADO Form APCD-211 -Gas Venting APEN - Revision 3/2019 1 I Al's""= Permit Number: 20WE0119 AIRS ID Number: 123 /AOB7/011 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Add point to existing permit O Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info ft Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Heater treater and surge drum gas streams Company equipment Identification No. (optional): For existing sources,operation began on: 10/03/2019 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 hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS O Yes 0 No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, / Yes ❑ No Section XVII.G? ••• +COLORADO Form APCD-211 - Gas Venting APEN - Revision 3/2019 2 o Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/011 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4- Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: 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 ❑ No Vent Ga 2780 BTU/SCF Gas Venting Heating Value: Process Parameters5: Requested: 10.00 MMSCF/year Actual: N/A MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters5: Molecular Weight: 49.60 VOC (Weight%) 88.2009% Benzene(Weight%) 0.4551% Vented Gas Toluene(Weight%) 0.4104% Properties: Ethylbenzene(Weight%) 0.0739% Xylene(Weight%) 0.2114% n-Hexane(Weight%) 2.2928% 2,2,4-Trimethylpentane(Weight%) 0.0259% Additional Required Information: ❑✓ Attach a representative gas analysis(including BTEX Et n-Hexane,temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX 8 n-Hexane, temperature,and pressure) 5 Requested values wilt become permit limitations. Requested limit(s)should consider future process growth. COLORADO Form APCD-211 -Gas Venting APEN - Revision 3/2019 3 I ANY s� Permit Number: 20WE0119 AIRS ID Number: 123 /AOB7/011 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.7704, -103.9016 hDischarge�Height !'- ,� N i� 7'31 operator Temp Flow Rate ;Velocit ��ff Above Ground Level Stalk)D Nb (Feet) ("FJ {siC(a41Jt• r , i l c) No Modeling Required N/A N/A N/A N/A Indicate the direction of the stack outlet: (check one) El Upward ❑Downward ❑Upward with obstructing raincap O Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ,/❑Circular Interior stack diameter(inches): N/A O 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: ❑ VRU: Requested Control Efficiency: VRU Downtime or Bypassed: % Pollutants Controlled: VOC, HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: Zeeco, HREC rm Combustion Requested Control Efficiency: 95 LLI Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2780 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0.1 95 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: 'Cfl.ORA@O Form APCD-211 - Gas Venting APEN - Revision 3/2019 4 J �,Nuno Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/011 [Leave blank unless APCD has already assigned a permit"and AIRS ID] Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): 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? N/A Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Units (AP-42, Emissions Emissions° Emissions Emissions Basis Mfg•,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM 1.2728 lb/MMscf AP-42 0.01 0.01 SOX 0.1005 lb/MMscf AP-42 0.00 0.00 NOX 205.8185 lb/MMscf AP-42 1.03 1.03 CO 876.0110 lb/MMscf AP-42 4.38 4.38 VOC 115,463.0189 lb/MMscf HYSYS,AP-42 577.32 28.86 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service (CAS) Uncontrolled (AP-42, Emissions Emissions Units 6 Number Mfg.,etc.) (pounds/year) (pounds/year) Benzene 71432 595.5767 Ib/MMscf HYSYS/AP-42 5,956 298 Toluene 108883 537.1122 lb/MMscf HYSYS/AP-42 5,371 269 Ethylbenzene 100414 96.6862 lb/MMscf HYSYS/AP-42 967 48 Xylene 1330207 276.6828 Ib/MMscf HYSYS/AP-42 2,767 138 n-Hexane 110543 3,000.8481 lb/MMscf HYSYS/AP-42 30,008 1,503 2,2,4- 540841 33.8955339 17 Trimethytpytpentane lb/MMscf HYSYS/AP-42 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. IEwa COLD F,ZnA.Di> Form APCD-211 -Gas Venting APEN - Revision 3/2019 5 < Permit Number: 20WE0119 AIRS ID Number: 123 /A0B7/011 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 04/29/2020 Signature of Legally Authorized Person(not a vendor or consultant) Date • Janessa Salgado Environmental Engineer Name(please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 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.gov/cdphe/apcd COLORADO Form APCD-211 -Gas Venting APEN - Revision 3/2019 6 I ��i , ,:.M COLORADO . Air Pollution Control Division COPHE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0119 Issuance: 1 Date issued: Issued to: Noble Energy Inc. Facility Name: LD07-01 Econode T9N-R58W-S7 L01 Plant AIRS ID: 123/A0B7 Physical Location: NENE Section 7 T9N R58W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Two (2) 500 bbl fixed roof storage COND TK 008 vessels connected via liquid manifold Enclosed Combustor for off-spec condensate Four (4) 500 bbl fixed roof storage PW TK 009 vessels connected via liquid manifold Enclosed Combustor for produced water Loadout 010 Hydrocarbon loadout to tank trucks Enclosed Combustor Heater Venting from two (2) heater treaters Treater and 011 Enclosed Combustor Surge Drum and one surge drum This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 14 -M.µ<z- COLORADO Mr Pollution Control Division CDANE Department of Publtc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 2. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months 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 I.F.4.) ) 3. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.), Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type COND TK 008 --- --- 2.8 --- Point PW TK 009 --- 5.5 19.7 25.0 Point Loadout 010 -- 2.1 --- Point Heater Treater and 011 --- --- 28.9 4.4 Point Surge Drum Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 14 "•z- COLORADO 4440 • Air Pollution Control Division CDPME Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled COND TK 008 Enclosed Combustor VOC and HAP PW TK 009 Enclosed Combustor VOC and HAP Loadout 010 Enclosed Combustor VOC and HAP Heater Treater 011 Enclosed Combustor VOC and HAP and Surge Drum PROCESS!LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division,for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit COND TK 008 Off-spec condensate throughput 464,645 bbl PW TK 009 Produced water throughput 3,000,000 bbl Loadout 010 Off-spec condensate throughput 464,645 bbl Heater Treater and 011 Total gas from heater treater 10.0 MMSCF Surge Drum and surge drum venting to flare The owner or operator must monitor monthly process rates based on the calendar month. 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. 9. AIRS ID 011: The owner or operator must continuously monitor and record the total volumetric flow rate of gas vented from the heater treater and surge drum venting to the flare 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 Page 3 of 14 0 - .... COLORADO ` Y Air Pollution Control Division CDPHE Department of Pubic Health t,Environment Dedicated to protecting and improving the health and environment of the people of Colorado 10. 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. AIRS ID 008, 009 and 011: The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section 11.8.2. 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. 13. AIRS ID 008 and 009: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. AIRS ID 008 and 009: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. AIRS Point 010: Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 16. AIRS Point 010: Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 17. AIRS Point 010: The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): Page 4 of 14 0 .• -';. COLORADO 44"Y Air Pollution Control Division COPHE Department of Public Wealth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, 18. AIRS Point 010: The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • ' If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which ''loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 19. AIRS Point 010: The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. Page 5 of 14 a COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Records of the annual training program, including the date and names of persons trained. 20. AIRS Point 010: Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 21. AIRS Point 011: The separation equipment 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. 22. 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 a MAINTENANCE.REQUIREMENTS 23. 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 OFtM 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 24. AIRS ID 008: Within one hundred and eighty days (180) after issuance of this permit, the owner or operator must complete site specific sampling including a compositional analysis of the pre- flash pressurized off-spec condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. The pre- flash pressurized off-spec condensate sample must be obtained from the outlet of the surge drums and prior to the inlet of the off-spec tanks. Testing must be in accordance with the guidance contained in PS Memo 14-03. Results of the analysis must be used to calculate site- specific emission factors for the pollutants referenced in this permit (in units of lb/bbl condensate throughput) 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 Page 6 of 14 a . . COLORADO 4440 Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado "Notes to Permit Holder" 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. ADDITIONAL REQUIREMENTS 25. 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. 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. 26. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 27. 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. 28. 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 Page 7 of 14 •,:,,,....- COLORADO • Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 29. 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. 30. 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. 31. 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. 32. 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. 33. 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 Page 8 of 14 aw -r.4,.,. COLORADO IIP j Air Pollution Control Division ‘"I'lliP Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issued to Noble Energy Inc. for • Two 500 bbl off-spec condensate tanks Issuance 1 This Issuance • Four 500 bbl produced water tanks • Hydrocarbon loadout to tank trucks • Venting from two heater treaters and one surge drum Page 9 of 14 •7., COLORADO - Air Pollution Control Division CDPHE Department of Pubic 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 525 26 Toluene 108883 444 22 COND TK 008 Ethylbenzene 100414 75 4 Xylenes 1330207 212 11 n-Hexane 110543 2,600 130 Benzene 71432 21,000 1,050 PW TK 009 n-Hexane 110543 66,000 3,300 Benzene 71432 329 16 Toluene 108883 278 14 Loadout 010 Ethylbenzene 100414 47 2 Xylenes 1330207 133 7 n-Hexane 110543 1,628 81 Benzene 71432 5,956 298 011 Toluene 108883 5,371 269 Page 10 of 14 r,•".z COLORADO i Air Pollution Control Division CDPHt Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Heater Ethylbenzene 100414 967 48 Treater and Surge Drum Xylenes 1330207 2,767 138 n-Hexane 110543 30,008 1,503 2,2,4- 540841 339 17 Trimethylpentane 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 008: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0004 0.0004 AP-42, Ch 13.5 CO 0.0019 0.0019 AP-42, Ch 13.5 VOC 0.2449 0.0122 Source 71432 Benzene 0.0011 0.00006 Source 108883 Toluene 0.0010 0.00005 Source 100414 Ethylbenzene 0.0002 0.00001 Source: '. 1330207 Xylene 0.0005 0.00002 Source 110543 n-Hexane 0.0056 0.0003 Source Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 009: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0037 0.0037 AP-42, Ch 13.5 CO 0.0167 0.0167 AP-42, Ch 13.5 VOC 0.262 0.0131 CDPHE 71432 Benzene 0.0070 0.0004 CDPHE 110543 n-Hexane 0.022 0.0011 CDPHE - Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 010: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0002 0.0002 AP-42, Ch 13.5 CO 0.0008 0.0008 AP-42, Ch 13.5 VOC 0.1766 0.0088 AP-42, Ch 5.2 71432 Benzene 0.0007 0.00004 HYSYS 108883 Toluene 0.0006 0.00003 HYSYS 100414 Ethylbenzene 0.0001 0.00001 HYSYS Page 11 of 14 C .r '�. COLORADO C- ry i Air Pollution Control Division Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 1330207 Xylene 0.0003 0.00001 HYSYS 110543 n-Hexane 0.0035 0.0002 HYSYS The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.2957 psia M (vapor molecular weight) = 67 lb/lb-mot T (temperature of liquid loaded) = 511 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the HYSYS model for the flash vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 011: Emissions for Point 011 include venting of gas from the heater treater and surge drum to the flare, combustion of heater treater and surge drum gas at the flare and combustion of pilot light gas for the flare. Total emissions are based on the sum of emissions from all three activities. Venting of Heater Treater and Surge Drum Gas to Flare: Weight Uncontrolled Controlled Fraction Emission Emission CAS # Pollutant of Gas Factors Factors Source (%) (lb/MMscf) (lb/MMscf) VOC 88.2 115,463 5,772.4 HYSYS 71432 Benzene 0.5 595.58 29.779 HYSYS 108883 Toluene 0.4 537.11 26.856 HYSYS 100414 Ethylbenzene 0.1 96.686 4.8343 HYSYS 1330207 Xylene 0.2 276.68 13.834 HYSYS 110543 n-Hexane 2.3 3,000.8 150.33 HYSYS 540841 2'2'4 0.03 33.896 1.6948 HYSYS Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 12 of 14 a ..,. . COLORADO 4.41 Air Pollution Control Division CDPME Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Combustion of Heater Treater and Surge Drum Gas: Combustion emissions from heater treater and surge drum gas combusted at the flare are calculated using the following emission factors and actual monthly volume of heater treater and surge drum gas routed to the flare. Uncontrolled Emission Factors lb/MMscf heater treater and CAS # Pollutant surge drum gas Source NOx 189.04 AP-42, Ch 13.5 CO 861.80 AP-42, Ch 13.5 Permitted emissions are based on a heat content of 2,780 btu/scf. Combustion of Pilot Light: Combustion emissions from the pilot light are calculated using the following emission factors and most recent monthly volume of fuel to the pilot lights. The pilot light gas throughput shall be assumed to have a constant value of 0.195 MMBtu/hr for both burners.Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by the flare monthly hours of operation. Uncontrolled Emission Factors CAS # Pollutant lb/MMBtu Source NOx 0.098 AP-42, Table 1.4-4 CO 0.0824 AP-42, Table 1.4-4 Permitted emissions are based on a heat content of 1,000 btu/scf. 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, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Not applicable 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 Page 13 of 14 -i.r. COLORADO Air Pollution Control Division a �Y n COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 14 of 14 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Carissa Money Package #: 422682 Received Date: 12/6/2019 Review Start Date: 3/17/2020 Section 01 - Facility Information Company Name: Noble Energy Inc. Quadrant Section Township Range County AIRS ID: 123 [_ 5 • Plant AIRS ID: A0B7 Facility Name: LD07-01 Econode T9N-R58VW-57 l01 Physical Address/Location: NENE quadrant of Section 7, Township 9N, Range 58W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Productior & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Leave Blank - For Division Use Only Permit # AIRs Point # Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit Initial 008 Condensate Tank COND Tank Yes 20WE0119 1 Issuance Permit Initial 009 Produced Water Tank PW Tank Yes 20WE0119 Issuance Permit Initial 010 Liquid Loading Condensate Loadout Yes 20WE0119 issuance - -~ �-_- - --� --_- Permit Initial 011 Separator Venting ter Treater and Surge C 20WE0119 Issuance Section 03 - Description of Project Noble is requesting the initial permit issuance for a new oil and gas exploration and production well pad which commenced operation 10/3/2019. Noble stated the site is located outside the non-attainment area (NAA) boundary. I confirmed the well locations on the COGCC GIS map and confirmed these locations are north of the NAA boundary. Noble provided revised emissions estimates on 4/29/2020 for Points 008, 010 and 011. Sections 04, 05 & 06 - For Division Use Only Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Y'c If yes, indicate programs and which pollutants: SO2 NOS CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) O O O © ❑ ❑ Title V Operating Permits (OP) ❑ ❑✓ ❑ O O Non-Attainment New Source Review (NANSR) ❑ ❑ Is this stationary source a major source? Nc If yes, indicate programs and which pollutants: SO2 NOx Co VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) O O ❑ O ❑ ❑ Title V Operating Permits (OP) ❑ O O O ❑ O O O Non-Attainment New Source Review (NANSR) O ❑ Condensate Storage Tank(s) Emissions Inventory Section 01 - Administrative Information 123 A087 008 Facility AIRs ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two 500 bbl storage vessels connected via liquid manifold for off-spec condensate Description: Emission Control Device Enclosed flare Description: Requested Overall VOC & HAP Control Efficiency %: 95.0 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Barrels (bbl) per year Requested Permit Limit Throughput = 464,645.0 Barrels (bbl) per year Requested Monthly Throughput = 39463.0 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = 464,645.0 Barrels (bbl) per year 4794275 modeled bbl/yr 13135 4617250 1273 232322.5 Secondary Emissions - Combustion Device(s) 464645 Heat content of waste gas = 2710.6 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 2.2 scf/bbl 17.48236174 Actual heat content of waste gas routed to combustion device = 0.0 MMBTU per year Requested heat content of waste gas routed to combustion device = 2,790.2 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 2,790.2 MMBTU per year Control Device `Pilot light is included in with the heater treater/surge drum venting Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 0.2448 0.0122 Benzene 0.0011 0.00006 Toluene 0.0010 0.00005 Ethylbenzene 0.0002 0.00001 Xylene 0.0005 0.00002 n-Hexane 0.0056 0.0003 . . . 224 IMP 0.0000 Control Device U-icontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0075 0.0000 PM2.5 0.0075 0.0000 !s..: . • _ . . , NOx 0.0680 0.0004 t CO 0.3100 0.0019 '." Pilot Light Emissions U icontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat (Pilot Gas Cambusted) Throughput) PM10 _ 0.0000 PM2.5 0.0000 NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants U icontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (:ons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 56.9 0.0 0.0 56.9 2.8 483.0 PM10 0.0 0.0 0.0 0.0 0.0 1.8 PM2.5 0.0 0.0 0.0 0.0 0.0 1.8 NOx 0.1 0.0 0.0 0.1 0.09 16.1 CO 0.4 0.0 0.0 0.4 0.4 73.5 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled :lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 525.0 0.0 0.0 525 26 Toluene 445.6 0.0 0.0 446 22 Ethylbenzene 77.5 0.0 0.0 77 4 Xylene 220.3 0.0 0.0 220 11 n-Hexane 2600.0 0.0 0.0 2600 130 2 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Condensate Storage Tank(s)Emissions Inventory 224 TMP I 0.0 I 0.0 I 0.0 ' 0 I 0 3 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Condensate Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage Talk is not subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Ta ik is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Talk is not subject to NSPS 0000a Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? No If yes, are the uncontrolled act Jal or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. But sample is not immediately prior to tanks so an initial sample prior to the tanks is required. If no, the permit will contain ai "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? T_ , If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Noble submitted a HYSYS model based on five site-specific pressurized liquids sample collected 11/8/2019. The pressurized liquids samples were then used as the inlets toestimate emissions from the heater treater (AIRS ID 011), :he surge drums (AIRS ID 011) and then the off-spec tanks which are covered by AIRS ID 008. For each of the pressurized liquids samples, the source created a compound for the decanes+ portion of the stream. Noble explained in HYSYS you can either use a standard component with standard critical properties (MW and ideal liquid density) or you have the option of creating your own specific component Because samples are provided with Decanes + lumped together, it is not always appropriate to assume that n-Decane is representative of the sample specific Decanes +. The samples provide the specific Decanes + MW and relative specific gravity, so Noble created the specific Decanes + components in each model liquid stream for each sample. The model assumes a pressure of 117.1 psia into the heater treater, 25 psig at the outlet of the heater treater, and 3 psig at the outlet of the surge drums. The pressure drop at the off-spec tanks is then from 3 psig to 0 psig. The model in the Dec 2019 application showed no flashing from the tanks. I asked Noble about this assumption. Noble stated in an email 4/22/2020 that they do not have a way to ensure there aren't any flash emissions. Noble monitors tie pressure at the surge drum via automation, so for the initial permit application, Noble pulled all of the pressure readings from the surge drum and the average value was 2.39. So Noble used a value of 3 psig in the model. Noble pulled additional pressure readings again now that there aremore data and the average value is 3.18. Noble stated at 3.18 psig, the model predicted 8.128e-002 Mscf/hr of flash at the tank. I calculated an additional 39 tpy uncontrolled VOC emissions based on this flow so I asked Noble to revise the emissions. Noble provided revised emissions on 4/29/2020. Noble also included working and breathing emissions based on Tanks 4.0.9d. I confirmed the working and breathing emissions are based on assuming petroleum distillates with RVP 10, and for Denver, CO. The throughput was based on the requested throughput divided by 2, the number of tanks. I asked Noble if the tanks collect liquids from other sites. Noble confirmed the tanks only receive liquids produced at this site. Thus, the tanks are eligible for the NSPS Kb exemption. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process U SCC Code Pollutant Factor Control % Units 01 4-04403.4" r z PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 Ib/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallons condensate throughput VOC 5.8 95 lb/1,000 gallons condensate throughput CO 0.04 0 lb/1,000 gallons condensate throughput Benzene 0.03 95 lb/1,000 gallons condensate throughput Toluene 0.02 95 Ib/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.01 95 lb/1,000 gallons condensate throughput n-Hexane 0.13 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 Ib/1,000 gallons condensate throughput 4 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Condensate Tank Regulatory Analysis Worksheet The regulatory requirements below are determiied based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Requires an APEN. Go to 2. Is the constructioi date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? No Go to next question 3. Are total facility uncontrolled VOC emissions greater flan 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Yes Source Requires a permit Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutant; from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 51 PY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source is in the Attainment Area Colorado Regulation 7. Section XII.C-F 1. Is this storage tark located in the 8-hr ozone control atea or any ozone non-attainment area or attainment/maintenance area? No Storage Tank is not subject to Rc 2. Is this storage tark located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes 3. Is this storage tark located upstream of a natural gas processing plant? Yes Source is subject Storage Tank is not subject to Regulation 7, Section XiI.C-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section Xil.C.2— Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section XII.E — Monitoring Section XII.F — Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8-hr ozone control a.ea or any ozone non-attainment area or attainment/maintenance area? No Storage Tank is not subject to Re 2. Is this storage tank located at a natural gas processing plant? No Storage Tank is not subject to RE 3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is rot subject to Regulation Section XII.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2— Emission Estimation Procedures Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - You have indicated th 2. Is this condensate storage tank' located at an oil and has exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? Yes Go to the next question - You ha 3. Is this condensate storage tank a fixed roof storage tank? Yes Go to the next question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to parts of Reg Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B— 5eneral Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 • Emissions Control and Monitoring Provisions Section XVII.C.3 . Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabiized" liquids? No Source is subject to all provision. Storage tank is subject to Regulation 7, Section XV1I.C.2 Section XV1I.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60, Subpart Kb. Standards of Performance for Volatile Organic Llauld Storage Vessels 1. Is the individual storage vessel capacity greater than cr equal to 75 cubic meters (m3) ('472 Bets]? Yes Go to the next question 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not subject NSPE a. Does the vessel has a design capacity less -han or equal to 1,589.874 m3 (-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel": in 60.111b? 5. Does the storage vessel store a "volatile organic liquic (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel des gned to operate in excess of 204.9 kPa ["29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 ["'950 BBL] and stores a liquid with a maximum true vapor pressure° less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 (`472 BBL] but less than 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 kPa(60.11ob(b))? 7. Does the storage tank meet either one of the followir g exemptions from control requirements: a. The design capacity is greater than or equal to 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity is greater than or equal to 75 M3 [-472 BBL) but less than 151 m' (`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? Storage Tank is not subject to NSPS Kb 40 CFR.Part 60. Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue - You have indicated th 2. Was this condensate storage vessel constructed, reccnstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Nu Storage Tank is not subject NSPE 3. Was this condensate storage vessel constructed, reccnstructed, or modified (see definitions 40 CFR. 60.2) after September 18, 2015? Yes Go to the next question 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? Na Storage Tank is not subject NSP5 5. Does this condensate storage vessel meet the definit on of "storage vessel"' per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in acccrdance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000a [Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per 60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH,Oil and Gas Productbn Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Continue - You have indicated th a. A fa_ility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A fazility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located at a facility that is major for HAP:? No Storage Tank is not subject MAC 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MAC HH Subpart A, General provisions per §63.7E4 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations. and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as "recommend," "may," "should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as `must"and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Separator Venting Emissions Inventory Section 01 - Administrative Information 123 A087 008 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details *THIS SHEET IS TO ESTIMATE FLASHING EMISSIONS FROM THE HYSYS MODEL. THE FLASHING EMISSIONS ARE ADDED INTO THE "008 CONDENSATE TANK" TAB FOR TOTAL EMISSIONS Detailed Emissions Unit Description: Flashing from off-spec tanks Emission Control Device Description: Enclosed flare Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = MMscf per year Requested Permit Limit Throughput = 0.7 MMscf per year Requested Monthly Throughput = 0.1 MMscf per month Potential to Emit (PTE) Throughput = 0.7 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 2710.6 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04 - Emissions Factors & Methodologies Description Flash flowrate and composition based on HYSYS model and stream labeled "flashTM. Surge drum MW 48.3 lb/lb-mol Displacement Equation Surge drum Ex = Q * MW * Xx / C Weight % Helium CO2 0.9 N2 0.0 methane 2.1 ethane 10.2 propane 34.4 isobutane . 5.9 n-butane 24.0 isopentane 5.7 n-pentane 7.9 cyclopentane 2.8 n-Hexane 2.0 cyclohexane Other hexanes heptanes 2.2 methylcyclohexane 224-TMP Benzene 0.4 Toluene 0.3 Ethylbenzene 0.1 Xylenes 0.2 C8+ Heavies 1.0 Total 100.01 VOC Wt % 86.80 6 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 110641.3720 5532.0686 _ _ Hk: Ya Benzene 509.8681 25.4934 HYSYS Toluene 433.3879 21.6694 HYSYS Ethylbenzene 76.4802 3.8240 FlY5YS _ Xylene 216.6939 10.8347 _ HYSYS n-Hexane 2523.8470 126.1923 HMS 224 TMP 0.0000 0.0000 HYSYS Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 20.1966 AP-42 Table 1.4-2 (PM10/PIVI.2.5) PM2.5 0.0075 20.1966 AP-42 Table 1.4-2 (PM10/PM.2.E. SOx 0.0006 1.5945 AP-42 3abfe 1.4-2 (Sox) NOx 0.0680 184.3208 AP-42 Chapter 13.5 Industrial Flares (NOx) CO _ 0.3100 840.2860 apter 133 Industrial dares (CC Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 0.0000 5,:- - 4,;.: i b 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 0.0000 _ AP-42 Table 1.4-2 (PM10/PMM1.2.5) SOx _ 0.0006 0.0000 AP-42 Table 1.4-2 (SOx) NOx 0.0980 0.0000 AP-42 Table 1-4-1 (N0x) CO 0.0824 0.0000 AP--42 Table 1.4.1 (CO) 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 0.0 0.0 0.0 0.0 0.0 1 PM2.5 0.0 0.0 0.0 0.0 0.0 1 SOx 0.0 0.0 0.0 0.0 0.0 0 NOx 0.1 0.0 0.0 0.1 0.07 11 VOC 39.4 0.0 0.0 39.4 2.0 335 CO 0.0 0.0 0.0 0.3 0.3 51 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 363 0 0 363 18 Toluene 309 0 0 309 15 Ethylbenzene 54 0 _ 0 54 3 Xylene 154 0 0 154 8 n-Hexane 1797 0 0 1797 90 224 TMP 0 0 0 0 0 7 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 01 - Administrative Information Facility AIRS ID: 123 A0B7 009 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Sixteen (16) 500 bbl storage vessels connected via liquid manifold for produced water Description: Emission Control Device Enclosed flare Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Barrels (bbl) per year Requested Permit Limit Throughput = 3,000,000 Barrels (bbl) per year Requested Monthly Throughput = 254798 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = 3,000,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 36.0 scf/bbl Actual heat content of waste gas routed to combustion device = 0.0 MMBTU per year Requested heat content of waste gas routed to combustion device = 161568.0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 161568.0 MMBTU per year Control Device 'Pilot light is included in with the heater treater/surge drum venting Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies ••:\ ':In 1:. •• G.•LN' �y,. l 1 nnR3 r.r? Will this storage tank emit flash emissions? ` : s ” :- ; Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) VOC 0.2620 0.0131 Produced Water State E.F. (includes flash) - Fro:— Benzene 0.0070 0.0004 Produced Water State E.F. (includes flash) - Fror . Toluene 0.0000 Ethylbenzene 0.0000 Xylene 0.0000 n-Hexane 0.0220 0.0011 Produced Water State E.F. ("snedudes flash) - Front 224 TMP 0.0000 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) PM10 0.00745 0.00040 AP-42 Table 1.4.2 (►PM10/PM.2-S:) PM2.5 0.00745 0.00040 AP-42 Table 1.4.2 (PM10/PM.2.5) NOx 0.06800 0.0037 AP-42 Chapter 13.5 industrial Flares (NOx) CO 0.31000 0.0167 AP-4? Ct, titer 13..5 indutrial Fiares.(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0000 PM2.5 0.0000 NOx 0.0000 CO 0.0000 Section 05 - Emissions Inventort 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) VOC 393.0 0.0 0.0 393.0 19.7 3337.8 PM10 0.6 0.0 0.0 0.6 0.6 102.2 PM2.5 0.6 0.0 0.0 0.6 0.6 102.2 NOx 5.5 0.0 0.0 5.5 5.5 933.1 CO 25.0 0.0 0.0 25.0 25.0 4253.9 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 21000.0 0.0 0.0 21000 1050 Toluene 0.0 0.0 0.0 0 0 Ethylbenzene 0.0 0.0 0.0 0 0 Xylene 0.0 0.0 0.0 0 0 n-Hexane 66000.0 0.0 0.0 66000 3300 224 MAP 0.0 0.0 0.0 0 0 8 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C 3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO. NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? No If yes and if there are flash emissicns, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed usirg flash liberation analysis? This sample should be considered representative which generally means site-specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a cont-ol device efficiency greater than 95% for a flare or combustion device? No If yes, the permit will contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Noble is using state default emission factors. Noble is also using the state default assumptions for heat content and scf/bbl. I asked Noble if the tanks collect liquids from other sites. Noble confirmed the tanks only receive liquids produced at this site. Thus, the tanks are eligible for the NSPS Kb exemption. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point q Process # SCC Code Pollutant Factor Control % Units 009 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses PM10 0.0096 0.0 lb/1,000 gallons liquid throughput PM2.5 0.0096 0.0 lb/1,000 gallons liquid throughput NOx 0.0872 0.0 lb/1,000 gallons liquid throughput VOC 6.2381 95.0 lb/1,000 gallons liquid throughput CO 0.3975 0.0 lb/1,000 gallons liquid throughput Benzene 0.1667 95.0 lb/1,000 gallons liquid throughput Toluene 0.0000 95.0 lb/1,000 gallons liquid throughput Ethylbenzene 0.0000 95.0 lb/1,000 gallons liquid throughput Xylene 0.0000 95.0 lb/1,000 gallons liquid throughput n-Hexane 0.5238 95.0 lb/1,000 gallons liquid throughput 224 TMP 0.0000 95.0 lb/1,000 gallons liquid throughput 9 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Ye Source Requires an AP 2. Is the operator cla ming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) N .: Go to next question 3. 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)? :c:r, Source Requires a perr Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Pan B, Section II.D.2)? You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? No Continue - You have in 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? Yes Continue - You have in 3. Is this produced water storage tank a fixed roof storage tank? Yes Go to the next questio 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Yes Source is subject to pa Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Source is subject to all Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ["472 BBLs]? Yes Go to the next questio 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not sut a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 (`10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel„3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"'as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 O950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 3.5 kPa (60.11ob(b))?; or c. The design capacity is greater than or equal to 75 M3 ['472 BBL] but less than 151 m3 [-950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.110b(b))? 7. Does the storage tank meet either one of the following exemptions from control requirements: a. The design capacity is greater than or equal to 151 m3 [`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?; or b. The design capacity is greater than or equal to 75 M3 [`472 BBL] but less than 151 m3 [--950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? Storage Tank is not subject to NSPS Kb 40 CFR, Part 60, Subpart 0000/0O00a, Standards of Performance for Crude Oil and Natural Gas Production:Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue - You have in 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not sut 3. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? yes Go to the next questio 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not sut 5. Does this produced water storage vessel meet the definition of "storage vessel"2 per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS 0000a (Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO/0000a per RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer Ths document assists operators w:th determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is no: 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, " 'stove, " and "can, " is intended to describe APCD interpretations and recommendations. Mandatory terminobgy 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. Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information 123 A0B7 010 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Hydrocarbon loadout to tank trucks Description: Emission Control Device Enclo;ed flare Description: Is this loadout controlled? Yes • Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Barrels (bbl) per year Requested Permit Limit Throughput = 464,645 Barrels (bbl) per year Requested Monthly Throughput = 39463 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 464,645 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2707.8 Btu/scf Actual Volume of waste gas emitted per year = 0 scf/year Requested Volume of waste gas emitted per year = 464407 scf/year Actual heat content of waste gas -outed to combustion device = 0 MMBTU per year Requested heat content of waste gas routed to combustion device = 1,258 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 1,258 MMBTU per year 'Pilo- light is included in with the heater treater/surge drum venting Control Device Pilot Fuel Use Rate: scfh 0.0 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0.0 MMBTU/yr Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? ltic Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? No A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Loading Loss Equation L = 12.46*S*P*M/T Factor Meaning Value Units Source S Satu -ation Factor 0.6 -1 Submerged Loading. Dedicated Normal Service (S .6.1 P True Vapor Pressure 4.2957 psia AP-42 equations M Molecular Weight of Vapors 67 Ib/Ib-mol AP-42 equations T Liquid Temperature 511.4625 Rankine L Loading Losses 4.20691989 lb/1000 gallons 0.176690635 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.004008 0.000708176 lb/bbl Based on stream composition in HYSYS model for tank flash emissions Toluene 0.003384 0.000597921 lb/bbl Based on stream composition in HYSYS model for tank flash emissions Ethylbenzene 0.000573 0.000101244 lb/bbl Based on stream composition in HYSYS model for tank flash emissions Xylene 0.00162 0.000286239 lb/bbl Based on stream composition in HYSYS model for tank flash emissions n-Hexane 0.019829 0.003503599 lb/bbl Based on stream composition in HYSYS model for tank flash emissions 224 TMP 0 lb/bbl Based on stream composition in HYSYS model for tank flash emissions Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Volume (Volume Loaded) Loaded) VOC 0.17t,1 0.0088 Otte Specific -AP-42:Chapter 5.2, Equation x Benzene 0.0007 0.00004 Site Specific - 1P-42: Chapter 5.2, Equation 1 Toluene 0.0006 0.00003 Site Specific - AP-42: Chapter 5?, Equation I Ethylbenzene 0.0001 0.00001 Site Specific - AP-42; Chapter 5.2, Equation 1 Xylene 0.0003 0.00001 Site Specific AP-42: Chapter 5.2, Equation 1 n-Hexane 0.0035 0.0002 Site Specific - AP-42: Chapter 5..2, Equation 1 224 TMP 0.00E+00 0.00E+00 Site Specific - AP-42: Chapter 5.2, Equation 1 Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 0.0075 2.02E-05 AP-42 Table 1.4-2 (PM1OfPM.2.5) PM2.5 0.0075 2.02E-05 AP-42 Table 1.4-,2 (PP 112IPfM-,'1.2..5 SOx 0.0006 1.59E-06 AP-42 Table 1.4-2 (S• NOx 0.0680 0.0002 AP-42 Chapter 13.5 Industrial Hares (NO () CO 0.3100 0.0008 AP-42 Chapter 13.5 industrial Fares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM10 0.0000 PM2.5 0.0000 SOx 0.0000 N O x 0.0000 CO 0.0000 11 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Hydrocarbon Loadout Emissions Inventory 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 0.00 0.00 0.00 0.00 0.00 1 PM2.5 0.00 0.00 0.00 0.00 0.00 1 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.04 0.00 0.00 0.04 0.04 _ 7 VOC 41.05 0.00 0.00 41.0 2.1 349 CO 0.19 0.00 0.00 0.19 0.19 33 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 329 0 0 329 16 Toluene 273 0 0 278 14 Ethylbenzene 47 0 0 47 2 Xylene 133 0 0 133 7 n-Hexane 1628 0 0 1628 81 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Secticn III.D.2.a Site is in attainment and not subject to RACT (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes I confirmed with Noble that the true vapor pressure and vapor molecular weight are based on AP-42. Noble stated that because Table 7.1-2 only provides values for a specific set of liquid mixtures, Noble calculated the properties using AP-42 equations but for a liquid with an RVP 9. While the source did not provide a sample to document RVP 9, the source has selected a conservatively high RVP so it is appropriate to use. This source is also subject to the Reg 7 requirements in Part D, Section II.C.5. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process #t SCC Code Pollutant Factor Control % Units 010 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 4.2 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.02 95 lb/1,000 gallons transferred Toluene 0.01 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.01 95 lb/1,000 gallons transferred n-Hexane 0.08 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 12 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Go to next 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? Yes Go to the n 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No Go to next 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next 6. 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 II.D.3)? Yes The loadou Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? , 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.I)? 3. Is the Ioadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source Is in the Attainment Area 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Site is in attainment and not subject to RACT 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," '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. Separator Venting Emissions Inventory Section 01 - Administrative Information 123 A0B7 011 Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Heater treater and surge drum gas streams Emission Control Device Description: Enclosed flare Requested Overall VOC & HAP Control Efficiency %: ,.- ; : 95 Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = MMscf per year Requested Permit Limit Throughput = 10.0 MMscf per year Requested Monthly Throughput = 0.8 MMscf per month Potential to Emit (PTE) Throughput = 10.0 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 2780.0 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: 195 scfh 1.7 MMscf/yr 0. 195 Pilot Fuel Gas Heating Value: 1000 Btu/scf , Section 04 - Emissions Factors & Methodologies &� Description Noble submitted a HYSYS model based on five site-specific pressurized liquids sample collected 11/8/2019. The pressurized liquids samples were then used as the inlets to estimate emissions from the heater treater (AIRS ID 011), the surge drums (AIRS ID 011) and then the off-spec tanks which are covered by AIRS ID 008. The model predicted outlet gas streams for the heater treater and the surge drums. Since these vent streams Join together and are then metered and routed to a flare, they will be permitted as one point. Noble used the stream composition from the surge drums to estimate emissions. The model assumes a pressure of 117.1 psia into the heater treater, 25 psig at the outlet of the heater treater, and 3 psig at the outlet of the surge drums. Surge drum MW 49.6 Ib/Ib-mol Displacement Equation Surge drum Ex = Q * MW * Xx / C Weight % Surge drum original app I-Water treater Surge drum gas sample 11/8/2019 Helium CO2 0.8 0.8 2.2 0.4701 N2 0.0 0.0 0.13 0.6381 methane 1.8 1.8 10.28 1.0853 ethane 9.2 9.1 16.54 13.0746 propane 32.8 32.6 32.24 32.9771 isobutane 5.9 5.9 4.50 6.3472 n-butane 24.4 24.5 17.54 24.2005 isopentane 6.0 6.1 3.99 5.9693 n-pentane 8.6 8.6 5.60 7.8495 cyclopentane 3.1 3.1 2.01 0.4232 n-Hexane 2.3 2.3 1.48 1.8413 cyclohexane 0.554 Other hexanes 2.1921 heptanes 2.; 2.7 1.75 1.7074 methylcyclohexane 0.2002 224-TMP 0.0 0.0 0.0259 Benzene 0. 0.5 0.29 0.237 Toluene 0.4 0.4 0.27 0.057 Ethylbenzene 0.1 0.1 0.05 0.0025 Xylenes 0.2 0.2 0.14 0.0136 C8+ Heavies 1.3 1.3 0.90 0.1327 Total 100.01 100.00 100.0 100.0 VOC Wt % 88.2 88.4 70.9 84.7 14 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Separator Venting Emissions Inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 115436 5771.8 ' FICISYS Benzene 602.01 30.100 HYSYS Toluene 536.57 26.828 HYSYS Ethylbenzene 91.609 4.5805 HYSYS Xylene 274.83 13.741 HYSYS n-Hexane 2996.9 149.85 HYSYS 224 TMP 33.896 1.6948 “ve-vr Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 _ 0.0075 20.7137 AP-42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 20.7137 AP-42 Table 1,4-2 (PM14/PM.2.5) sox 0.0006 1.6353 AP-42 Table 1.4-2 (SOx) NOx 0.0680 189.0400 AP-42 Chapter 13.5 Industrial Flares (NOx) CO 0.3100 861.8000 AP-42 Chapter 13.5 Industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 7.4510 AP-42 i JiJic• _.4.2 t iti.i i.jk M.2.5 PM2.5 0.0075 7.4510 AP-42 Table 1.4-2 (PM10/PM.2.5) SOx 0.0006 0.5882 AP-42 Table 1.4-2 (SCx? NOx 0.0980 98.0392 AP-42 Table 1.4-1 (NOxi CO 0.0824 82.3529 :2 $ T:*! 1 4.1 (CO) 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 0.1 0.0 0.0 0.1 0.1 19 PM2.5 0.1 0.0 0.0 0.1 0.1 19 SOx 0.0 • 0.0 0.0 0.0 0.0 1 NOx 1.0 0.1 0.0 1.0 1.0 175 VOC 577.2 0.0 0.0 577.2 28.9 4902 CO 0.0 0.1 0.0 4.4 4.4 744 'Source's values are used in permit-. Potential to Emit Actual Emissions Requested Permit Limits Source's Values Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 6020 0 0 6020 301 5956 298 Toluene 5366 0 0 5366 268 5371 269 Ethylbenzene 916 0 0 916 46 967 48 Xylene 2748 0 _ 0 2748 137 2767 138 n-Hexane 29969 0 0 29969 1498 30008 1503 -_ 224 TMP 339 0 0 339 17 339 17 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVIl.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 15 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.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? No ; *The source included a site-specific gas sample showing the concentrations were slightly lower than the mode 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 wile contain an "Initial Testing F.equirement" 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. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? 'No If yes, the permit wi I 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 mete- installed and operational upon startup of this point? Yes 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 greaser than 95% for a flare or combustion device? If yes, the permit wil contain compliance testing requirements to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. f. %•? g s �.., ) . ;i . rar Y » s -'n `� ' - ly t Ir . . H1.3.-1 v :�irr [ fl t I t r r ' ' s .. — '. .. f .:,• �. rr.t.,.i '� .`i ri�J.? ./+ ?vt..: v. ,) L `Jss �-� 1 ai c l ..,x.. ,�..,. O.j�....� it( M.� . f. 4 .a 1. �. Section 08 - Technical Analysis Notes I compared the modeled stream composition from the heater treater and surge drums and the surge drums has a higher VOC wt% ( 88.2% vs 70.9%) and higher HAP wt%, except for 224-TMP. Noble also provided a site-specific sample of the surge drum gas collected 11/14/2019. This sample showed slightly lower VOC wt% at 84.7 wt% and slightly lower HAPs. Thus, it is appropriate to use the modeled results for the surge drum to establish emission limits. The concentration for 224-TMP was included based on the surge drum gas sample to be conservative. Since an initial sample was already collected, the permit will not require an initial sample. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code Pollutant Uncontrolled Emissions Factor Control % Units 011 01 3-10-001 -60 Flares PM10 20.7 0 lb/MMSCF SCC coding withpilot PM2.5 20.7 0 Ib/MMSCF emissions in lbs divid 5Ox 1.6 0 Ib/MMSCF NOx 189.0 0 Ib/MMSCF VOC 115435.7 95 Ib/MMSCF CO 861.8 0 Ib/MMSCF Benzene 602.0 95 Ib/MMSCF Toluene 536.6 95 Ib/MMSCF Ethylbenzene 91.6 95 Ib/MMSCF Xylene 274.8 95 lb/MMSCF n-Hexane 2996.9 95 Ib/MMSCF 224 TMP 33.9 95 Ib/MMSCF 16 of 17 C:\Users\cdmoney\Documents\Package 422682\20WE0119.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B - APEN and P?rmit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? Yes Source Re 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 II.D.3)? Yes Source Re Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source is it the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically f-actured, or recompleted on or after August 1, 2014? Ye. Source is Source is subject to Regulation 7, Section XVII.B.2. G Section XVII.B.2 — General Provisions for Air Po lution Control Equipment and Prevention of Emissions Section XVII.G - 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? No The contra The control device for this separator is not subject to Regulation 7, Section XVII.B,2.e 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 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 bir ding 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. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Enemy Inn County AIRS ID 123 History File Edit Date 3/1812020 Plant AIRS ID A057 Ozone Status Attainment Facility Name LD07-01 Econode T9N R58WS7 L01 EMISSIONS Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Descnphmt PM10 PM25 H2S S02 NOx VOC Fug CO Total PM10 PM25 H25 502 900 VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 New Facility No Previous Total Previous Penndted Fec,ldytolal 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 001 GP02 203 bhp Caterpillar G3306TA 4SRB 02 02 325 14 325 05 02 02 10 14 39 05 002 GP02 203 bho Caterpillar G3306TA 4SRB 02 02 325 14 325 05 02 02 10 14 39 05 003 GP02 1380 bhp Caterpillar G3516J 4SLB 05 05 67 128 324 66 05 05 67 93 200 66 004 GP02 380 bhp Cummins KTA19GC 4SRB 03 03 - 470 34 224 03 03 03 18 26 7.3 03 li 005 GP02 92 bhp GMVortec 574SRB 01 01 124 06 98 01 01 01 09 06 18 01 006 GP02 92 bhp GMVorieo 574SRB 01 01 124 06 98 01 01 01 09 06 18 01 007 GP02 92 bhp GM Venom 574SRB 01 01 124 06 98 01 01 01 09 06 18 01 008 20WE0119 Two 500 bbl Off spec Condensate 01 569 04 19 01 28 04 01 storage tanks 009 20WE0119 Sxteen 500551 produced water 55 3930 250 43.5 55 197 250 22 storage tanks 010 20WE0119 Hydrocarbon 11n51d leaden 00 410 02 12 0,0 21 02 0.1 011 20WE0119 Venting horn heater treater and surge 01 0.1 1.0 5772 44 22,7 01 0,1 10 20,9 44 1.1 0,0 0 0 FACILITY TOTAL 16 16 0.0 00 1625 1 088 9 00 179.2 775 16 16 00 00 198 700 00 705 117 VOC Syn Minor(POD and OP) NOx Syn Minor(OP) CO Syn Minor(OP) HAPS Syn Minor Total benzene n hexane 2222 Bye Minor Penndled Feebly Total 16 16 00 00 1625 1,0889 00 1792 775 86 16 00 00 198 700 00 705 117 Excludes undo exempt from permIts/APENs (A)Change in Permitted Emissions 16 16 00 00 198 700 00 705 Pubcom required for new syn minor limos Total VOC Facility Emissions Mainland fupi We) 70 0 Feeley is eligible for GP02 bemuse n 50 tpy (e)Change in Total Permitted VOC emissions(paint and fugitive) 70 0 Protect emissons greater than 25150 toy Note 1 Note 2 Page I oft Printed 4/30/2020 • it ' r 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 A0B7 Facility Name LD07-01 Econode T9N-R58W-S7 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 GP02 203 bhp Caterpillar G3306TA 4SRB 980 45 42 25 0.5 002 GP02 203 bhp Caterpillar G3306TA 4SRB 980 45 42 25 0.5 003 GP02 1380 bhp Caterpillar G3516J 4SLB 11461 834 513 44 250 6.6 004 GP02 380 bhp Cummins KTA19GC 4SRB 367 75 70 43 0.3 005 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 0.1 006 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 0. 1 007 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 _ 0. 1 008 20WE0119 Two 500 bbl Off-spec Condensate storage tanks 525 446 2600 1 .9 009 20WE0119 Sixteen 500 bbl produced water storage tanks 21000 66000 43.5 010 20WE0119 Hydrocarbon liquid loading 329 278 .±. -- 1628 1 .2 011 20WE0119 Venting from heater treater and surge drums 5956 5371 967 2767 30008 339 22.7 0.0 TOTAL (tpy) 7.1 0.5 0.4 14.0 3.0 0.5 1 .6 50.1 0.1 0.2 0.0 0.0 77.5 '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 GP02 2C3 bhp Caterpillar G3306TA 4SRB 980 45 42 25 0.5 002 GP02 203 bhp Caterpillar G3306TA 4SRB 980 45 42 25 0.5 003 GP02 1380 bhp Caterpillar G3516J 4SLB 11461 834 513 44 250 6.6 004 GP02 380 bhp Cummins KTA19GC 4SRB 367 75 70 43 0.3 005 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 0. 1 006 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 0. 1 007 GP02 92 bhp GM Vortec 5.7 4SRB 149 20 19 0. 1 008 20WE0119 Two 500 bbl Off-spec Condensate storage tanks 26 22 130 0. 1 009 20WE0119 Sixteen 500 bbl produced water storage tanks 1050 3300 2.2 010 20WE0119 Hydrocarbon liquid loading 16 14 2 81 0.1 011 20WE0119 Venting from heater treater and surge drums 298 269 48 138 1503 17 1 .1 0.0 TOTAL (tpy) 7.1 0.5 0.4 0.8 0.2 0.0 0.1 2.5 0.1 0.0 0.0 0.0 11 .7 2 123A0B7 4/30/2020 Hello