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Home My WebLink About20200678.tiffCOLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 February 4, 2020 Dear Sir or Madam: RECEIVED FEB 18 2020 WELD COUNTY COMMISSIONERS On February 5, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - MCCLELLAN T8N-R59W-S9 L01 /DOROTHY STATE LG01-16 ECONODE T8N-R59W-S4 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Po61:C Re J LJ CG'.PL(119, i.c) p (sh/eR/GHt/cK), O3/O1 /a° c. tv h.) O2- /27 /aO 2020-0678 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - MCCLELLAN T8N-R59W-S9 L01 /DOROTHY STATE LG01-16 ECONODE T8N- R59W-S4 L01 - Weld County Notice Period Begins: February 5, 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: MCCLELLAN T8N-R59W-S9 L01 /DOROTHY STATE LG01-16 ECONODE T8N-R59W-S4 L01 Exploration and Production Well Pad/ECONODE NENE SEC 9 T8N R59W/SESE SEC 4 T8N R59W (Co -located sites) Weld County The proposed project or activity is as follows: This co -located facility, consisting of the McClellan and Dorothy State well pads, has added new equipment to their facility as of 4/10/2019 and is requesting permit coverage for condensate storage tanks, produced water tanks, loadout, and separator venting. Additionally, this request is add permit coverage for produced water tanks, which had been previously APEN exempt. Concurrently, the source has requested GP02 coverage for 4 natural gas engines. These two facilities combined are synthetic minor for NOx, CO, VOC, n -hexane, and total HAPs. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 13WE2925 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: COLORADO Department of Public Health 5 Environment Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 21 COLOR ADO Departnent of Public Health Q Enviranxrncnt COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 13WE2925 Issuance: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Noble Energy, Inc. MCCLELLAN T8N-R59W-59 L01 123/9CO2 NENE SEC 09 T8N R59W Weld County Well Production Facility Equipment or activity subject to this permit: 3 Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Battery #415852032 001 Five (5) 300 barrel fixed roof storage vessels used to store condensate Enclosed Combustion Device PW Tanks 012 One (1) 300 barrel fixed roof storage vessel used to store produced water Enclosed Combustion Device 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 the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Battery #415852032 001 --- --- 1.7 --- Point PW Tanks 012 --- --- 1.6 2.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) 5. 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Battery #415852032 001 Enclosed Combustion Device VOC and HAP PW Tanks 012 Enclosed Combustion Device VOC and HAP Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 6. 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit Battery #415852032 001 Condensate Throughput 200,000 barrels PW Tanks 012 Produced Water Throughput 246,000 barrels 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. 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) 8. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 9. Point 001: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating property. (Regulation Number 7, Section XII.C.) (State only enforceable) 10. The combustion devices covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; 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 Page 3 of 10 u COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 11. Point 012: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. 12. Point 012: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management. System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (08M) 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 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. 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: Page 4 of 10 Ig*tio COLORADO Aix Potlutiom Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. 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. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. 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. 22. 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. 23. 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. 24. 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. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 August 14, 2014 Issued to Noble Energy, Inc. Issuance 2 June 16, 2015 Issued to modify limits to point 004 due to self - certification. Issuance 3 This Issuance Issued to Noble Energy, Inc. as Final Approval Removed points 002 and 004 from permit (cancelled). Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Added point 012 (produced water tanks) to this permit. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr)' 001 Benzene 71432 280 14 n -Hexane 110543 2,400 120 012 Benzene 71432 1,722 86 n -Hexane 110543 5,412 271 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source lb/BBL Condensate Throughput lb/BBL Condensate Throughput VOC 0.33 0.0165 WinSym 110543 n -Hexane 0.012 0.0006 WinSym 71432 Benzene 0.0014 0.0001 WinSym Note: The controlled emissions factors for point 001 are based on the flare control efficiency of 95%. Page 8 of 10 Point 012: COLORADO Air Pollution Control Division Department of Public Health S Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO 0.0173 0.0173 AP -42, Chapter 13.5 VOC 0.262 131E-02 CDPHE Produced Water Emission Factor 71432 Benzene 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement_: Operating Permit Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, and Total HAPs PSD True Minor Source NANSR Synthetic Minor Source of: VOC, NOx 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0813 Issuance: 1 Date issued: Issued to: Noble Energy, Inc. Facility Name: Dorothy State LG01-16 ECONODE T8N-R59W-S4 L01 Plant AIRS ID: 123/9CO2 Physical Location: SESE Section 4 T8N R59W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point s Equipment. Description Emissions Control Description Tanks 013 Two (2) 500 bbl fixed roof storage vessels used to store condensate Enclosed Combustion Devices PW Tanks/Temp Tanks 014 Fourteen (14) 500 -bbl fixed roof storage vessels used to store produced water Enclosed Combustion Device Loadout 015 Truck loadout of condensate by submerged fill Enclosed Combustion Device HREC Knockout Vessel 016 HREC Knockout Vessel which received gas streams from heater treater and surge drum gas streams during VRU downtime Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. Page 1 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as requiredin this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Tanks 013 --- --- 0.5 --- Point PW Tanks/Temp Tanks 014 --- 2.6 9.4 12.0 Point Loadout 015 --- --- 0.7 --- Point HREC Knockout Vessel 016 --- --- 23.4 3.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Page 2 of 14 g,t3- COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 9. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled Tanks 013 Enclosed Combustion Device VOC and HAP PW Tanks/Temp Tanks 014 Enclosed Combustion Device VOC and HAP Loadout 015 Enclosed Comustion Device VOC and HAP Page 3 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado HREC Emissions from the heater treater and surge drum are routed through the HREC Knockout Vessel 016 Knockout Vessel to an enclosed combustion device during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Tanks 013 Condensate Throughput 172,353 barrels PW Tanks/Temp Tanks O15 Produced Water Throughput 1,440,000 barrels Loadout Condensate Loaded 172,353 barrels HREC_.,...! Knockout Vessel 016 Natural Gas Venting 7.94 MMSCF Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month, a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. Point 016: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 4 of 14 4,30 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 14. Points 013, 014, 016: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 15. Points 013, 014: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.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 May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.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. 16. Points 013, 014: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 17. Point 013: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) Page 5 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 18. Point 015: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill. (Reference: Regulation 3, Part B, III.D.2) 19. Point 015: All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 20. Point 015: The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. 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 loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for ! periods of maintenance, gauging, or safety of personnel and equipment. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 21. Point 015: For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. Page 6 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. Point 016: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 23. Points 013, 014, 015, 016: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 24. Point 013: The owner or operator must complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 25. Point 016: The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, -the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit Page 7 of 14 avto COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 26. Points 013, 014, 015, 016: The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 27. Point 016: On an annual basis, the owner/operator must complete a site -specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor 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 factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to ' the Division within 60 days,'or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). ADDITIONAL REQUIREMENTS 28. 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 V0C 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 Page 8 of 14 COLORADO Air Pollution Control Division Department of %61n Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 29. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 30. 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. 31. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 32. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. Page 9 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 33. 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. 34. 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. 35. 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. 36. 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. Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Page 10 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment D I(lb/yr) AIRS Point Pollutant CAS # Uncontrolled Emissions Controlled Emissions (lb/yr) Tanks 013 n -Hexane 110543 445 22 PW Tanks/Temp Tanks 014 Benzene 71432 10,080 504 n -Hexane 110543 31,680 1,584 Loadout 015 n -Hexane 110543 568 28 HREC Knockout Vessel 016 Benzene 71432 4,775 239 Toluene 108883 5,375 269 Ethylbenzene 100414 817 41 Xylenes 1330207 1,840 92 n -Hexane 110543 26,409 1,323 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 11 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 013: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.1042 5.21E-03 AP -42, Chapter 7 /Speciation from HYSYS Model based on site - specific sampling 110543 n -Hexane 0.0026 1.3E-04 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 014: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.66E-03 3.66E-03 AP -42, Chapter 13.5 CO 1.67E-02 1.67E-02 VOC 0.262 1.31E-02 CDPHE State - Approved Emission Factors (PS Memo 14-03) 71432 Benzene 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 015: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 1.526E-01 7.63E-03 AP -42, Chapter 5.2, Equation 1 n -Hexane 110543 3.3E-03 1.65E-04 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) = 3.6568 psia M (vapor molecular weight) = 68 lb/lb-mol 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 vapors as modelled by HYSYS modeling based on site -specific sampling by the VOC emission factor. Page 12 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 016: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 212.14 212.14 AP -42, Chapter 13.5 CO 888.71 888.71 VOC 117,905.54 5,895.28 HYSYS Model of the Surge Drum Separator, based on 3 site -specific pressurized liquid samples (taken 5/23/2019) 71432 Benzene 601.05 30.05 108883 Toluene 676.52 33.83 100414 Ethylbenzene 102.84 5.14 1330207 Xylene 231.60 11.58 110543 n -Hexane 3,324.21' 166.21 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The combustion emissions were calculated based on a vent gas heating value of 2,810 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, and Total HAPs PSD True Minor Source NANSR Synthetic Minor Source of: VOC, NOx Page 13 of 14 L COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories 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 DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Noble Energy County AIRS ID 123 Plant AIRS ID 9CO2 Facility Name McClellan T8N-R59W-S9 L01/Dorothy State LG01-16 Econode T8N-R59W-S4 L01 001 13WE2925 300 bbl condensate tank 14 120 0.1 002 ... 13WE295.CN.:';loadout'"F 00 003 13WE2925CN :: Flare _' 004 " 131A/E2B26„CN-''Equipment leaks; 005 GP02 Caterpillar G3406 Compression engine(snry4FD02077) 0.0 006 16WE1489.XP Kubota DG972 24 hp 0.0 007; -0P02-.C14,", Caterpillar 63406 St?4FD02086 . (k0 008 GP02 Cummins 4SRB 380 HP NG RICE 367 75 71 43 15 82 0.3 009 GP02 Cummins 4SRB 380 HP NG RICE 367 75 71 43 15 82 0.3 010 GP02 Cummins 4SRB 118 HP NG RICE 191 26 24 15 28 0.1 011 GP02 Cummins 4SRB 118 HP NG RICE 191 26 24 15 28 0.1 012 13WE2925 Produced Water Tanks(2-800 bbl ttl) 86 271 0.2 013 19WE0813 Condensate Tanks(2-500 bbl) 4 4 1 2 22 0.0 014 19WE0813 Produced Water Tanks(14-7,0000 bbl ttl) 504 1584 1.0 015 19WE0813 Condensate Loadout 5 6 1 2 28 0.0 016 19WE0813 HREC Knockout Vessel 239 269 41 92 1323 1.0 0.0 APEN Exempt/Insignificant Sources 0.0 (Dorothy) Heater Treaters(2) 0.0 (Dorothy) HP Heaters(7) 0.0 (Dorothy) Fugitives 0.0 McClellan TL-415852032 0.0 McClellan Fugitives 0.0 TOTAL(tpy) 0.6 0.1 0.1 0.5 0.2 0.0 0.0 1.7 0.1 0.0 0.0 0.0 3.2 20 19WE0813.CP1 - 1/28/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT " AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Noble Energy County AIRS ID 123 Plant AIRS ID 9CO2 Facility Name McClellan T8N-R59W-59 L01/Dorothy State LG01-16 Econode TBN-R59W-S4 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 13WE2925 300 bbl condensate tank 280 2400 1.3 002 13WE2925 CND" loadout DD 003 13WE2925CN Flare.. :; " s .. .0','C(7:',"::004 13WE2925':CN Equipment leaks - .. ,, .o " . .. 00 005 GP02 Caterpillar G3406 Compression engine(sn 4FD02077) 0.0 006 16WE1489.XP Kubota DG972 24 hp 0.0 007," '.G1 02.CN; Cater illar G3406 sn 4FD02086 008 GP02 Cummins 4SRB 380 HP NG RICE 367 75 71 43 15 82 0.3 009 GP02 Cummins 4SRB 380 HP NG RICE 367 75 71 43 15 82 0.3 010 GP02 Cummins 4SRB 118 HP NG RICE 191 26 24 15 28 0.1 011 GP02 Cummins 4SRB 118 HP NG RICE 191 26 24 15 28 0.1 012 13WE2925 Produced Water Tanks(2-800 bbl ttl) 1722 5412 3.6 013 19WE0813 Condensate Tanks(2-500 bbl) 86 86 17 34 448 0.3 014 19WE0813 Produced Water Tanks(14-7,0000 bbl ttl) 10080 31680 20.9 015 19WE0813 Condensate Loadout 105 110 16 35 568 0.4 016 19WE0813 HREC Knockout Vessel 4775 5375 817 1840 26409 19.6 0.0 APEN Exempt/Insignificant Sources 0.0 (Dorothy) Heater Treaters(2) 0.0 (Dorothy) HP Heaters(7) 0.0 (Dorothy) Fugitives 0.0 McClellan TL-415852032 0.0 McClellan Fugitives 0.0 TOTAL(tpy) 0.6 0.1 0.1 8.6 2.8 0.4 1.0 33.5 0.1 0.0 0.0 0.0 47.1 *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 IXylenes 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 19 19WE0813.CP1 1/28/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy County AIRS ID 123 History File Edit Date 1/28/2020 _ Plant AIRS ID 9C02 Ozone Status Non-Attainment _ FoGilitY Name McClellan T8N-R59W-S9 L01/Dorothy State Last Modified By: I Lauraleigh Lakocy EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S 5O2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 51,1 52.7 0.0 85.9 2.5 0.0 0.0 0.0 0.0 3.3 21.4 0.0 55.7 _ 1.2 From May 2017 Previous Permitted Facilit total 0.0 0.0 0.0 0.0 _ 51.1 52.7 0.0 859 2.5 _ 0.0 0.0 0.0 0.0 3.3 21.4 0.0 557 1.2 001 13WE2925 300 bbl condensate tank 33.0 1.3 1.7 0.1 002 -- 13WE2925.CE. IoadouE ' ._ - 00 ' ' .'''' _ `O0 Cancellation received 08/28/2018 003 -- ^I3WE2925CN' Flare =` • 0.0 .-0.0 Cancellation request received 9/24/14 004 13WE2925.CE Equipment leaks = '. ?=0.0 ' - - Ib0 Cancellation requestreceived8/6/15 005 - 0P02 Caterpillar 03406 Compression j_0.9 "0 0 C noellatipn rf3gpiypd 12/02/2O18 engine fan 4P©02077) 006 16WE1489.XP Kubota OO972 24 hp 0.4 0.7 24.3 0.0 0.4 0.7 24.3 0.0 007 =-GP02 CN �' Cateryrllar'03408 sn 4F002086 "'00 0 `0.0 Cancellation request'received 7/29/19 008 GP02 Cummins 4SRB 380 HP NG RICE 0.3 0.3 47.0 3.4 224 0.3 0.3 0.3 3.7 2.6 7.3 0.3 Newly requested point(Dorothy) 009 GP02 Cummins 4SRB 380 HP NG RICE 0.3 0.3 47.0 3.4 22.4 0.3 0.3 0.3 3.7 2.6 7.3 0.3 Newly requested point(Dorothy) 010 GPD2 Cummins 4SRB 118 HP NO RICE 0.1 0.1 15.8 0.8 10.3 0.1 0.1 0.1 1.1 0.8 2.3 0.1 Newly requested point(Dorothy) 011 _GP02 Cummins 4SRB 118 HP NG RICE 0.1 0.1 15.8 0.8 10.3 0.1 0.1 0.1 1.1 0.8- 2.3_ 0.1 Newly requested point(Dorothy) 012 13WE2925 Produced Water Tanks(2-800 bbl ttl 0.5 32.2 2.1 3.6 0.5 2.1 1.6 0.2 Newly requested point(McClellan) 013 19W90813 Condensate Tanks(2-500 bbl) 8.9 0.3 0.5 0.0 Newly requested point(Dorothy) 014 19WE0813 Produced Water Tanks(14-7,0000 2.6 188.6 12.0 20.9 2.6 9.4 12.0 1.0 Newly requested point(Dorothy) bbl ttl) 015 19WE0813 Condensate Loadout 13.2 0.1 0.4 0.7 0.1_ 0.0 Newly requested point(Dorothy) 016 19W90813 HREC Knockout Vessel 0.8 468.4 3.5 19.6 0.8 23.4 3.5 1.0 Newly requested point(Dorothy) 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 (Dorothy) Heater Treaters(2) 0.1 0.1 1.3 0.1 1.1 0.0 0.1 0.1 1.3 0.1 1.1 0.0 From Form APCD-102 (Dorothy) HP Heaters(7) 0.1 0.1 1.8 0.1 1.5 0.0 0.1 0.1 1.8 0.1_ 1.5 0.0 From Form APCD-102 (Dorothy! Fugitives 0.9 0.0 0.9 0.0 From Form APCD-102 McClellan TL-415852032 0.7 0.0 0.7 0.0 From Form APCD-1O2 McClellan Fugitives 0.4 0.0 0.4 0.0 From Form APCD-102 FACILITY TOTAL - 1.0 1.0 0.0 0.0 133.0 754.3 1.3 110.0 47.1 1.0 1.0 0.0 0.0 17.0 46.2 1.3 63.3 3.2 VOC: Syn Minor{NANSR and OP) NOx:Syn Minor(NANSR and OP) CO: Syn Minor(PSD and OP) HAPS: Syn minor n-hexane&total HAPs Permitted Facility Total 0.8 0.8 0.0 0.0 129.5 752.7 0.0 83.1 47.1_ 0.8 0.8 0.0 0.0 13.5 44.6 0.0 36.4 3.2 Excludes units exempt from permitslAPENs (A)Change in Permitted Emissions 0.8 0.8 0.0 0.0 10.2 23.2 0.0 -19.3 Pubcom required because project emissions>25 tpy VOC in nonattainment area. Modeling not required based on division guidelines. Total VOC Facility Emissions(point and fugitive) 47.5 Facility is eligible for OP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 23.2 Project emissions not less than 25 tpy" Note 1 The McClellan and Dorothy sites are collocated.The McClellan is covered under 13WE2925 and Dorothy operations are under 19We0813. Because of the cancellations,the change in emissions quantified on this spreadsheet indicate that the change is less than 25 tpy;however,the individual permitted points have>25 tpy VOC added to facility,so this will go to public comment.Additionally,these are new Note 2 synthetic minor limits Page 18 of 20 Printed 1/28/2020 Separator Venting Regulatory Analysis Worksheet Colorado Re. latlon 3 Parts Aand B-APEN and Permit Requirements �Sourc0 is in the Nan-Attainment Area ATTAINMENT • 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY(Regulation 3,Part A,Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than SIPS,NOx greater than 10 TPY or CO emissions greater than 10 TPV(Regulation 3,PartB5ection 11.0.31? You have indicated that sums is In the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY(Regulation 3,Part A,Section 11.01.4)7 'Source Req 2. Are total facility uncontrolled VOC emissions from the greater than 2TPV NOx greater than 5 TPY or CO emissions greater than le TPY(Regulation 3,Part O,Section 11.0.2)? Yek ,source Req (Source requires 0 permit Colorado Regulation 7,Section XVII 1. Was the well newly constructed hydraulically fractured,or recompleted on or after August 1,2014? rii0i4AEsunce is s) 'Source is subject to Regulation 7,Section 1511.0.2,G Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions • Section 0011.0-Emissions Control Alternative Emissions Control lOptiadal Section' • a. Is this separator controlled bye hack-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? E::`6 „IThe control ITtre control derive for this separator is ties subject to Regulodun 7,Section X11I1.S.2.a Section XV11.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act,its implementing regulations,and Air Quality Central 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"am 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 0s-Technical Analysis Motes provided p liquid p (taken J IV upstream :fseparator P�, a., The source 3. ressur¢ed samples 5 23 2019 from 3 wells at he facility,which oaken the i ubased m.which wells were operatrgAa the time o{sarnpl[ng To de etRl7 a"a„r representatwe emissions,the source states that they ttypically try to take samples from s/_of the wens t the facility.The f y van he reruered to havended g ampling of the b ed g t to demonst the requested permit limits.Dee to rounding differences in calculation-the emissions lintits and emissions factors that were r quested by the source will serve as the I mits and estabirshed ernissems factors in the permit The source has requested that-the Heater Treaters and Surge Drum gas venting:is grouped together by permitting the HRhc knockout vessel as the gas streams from both are routed through the HP:C Knockout vessel before go ngto thz enclosed combustion device - a £ Section 09-Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions AIRS Point it Process IS 5CC Code Pollutant Factor Control% Units 016 01 3-10-001-60 Flares PM10 30.94 0 ib/MMSCF PM2.5 20.94 0 €leJMMSCF 500 LOS 0 lb/MMSCF NOx 191.08 0 Ib/MMSCF VOC 110054.05 95 lb/M119SCF CO 871.10 0 (b/MM5CF Benzene 598.18 95 Eb/MMOCF Toluene 677,94 95 Ib/MMSCF Ethylhenzene 106,34 95 lbfMMSCF Xylene 239.27 95 €b(MMSCF n-Hexane 3333,22 95 Ib/MI'ttSCF 224 TMP - 0,00 90 €h/MMSC:F • 16 of 20 K:\PA\2019\19WE0813.CP1 Separator Venting 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 0.08 0,00 0.00 0.08 0.08 14 PM2.5 0.00 0.00 0.00 0.08 0,08 14 SOx 0.01 0.00 0.00 0.01 0.01 1 NOx 0.76 0.00 0.00 0.76 0.76 129 VOC 468,07 0.00 0.00 ?68.07 23.43 3081 CO 3.45 0.00 0.130 3,46 3.46 587 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/year) (lbs/year) Ohs/year) Benzene 4750 0 0 4750 237 Toluene 5383 0 0 5383 269 Ethylbenzene 844 0 0 844 42 Xylene 1900 0 0 .1.9110 05 n-Hexane 20380 0 0 26386 .1319 224 TMP 0 0 0 0 0 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 M1,8.2,6 Regulation 7,Section XVII.B.2.e The control device for this separator is not sub)ect to Regulation 7,Section 0011.8.2.0 (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific 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? ' H -'.....�'....4. If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? K. ; rr 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 Yni3 hoe indicated eE3ove Y1t at the.rno[S[Ynrei113;0 �s 13aranFeter i�nain;al g.m 4e ntuci,The{o11oW1n gl3cslions do not require 211,uimswer. t 2.< / p Qs', T� l J� 15 of 20 K:\PA\2019\19WE0813.CP1 Separator Venting Emissions Inventory 016 Separator Venting Facility AIRs ID: • --- - 016 -— County Plant Point Section 02-Equipment Description Details HeatarTreYer'atukSu aLyterm.ciasS'kr - :;:. r8 �ama��lRKno+ekalttUgss�l� i'--;:;�:-"Detailed Emissions Unit Description: i .. >.':' fosed�ambustuxrx.f}evPce, :. -- -.;'1:"" .:::::::�.::<•.;,,;.: Emission Control Device Description: � ?�, ._. Requested Overall VOC&HAP Control Efficiency%: &5:. 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=... 7₹9.MMscf per year Requested Monthly Throughput= 1 MMscf per month Potential to Emit(PTE)Throughput= 8 MMscf per year Process Control(Recycling) Equipped with a VRU: Is VRU process equipment: ° °° Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed(i.e.waste gas volume that is routed to the flare) Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: "-2030:'etu/sd Volume of waste gas emitted per BBL of • liquids throughput: c.4,:,1! O^<sd/bbl Section 04-Emissions Factors&Methodologies Description j'lipsdOtS 6.A4F[tled 3pressorzedlrgdidsamples{taken5/23/2019)from, wells at the facility Usrngfhesesamgfes,,ttrefacility was modeled in 35505.The composrtionattdtnolecularwotgfttltstedhelow.weretab*from tfta"5tttgek�rvt2Vapors ib VRU 5ft:2am0vgte.conservative ernss9ons esdmat9onJ.The source hasPet}vested'tbat'fRReater:Treaters.and Surge Drum gas vent ped YagetherrLypgrmwlt[ttg the HREC knockoUkVesse& 5s.5.�;.2:;=.K..- y asthegas�tteams from hoth ale rmmutexFt#rrough the HREKvnokqutdesse$be#gce.gping to iMe ersclgsed:combustion dev[ce'-': • ;�N':v3s3.•ii}?r}}:�.s.- tr..v.. .. -. .. .. . MW '!;.';.;;,i4<: =5 i.50ue lb/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Weight% Helium CO2 HZ .. .. .....-..L4tT.i methane .1.40 ethane it 8 56 propane 32 2tk: isobutane f a. 5.98: n-butane .; 24 i:1 isopentane n s• 0.24 n-pentane • 8.76 cyclopentane • • _0.00 n-Hexane 2.50 cyclohexane 0:00 Other hexanes 3,45 heptanes 2.Sil methylcyclohexane t.;.Et0"SS 224-TM P 038 Benzene Toluene 0 51 Ethylbenzene e 1508 Xylenes .0_18 C8+Heavies - --1,21 Total 190.00 VOCWt% 01.10 EMMEEM Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) 118014.0317 5902.7816 d y 29.9090 ism' 33.896& a'I .166.9.609 0.0000 0.0000 Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) - 0 0575 f ;0.06&0 191.480 a Stud a, PN91,1,9884198‘; "30' 14 of 20 K:\PA\2019\19WE0813.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Rey latlon 3 Parts A and B-APEN and Permit Requirements (Source is in the Non-Atteinrrient Area ATTAINMENT 1. Are uncontrolled actual emissionsfrgm any criteria pollutants from this individual source greater than 27PY(Regulation 3,Part A,Section ll.D.1.a)3 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)7 3. Is the loadout 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 uncontroled 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)? You have indiosted eheisauroe is in the b on.Actsinmeot Area 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)? 1125 Go tg next, 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.0.1.1)? yes Go to then 3. Is the loadout operation loading less than 10,000 gallons(238 BeLs)of crude lip day on annual average bass? (fib,";, :l Go to next, 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?an �fq'.i;iE't;:'':Go to next 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? ireokag Gots next 6. Are total facility uncontrolled VOC emissions Tram the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than sn TPY(Regulation3,Part B,Section 11..0.2)? ..Theloadou !Sauna require[a permit 7. RACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3,Part B,Section III.D.2.a)? '1heloadou 'The leadou5+nest be operated with submerged fill to satisfy 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 3 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,orany 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 Qualify 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"moot"and'required'are intended to describe controlling requirements under the berms of the Clean Air Act and Air CBoality Control Commission regulations,but this document does not establish legally binding requirements in and of itself 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/yea) (tons/yea) (tons/yea0 (tons/year) (Ibs/month) PM10 0,00 0.00 0.00 0.00 0.00 0 PM2.5 0.00 0.00 0.00 0.00 0.00 0 SOx 0,00 0,00 0.00 0.00 0.00 0 NOx 0.01 0.00 0.00 0.01 0.01 2 VOC 13.16 - 0.00 0.00 13.19 0.96 112 Co 0.05 0.00 0.00 0,05 0.09 9 • Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/yearl (Ibs/year) (Ibs/year) (lbs/year) Benzene 105 0 El 105 - S • Toluene 110 0 0 110 6 Ethylbenzene 16 0 0 15 1 Xylene 36 0 0 35 2 n-Hexane 568 0 0 568 28 224 TMP 0 0 0 0 0 • Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit RACr-Regulation 3,'Part e,Section III.D.2.e The load rut must.be opetated with submerged fill to satisfy PACT. (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements w 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 V estu 'tbagse HAP .e ght percent from the tank flash pe t as modelled by HYSYS The did t f bl d liquid sample analysis(taken 5/21/2019)Based on th co , ,oq `estei1P composition f all f the HAPS,with the exception of ihy b conservative,h r ,y r 1 ted using the tank hash emis ton and ?. •rsteb)Izadsatnprgyre nyoepn/5b) Th permit will niyest bush mission fastersf r vac al hexane.For yf Oare permit n the tncacon of the tonic flash mshoalot considered qr e stabdtaeckgl(�samPles0fcs 6a bk)ised deXaf U0e,emission facto a� ea -. act. rT ' -`S a Section 09-Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# 5CC Code Pollutant Factor Control% Units 015 - 01 4-06-001-32 Crude Oil:Submerged Loading Noestai Service(S=0.6) PM10 0.00 0 lb/1,000 gallons transferred PM25 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 3.6 95 lb/1,000 gallons transferred CO 0.01 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred • Toluene 0.52 95 lb/1,000 gallons transferred Ethylbenzene 0.00 ' 95 lb/1,000 gallons transferred Xylene 0.00 99 lb/1,000 gallons transferred n-Hexane 0,08 9S lb/1,000 gallons transferred 224 TMP 0,00 95 lb/1,000 gallons transferred 12 of 20 K:\PA\2019\19WE0813.CP1 Hydrocarbon Loadout Emissions Inventory 015 Liquid Loading Facility Allis ID: ' County Plant Point Section a2-Equipment Description Details Detailed Emissions Unit y Cmndange "fruck€aadou$ Description: Emission Control Device E tgTpxptFz 6ftbustCgn De doe Description: -....._a �.,.. .._ Is this loadout controlled? N1 Collection Efficiency: 'Sf LV Control Efficiency: Requested Overall VOC&HAP Control Efficiency%: 95.40 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= `Barrels(bbl)per year Actual Volume Loaded While Emissions Controls Operating= � ��.;;-Barrels(bbl)per year Requested Permit Limit Throughput= ,x.223;35:;Barrels(bbl)per year Requested Monthly Throughput= .9.4636 Barrels(bbl)per month Potential to Emit(PTE)Volume Loaded= 2:172$5.Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2255 Btu/scf Volume of waste gas emitted per year= 146644 scf/year Actual heat content of waste gas routed to combustion device= 0 MMBTU per year Requested heat content of waste gas routed to combustion device= 331 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device- 335.MMBTU per year Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? v--- Loading Lass Equation L=12.46'SoPeM/T Factor Meaning Value Units Source 5 Saturation Factor 3.5 l .,, % of&2;£F4aptsr,S,:yaomz1§rrbrrerged Load-erg:Ded"=rota Saw '" P True Vapor Pressure 4.6560 ;r,psis AP-42,C IvyIo,7,,Ta63e? M Molecular Weight of Vapors " 60 3 Ib/Ib-mol ' AP-44-CS-apter 7,'To ria a-12 T Liquid Temperature 511.4525.:Rankine ._,- Operational:Parameters Loading Losses :3,fi346'25718 lb/1000 gallons ,,,.. - _, 6,152656362 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene ,.-.H-003478 0.000606962 lb/bbl Took Flash EMissiors Spec{ation from 111115 Model Toluene 0.00063963 lb/bbl Tank Flash Emissioh Spec ationfrom HV???Model Ethylbenzene :::94008 9.15000E..05 lb/bbl -tank Plash Emission Speciatinn from 11Y525.Model Xylene 3,,,, ,.,.,f};001334 0.000203644 lb/bbl s - Tank Flash Emission.5pedation from ii15'FS Model n-Hexane 2 °x`-4..021603 0.003297830 lb/bbl Tank Flash Emissiap Speciationfrom H112S:Model 224TMP j. 0' 0Ib/bbl Tank Flash Emfssiolflpeciationfrotn 01525 Model • Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (Ib/bbl) (Ih/bbl) (Volume (Volume Loaded) Loaded) VOC 1.53E-01 7.63E-03 Benzene 5.07E-04 3.03E-OS '1413°-;dr;411.4 Toluene 5,40E-04 3.20E O5 WS or ATMFl Am. Ethylbenzene 3,16E-05 6.50E O6 Xylene 2.04E-04 Ht) s f:$PapfiB ua#₹0rtk 7 n-Hexane 3.30E-03 1,55E04 ,..--,23.30320.33236323-6222.46' 224 TMP 0.0#&:+OO tD,01D£:+i3tI li$ ,C �YBT, „ Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source (Volume (waste heat combusted) Loaded) PM10 !14075 1.43E-05 - PM25 F 00025 - 14360 5Ox r OO008 2.136-06 NOx 1.30604 • iaitay c0 -p d100 „zz�' 5.95E-O4 �)s(gk7S'5 11 of 20 R:\PA\2019\19WE0B13.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities,If the tanks you are reviewing are at one of these facilities,please review N5P5 Kb. Re ulation 3 Parts Aand 0-APEN and Permit Requirements Colorado Sourca is In the NoreAttainmant Anse ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutant from this individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.x)7 '' 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 ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TRY,NOB greater than 10 TPY or CO emissions greater than 10 TPV(Regulation 3,Part B,Section 11.0.3)7 lJs1 IYau have indicated that source Is in the Non-Attelement Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPV(Regulation 3,PartA,Section ll.O.1a)? Source Req 2. Is the operator claiming less than 1%crude oil and is the tank located ata non-commercial facility for processing oil and gas wastewater?(Regulation 3,Part B,Section ll.0.1.M) NV-W)4 Go to next 3. Are total facility uncontrolled VOC emissions greater than 2 TP7,NOx greater than 5 TPY or CO emissions greater than l0TPV(Regulation 3,Part B,Section 11.0.2)7 k'as"„''.j Source Req 'Source requires a permit • Colorado Regulation 7,Section XVII 1. Is this tank located at atransmission/storage facility? No Continue-' 2. Is this produced water storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor stations or natural gas processing plant? Yes Continue-' 3. Is this produced water storage tank a fixed roof storage tank? `y" Go to then 4. Are uncontrolled actual emissions of this storage tank equal teor greater than 6 tons per year VOC7 Source isst IStoraga tank is subject t Rogulatien 7,Section WO.IS,C.1 g C.? .... Section 0011.5—General Provisions far Air Pollution Control Equipment and Prevention of Emissions Section XVII,C.1-Emissions Control and Monitoring Provisions Section XVII.C.3-Recordkeeping Requirement ;�,� 5. Does the produced water storage tank contain only"stablRted`liquids?If no,the following additional provisions apply. I'hA-full Source is sr storage tank Is autierl to Regulation 7.Settles XVB.C.2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60,Subpart 0000,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 gastransmission and storage segment of the Industry? Yes Continue-' 2. Was this produced water storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.21 between August 23,2013 and September 15,20157 yF__.'=a^';Storage Tar 3. Are potential VOC emissions'from the Indly dual storage vesselgreater than or equal to 6 tons per year? N i'i;1;5tQrage Tar 4. Does this produced water storage vessel meet the definition of"storage vessel"'per 60.54307 p,.,.t„EI.Go to the 'Storage Tank is not auh]atl to NSPS OCIOO Subpart A,General Provisions per§60.5425 Table 3 460.53es-Emissions Control Standards for VOC 460.5413-Testing and Procedures (60.5395(g)-Notification,Reporting and Record keeping Requirements §60.5416(c)-Cover and Closed Vent System Monitoring Requirements §60.5417-Control Device Monitoring Requirements (Note:If a storage vessel is previously determined to be subjectto NIPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date,It should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6tons per year] RACT Review RACT review is required If Regulation 7 does not apply AND if the tank is In the ranattelnment 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 toe particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act.,its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or-regulation will control.The use of non-mandatory language such as'recommend,'"may," "should,'and'can,'is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must'and'required'are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. Produced Water Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements AREEiniing Does the company use a site specific emissions factor to estimate emissions? r 4- If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid'water sample drawn at the facility being permitted and analyzed using flash liberation analysis?This sample should be considered representative which generally means site-specific and collected within one year of the application received date. ; However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older site-specific sample, If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor.See PS Memo 14-03,Questions 5.9 and 5.12 for additional guidance on testing. 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 Ana Psis Notes Soor..he[isedistataehhss)dorfaotit,S3li •„h.'GpnZehfyga'Tb"W4*1atidtn to tt(atestrpsermisL � s'y ' 1. l„t. "1( Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 014 01 4-04-003-15 Fixed Roof Tank,Produced Water,working+breathing+flashing losses PM10 0.01 0 lb/1,000 gallons liquid throughput PM2.5 0,01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6,2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylhenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n-Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput • • 9 of 20 K:\PA\2019\19WE0813.CP1 Produced Water Storage Tank(s)Emissions inventory 014 Produced Water Tank '1x3 :5002 014 Facility Allis ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit - - -i Description: Fgw^(4}5003ibf`04.ioafvesSefs,and;4a�d.)5#IF3..,4P xe4�'cda te4SRlsusedf�p,43fusstoragp,9fprc(dl2egd+.dapp��? � ..` Emission Control Device Encfnsed-eamhusttgn deuiee ... = _ @teaA� i Description: Requested Overall VOC&HAP Control y Efficiency%: .. yss..,,�...,,.,. Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Produced Water Throughput= "'Barrels(bbl)per year Actual Produced Water Throughput While Emissions Controls Operating= *��)�.�Cr` Requested Permit Limit Throughput= • .1,44,.,010'Barrels(bid)per year Requested Monthly Throughput= 122301 Barrels(bbl)per month rae�\ Potential to Emit(PTE)Produced Water . - ' • Throughput= 1446#011W Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 1496'Btu/scf Volume of waste gas emitted per BBL of liquids. • produced= .•'3,6`?scf/bbl Actual heat content of waste gas routed to combustion device= 0 MMBTU per year Requested heat content of waste gas routed to combustion device= 77,553 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 77,553 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? Produced Water Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant - (Produced (Produced Water Water Throughput) Throughput) ll:112211 4ZRS ®-,, 1 E(6tEtun14S'Aastt FrsSot IMMEZIMM51057... ..:s. 0.000 .,a .. eS..0vsl*-Wamt. t :s 0,000 Px. e...^" - t mi,44 R 0.000 s. 4 �'9,r WOOS moat C\�5'i11333,,, ,t _ b, ,. IRK/ WOOD t8 „Ai?, Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/bbl) Pollutant - - -- -- Emission Factor Source (Produced (waste heat Water combusted) Throughput) s {1,0O7x 0,0004 t Ml$ -.Z.5) 0 es i 0,0004 FrratettA0higiiialAngini,rit 0.OEI37 ' ::Mittitailtegnntiganarr f',4a 1. 0.0167 httraVh"!sr"ldw.,nayY. Section 05 Emissions Inventory Potential to Emit Actual Emissions Requested Permit Umits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) VOC 185.6 D.6 0,0 183,6 8.4 1602 PM10 - - 0.3 0.0 0,0 03 0.3 43 PM2.5 0,3 0.03 0,0 0.3 0.3 43 NOx 2.6 0.0 0.0 2.6 2.0 448 CO 12-0 0,0 0,0 1231 12.0 2042 Potential to Emit Actual Emissions Requested Permit Umits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (&ss/year) (lbs/year) (lbs/year) Benzene 10080 0 0 10080 504 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane S'1500 0 0 31680 1564 224 TMP 0 0 0 0 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a pent* Regulation 7,Section XVII.B,C.1,C3 Storage tank€s subject to Regulation 7.Section XVII,B,0.1&C.3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation?7,Section XVII,C.2 Regulation 6,Part A,NSP5 Subpart 0000 Storage Tank is not subject to HIPS 0000 (See regulatory applicability worksheet for detailed analysis) 8 of 20 K:\PA\2019\19WE0813.CP1 • •Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts Aand B-OPEN and Permit Requirements IR..,.c in the 000.015llon,entkrn,e ATTAINMENT • 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2'MY(Regulation 3,Part?,Section 11.0,1.af?' 2. Is the construction date(seMoe date)priorta 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for addlianal guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 5 TOY.NOx greaterthan lO TPY or CO emissions greater than 10T0Y(Regulation 3,Part B,Section 11.0.3)? V0u hove indicated that source is 1n the Nrm-AtteYmn:ant Onto NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from thls individual source greaterthan l TM/(Regulation 3,Part A,section ll.o.l.e)? feMtI Source Req 2. Is the construction date(service data)clothdate)prior to 12/30/2002 and not modified after l2/31/2002(See PS Memo 05-01 Definitions 1.12 and114and Section l for additional guidance on grandfather appiicebility)? A'5 y�td Go to next, 3. Are total facility uncontrolled VOC emissions greaterthan 2 TPV NOx greaterthan 3TPV or CO emissions greater than 30 TPV(Regulation 3,Part°,Section 11.0.2)? yet,-,STSurce Req Sat..oo requ.res e pan ilk Colorado Regulation 7,Section Xll.C-F • 1. Is this storage tan k located in the 8-hr ozone control area or any oz nn-attainment area or attainment/maintenance ea? Yes Continue-' 2. Is this storage tank located at an oil and gas exploration and production operation',natural gas compressor station or natural gas dnpstatidn? 105 Continue-' 3. Is this storagetank located upstreamaf a natural gas processing plant? T ASourceisst kit-Rapt-irk is_ib;actto Reguiat en 7,Soot,on Section XII.CC—General Requirements for Air Pollution Control Equipment—Prevention of Leakage 5ee0t00 XII.C.2—Emission EMimatlon Procedures Section MILD—Emissions Control Requirements Section%II.E—Monitoring Section W.;—Recordkeeping and Reporting Colorado Regulation 7,Section XII.G 0. Is this storage tank located in they-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue-' 2. Is this storage tank located at a natural gas processing plant? No Storages' 3. Doe this storage tank exhibit"Flash"(eg string no stablaed liquids)emissions and have uncontrolled actual emissions greaterthan or equal to 2 tons per year VOC? MEi,,. ISSbraye 00nk is not auble.t ho Regulation 3,Ca 111011 XR? Section XII.G.2 r Emissions Control Requirements Section XII.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section 011.0.2—Emission Edonation Procedures Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? Sc Continue-' 2. Isthls Condensate storage ta,k'lacated at an oil and gasexpioranon and production operation,well production facility],natural gas compressor station'or natural gas processing plant? yes Go to then 3. Is this condensate storage tank a fixed roof storage tank? AIRIRRRIR Go to then • 4. Are uncantmlled Ctual emissions'of this storage tank equal to or greaterthan 6 tons per year VOC? WadSour-,,% ISto.getank it soh;OCt to Regulation 7,9e1dgn X011,0,C.10 C3 Section XVR.a—General Prceislons forAir Pollution Control Equipment and Prevention of Emissions Section IMI.C.1-Emissions Control and Monitoring Provisions Se.on IMI.C,3-Recordkeeping Requirements 5 Does the condensate nk contain only"stabilized" E liquids? ,:'Source ism I000r300 conks_sb act to 100003tion?,se-lon:0IIX:1 Section XVII.0.2-Capture and Monnoringfor Storage Tanks fitted with Air Pollution Control Equipment 40 CFR.Part 60.Subpart Kb,Standards of Performance for Volatile Organic Liouid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(ma))^472 BBts)? ;4U¢ tothen 2. Doeo the storage vessel meetthe fallowing exemption In 60.111b(d)(4)? ertgang."Storage,' a.Dorathe.vessel has a design opacity less than or equalba 1,589.874ms["10,000 BBL]used for pets leurn'or condensate stored,processed,or treated prior to custody transfer.as defined in 60.1110? 3. Was this condensate Sooge tank constructed,reconstructed,or modified(see definitions 40CFR,60.2)afteriuy 23,1984? 4. Doa the tank meet the definition of"storage vessel".in 60.1116? 5. Does thestorage vessel More a"volatle organic liquid(VOL)°s as defined in 60.111E? '.'an 6. Do a the starege vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designed to operate in excess of 2049 kPa["29.7psl]and without emissions to the atmosphere(60.11ob(d)(2))?;or b.The design opacity is greaterthan or equal to 151 m')^950 BBL]and store a liquid with a maximum true vapor pressure°los than 35 kPa)fi0.110b)b))?;or c The design capacity is greaterthan or equal to 75 Ms 1^472 BBL]but los than 151 m'["950 BBL].and stores a liquid with a maximum true vapor pressure]less than 15.0 kPa)60.110b(b))? I.,tarage Taokic mot suhiert.to MFRS Kira Subpart A,General Provisions 4601126-Emissions Control Standards for VOL 560.1136-Tasting and Procedures §60.115b-Reporting and Recordkeeping Requirements §60.1166-Monitoring of Operations 40 CFR.Part 60.Subpart 0DOO,Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1. Is this condensate storage vessel looted 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? Cont..Y 2. Was this condensate smregevessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? W.,...,,INI Stooge Tar 3. Are potential V0C em,ssnons'fram the individual storage vessel greaterthan or equal to 6 tons per year? ggIngRAS. 4. Does this condensate storage as meetthe dafnton of'storage vesot'per 60.5430 5. Is the storage vessel subjecttaand controlled n cordance with requirements for storage vessels in 40 CF0.Part 60 Subpart Kb or40 CF0.Part 63Subpart HH? IRtorage Tank is'RR nublect to 0103 0000 Subpart A,General Pmvisiom per§605425 Table 3 460.5353-Emissions Control standards for vOC 460.5413-Testing and Procedure • 460.5395(g)-Nottlotlon,Reporting and Recordkeeping Requirements 560.6416(c)-Cover and Closed Vent System Monitoring Requirements 560.5417-Control Device Dentotng Requirements [Note:If stooge vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per year VOC on the applicability determination date,it should remain subjectto NSPS 0000 per 60.5365(e)(2)even If potential VOC emissions drop below 6 tons ne vea,] 40 CFR.Part 63,Subpart MAR NN,Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets ether of the following criteria: [gas 'Continue-' • a.A facility that presesm,upgradm or stores hydrocarbon liquids')63.760(0))2));OR b.Afacility that processes,upgrades arstores natural gas prior bathe point at which natural gas enters the natural gas transmission and stooge source category or delivered to°final end user.(63.760(a)(3))? 2..is the tank located at a facility that is major for HA Ps? ,.'.'...��SS storage Tau 3. Does the tank meet the definition of"atoragevessel"'in 63.761? BMW 4. Do.thetank meet the definition of'storage vessel with the potential f rtlashemssons"a per 63.761? MOM S. IS the tank subject to controlrequre menis under 40 CFR Part 60,Subpart Ids or Subpart 0000? GEM I002000a Tank f<rscisubiectia MAC(HO Subpart A,General provisions per 463.764(a)Table 2 §63.766-Emissions Control Standards 463.'173-Monitoring 563.774-Recordkeeping §63.775-Reporting RACT Review PAR 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 Duality Control Commission regulations.This document is not a rule or regulation,and the analysis it 00000)ns 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,andAir 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. Condensate Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emssions? -w. If yes,are the uncontrolled actual or requested emissions estimated to be greater than or equal to 40 tans 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? - Ryes 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. If no,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 request a control device efficiency greater than 95%for a flare or combustion device? mo, r 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 »�`o rrye-tfta g2J'uie.'�Gg�s'Yusmg HYSY5 based on 3p ssurtze4well headsamples-Based on themodel,It prov dedthethecomposihon of theflash gas of lbetanf,tiowever�niodeledthatthere 11 • (g3uIdnoib ' lass540ndffeshamissions B thou assessment t b sed n a pressurized liquid sample taker directly upstre m of the tank,as required per PS Memo 05-01,there will tiedn311 tlaltfoi' ' lie*lnett"ie feriff 1i bees ablbtyro tootot the reoue,ted emisst n factors, Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled' Emissions AIRS Point It Process 0 SCC Code Pollutant Factor Control% Units 013 01 m.a /W. „« PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 2.5 95 lb/1,000 gallons condensate throughput CO 0.00 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.01 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n-Hexane 0.06 95 lb/1,000 gallons condensate throughput 224TMP 0.00 95 l6/1,000 gallons condensate throughput 6 of 20 K:\PA\2019\19WEOS13.CP1 Condensate Storage Tank(s)Emissions inventory 013 Condensate Tank Facility Allis ID: "�^* County Plant Point Section 02-Equipment Description Details . Detailed Emissions Unit itvek 13th.�f1Wri,Curb#ar Prusedl'pwtitstaragi8aFopndisbaata Description: F..........:....... .. ..... s::;:.=gyp:..:ds ^ir .... :;.. Emission Control Device ;flilfq§edar'itk1t15tic ti3'eylq' a IMf Description: '1 R `` _ )'.,:),,TT;)).:'... f Requested Overall VOC&HAP Control Efficiency°A: :95 .iM.! Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Condensate Throughput= . :::Barrels bbl '-t,i..._. <'.:..... (bbl)per year Actual Condensate Throughput While Emissions Controls Operating- `j°` ( )per year g- .:.:::e:<`.:�1<:Barrels hbl Requested Permit Limit Throughput= .172)3531..Barrels(bbl)per year Requested Monthly Throughput= 14638 Barrels(Mal)per month Potential to Emit(PTE)Condensate Throughput -k 'S = ='2725;;Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= .2a.n!Btu/scf Volume of waste gas emitted per BBL of liquids') €..,.;v,,i„^;,,;a.: produced= .::%'scf/bbl Actual heat content of waste gas routed to combustion device= 0 MMBTU per year Requested heat content of waste gas routed to combustion device= 0 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 0 MMBTU per year Section 04-Emissions Factors&Methodologies r Will this storage tank emit flash emissions? Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (Ih/bbl) (Ib/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC ,N0.0l.,0-10'.,'..' 0.01 P'a'Yirin Benzene „'0A01 - 0.000 S SP,e E€37KT'AM E.E=Wu aek iiraa₹$i3p Toluene .:0.001 0.000 Slte.5AeUlflcEIWTAhdtt5 E&.:Worldngand eget ?e Ethylbenzene :",0.000 0.0#1 Site SpecifioWPATAtdR11 F Worinngend4Ssata*: Xylene 0000 B.000 Site,5pecific.Er'.A.TACdKSE P MMIdtttgatr °d n-HexaneS 0003 : 0.000 C'.4?-010 __�__/�,�iM1,+C 224 TMP 0,000" ;' 0.000 .. ,; t ielatn,, srr�,,,8`seet₹za Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0007$? t 0.01ilE �YliklP092Sj PM2 S R..pXKfis 0.0000 v., :43W.?Ab,2.5}. .;', NOx ��s 0 B0 2 0.0000 .': i=4, CO } 1 033011:: . 0.0000 ® ,_,_ ,:f ' Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled ' (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) VOC 9.0 0.0 0.0 9.0 0.4 76 _ PM10 0.0 0.0 0.0 0.0 0.0 0 PM25 €1.0 0.0 0,11 11.11 0.0 0 NOx 0.0 0.0_ 0.0 0.0 0.0 0 CO 0.0 0.() 0.0 0.0 0.0 0 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) Ohs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 86 0 0 36 4 Toluene 36 0 II 06 4 Ethylbenzene 17 0 0 17 1 Xylene 34 0 0 34 2 n-Hexane 443 0 0 443 22 224 IMP 0 0 0 0 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section XII.C,D,E,F Storage tank is subject So Regulation 7,Section Xil.C-F Regulation 7,Section XII.G,C Stucuge Tank is not sub(ecl to Regulation 7,Section XII.G Regulation 7,Section XVII.B,C.1,C.3 Storage tank is subject to Regulation 7,Section KV11,B.C.1&C3 Regulation 7,Section XVIl.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 NIPS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage Toni(is not subject?o NIPS 0000 Regulation 8,Part E,MACF Subpart HH Storage Tank is not subject to MALT HH (See regulatory applicability worksheet for detailed analysis) 5 of 20 K:\PA\2019\19WE0813.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities.If the tanks you are reviewing are at one of these facilities,please review NSPS Kb. Colorado Re IatIon 3 Parts Aand 9-APEN and Pernik Requirements 'Source is in the 5o0Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section 11.1.1.0)7 2. Is the operator claiming less than 151 crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater?(Regulation 3,Part B,Section 11.0.1.M) �j/' 3. Are total facility uncontrolled VOC emissions greater than 5 TPA Noxgreater than SOTPV or CO emissions greater than 1OTPY(Regulation 3,Partg,Section 11.0.31? 'Yoe have indicated that souse is in the Non-Attainment Area . NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section ll.D.1.a)? ,,AAa Source Req 2. Is the operator claming less than 1%crude all and Is the tank located at a noncommercial facility for processing oil and gas wastewater?(Regulation 3,Part B,Section 11.0.1.M) _iikrer,'Goth next, 3. Are total facility uncontrolled VOC emissions greater than 2 TM',NOx greater than 5TPY or CO emissions greater than 10TPY(Regulation 3,Part B,Section 11.0.2)? Yebl- iSource Req 'Source requires a permit Colorado Regulation 7,Section XVII 1. Is this tank located ate transmission/storage facility? do Continue-' 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-' 3. Is this produced water storage tank a fixed roof storage tank? es :_,Go to the n 4. Are uncontrolled actual emieelonsof this storage tank equal to greater than 6 tons per year VOC? Wear Source Is at 'Storage tanit Ix.subject to Regulation'f,Section 3V9,0,C,E 0,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 S. Does the produced water storage tank contain only"stabllized"liquids?if no,the following'additional provisions apply- --elSource is sr. 'Storage tank in sublessee Regulation 7,Section XVIi.C.2 Section XVR.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR,Part 60,Subpart 0000,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this produced water storage vessel located ate facility In the onshore ail and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-' 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? Tarr"1 Go to then 3. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons Per Vear? #3.c„ Storage Tat 4. Does this produced water storage vessel meet the definition of"storage vessel"per 60.5430? .s :'4 Go to then ISeurege Tank is not aublect to NSPS 0000 Subpart A,General Provisions per§60.5425 Table 3 §60.5395-Emissions Control Standards far VOC §60.5413-Testing and Procedures • §60.5395(g)-Notification,Reporting and Recordkeeping Requirements 860.5416(c)-Cover and Closed Vent System Monitoring Requirements. _ - §60.5417-Control Device Monitoring Requirements Note:If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 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 rile 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 Qualify Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as'recommend,°may," 'should,"acid'can,"is intended to describe AFCD interpretations and recommendations.Mandatory terminology such as'must'and"regiiired"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. Produced Water Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? 0;1 If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis?This sample should be considered representative which generally means site-specific and collected within one year of the application received date. 536O1§46MaiigifliMBEifig However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to is use an older site-specific sample. aiiiiMENNIESSSION 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 control device efficiency greater than 95%far a flare or combustion device? •Nz7` , 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 S%.r # viBpsu�fY�E#J09(etnptf'"arytSk201�'7�r�:SqurcelS f.Rgyestfcfg fine r7sage of state is n s f tats heatcontent, dg to t rat � E r h � �- ", ��ti��'�'w - Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point 6 Process 9 SCC Code Pollutant Factor Control% Units 012 01 4-04-003-15 Fixed Roof Tank,Produced Water,working+breathing+flashing losses PM10 0.01 0 lb/1,000 gallons liquid throughput _ PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n-Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput • • 3 of 20 K:\PA\2019\19WE0813.CP1 Produced Water Storage Tank(s)Emissions Inventory 012 Produced Water Tank Facility Al Rs ID: ,..t.. - 9CO2County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit - �� One(1)300-barrel fixed roof tank used fatthestotagerof ro pducedwatets ,- Description: N..n.�' .., A,3g 1 . "91 *n Emission Control Device - Enclosed CuanbusYor g3` `aE 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= +,,�^.:;�` 3,43 �rrels(bbl)per year Actual Produced Water Throughput While Emissions Controls Operating= 'i 1,437 Requested Permit Limit Throughput= • ;;;-vgq,zogtool Barrels(bbl)per year Requested Monthly Throughput= • 20093 Barrels(bbl)per month Potential to Emit(PTE)Produced Water `a' Throughput= , Barrels(bbl)per year Secondary Emissions-Combustion Device(s) -@o , Btu/scf Heat content of waste gas= '�cna Volume of waste gas emitted per BBL of liquids 95,n09,159105,1 produced= 3s scf/bbl • Actual heat content of waste gas routed to combustion device= 77 MMBTU per year Requested heat content of waste gas routed to combustion device= 133,249 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 13,249 MMBTU per year Section 04-Emissions Factors&Methodologies Will this storage tank emitflash emissions? _ ,!, Emission Factors Produced Water Tank Uncontrolled Controlled (Ib/bbl) (Ib/bbl) Emission Factor Source Pollutant (Produced(Produced Water Water Throughput) Throughput) VOC 0.262 0.01 E*€trdose€)O0k"eFstatq"P y{[,ffCiizdrSi#a5ft}%. rfrsk Benzene 0 007 0.000 Pb406,a desdf,,F' Toluene 0.000P, Ethylbenzene _.._..-._ 0.000 i2r5tat Xylene 0.000 _., ( ¢gnu ,,. n-Hexane r702'_- 0.002P>≤4daced WaierF[a[3EF([ itde3 Hash fYesmt 224 TMP 0000 ,P„T,;d?ueed:Water State,E.F414Wesifasfir0101 Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMetu) (lb/bbl) Emission Factor Source (Produced (waste heat Water combusted) Throughput) PM10 0:0{#75 0.0004 Tait 1S# PM2.5 0,0075'x, 0,0004 N� NOx 02$30 00037 r'q" ?t CO 3.44.6631040" 0,0167 ≥� ... li� '. 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) VOC 32.2 0.2 0.0 32.2 1.6 274 PM10 0.0 0.0 0.0 0.0 0.0 8 PM2.5 0.0 0.0 0.0 0.0 0.0 8 NOx 0.5 0.0 0.0 0,0 0.5 77 CO 2.1 0.0 0.0 2.1 2.1 349 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 1722 10 1 1722 66 Toluene 0 - 0 0 0. 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane 5412 32 2 5412 271 224TMP 0 0 0 0 0 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 XVIM,B,C.1&C.3 Regulation 7,Section XVII.C.2 Storage tank is subject to Regulation 1,Section XVII.C.2 Regulation 6,Part A,NIPS Subpart 0000 Storage Tank Is not sub)ect to HOPS 0000 (See regulatory applicability worksheet for detailed analysis) 2 of 20 - K:\PA\2019\19WE0813.CP1 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: kagralefgjttigiT yf Package#: 4172et3;;= Received Date: 9/10/2019 Review Start Date: 10/22/2019 Section 01-Facility Information Company Name: Noble Energy,Inc:• � '_. Quadrant Section Township Range County AIRS ID: 123 -SESE I -:- 4 EPd °`59 Plant AIRS ID: 9002 Facility Name: Co-Located:MCCLELLANN;RSW'TR 553 MptRthTlY STATE LG01-1E EC0N00ETRN-ff59W-S4 LOS - Physical Address/Location: SESE quadrant of Section 4,Township RN,Range 59W County: 'Weld County Type of Facility: €xploaa 07 #ckftilckr`,1 lhlmgCtII What industry segment? K agf ltgas Ptzztuc 0Alfr d , Is this facility located in a NAAQ5 non-attainment area? Ett , 's,•,„_ If yes,for what pollutant? Carbon Monoxide(CO) Q Particulate Matter(PM) El Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point# Emissions Source Type Equipment Name Control? Permit# Issuance# Required? Action Remarks bk � PradcedUuaterTwk =sroiucedaterStorage: Yes- 13WE2825 3 lVD tAftdrbein { Permitlttdtiai 013 CUCtdensacaT OffSp .Tanks yes 19WE0813 2 Yea : y gtuence ?' l? mt�tal 014- P'rr�r ucey fir, k 0roduced Water Storage yes'`,.',.- 19WE0813 1 Yes 5u5t3€e 015 Liquid oath ofit pndensateTruck Loa do Yes 19WE0813 1 Yes totSq CllatgligtDIN 59 k r � reater/SurgwDruOGas YesS 19WE0813 1 Yes flee ra Section 03-Description of Project This E&P site has added condensate storage tanks,produced water tanks,loadout,and separator venting at their site as of 4/10/2019 at the Dorothy Stde₹uei p Additionally,thesite added four natural gas RICE,which were requested under 5502 coverage.ge At the collocated facility,McClellan,the taciiity has addgt3,proc(ucrdweter hasafd„tj�uulCle i4 tan#rs,These fae$Idtdes are cons,idared cp-toaated as t€tpy share equrpment,,ncluding a,gas lift This facility is lccatad in the s unattainmerrlsessod emissions of 46.2 tpy include insi nifi'cant&APEN exempt sources re orted on thef<ct₹'t' ride e n;ssions inventory toxin p`I g P P /,< Y�„ Section 04-Public Comment Requirements Is Public Comment Required? If yes,why? Regaes pg Syn neoe Mih, Section 05-Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? IiNtiiarnireMigigiae 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? Flop ltf i % Is this stationary source a synthetic minor? If yes,indicate programs and which pollutants: SO2 NOx Co VOC PM2.55I PM10 TSP HAPs Prevention of Significant Deterioration(P5D) C ❑ ❑ Title V Operating Permits(OP) — J ✓ J ._li ELI J Non-Attainment New Source Review(NANSR) ✓ Is this stationary source a major source? � �fn• � If yes,explain what programs and which pollutants herr 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) _ — ❑ _ ❑ ❑ Title V Operating Permits(OP) Non-Attainment New Source Review(NANSR) Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU 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 listof all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.govipacific/cdpheiair-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: RECEIVED SEP 1 0 2019 APO) 5tAtionalY Source AIRS ID Number: 123 19CO2 f (. Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: MCCLELLAN 18N-R59W-S9 L01 Site Location: NENE SEC09 T8N R59W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail AddressZ: Laura. Davis@nblenergycom ' 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 wilt be issued by the APCD via a -mail to the address provided. 417265 Permit Number: AIRS ID Number: 123 / 9CO2 Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 ❑ 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 O Change permit limit ❑ Transfer of ownership4 0 Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ID APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Emissions from produced water were below reportable values previous to 2019, due to a frac-into event, produced water emissions are now reportable. 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: 7/27/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: ❑ Exploration & Production (E&P) site days/week 52 weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? p Yes ■ No Are Flash Emissions anticipated from these storage tanks? 19 Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No ■ p Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes MI No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ■ p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIS emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APLD L07 Produced : _ier St..orase TanHS I APEN 312019 21 OR 0O ✓Q Upward O Horizontal Permit Number: AIRS ID Number: 123 19CO2/ Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbtl year) 1,436.64 Requested Annual Permit Limits (bbf/year) 246,000 From what year is Tank design:. ✓l Fixed roof Count? 2018 O Internal floating roof O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW Tanks 1 300 11/2013 Temp Tanks 1' 500 04/2019 Wells Serviced by this Storage Tank or Tank Battery6 (EaP Sites On y) API Number Name of Well Newly Reported Well 05 -123 -36972 MCCLELLAN LG09-72HN ■ ■ at O s Requested values wilt become permit limitations. Requested limit(s) should consider future growth. The EEtP Storage Tank APEN Addendum (Form APCD-2i2) 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 UM) 40,6839, -103.9727 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) O Downward other (describe): Indicate the stack opening and size: (check one) 0Circular Interior stack diameter (inches): J Square/rectangle Interior stack width (inches): O Other (describe): O Upward with obstructing raincap Interior stack depth (inches): Permit Number: AIRS ID Number: 1 23 / 9C02 / (Leave blank wniess A?CD has asst ned permit and AIRS IDi 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. Vapor ❑ . Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95 98 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr 0 Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: 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)? —100, 50 psig Describe the separation process between the well and the storage tanks: The wellheads produce fluid to gas/liquid separator(s). The produced water is routed to water tank(s). Emissions from the produced water tanks are routed to the enclosed combustor on site. Form APCD-2O7 Produced Water Storage Tank(s) APEH Revision 3/2019 ACOLORADO Permit Number: AIRS ID Number: 123 / 9CO2 / 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): Pollutant Description of Control Methods) Overall Requested Control Efficiency (11, reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: Front what year is the foiIowin?reported or toot nnriuol omissions data? 201 8 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg.. etc.) Uncontrolled Emissions (tons/year) y } Controlled Emissionse (tons/year) ;, Uncontrolled Emissions {tons/year) Controlled Emissions (tonslyear) VOC 0.2620 lb/bbl CDPHE 0.19 0.01 32.23 1.61 NOx 0.068, 100 "Mk. "uut AP -42 0.09 0.09 0.53 0.53 CO 0.310, 84 +Mel,&4e 1 AP -42 0.08 0.08 2.12 2.12 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS)' Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42. Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 1,722 86 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 Ib/bbl CDPHE 5,412 271 2,2,4- Trimethylpentane 540841 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. Laura Davis Permit Number: AIRS ID Number: 123 / 9CO2 / 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 will b.l rated in full compliance with each condition of the applicable General Permit. 07/09/2019 uthorized Person (not a vendor or consultant) Date Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: e Draft permit prior to issuance J 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 registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-81 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692.3175 or (303) 692.3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado.gov/cdphe/apcd 61 Produced Water Storage Tank(s) APEN - Form APCD-207 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 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 alt available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.coloradosqov/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: 13WE2925 AIRS ID Number: 123 /9=4)12 (Leave blank un es: APCD has a:+ a' f a rw o permit i, # earl AI ..:': Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: MCCLELLAN T8N-R59W-S9 L01 Site Location: NENE SEC09 T8N R59W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E Mail Address2: Laura.Davis@nbtenergy.com. i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt 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. APCD.-.07. _--"7 ' f ' d Water Storage TatlItEll 9 AI +` COLORADO Permit Number: 13WE2925 AIRS ID Number: 123 19CO2/012 Section 2 - Requested Action Q NEW permit OR newly -reported emission source Ei Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 0 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 Et Notes: Emissions from produced water were below reportable values previous to 2019, due to a frac-into event, produced water emissions are now reportable. 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: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 7/27/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 Q Exploration & Production (E&P) site weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ■ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No ■ ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes 0 No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No I9 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No ✓ ■ 3-_..'9 �Y taLaanoo ❑✓ Upward O Horizontal Permit Number: 13WE2925 AIRS ID Number: 123 19CO21012 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/ year) Produced Water Throughput: From what year is the actual annual amount? Tank design: 0 Fixed roof 1,436.84 2018 O Internal floating roof Requested Annual Permit Limits (bbl/year) .: 246,000 O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage: Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) : Date of First Production (month/year) PW Tanks 1 300 11/2013 Wells Serviced by this Storage Tank or Tank Battery° (EaP Sites On y)' _r API Number Name of Well Newly Reported Well 05 -123 -36972 MCCLELLAN LG09-72HN 5 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 UTM) '. 40.6839, -103.9727 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°0) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ['Downward O Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) El Circular Interior stack diameter (inches): �] Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Farm h_Li'_+-;?.?)7 Cf.. -� _.. ..'i ) �] - 's:.iAPEI 312.019 3 COLORADO Cann. u,a R.4 Permit Number: 13VVE2925 AIRS ID Number: 123 /9CO2/012 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. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ✓0 Combustion Device: Pollutants Controlled: VOCS and HAPs Rating: MMBtu/ hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? ~100, 50 psig Describe the separation process between the well and the storage tanks: The wellheads produce fluid to gas/liquid separator(s). The produced water is routed to water tank(s). Emissions from the produced water tanks are routed to the enclosed combustor on site. COLORADO I Y' D Permit Number: I3 W E2925 AIRS ID Number: 123 19CO2/012 Section 8 - Emissions Inventory Information Attach Mt emissions calculations and emission factor documentation to this APEN forme. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant. Emissions inventory Pollutant Emission Factor Actual Emissions Requested Annual Emission Permit < . Limit(s)5 Uncontrolled Basis. ' Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions ' (tons/year) Controlled Emissions (tonslyear) VOC 0.2620 lb/bbl CDPHE 0.19 0.01 32.23 1.61 NOx 0.068, 100 t'W.• ibiMMwr AP -42 0.09 0.09 0.53 0.53 CO 0.310, 84 k" .19" `b4 AP -42 0.08 0.08 2.12 2.12 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract: Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg•, etc.) Uncontrolled Emissions (Pounds/year) Controlled Emissions8 (pounds/year) .. . Benzene 71432 0.0070 lb/bbl CDPHE 1,722 86 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl CDPHE 5,412 271 2,2,4- Trimethylpentane 540841 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. 5► [tias. COLO ii DO Permit Number: 13 W E2925 AIRS ID Number: 123 /9O02/ 012 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 will be 9p re aced in full compliance with each condition of the applicable General Permit. 1/28/2020 ignature of l�e�a,tj Authorized Person (not a vendor or consultant) Date Laura Dav Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 43O0 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.00v/cdphe/aocd 9 6L Cot°RAO° Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU 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 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 wilt 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, ILC. for revised APEN requirements. Permit Number: / 9 WE 03 13 se -p 1 AIRS ID Number: 123 / 9C02 / l9 (.3 Section 1 - Administrative Information Company Name': Noble Energy, inc. Site Name: DOROTHY STATE LG01-16 ECONODE T8N-R59WSd L01 Site Location: SESE SEC04 T8N 59W Mailing Address: dwa (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@nbIenergy.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the companyne a 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. a A17257 Permit Number: AIRS ID Number: 123 / 9C02 / Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source • Request coverage under traditional construction permit O Request coverage under a General Permit O GP01 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) O 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 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): For existing sources, operation began on: 04/10/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration a Production (E&P) site weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? O Yes ■ No Are Flash Emissions anticipated from these storage tanks? • Yes O No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ■ Yes O No If "yes", identify the stock tank gas -to -oil ratio: q. m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. • Yes D No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No II MI Fc,rm AF(D 205 Conde tom e Tai si APE+ Revision 3 .: i° 2 I Permit Number: AIRS ID Number: 123 /9O02/ Section 4 - Storage Tank(s) information Actual Annual Amount (bbl/year) Condensate Throughput: From what year is the actual annual amount? N/A Average API gravity of sales oil: 34.91 degrees Requested Annual Permit Limits (bbtlyear) Tank design: 0 Fixed roof O Internal floating roof 172,353 RVP of sales oil: a492""'"'"' O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Tanks 2 1000 04/2019 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Ony) API Number Name of Well Newly Reported Well SEE ATTACHED • O ■ ■ s Requested values will become permit limitations. Requested limit(s) should consider future growth. b The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.685, -103.9752 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustor 50 Variable Variable Variable Indicate the direction of the stack outlet: (check one) Q Upward ❑ Horizontal ❑ Downward ❑ Other (describe): O Upward with obstructing raincap Indicate the stack opening and size: (check one) Q Circular Interior stack diameter (inches): 120 ❑Square/rectangle interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): 31 Permit Number: AIRS ID Number: 123 / 9C02 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make /Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % ❑ Combustion r Device: Pollutants Controlled: VOCs and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor Make/Model: Zeeco, H REC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: El Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 2 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. t _. `)5 Condensate _,e 41 COl. ORADO ON PM closed £ ual'/ ME'O( 121312011 Permit Number: AIRS ID Number: 123 19CO21 Section 8 - Emissions Inventory Information Attach alt 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 Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: t what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source tAP-42, Mfg., etc.) Uncontrolled Emissions (tonslyear) Controlled Emissions 8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.1042 Ib/bbl livsYsaaakseidgt 8,98 0.45 NOx 0.068 IbiMMBtu AP -42 0.01 0.01 CO 0.310 ib/MMBtu AP -42 0.07 0.07 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (poundsfyear) Controlled Emissionss (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 PID4Z n -Hexane 110543 0.0026 lb/bbl YIYSYS5.4." 0kW 445 22 2,2,4- Trimethylpentane 540841 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. Permit Number: AIRS ID Number: 123 t 9002 / 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 - egistration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be .p -r• ted in full compliance with each condition of the applicable General Permit. ature of July 09, 2019 uthorized Person (not a vendor or consultant) Date a ra Davis Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: El 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 registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.govicdphe/apcd 6 1/8/2020 State.co.us Executive Branch Mail - Noble Energy, Inc. - McClellan & Dorothy State Permit Applications STATE OF COLORADO Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us> Noble Energy, Inc. - McClellan & Dorothy State Permit Applications Laura Davis <Laura.Davis@nblenergy.com> Tue, Dec 3, 2019 at 12:10 PM To "Lakocy - CDPHE, Lauraleigh" <lauraleigh.lakocy@state.co.us> Good Afternoon Lauraleigh, Thank you for your response and clarification on your request, please see my comments/responses below: Additionally, as a head's up starting tomorrow December 4th through Monday December 9th I will be out of the office. I hope you had a great Thanksgiving. Thank you, Laura From: Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us> Sent: Monday, December 02, 2019 12:36 PM To: Laura Davis <Laura.Davis@nblenergy.com> Subject: EXTERNAL: Re: Noble Energy, Inc. McClellan & Dorothy State Permit Applications Good Afternoon Laura, l: am gi g to red -fine the condensate APEIV to reflect AP -42 as the source of the working/breathing emissions calculations. l am aware that Tanks 4.0.9d is no longer supported; however, the documentation you provided stated that the emissions were calculated using the software, which is why I was requesting additional clarifications. ttk`you, we will use AP-42°in the future. A Thank you for the clarification on the modeling methodology. Please note that based on the guidance provided in both. PS Memo 05-01 and 14-03, this source will be required to take a pressurized liquid sample from the outlet of the "Surge Drum" (i.e.. the pre -flash pressurized oil obtained from the separator outlet to the sales tank) to demonstrate compliance with the requested emissions and emissions factors. I see that is included in the PS Memos, this is the first time I have been asked for this, but we will take the sample to demonstrate compliance. Do you want this taken prior to permit submittal or as a permit condition? https://mail.google.com/mail/u/0?ik=44f88835c3&view=pt&search=al I&permmsgid=msg-f%3A1651926862502010152&simpl=msg-f%3A16519268625... 1/2 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for 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.Rovlpacificicdphelair-permits. This emissionnotice 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: J ! (t%r o `j J3 AIRS ID Number: 123 /9CO2/ C/171 - Section 1 - Administrative Information Company Name: Noble Energy, Inc_ SiteName: DOROTHY STATE LO01-16 ECONODETBN-R5SWS4 101 Site Location: SESE SEC04 T8N 59W Mailing Address: (Maude Zip 1625 Broadway, Suite 2200 Zip Code) Site Location County: Weld NAICS or SIC Code: 1311 Denver, CO 80202 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@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 fetters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 4172,53 Permit Number: AIRS ID Number: 123 /9CO2 t Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑✓ 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. Oa- ❑ MODIFICATION to existing permit (check each box below that app! es) ❑ Change in equipment O Change company name3 O Change permit limit O Transfer of ownership' 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 & 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. 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: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 4/10/2019 For new or reconstructed sources, the projected start-up date is: Normal. Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: ✓❑ Exploration Et Production (E&P) site days/week 52 weeks/year El Midstream or Downstream (non EEP) site Will this equipment be operated in any NAAQS nonattainment area? Q Yes ■ No Are Flash Emissions anticipated from these storage tanks? Q Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? yes No ■ Si Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes EJ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 8O5 series rules? If so, submit Form APCD-105. yes No ■ Q .. Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? Yes No 0 ■ Permit Number: AIRS ID Number: 123 / 9CO2 / Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) IProduced Water Throughput: From what year Is the actual annual amount?N/A. Tank design: 0 Fixed roof O Internal floating roof 1,440,000 O External floating roof Storage Tank ID of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW Tanks 4 2,000 04/2019 Temp Tanks 10 5,000 04/2019 Wells Serviced by this Storage Tank or Tank Battery° (E P Sites On y) API Number Name of Well Newly Reported Well SEE ATTACHED ■ ■ ■ ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth_ 6 The EEP 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) 40.685, -103.9752 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustor 50 Variable Variable Variable Indicate the direction of the stack outlet: (check one) Q Upward O Horizontal ❑ Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) 9Circular Interior stack diameter (inches): 120 Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0Other (describe): Permit Number: MRS ID Number: 123 /9c02/ 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. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): rm Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor Make/Model: Zeeco, H REC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: 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)? —125, 25, 2 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 the surge drum 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. Permit Number: AIRS ID Number: 123 / 9CO2 I Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the verall (or combined) control efficiency f% reduction): Pollutant _ Description of Control Method(s) Overall Requested Control Efficiency (o reduction in emissions) V0C Encased Combustor 95`k_ NO CO HAPs Enclosed Combustor 95% Other: From what year is the following reported.] actual annual erniss,°ons data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, MIS, etc-) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tonslyear) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.2620 Ib/bbi CDPHE 188.64 9.43 NOx 0,068 Ib/MMBiu AP -42 2.64 2.64 CO 0.310 lb/MMBtu AP -42 12-02 12.02 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 10,080 504 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl COPHE 31.680 1,584 2,2,4- Trimethylpentane 540841 5 Requested values wilt 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. Permit Number: AIRS ID Number: 123 / 9CO2 / Section 9 - Applicant Certification t 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 o, ated in full- compliance with each condition o€ the applicable General Permit. ature of Le July 09, 2019 horized Perso not a vendor or consultant) Date abra Davis Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: D Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, 11.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of 5312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 8O246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: r !www, colorado. goy jcdphe taped 6 Hydrocarbon Liquid Loading APEN Form APCD-208 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-2OO) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/aped. So kzd 4/9 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: iqvuEoFti AIRS iD Number: 123 / 9C02 16 / Section 1 - Administrative information Company Name': Noble Energy, Inc. Site Name: DOROTHY STATE LG01-16 ECONODE T8N-R59W-S4 L01 Site Location: SESE SEC04 T8N 59W Mailing (nlAddress: 1625 Broadway, Suite 2200 (include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or sic Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@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. I Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided. 417253 Permit Number: AIRS ID Number: 123 / 9CO2 Section 2 - Requested Action O NEW permit OR newly -reported emission source 0 Request coverage under construction permit O 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 O Transfer of ownership'' O Other (describe below) Os- ❑ APEN submittal far update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional info & Notes: 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-1O4) 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: 04/10/2019 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No Q ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • Q Does this source load gasoline into transport vehicles? O Yes No Q Is this source located at an oil and gas exploration and production site? 0 Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • Q Does this source splash fill less than 6750 bbl of condensate per year? a Yes No ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ 12 Permit Number: AIRS ID Number: 123 /9CO2/ Section 4 - Process Equipment Information Product Loaded: 9 Condensate ❑ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5 172,353 bbl/year This product is loaded from tanks at this faci ity into: (e.g. "rail tank cars" or "tank trucks") _ Actual Volume Loaded: bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor:0.6GG Average temperature of bulk liquid loading: 51.7925 °F True Vapor Pressure: 3.6568 Psia @ 60 "F Molecular weight of displaced vapors: G r� 68 lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading tines, complete the following: Requested Volume Loaded: bbl/year Actual Volume Loaded: bbl/year Product Density: lb /ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft?/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Permit Number: AIRS ID Number: 123 I9CO2/ Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.685, -103.9752 Operator Stack ID No, Discharge Height Above Ground Level (feet) Temp. CF) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustor 50 Variable Variable Variable indicate the direction of the stack outlet: icheck one) Upward 0 Downward 0 Horizontal 0 Other (describe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter (inches): 1 20 0 Other (describe): 0 Upward with obstructing raincap 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. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: 9 Device: Combustion Used for control of: VOCs and HAPs Rating: 83 MMBtu / hr Type: Enclosed Combustor Make/Model: Zeeco, HREC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 m Minimum Temperature: F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr 0 Other: Pollutants Controlled: Description: Requested Control Efficiency: Permit Number: AIRS ID Number: 123 / 9CO2 / 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 (i reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (a reduction in emissions) PM SOX NO. CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 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 year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg.. etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 7.60 lb/MMscf AP -42 0.00 0.00 SOx 0.50 Ib/MMscf AP -42 0.00 0.00 NO„ 0.068 Ib/MMBtu AP -42 0.01 0.01 CO 0.310 Ib/MMBtu AP -42 0.06 006 VOC 0.1526 lb/bbl AP -42 13.15 0.66 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, M etc.) fg•. Uncontrolled Emissions (pounds/year) Y ) Controlled Emissions (pounds)year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0033 lb/bbl AP -42. 568 28 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. c Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Laura Davis Permit Number: AIRS ID Number: 123 / 9CO2 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 i - registration for coverage under General Permit GP07, I further certify that this source is and will be operated full compliance with each condition of General Permit GP07. July 09, 2019 uthorized Person (not a vendor or consultant) Date Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance [] Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main. Phone Number (303) 692-3150 Or visit the APCD website at: https: /1www.colorado.gov /cdphef aped Gas Venting APEN Form APCD-211 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 wilt be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. 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: l9 WE 813 AIRS ID Number: 123 19O02 / 616 Section 1 - Administrative Information Company Name1: Noble Energy, Inc. Site Name: DOROTHY STATE LG01-16 ECONODE T8N-R59W-S4 101 Site Location: SESE SEC04 T8N 59W Mailing Address: 1625 Broadwa , Suite 2200 (include Zip Code) y Site Location Weld County: NAICS or SIC Code: 1311 Denver, CO 80202 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@nblenergy.com 1 Use thefull, 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. 417260 11 Permit Number: AIRS ID Number: 123 /9O02/ 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 O Change company name3 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 O Other (describe below) OR - APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Heater treater and surge drum gas streams Company equipment Identification No. (optional): For existing sources, operation began on: 4/10/2019 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form AP(U-21I Gas Venting AMEN Revision 3/2019 El El days/week weeks/year Yes Yes Yes ❑ No ✓❑ No ❑ No raEokaca 2 I :... Permit Number: AIRS ID Number: 123 / 9CO2 / Section 4 - Process Equipment Information ✓0 Gas/Liquid Separator Welt Head Casing O Pneumatic Pump Make: Model: ▪ Compressor Rod Packing Make: Model: • Blowdown Events N of Events/year: [] Other, Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 9 Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: No Vent Gas Heating Value: 2810 BTU/SCF Requested: 7,94 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 50.38 VOC (Weight %) 88,80% Benzene (Weight %) 0.45% Toluene (Weight %) 0.51% Ethylbenzene (Weight %) 0.08% Xylene (Weight %) 0.17% n -Hexane (Weight %) 2.50% 2,2,4-Trimethylpentane (Weight %) 0.00% Additional Required Information: ✓[J Attach a representative gas analysis (including BTEX et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX a n -Hexane, temperature, and pressure) 9 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Folm A.PCD•21 i Gas Ventutg, APEI-1 - R.evisiDn 3'2019 COLORADO 3I Permit Number: AIRS ID Number: 123 / 9CO2 / Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.685, -103.9752 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp.Flow F ( ) Rate ( ACFM) Velocity (ft/sec) Enclosed Combustor 50 Variable Variable Variable Indicate the direction of the stack outlet: (check one) ✓0 Upward O Downward O Horizontal O Other (describe): Indicate the stack opening and size: (check one) ✓0 Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap 120 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. VRU: Pollutants Controlled: Size: Make/Model: • Requested Control Efficiency: % VRU Downtime or Bypassed: % Combustional Device: Pollutants Controlled: VOCs and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor Make/Model: Zeeco, H REC Requested Control Efficiency: 95 % Btu/scf MMBtu/hr Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: O Yes ■ No Pilot burner Rating: 0,195 Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APED -211 ,,as Venting APE1i Revision 3/201`+ 4I A 00 r, t erectma r l jJzick 1141��20. .t,ltl!mow Permit Number: AIRS ID Number: 123 I 9CO2 / 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 _„ r :• Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO), CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit -: s Emission Limits) Uncontrolled Basis. Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions° (tonslyeor) Uncontrolled Emissions (tons/year) Controlled Emissions (tons)year) PM 7.60 lb/MMscf AP -42 0.01 0.01 SOx 0.60 lb/MMscf AP -42 0.00 0.00 NOx 0.068, 100 "Ma',M'.!M AP -42 0.84 0.84 CO 0.310, 84 b,ua+®n..tfi'MW AP -42 3.53 3.53 VOC 118.1182 Ib/Mscf HYSYS/AP-42 468.35 23.42 • Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (poundslear y ) Controlled Emissions° (pounds/year) Benzene 71432 g61`ois lb/Mscf HYSYS/AP-42 4,775 239 Toluene 108883 4:•6.7-7.04.14 1b/Mscf HYSYS/AP-42 5,375 269 Ethylbenzene 100414 toz.al lb/Mscf HYSYS/AP-42 817 41 Xylene 1330207 4'i°JIb/Mscf HYSYS/AP42 x4;84& IA 92 n -Hexane 110543 .3-328P1 ib/Mscf HYSYS/AP-42 26,409 1,323 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 wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. E,..iS y lE::if- 5I Permit Number: AIRS ID Number: 123 / 9C02 f Section 8 - Applicant Certification I hereby certify that alt information contained herein and information submitted with this application is complete, true, and correct. 07/09/2019 gnature ofAuthorized Person (not a vendor or consultant) Date Laura Davis Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance ✓9 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, 11.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Qovfcdphe/aped 6 1/28/2020 State.co.us Executive Branch Mail - Noble Energy, Inc. - McClellan & Dorothy State Permit Applications STATE OF COLORADO Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us> Noble Energy, Inc. - McClellan & Dorothy State Permit Applications Laura Davis <Laura.Davis@nblenergy.com> Thu, Jan 16, 2020 at 8:50 AM To: "Lakocy - CDPHE, Lauraleigh" <lauraleigh.lakocy@state.co.us> Hi Lauraleigh, Thank you for the draft permits. Please find my comments for each permit below: 19WE0813: • In paragraph 24, can you please include the 60 day permit modification language that is included in paragraph 25? • In paragraph 27, what is the basis forihis requirement? We would prefer not to conduct periodic testing when we will already be required to conduct initial testing. • In the Notes to Permit Holder, I have a couple of requests for corrections, all corrections are based on the submitted calculation spreadsheet and what looks like a couple of errors I made filling out the APEN for Point 016. I entered the incorrect values for uncontrolled emission factors for several criteria and HAP pollutants. Would you like me to resubmit the APEN or can you make the corrections as a redlined version to the submitted APEN? 4. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Tanks 013 n -Hexane 110543 445 22 PW Tanks/Temp Tanks 014 Benzene 71432 10,080 504 n -Hexane 110543 31,680 1,584 Loadout 015 n -Hexane 110543 568 28 HREC Knockout Vessel 016 Benzene 71432 4,775 239 Toluene 108883 5,375 269 Ethylbenzene 100414 817 41 Xylenes 1330207 1,840' 1,813 92 n -Hexane 110543 26,409 1,323 5. Point 016: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 212.14 211.59 10.61 211.55 AP -42, Chapter 13.5 https://mail.google.com/mail/u/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1655900564633031478&simpl=msg-M3A1655900564... 1/13 1/28/2020 State.co.us Executive Branch Mail - Noble Energy, Inc. - McClellan & Dorothy State Permit Applications CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (Ib/MMscf) Source CO 888.71 839.17 889.17 44.44 VOC 117,905.54'118,118.2 5895.28 5,905.91 HYSYS Model of the Surge Drum Separator, based on 3 site -specific pressurized liquid samples (taken 5/23/2019) 71432 Benzene 601.05`302.1 30.05 15.105 108883 Toluene 676.52"677.7 33.83 33.885 100414 Ethylbenzene 102.84 103.0 5.14 5.15 1330207 Xylene 231.60 232.9 11.58 11.6 110543 n-l-lexane 3324.21 3,330.2 166.21 166.51 • I have a small rounding discrepancy with the NOx emission factors for Point 014: 5. CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.66E -03.3.67E 03 3.66E-03 3.67E 03 AP -42, Chapter 13.5 CO 1.67E-02 1.67E-02 VOC 0.262 1.31 E02 CDPHE State - Approved Emission Factors (PS Memo 14-03) 71432 Benzene 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 13WE2925: • The temporary tank has been removed from this location, can this language please be removed from the permit? • Under Permit History — Issuance 3 can you please include that Issuance 3 is the final approval? • Under Notes to Permit Holder, the, AIRS point should be updated to 012 4. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 - 280 14 n -Hexane 110543 2,400 120 012 892 Benzene 71432 1,722 86 https://mai tgoogle.com/ma"l/u/0?ik=44 f88835c3&view=pt&search=all&permmsgid=msg-P/u3A1655900564633031478&simpl=msg-f%3A1655900564:.. 2/13 1/28/2020 State.co.us Executive Branch Mail - Noble Energy, Inc. - McClellan & Dorothy State Permit Applications n -Hexane 110543 5,412 271 • When I calculate the emission factor for CO for the produced water I get a different value: 5. CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO 0.0173 0.167 AP 42, Chapter 13.5 0.0173 0.0167 V0C 0.262 131E-02 CDPHE Produced Water Emission Factor 71432 Benzene. 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 Thank you, Laura From: Lakocy - CDPHE, Lauraleigh <lauraleigh.lakocy@state.co.us> Sent: Wednesday, January 08, 2020 3:59 PM To: Laura Davis <Laura.Davis@nblenergy.com> Subject: EXTERNAL: Re: Noble Energy, Inc. - McClellan & Dorothy State Permit Applications Hi Laura, You as well! I was mostly in the office and I suspect It was the "calm before the storm," between the redesignation and the new regulations being adopted. I have attached draft permits for you to review prior to them being sent to public comment. They have been prepared in consideration of the redesignation limits. Can you please provide any feedback by Wednesday, January 22? Let me know if you have any questions! Sincerely, Lauraleigh Lakocy Oil Et Gas Permit Engineer Stationary Sources Program COLORADO Air Pollution Control Division Department of Public Health b Environment P 303.692.3146 4300 Cherry Creek Drive South, Denver, CO 80246 https://mail.google.com/mail/u/0? ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1655900564633031478&simpl=msg-f%3.O1655900564... Produced Water Storage Tank(s) APEN - Form APCD-207 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 ff 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 notsatisfy 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.govipacific/cdphetair-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: AIRS ID Number: 1 23 / 9C02 /Oz. RECEIVED SEP 1 0 2019 APCD Statiosory Sources s el Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: MCCLELLAN T8N-R59W-S9 L01 Site Location: NENE SEC09 T8N R59W Mailing Address: dwa (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@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. 417265 Permit Number: AIRS ID Number: 123 /9C02/ Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 D 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 O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Emissions from produced water were below reportable values previous to 2019, due to a frac-into event, produced water emissions are now reportable. 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: 7/27/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: ❑✓ Exploration & Production (E&P) site days/week 52 weeks/year ❑ Midstream or Downstream (non MP) site Will this equipment be operated in any NAAQS nonattainment area? INI Yes ■ No Are Flash Emissions anticipated from these storage tanks? O Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • p Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes Q No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes ❑✓ No Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualMI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Fu -1 ',PCD,207 Produc,nd i,°,:nhs APEN Re ison 312019 COLORADO 2 I ✓[� Upward 0 Horizontal Permit Number: AIRS ID Number: 123 / 9CO2/ Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bb(l year) 1,436.54 Requested Annual Permit Limits (bbl/year) 246,000 ram what year is the actual annual amount? Tank design: ✓❑ Fixed roof 2018 0 Internal floating roof O External floating roof Storage Tank ie # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank Obi) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW Tanks i 300 11/2013 Temp Tanks 1 500 04/2019 Wells Serviced by this Storage Tank or Tank Battery& (E&P Sites On y) API Number Name of Well Newly Reported Well 05 -123 •36972 MCCLELLAN LG09-72HN ■ ■ ■ ■ ■ s Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Farm APCD-212) should be completed and attached when additional space is needed to report alt wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.6839, -103.9727 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft)sec) Indicate the direction of the stack outlet: (check one) O Downward [Other (describe): Indicate the stack opening and size: (check one) E Circular Interior stack diameter (inches): O Square/rectangle Interior stack width (inches): bother (describe): 0 Upward with obstructing raincap Interior stack depth (inches): 3 Permit Number: AIRS ID Number: 123 / 9O02 / (LerP.e bten wr(es; APCD `ds a ready assi ned •; permit and AIRS !DI 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. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): O Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: 0 Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: • % Section 7 - Gas/Liquids Separation Technology Information (Ear) Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —100, 50 psig Describe the separation process between the welt and the storage tanks: The wellheads produce fluid to gas/liquid separator(s). The produced water is routed to water tank(s). Emissions from the produced water tanks are routed to the enclosed combustor on site. /� "] <GtGRx DU Form A?CD-2O7 Produced Water Storage Task(s) APEN Revision 3/2019 Permit Number: AIRS ID Number: 123 / 9C02 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 dl control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C Enclosed Combustor 95% N0x CO HAPs Endosed Combustor 95% Other: From what year is the following reported nctuof wmuoi emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Units Source (AP -42, Mfg.. etc.) Uncontrolled Emissions (tons/year) Controlled Emissions' (tons/year) Uncontrolled Emissions ... (tons/year) Controlled Emissions (tons/year) VOC 0.2620 lb/bbl CDPHE 0.19 0.01 32.23 1.61 NOx 0.068, 100 M7.:M9'y.mm.l AP -42 0.09 0.09 0.53 0.53 CO 0.310, 84 44O494, '00'0 AP -42 0.08 0.08 2.12 2.12 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract CA Service S ( ) Number Emission Factor7 Actual Annual Emissions olled Uncontrolled Bas is Units Source (AP -d2, ', Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 8 (pounds/year) Benzene 71432 0.0070 Ib/bbl CDPHE 1,722 86 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 Ib/bbl CDPHE 5.412 271 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limits) should consider future growth. 7 Attach produced water talxratory 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. Laura Davis Permit Number: AIRS ID Number: 123 I 9CO2 / 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 will bjl rated in full compliance with each condition of the applicable General Permit. 07/09/2019 uthorized Person (not a vendor or consultant) Date 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 registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphetapcd 6I Produced Water Storage Tank(s) APEN - Form APCD-207 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 wilt require re -submittal. Your APE! 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.cotorado.gov/oacific/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, I1.C. for revised APEN requirements. Permit Number: 13WE2925 AIRS ID Number: 1.23. f 9O02 /012 (L._.e:: thank un.ez APCD h, ...r. _. Wit_:_ :, �7 p..�r� �.... ar:ci AIRS Dl Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: MCCLELLAN T8N-R59W-S9 L01 Site Location: NENE SEC09 T8N R59W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Laura Davis Phone Number: 303-228-4181 E -Mail Address2: Laura.Davis@nbtenergy.com 1 use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes wilt require additional paperwork. 2 Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided. o.__,_.t.?_juedVattr aq. Tac.i. :PEEr 3;__fti9 j n coioaaao 1 i A. Permit Number: 13W E2925 AIRS ID Number: 123 /9002/012 Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 ❑ 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 0 Other (describe below) OR - ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Emissions from produced water were below reportable values previous to 2019, due to a frac-into event, produced water emissions are now reportable. 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: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 7/27/2013 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ❑✓ Exploration & Production (E&P) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? / Yes ■ No Are Flash Emissions anticipated from these storage tanks? / Yes • No Are these storage tanks located at a commercial facility that accepts ail production wastewater for processing? Yes No • 1 Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes p No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No / ■ 3.2: 9 p COLORADO 2 I ,C�` ❑✓ Upward ❑ Horizontal Permit Number: 13WE2925 AIRS ID Number: 123 19CO2/012 Section 4 - Storage Tank(s) Information Produced Water Throughput:, Actual Annual Amount (bbl/year) 1,436.84 Requested Annual Permit Limits (bbl/year) .: 246,000 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof 2018 O Internal floating roof 0 External floating roof Storage Tank ID : # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bb!) installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW Tanks 1 300 11/2013 Wells Serviced by this Storage Tank or Tank Battery6 (EaP Sites On y) API Number Name of Well Newly Reported Well 05 -123 -36972 MCCLELLAN LG09-721N 0 5 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 alt wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) '. 40.6839, -103.9727 Operator Stack ID No. Discharge Height Above Ground Level (feet) .: : Temp. (°F) Flow Rate (ACFM) Velocity, (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Downward O Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) Q Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): 3'_,.:9 3 ANy COLORADO WO.rani n«.e Nr.�:niLn., t. Permit Number: 13W E2925 AIRS ID Number: 123 / 9CO2 / 012 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. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑✓ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: Yes ❑ No Pilot Burner Rating: Btu /scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? --100, 50 psig Describe the separation process between the well and the storage tanks: The wellheads produce fluid to gas/liquid separator(s). The produced water is routed to water tank(s). Emissions from the produced water tanks are routed to the enclosed combustor on site. �Y coioenoo Permit Number: 13W E2925 _, a AIRS ID Number: 123 / 9CO2 / 012 Section 8 - Emissions Inventory Information Attach alt emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction In emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant. Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Emission Permit . <:. Limit(s)5 Uncontrollednits Basis Source (Al'' 4Z,' Ns.. etc..) Uncontrolled Emissions (tons/year) Controlled Emissions$ (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 02620 Ib/bbl CDPHE 0.19 0.01 32.23 1.61 NOx 0.068, 100+8UMr+ AP -42 0.09 0.09 0.53 0.53 CO 0.310, 84 BAR{B . Mal., ,et AP -42 0.08 0.08 2.12 2.12 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service : (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg.,:etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions$ (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 1,722 86 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0,0220 ib/bbl CDPHE 5,412 271 2,2,4- Trimethylpentane 540841 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. !O 5 1 COLORADO ife;1:NSFn��r x.�e.. Permit Number: 13 W E2925 AIRS ID Number: 123 / 9CO2 / 012 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 will be 9perated in full compliance with each condition of the applicable General Permit. ARA.G! ignature of I\e�aAuorized Person (not a vendor or consultant) Date Laura Dav 1/28/2020 Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 430O Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.aov/cdphe/apcd 1 1 _ 61 AwOlC5a0O Hello