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Home My WebLink About20202911.tiff CX•Ys COLORADO • Department of Public RECEIVED `i Health b Environment SEP 1 8 2020 WELD COUNTY COMMISSIONERP Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 September 14, 2020 Dear Sir or Madam: On September 15, 2020, the Air Pollution Control Division wilt begin a 30-day public notice period for Noble Midstream, LLC - Lilli Gas Plant _ 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 I 47 / O\, Jared Potis, Governor ( Jill Hunsaker Ryan,MPH, Executive Director 4, . /_/, Pub I z c !Ze v i e w ceir0P, Hi_(Ds)pci(aM/ER/c- /cK)) 2020-2911 04:1/2V20 oG(s M� O9/zl/2O ?"C" Air Pollution Control Divisio n nNotice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Noble Midstream, LLC - Lilli Gas Plant - Weld County Notice Period Begins: September 15, 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 Midstream, LLC Facility: Lilli Gas Plant Natural gas processing plant SWSE Section 4, T8N, R58W Weld County The proposed project or activity is as follows: Applicant is requesting a construction permit to authorize venting of gas from plant maintenance events and blowdown activities to an open flare. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0364 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 a. , COLORADO 1 Department of Public _DPME Health 6 Envimnrnent CDPHE COLORADO y i Air Pollution Control Division Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0364 Issuance: I Date issued: Issued to: Noble Midstream, LLC Facility Name: Lilli Gas Processing Plant Plant AIRS ID: 123/0468 Physical Location: SWSE Section 4, T8N, R58W County: Weld County Description: Natural Gas Processing Plant Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Venting of gas to flare from routine maintenance/blowdown activities, pressure safety valves, plant shutdowns, and purging of gas. Activities are controlled by an elevated, open, air- assisted process flare. Purge gas prevents One (1) open flare Flare 022 low flashback problems to the flare and (Make: Flare keeps the flame stable. The purge gas and Industries, MAVP-1030 pilot gas used consists of residue gas and SN: N/A) helps the flare maintain a minimum required positive flow through the system. This open flare also controls emissions from the amine sweetening unit (Point 014). 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. Page 1 of 15 44, CDPHE COLORADO ,`4 Air Pollution Control Division T Health u r;nr^ *o: Dedicated to protecting and improving the health and environment of the people of Colorado 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. 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 shall 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 shall 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 shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall 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 shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment Process ID Point PM10 PM2.5 SO, NO, VOC CO Type 01 --- --- --- 0.9 3.7 4.1 Point Flare 022 02 --- --- --- 0.1 0.3 0.4 Point Notes: Page 2 of 15 CDPHE ,1COLORADO CO Air Pollution Control Division ik .r Health Dedicated to protecting and improving the health and environment of the people of Colorado 1. See "Notes to Permit Holder" #4 for information on emission factors and methods used to calculate limits. 2. PrOcess 01, 02 are as follows: a. Process 01: Combustion of purge gas and gas routed to the flare due to routine and foreseeable maintenance and blowdown activities. b.i Process 02: Combustion of pilot light fuel. Facility-wide emissi ns of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissi ns of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide e issions limitation for hazardous air pollutants shall apply to all permitted emission units at thi facility. Compliance with t annual limits, for both criteria and hazardous air pollutants, shall be determined on a rol ing twelve (12) month total. By the end of each month a new twelve month total is calculated b sed on the previous twelve months' data. The permit holder shall calculate actual emissions ea h month and keep a compliance record on site or at a local field office with site responsibility f r Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. 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. For Process 01, the owner or operator shall calculate uncontrolled VOC and HAP emissions on a monthly basis using the most recent measured gas composition and most recent monthly measured flow volume for the flare header associated with purge gas and routine and foreseeable mainte lance and blowdown activities. A control efficiency of 95% for VOC and HAPs, based on operating the flare in compliance with requirements specified in this permit, shall be applied to the uncontrolled VOC and HAP emissions. Compliance for Process 01 shall be based on the sum of VOC and HAP emissions from all inlets to the flare. 9. The emission points in the table below shall 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 AIRS Pollutants Equipment Point Control Device Controlled ID Flare 022 Open Flare VOC, HAPs Page 3 of 15 GDPHE , COLORADO ,� Air Pollution Control Division D n-n-gn- r,'c {ath&En rpnri—it Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS - Equipment Process Process Parameter Annual Limit ID Point Combustion of purge gas and gas routed to the flare during 01 routine and foreseeable 21.9 MMscf/yr Flare 022 maintenance and blowdown activities 02 Combustion of pilot light fuel 2.3 MMSCF Note: The open flare covered under point 022 wilt handle gas routed to the flare during standard operational process/normal operation of equipment (i.e. purge gas, maintenance activities and blowdown activities). In addition, gas will be routed to this flare during any events that qualify as a malfunction per the Colorado Common Provisions Regulation Section II.E and II.J. The process limit does not include gas routed to the flare during malfunction events or startup and shutdown events per the Colorado Common Provisions Regulation Section II.E and II.J. The process limit does not include waste gas associated with the amine sweetening unit (Point 014) (i.e. flash tank gas routed to this flare during recycling system downtime and still vent gas routed to this flare). The owner or operator shall monitor monthly process rates based on the calendar month. 11. For Process 01, the owner or operator shall continuously (i.e., at least once every 15 minutes) monitor and record the volumetric flow rate of gas routed to the flare, including purge gas and gas from routine and foreseeable maintenance and blowdown activities, using a flow meter(s). The flow meter(s) must be capable of accurately measuring and recording the maximum and minimum potential flow rates routed to the flare. The operator shall assume a gas flow rate of 2,000 scfh for all times when the flare is operational but the flow meters are not functioning or collecting data. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit for Process 01 and to calculate emissions as described in this permit. Compliance for Process 01 shall be based on the sum of all inlets to the flare. 12. The owner or operator shall install, calibrate, operate and maintain each flow meter according to the manufacturer's procedures and specifications. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) Page 4 of 15 cDPHE ! COLORADO Air Pollution Control Division Health h-n.z-�r7et?ir Dedicated to protecting and improving the health and environment of the people of Colorado 14. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.) 15. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 16. The flare shall be air-assisted and shall be designed and operated in accordance with the New Source Performance Standards requirements of Subpart A Section §60.18, General Control Device and Work Practice Requirements, including, but not limited to, the following:S60.18(b) Flares. Paragraphs (c) through (f) apply to flares. a. §60.18(c)(1) Flares shall be designed for and operated with no visible emissions as determined by the methods specified in paragraph (f), except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. b. §60.18(c)(2) Flares shall be operated with a flame present at all times, as determined by the methods specified in paragraph (f). c. §60.18(c)(3) An owner/operator has the choice of adhering to either the heat content specifications in paragraph (c)(3)(ii) of this section and the maximum tip velocity specifications in paragraph (c)(4) of this section,or adhering to the requirements in paragraph (c)(3)(i) of this section. o §60.18(c)(3)(i)(A) Flares shall be used that have a diameter of 3 inches or greater, are nonassisted, have a hydrogen content of 8.0 percent (by volume), or greater, and are designed for and operated with an exit velocity less than 37.2 m/sec (122 ft/sec) and less than the velocity, Vmax, as determined by the following equation: Vmax = (XH2—K1)* K2 Where: Vmax = Maximum permitted velocity, m/sec. Kl = Constant, 6.0 volume-percent hydrogen. Kz = Constant, 3.9(m/sec)/volume-percent hydrogen. XH2 = The volume-percent of hydrogen, on a wet basis, as calculated by using the American Society for Testing and Materials (ASTM) Method D1946-77. (Incorporated by reference as specified in §60.17). o §60.18(c)(3)(i)(B) The actual exit velocity of a flare shall be determined by the method specified in paragraph (f)(4) of this section. o $60.18(c)(3)(ii) Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam-assisted or air-assisted; or with the net heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare is Page 5 of 15 CDPHE COLORADO co Air Pollution Control Division . H mrt n�of n,r) Health u€ 9 r>nrni^nC Dedicated to protecting and improving the health and environment of the people of Colorado nonassisted. The net heating value of the gas being combusted shall be determined by the methods specified in paragraph (f)(3) of this section. d. §60.18(c)(5) Air-assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by the method specified in paragraph (f)(6). e. §60.18(c)(6) Flares used to comply with this section shall be steam-assisted, air- assisted, or nonassisted. f. §60.18(d) Owners or operators of flares used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs. Applicable subparts will provide provisions stating how owners or operators of flares shall monitor these control devices. g. §60.18(e) Flares used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. h. §60.18(f)(1) Method 22 of appendix A to this part shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. j. §60.18(f)(2) The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. k. §60.18(f)(3) The net heating value of the gas being combusted in a flare shall be calculated using the following equation: n HT • K L C11t i=1 Where: Hr = Net heating value of the sample, MJ/scm; where the net enthalpy per mole of offgas is based on combustion at 25 °C and 760 mm Hg, but the standard temperature for determining the volume corresponding to one mole is 20 °C; K Constant. 19 mole MJ 1.740 x 10' {ppni scm {c aP where the standard temperature for (g molt) is 20*C; scm C1 = Concentration of sample component i in ppm on a wet basis, as measured for organics by Reference Method 18 and measured for hydrogen and carbon monoxide by ASTM D1946-77 or 90 (Reapproved 1994) (Incorporated by reference as specified in §60.17); and H1 = Net heat of combustion of sample component i, kcal/g mole at 25 °C and 760 mm Hg. The heats of combustion may be determined using ASTM D2382-76 or 88 or Page 6 of 15 ` cDPHE I COLORADO T4 CO j Air Pollution Control Division Dedicated to protecting and improving the health and environment of the people of Colorado D4809-95 (incorporated by reference as specified in §60.17) if published values are not available or cannot be calculated. 1. §60.18(f)(4) The actual exit velocity of a flare shall be determined by dividing the volumetric flowrate (in units of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the unobstructed (free) cross sectional area of the flare tip. m. $60.18(f)(5) The maximum permitted velocity, Vmax, for flares complying with paragraph (c)(4)(iii) shall be determined by the following equation. Logic) (Vmax)=(HT+28.8)/31.7 Vmax = Maximum permitted velocity, M/sec 28.8=Constant 31.7=Constant HT = The net heating value as determined in paragraph (f)(3). n. §60.18(f)(6) The maximum permitted velocity, Vmax, for air-assisted flares shall be determined by the following equation. Vmax = 8.706+0.7084 (HT) Vmax = Maximum permitted velocity, m/sec 8.706=Constant 0.7084=Constant HT = The net heating value as determined in paragraph (f)(3). 17. This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2.b. The following requirements were determined to be RACT for this source: Facility Equipment ID AIRS RACT Pollutants Point Flare 022 Installing and operating the flare VOC according to 40 CFR 60.18 OPERATING a MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 7 of 15 j CDPHE ( COLORADO coA� y Air Pollution Control Division Dena-r nnf of rto,c 1—foa , c :ronro,or Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. The owner or operator shall complete the initial extended gas analyses of the commingled gases routed to the plant flare, including purge gas and routine and foreseeable maintenance and blowdown activities, within one hundred and eighty days (180) of the issuance of this permit. The sample shall be representative of all gases routed to the flare header associated with purge gas and routine and foreseeable maintenance and blowdown activities at the time of the sample. The sample shall be analyzed for heat content and stream composition including VOC, Benzene, Toluene, Ethylbenzene, Xylene, n-Hexane, and 2,2,4-trimethylpentane content using EPA approved methods. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) Periodic Testing Requirements 20. At a minimum frequency of once per every three months, the owner or operator shall sample and complete an extended gas analysis of the gas in the flare header associated with purge gas and routine and foreseeable maintenance and blowdown activities. Consecutive samples shall be taken at least two months apart. The sample shall be representative of all gases routed to the flare header associated with purge gas and routine and foreseeable maintenance and blowdown activities at the time of the sample. Each sample shall be analyzed for gross (higher) heat content and stream composition including VOC, Benzene, Toluene, Ethylbenzene, Xylene, n-Hexane, and 2,2,4-trimethylpentane content using EPA approved methods. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify compliance with the emission limits. ADDITIONAL REQUIREMENTS 21. The owner or operator shall maintain the following records for a period of 5 years: a. Operating hours for the flare. b. Volume of gas routed to flare. c. Gas sampling. d. Recalibration results for the flow meter and any adjustments made. e. All records required by this permit shall be retained for not less than 5 years following the date of such measurements, maintenance, and reports. 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: Page 8 of 15 CDPHE COLORADO 0. Air Pollution Control Division r p.ivr,,...t rLr,c Health 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. 23. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the Operating Permit. The application for the modification to the Operating Permit is due within one year of the issuance of this permit. The initial Operating Permit application for this facility is due on 01/27/2021. 24. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 25. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 26. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization Page 9 of 15 GDPHE COLORADO Air Pollution Control Division Cif P n:v 0 `l'}-loath r)nrvi C-lt Dedicated to protecting and improving the health and environment of the people of Colorado 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. 27. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 28. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 29. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit History Page 10 of 15 j 6D ICOLORADO «> Air Pollution Control Division • 1"tcna-r"re of rub Health&c^ 7 7ru,7≥ Dedicated to protecting and improving the health and environment of the people of Colorado Issuance Date Description Issuance 1 This Issuance Issued to Noble Midstream, LLC Newly permitted, existing equipment. • Page 11 of 15 CDPHE ! COLORADO Air Pollution Control Division 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 shall 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 shall 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. Uncontrolled Controlled AIRS Emission Emission Point Pollutant CAS # (lb/yr) (lb/yr) Benzene 71432 120 6 Toluene 108883 229 13 Ethylbenzene 100414 46 3 022 Xylenes 1330207 118 7 n-Hexane 110543 627 33 2,2,4- 540841 12 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 022: Emissions associated with the open flare result from the combustion of routine and foreseeable maintenance gas (i.e. gas from various plant processes during maintenance), purge gas (residue gas composition), and pilot light gas. Total actual emissions are based on the sum of the emissions calculated for the combustion of maintenance gas and purge gas (process 01) and the combustion of pilot light gas (process 02). This open flare will handle gas routed to the flare during standard Page 12 of 15 CDP +E ' COLORADO Air Pollution Control Division tTh.7's 1-e-\aitn 4€r r)nrtr lc Dedicated to protecting and improving the health and environment of the people of Colorado operational process/normal operation of equipment (i.e. maintenance and blowdown activities). The process limit does not include gas routed to the flare during malfunction events or startup and shutdown events per the Colorado Common Provisions Regulation Section II.E and II.J. The process limit also does not include waste gas associated with the amine unit (Point 014). Process 01: Combustion of routine and foreseeable maintenance and blowdown gas and purge gas Emission Factors CAS # Pollutant Uncontrolled Source lb/MMBtu N0x 0.068 AP-42 Chapter 13.5 CO 0.31 AP-42 Chapter 13.5 Note: Combustion emissions are calculated using the emission factors in the table above, the most recent monthly flare gas higher heat content and the volume of gas combusted. Actual V0C and HAP emissions shall be calculated based on the most recent gas sampling and most recent monthly gas flow volume. Controlled emissions are based on 95% control for V0C and HAP. Actual V0C and HAP emissions are calculated using the following equations: Equation for Actual V0C Emissions Calculations: lb l VOCFlare Header (month/ scf = [VOC concentration(wt%)- 100 x Purge/Process Gas (month) month x Gas Molecular Weight (Ibmol) _ 379 (Ibcmol) x (1—95%control)] *V0C concentration and Gas Molecular Weight are based on actual monthly-average sampled values of the gas streams routed to flare. *Purge/Process Gas is the actual measured monthly flow volume of the gas routed to flare in each header. Equation for Actual HAP Emissions Calculations: HAP Fiare Header lb ) (month scf = HAP concentration(wt%) ± 100 x Purge/Process Gas (month) x Gas Molecular Weight (Ibmol) —379 (ibmol) x (1 —95%control) *HAP concentration and Gas Molecular Weight are based on actual sampled values of the gas streams routed to flare. • Page 13 of 15 cDPH ' COLORADO CO - Aar Pollution Control Division Dedicated to protecting and improving the health and environment of the people of Colorado *Purge/Process Gas is the actual measured monthly flow volume of the gas routed to flare in each header. Process 02: Combustion of pilot light fuel Emission Factors CAS # Pollutant Controlled Source lb/MMscf NOx 79.47 AP-42 Chapter 13.5 CO 362.29 VOC 213.92 Mass Balance 110543 n-Hexane 0.57 Note: The emission factors in the table above are based on a higher heat value of 1,169 Btu/scf. The flare pilot light flow rate shall be assumed to have a constant flow rate of 65 scf/hr per burner (total of four (4) burners).. Monthly pilot gas throughput shall be determined by multiplying the total pilot light flow rate (260 scf/hr) by the flare monthly hours of,operation. Actual emissions are calculated by multiplying the emission factors in the table above by the total pilot gas throughput. 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 shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source of: V0G, NOx NANSR Major Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/; Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 14 of 15 CDPHE ! COLORADO //q►. , Air Pollution Control Division D4-- Hoalth Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart M - 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 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: tittp://www.colorado.gov/pacific/cdphe/air-permit-self- certification Page 15 of 15 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Bradley Eades Package#: 428072 Received Date: 3/25/2020 Review Start Date: 5/7/2020 Section 01-Facility Information Company Name: Noble Midstream,LLC I quadrant Section Township Range County AIRS ID: 123 SWSE 4 �. 8N I 58 Plant AIRS ID: 0468 Facility Name: U®i Gas Plant _ Physical Address/Location: salp SN,Range S8W County: Weld County Type of Facility: Natural Gas Processing Plant What industry segment?08&Natural Gas Production&Processing '$, Is this facility located in a NAAO3 non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank For Division Use Only AIRS Point# Permit# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Contras? APCD has already # Required? Action Remarks has already assigned) assiened) Permit 014 - Amine Unit AMN Yes 09WE0848 - 5 Modification Increase limits Permit Initial prevGP02- 016 Natural Gas RICE Inlet 3 Yes 20W60305 1 Yes Issuance 1775HP 4SLB .._.APEN Required/ Existing- Permit Previously 021 NG Heater Amine Reboiler No 20WE0363 1 Yes - - Exempt reported w/014 • Existing- - Permit Initial Previously 022 Process Flare Flare - -Yes 20WE0364 1 Yes Issuance reported w/014 Permit Initial New-1380 hp 023 Natural Gas RICE Inlet 4 Yes 20WE0366 1 Yes :Issuance 4SLB Section 03-Description of Project eDPHE(A.Scherer&B.Eades)visited this site on October 17,2019 to observe the stack-test scheduled for the Amine Unit Point 014.Upon discussion with the Noble representative(J.Eichman),it was discovered that the operating conditions reflected in the process simulation used to develop the limits included in Issuance 4 for Point 014 were not representative of actual operating conditions.This modification is intended to adjust process models(using ProMax)to represent actual operating conditions and increase limits accordingly.Applicant is also requesting to increase processing rate. - In addition,it was discovered(at the October 2019 stack test)that the flare that was induded with Point 014 was also controlling other process streams (maintenance and other vents during non-normal operations).Lastly,it was discovered that the amine reboiler heater included with Point 014 was innaccurately represented as 4.3 MMBtu/hr when it is actually rated at 8.5 MMBtu/hr.As a result of the above findings,Noble is requesting the following: *Modification for Point 024 to increase limits *Add new point(Point 022)for process flare previously reported with Point 014 to include purge gas,and maintenance events. *Add new point(point 021)to authorize 8.5 MMbtu/hr heater previously reported withYoint 014 as 4.3 MMbtu/hr capacity.Permit exempt *Add new point(Point 023)to authorize a new,additional RICE(reciprocating internal combustion engine)for gas compression. *Modify permit coverage for an existing RICE(Point 016)from GP02 to individual permit coverage. Upon nonattainment redesignation of the DMNFR on 1/27/2020,this facility became a major source of NOx(facility-wide PTE of 85.7 tons per year)per Reg 3,Part D.As a result,this modification is evaluated to determine if modification qualifies as a major modification per Part D.Increase in NOx associated with this project are 11.4 tpy and increase in VOC is 18.7 tpy when considering project increases only.Since the significant emission rate is 25 tons per year for NOx,this project does not qualify as a major modification.Furthermore,since the emission increase associated with this mod is less than 50 tpy VOC,it is not a new major stationary source of VOC.This analysis is displayed below: Emissions prior to project: Point 014:4.7 tpy NOx,10.8 tpy VOC Point 016:8.6 tpy 000,:12.0 tpy VOC Emissions after requested project: Point 014:3.6 tpy NOx;:16.2 tpy VOC Point 016:8.6 tpy NOx,12.0 tpy VOC Point 021:3.7 tpy NOx,0.2 tpy VOC Point 022:1.0 tpy NOx,4.0 tpy VOC Point 023:6.7 tpy NOx,9.3 tpy VOC Change in emissions associated with proposed project Point 014:-1.1 tpy NOo(does not count toward increase),5.4 tpy VOC Point 016:no change- Point 021:3.7tpy NOx,0.2 tpy VOC Point 022:1.0 tpy NO0,4.0 tpy VOC Point 023:6.7 tpy NOx,9.3 tpy VOC TOTAL:11.4 tpy NOx(<25 tpy),18.9 tpy VOC(<50 tpy,since facility is new major source for VOC) Public notice is required for the flare permit(Point 022,20W E0364)since without limits on PTE as imposed in the construction permit,this project would trigger a significant increase per Regulation 3,Part D,Sections V or VI(Regulation 3,Part B IIl.C.1d) Ce iorado Air Permitting Project Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? •i'egdesting Synthetic Minor Permit Section OS-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes Title V Operating of SiPermits p - J - �PM10 TSP HAPs If yes,indicate programs and which pollutants' SO2 NOx CO VOC PM2.5 Prevention of Significant Deterioration(PSD) � ) Li Ll • Non-Attainment New Source Review(NAN5R) • Is this stationary source a major source? Yes. If yes,indicate programs and which pollutants: S02 NOx CO VOC PM2.5 PM10 TSP NAPs Prevention of Significant Deterioration(PO) — ❑ ❑ Title V Operating Permits PP) .� J • Non-Attainment New Source Review(NANSR) ✓ ✓ __ Flare Emissions Inventory Section 01-Adminstrative Information 'Facility AIRs ID: 123 0468 022 County Plant Point Section 02-Equipment Description Details One(1)open flare used to control gas produced from blowdowns,pressure safety valves and plant shutdowns.Flare is also supplied with purge gas and pilot fuel.This open flare also controls emissions from the amine sweetening unit covered under Detailed Emissions Unit AIRS Point 014.Emissions associated with combustion of amine unit waste gas streams are reported with AIRS Point 014. Description: Emission Control Device Open Flare(Make:Flare Industries,Model:MAVP-1030,SN:N/A) Description: - - Requested Overall VOC&HAP Control Efficiency%: 95 Section 03-Processing Rate Information for Emissions Estimates Pilot Gas(O.OS MMBtu/hr rating) ... - Purge Gas(Residue Gas Composftion): Volume of gas: 0.0062 MMscf/day 260 sef/hr Volume of gas: 0.048 MMscf/day 2000 scf/hr Heat Content of gas: 1168.665964 Btu/scf (4 burners @ 65 scfh) Heat Content of gas: 1168.665964 Btu/scf Requested volume of Requested volume of gas: _..d MMscf/year gas: MMscf/year Actual volume of gas: Actual volume of gas: MMscf/year MMscf/year PTE volume of gas: _._"'a MMscf/year PTE volume of gas: MMscf/year Requested heat content of Requested heat gas: MMBtu/year 0.303853151 MMBtu/hr content of gas: 20,47, MMBtu/year Blowdowns to Flare(Inlet Gas Composition): Volume of gas: 0.012 MMscf/day 500 scf/hr Heat Content of gas: 1313.490227 Btu/scf Requested volume of gas: MMscf/year Actual volume of gas: MMscf/year PTE volume of gas: ,P-MMscf/year Requested heat content of gas: 8753 _ 3 MMBtu/year Total Throughput: Total Requested Throughtput to Flare (Permit Limit) 21..... .MMscf/year Requested Pilot Throughput(Permit Limit) 2.22 MMscf/year Actual throughput 0.220 MMscf/year PTE Throughput .__.3t MMscf/year Requested Purge Gas: 0..42 MMscf/yr Requested Waste Gas: tt MMscf/yr Actual Purge Gas: MMscf/yr Actual Waste Gas: MMscf/yr 350.4 Purge Gas HHV: .:; Btu/scf Avg Waste Gas HHV: -: Btu/scf r Mira. di g !t , . �e VOC and HAP from Inlet Gas Combustion(blowdowns,PSV;ESDs) Throughput(Q) I €'02 MMscf/yr , scf/hr Throughput(Q) MMscf/yr 000 scf/hr MW 19.3.Ib/Ib-mol - MMscf/d MW 22.7 Ib/Ib-mol 0.312 MMscf/d Buffer: 10% mass fraction lb/hr lb/yr tpy mass fraction lb/hr lb/yr tpy H2S 0.000E+00. 0 0 _ H2S 9.014E-06 0.00 2.33 CO2 5.916E-04 = CO2 3.584E-02 1,017 . -: N2 1.738E-02 - N2 1.262E-02 0-38 3. methane 6.721E-01. - methane 5.112E-01 ;5,20 ethane 2.258E-01 -- ethane 1.602E-01 4.79 - _. s.. propane 7.916E-02 propane 1.692E-01 5.36 „_ isobutane 9.683E-04 -. isobutane 9.963E-02 0.59 ... n-butane 1.457E-03 _ n-butane 6.127E-02 1.83 ,?.. isopentane 1.985E-04 isopentane .1.051E-02 0.32 _7 n-pentane 2.771E-04 n-pentane 1.204E-02 0.3E 31 cyclopentane 2.912E-05 - cyclopentane 4.545E-04 0.1 , n-Hexane 2.236E-04 ..1.. n-Hexane 1.630E-03 0.05 a_. 2_. cyclohexane 5.678E-05 5-3.54 0.03 cyclohexane 5.008E-04 0.01 1 4 Other hexanes 2.013E-04 170-14 5.05 Other hexanes 2.545E-03 0..1M .... _. heptanes 6.449E-04 573.86 0.29 heptanes 1.603E-03 0,10 0 methylcyclohexane 1.885E-04 07.33 5.00 methylcyclohexane 1.948E-04 0.01 .. 224-TMP 5.928E-06 3.30 0.00 224-TMP 2.518E-05 0,90 Benzene 4.865E-05 43.30 0.02 Benzene 2.927E-04 0.01 Toluene 2.295E-04 204.31 0.10 Toluene 8,936E-05 0.00 Ethylbenzene 4.959E-05 .4.14 0.02 Ethylbenzene -4.880E-06 0.00 Xylenes 1.322E-04 0.01 €`7.71 0.08 Xylenes 0,000E+00 0.00 - 0.80 08+Heavies 3.362E-04 0.03 20921 0,15 C8+Heavies 1.771E-04 0.01 ..;.-ia 0.52 VOC mass fraction: 8.42% Total VOC(Uncontrolled) 37.48 VOC mass fraction: 28.02% Total VOC(Uncontrolled) 36.73 4 of 7 C:\Users\beades\Desktop\Remote Work\Noble-Lilli\Save to K\09WE0848.CP5 Flare Emissions Inventory I I Section 04-Emissions Factors&Methodologies '"A.S„:4i`i: ;i:., Pilot Gas: Control Device Controlled E.F. Uncontrolled E.F. (Ibs/MMscf Pollutant (Ibs/MMBtu waste gas Emissions Factor Source Citation waste heat volume combusted) combusted) PM10 • 8.7077 AP-42 Table 1.4-2 PM2.S `� 8.7077 '-AP-42 Table 1.4-2 NOx 0.068 79.4693 AP-42 Eft 13,5 Industrial Flares(NOx/CO) VOCc ..213.9164 Masmaalance CO 0 31 362.2864 AP-42 Ch 13.5 Industrial Flares(NOx/CO) 502 0.6875 AP-42 Table 1.4-2 Benzene 4:`.__�» 0.1236 ",;Masse3alance Toluene �� 05831 :ii' ass33alance Ethylbenzene �. 0.1260 ass�alance '' Xylene .0.3359 ' ' ass8alanse n-Hexane 0.5677 ilskliwasse3alance 224TMP pia °*; 0.0151 ass>Balance Emission Factors for Waste Gas(Based on inlet gas composition) Emission Factors Plant Flare Uncontrolled Controlled )lb/MMscf) (Ib/MMscf) Emission Factor Source Pollutant (Gas (Gas Throughput) Throughput) VOC Sd759 Si0 EPA Emission Inventory Improvement Publication Benzene 17.507. EPA Emission Inventory improvement Publication Volume Toluene 5.345 EPA Emission Inventory Improvement Publication Volume Ethylbenzene 0.20:' EPA Emission Inventory Improvement Publication Volume Xylene 0.0C.: EPA Emission Inventory Improvement Publication Volume n-Hexane 97.4E•. - EPA Emission inventory Improvement Publication Volume 224TMP 1.50 EPA Emission Inventory Improvement Publication Volume EMi tlst Factors for Purge Gas(Residue gascomposition) Emission Factors Plant Flare Uncontrolled Controlled Pollutant (Ib/MMscf) (lb/MMscf) Emission Factor Source (Gas (Gas Throughput) Throughput) VOC Z 1 3_.5 EPA Emission Inventory Improvement Publication Benzene .,._> EPA Emission Inventory Improvement Publication Volume Toluene ...' EPA Emission Inventory Improvement Publication Volume Ethylbenzene ___ EPA Emission Inventory improvement Publication Volume Xylene a.i:,. EPA Emission Inventory Improvement Publication Volume n-Hexane EPA Emission Inventory Improvement Publication Volume 224TMP Cd EPA Emission Inventory Improvement Publication Volume %©ntrol Device(Combustion.of Waste Gas) Uncontrolled Uncontrolled E.F. E.F.(Ibs/MMscf Pollutant (Ibs/MMBtu waste gas Emissions Factor Source Citation waste heat volume combusted) combusted) NOx AP-42 Chapter 13.5 Industrial Flares(NOx/CO) .sru"`<.�..,.ii ..s,3 P/f 'se>re ;-sm-omz- CO AP-42 Chapter 133 Industrial Flares(NOx/CO) 502 _ AP-42 Table 1.4-2 ; control Device(Combustion of Purge Gas) Np- Uncontrolled Pollutant Uncontrolled E.F. E.F.(Ibs/MMscf Emissions Factor Source Citation (lbs/MMBtu waste gas waste heat volume combusted) combusted) NOx AP-42 Chapter 13.5 Industrial Flares(NOxr/CO3 , I , r1 ,. I§SP ''.v. �EINC s rl,lriskIC��'u k,'i .. CO _ AP-42 Chapter 1,3.5 Industrial Flares)NOx/CO') S02 611.011PROP AP-42 Table 1.4.2 5 of 7 C:\Users\beades\Desktop\Remote Work\Noble \Save to K\09WE0848.CP5 Flare Ernissio'ic inventory Section 05-Emissions Inventory ..-,', .. Pilot Gas •.. Potential to Emit Requested Permit Limits Actual Emissions Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Crmt ollced (tons/year) (tons/year) (tons/year) (tons/year) (tons/;ear) PM10 0 01 0.01 0.01 PM2.5 0 01 0.01 0.01 NOx 0 09 0.09 0.09 VOC 0 24 0.24 0.24 CO 0 41 0.41 0.41 502 3.45' 0.00 0.00 Benzene 1.s0 0.00 0.00 Toluene C 00 0.00 0.00 Ethylbenzene 0 30 0.00 0.00 Xylene 0.•JC 0.00 0.00 n-Hexane 0.00 0.00 0.00 224 TMP 0._0 0.00 0.00 Waste Gas(Blowdowns,PSV,ESDs)Process 01. Potential to Emit Requested Permit Limits Actual Emissions Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) PM10 '3.10 0.00 0.00 PM2.5 303 0.00 0.00 NOx .... 0.20 0.20 VOC 3,s. .. 36.70 1.84 CO 7 3.3 0.89 0.89 S02 5.0r. 0.00 0.00 Potential to Emit Requested Permit Limits Annual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/years (lbs/year) (lbs/year) Benzene 1.04# 0.04 0.00 77 4 Toluene 2.11 0.01 0.00 23 - - Ethylbenzene 0,,'0 0.00 0.00 0,• 0.89 Xylene i C 0.00 0.00 3 0 3.71 n-Hexane .2: 0.21 0.0_ 57 21 4.07 224 TMP 0.00 7 3 0.01 P.:Urge Gas(Preces01) a Potential to Emit Requested Permit Limits Actual Einissions Criteria Pollutants Uncontrolled Uncontrolled Controlled Unsonsiolled controlled (tons/year) (tons/year) (tons/year) (tors/year) (tons/Year) PM10 0.00 0.00 PM2.5 . 0.00 0.00 NOx .. 0.70 0.70 VOC 5. - 37.48 1.87 CO 3.17 3.17 502 0.01 0.01 Potential to Emit Requested Permit Limits Actual Emission, Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Sincout;olled Controlled Uncontrolled Controlled (tons/year) (tons/year) (tons/year) toons/year (tens/yearl (lbs/year) (lbs/year) Benzene .. 0.02 0.00 '.00 000 »3 2 Toluene 6. 0.10 0.01 204 10 Ethylbenzene 0.02 0.00 44 2 Xylene . 0.06 0.00 n-Hexane •- 0.10 0.00 :4.5 10 224 TMP 0.00 0.00 Total Emissions(Pilot+purge+waste Gas) Potential to Emit Requested Permit Limits Actual Emissions Criteria Pollutants Uncontrolled Uncontrolled Controlled ltocontrolled Controllco (tons/year) (tons/year) (tons/year) _c/year) (tons/beau PM10 . 0.01 0.01 PM2.5 ' . 0.01 0.01 NOx 0.98 0.98 VOC 74.43 3.95 CO - • 4.48 4.48 SO2 ' . 0.01 0.01 Potential to Emit Requested Permit Limits Actual Ee-•ssiors Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Ccntrodea Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) _ ,yeas; (lbs/year) (lbs/year) Benzene 0.06 0.00 ..4 6 Toluene 0.11 0.01 ... 13 Ethylbenzene ' . 0.02 0.00 sy 3 Xylene • 0.06 0.00 7 n-Hexane - 0.31 0.02 52 33 224 TMP ' .1 0.01 0.00 l... 1 6 of 7 C:\Users\beades\Desktop\Remote Work\Noble-Lilli\Save to K\09WE0848.CP5 Section 06-Regulatory Summary Analysis Section II.A.1-Except as provided in paragraphs 2 through 6 below,no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at i5-second intervals for six minutes.The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR,Part 60,Appendix A Regulation 1 (July,1992))in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2 Section I.A-No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits:For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air. Part A-APEN Requirements Criteria Pollutants:For criteria pollutants,Air Pollutant Emission Notices are required for:each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed)for which the area is non-attainment. Regulation 3 Applicant is required to file an APEN since emissions exceed 1 ton per year VOC Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.OTPY threshold(Reg.3,Part B, Section II.D.2.a) this flare can be used to control equipment subject to Regulation 7,Part 0,Section II(formerly XVII),it must be approved as an alternate control device per Regulation 7 Section XVII.B.2.e. Regulation 7 Section 07-Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes *This permit will not Include short ter"m limit's(le.monthly limits),This is due to the"backup"nature of this equipment w ith'variable peaks of throughput(i.e.the throughput is not constant but rather occurs in pulses based on maintenance activities performed at thefacility).It cannot be reasonable predicted how the annual throughpu t will be distributed on a monthly basis.: *Applicant indicates that there is a flow meter on the flare header that measures the rate of all gases sent through the flare header including purge volumes,blowdown,ESD and PSV/PRY vapors.There is a separate flow meter that measures the flow rate from the amine still vent and an additional meter that measures the volume of pilot gas and supplimental fuel supplied to the flare(still vent,pilot and supplemental fuel are reported with Point 014).The data from each of these meters is recorded in a historian and can be acce ssed as needed.Furthermore,during flash tank VRU.downtime(i.e.when amine unit flash tankvapors are sent to the flare),all gas metered at the flare is attributed to the amine unit flash tank,This stream will be metered at the flare header used to demonstrate compliance with Point 022 for purge,blowdown,ESD and PSV/PRV;vapors.The gas attributed to the flash tank does not need to be accounted for with 022(i.e.do not intend to double count emissions from amine flash tank). I've included a requirement to assume the purge gas vent rate(2,000 scfh)for all times thatthe flare is operational but the meters are not functioning or collecting data.This is based on the idea that purge gas Is ,constantly fed to the flare and if no flow is detected,we can at least be sure that the flow:isat least 2,000 scfh.Applica nt indicated that he is not aware of situations where the flare header meter is measuring 0 flow despite,knowingly sending vaporsto the,flare.Applicant indicates that 2,000 scfh is a conservative:estimate of purge flow and _ Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point If Process# SCC Code Pollutant Factor Control% Units 3-4446,1iO3-4446,1iFlares Coptbustfug'GaseS 53440 GTUlsc# NOx -0 Ib/MMscf E VOC _„... 95 Ib/MMscf E CO _ ,. 0 lb/MMscf Benzene 95 Ib/MMscfB • Toluene 95 lb/MMscf B Ethylbenzene __ 95 lb/MMscf Xylene ?_:..,. 95 Ib/MMscf e n-Hexane __.._, 95 lb/MMscf E 02 3.{ouUoz,$fttrew C'£f01(F;SbhjIWGue ,kffi t19Cf;:-, PM10 ..-_. 0 Ib/MMscfB PM2.5 ,__ 0 Ib/MMscf B NOx :.. 0 lb/MMscf VOC _„___ 0 Ib/MMscfE CO _._-__.: 0 lb/MMscfE SO2 _ 0 lb/MMscf B n-Hexane ,.- 0 lb/MMscf E 'Process 01 represents waste gas combustion associated with purge gas,inlet gas and residue gas while process 02 represents pilot light combustion.The emissions factors represented in process 01 are based on a average of inlet and residue gas. 7 of 7 C:\Users\beades\Desktop\Remote Work\Noble-Lilli\Save to K\09WE0848.CP5 CAPCDGeneral 440 Air APEN -lutant Emission Force m) -2000 and COPHE 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. There may be a more specific APEN for your source (e.g. boiler, mining operations, engines, etc.). A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 20V08.U5{ltd-' AIRS ID Number: J 2 3 / 64(P' / C 2 2.. Section 1 - Administrative Information Company Name': Noble Midstream, LLC Site Name: Lilli Gas Plant Site Location: 62119 CR 96 Site Location Weld County: New Raymer, CO 80742 NAICS or SIC Code: 1311 Mailing Address: 2115 117th Avenue (Include Zip Code) Greeley, CO 80634 Contact Person: Jeff Eichman Phone Number: 970-304-5337 Portable Source Home Base: E-Mail Address2: jeff.eichman@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. 428069 COLORADO Permit Number: AIRS ID Number: -Section-2 - Requested Action • NEW permit OR newly-reported emission source(check one below) El STATIONARY source 0 PORTABLE source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: This flare has been previously included as the control device for AIRS point 123/04681014 under permit 09W60848. We wish to have a separate unit ID for the Flare.Additionally pilot and purge emissions from the unit have been APEN exempt historically. 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: The process flare controls emissions from the amine unit and emissions from blowdowns,PSVs and ESDs. + Manufacturer: Flare Industries Model No.: MAVP-1 030 Serial No.: Custom Company equipment Identification No. Flare (optional): For existing sources, operation began on: 10/05/2010 For new or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Seasonal use percentage: Dec-Feb: Mar-May: Jun-Aug: Sep-Nov: 2 leeCOLORADO Hey Fn r Permit Number: AIRS ID Number: / / Section 4 - Processing/Manufacturing Information a Material Use l] Check box if this information is not appicable to source or process From what year is the actual annual amount? Design Process Actual Annual Requested Annual Description Rate Amount Permit Limits (Specify Units) (Specify Units) (Specify Units) Material Consumption: Finished Product(s): s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs, including APEN updates. Section 5 - Geographical/Stack Infoormation Geographical Coordinates (Latitude/Longitude or UTM) 40.685608,-103.875705 ❑ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator Temp. Flow Rate Velocity Stack ID No. Above GFow)d Level (•F) (ACFM) (ft/sec) (Feet) Flare 35 1400 2,860 15.17 Indicate the direction of the stack outlet: (check one) ID Upward ❑Downward 0 Upward with obstructing raincap ❑ Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) E1 Circular Interior stack diameter (inches): 24 inch (flare tip) O Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0 Other(describe): COLORADO 3 ��rmm ,. Permit Number: AIRS ID Number: Section 6 - Combustion Equipment Et Fuel Consumption Information O Check box if this information is not applicable to the source (e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit limits (MMBTU/hr) (Specify Units) (Specify Units) 3.30 (Pilot, Purge and Safety only) 24.2 MMscf(does not include amine unit volume) From what year is the actual annual fuel use data? NA Indicate the type of fuel used6: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) El Field Natural Gas Heating value: 1168 BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coal Heating value: BTU/lb Ash content: Sulfur content: ❑ Other(describe): Heating value (give units): 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider future process growth. Requested values are required on alt APENs, including APEN updates. 6 If fuel heating value is different than the listed assumed value, provide this information in the"Other"field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? I]Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant Description (%of total emissions captured by (%reduction of captured control equipment) emissions) TSP(PM) PM10 PM2.5 SOx NOx CO VOC Flare, this flare 100% 95% Other: HAPs Flare, this flare 100% 95% COLORADO • Permit Number: AIRS ID Number: From what year is the following reported actual annual emissions data? NA Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Requested Annual Permit Uncontrolled Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Emission Source FaAP-42,M Uncontrolled Controlled Uncontrolled Controlled (Specictor (fy Units) Mfg., eik.) (tons/year) (tons/year) (tons/year) (tons/year) TSP (PM) PKo PM2.5 SO. NOx 0.068 Ib/MMbtu AP-42 0.98 0.98 Co 0.31 Ib/MMbtu AP-42 4.48 4.48 VOC 326.7 lb/MMscf saaY„s^+„ear^=a 79.01 3.95 Other: 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider future process growth. Requested values are required on all APENs, including APEN updates. 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information • Does the emissions source have any uncontrolled actual emissions of non-criteriaEj Yes El No pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Uncontrolled Controlled CAS Chemical Overall Emission Emission Factor Actual Actual Number Name Control Factor Source Emissions Emissions? Efficiency Units) (AP-42,Mfg.,etc.) (lbs/year) (Specify ( y ) (lbs/year) 7 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. ge COLORADO H o 1 menlot Wm.c �� 'l) �.. .1FC a n ] ..�. �!-'.+ 5;F' ., binnrtrvmcn Permit Number: AIRS ID Number: Section 9 - Applicant Certification I hereby certify that all inf rmation contained herein and information submitted with this application is complete, true, and correct. C.5‘2C/Aa%20 ' n f Legally Authorized Person (not a vendor or consultant) Date Je Eichman Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: D Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303) 692-3175 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303) 692-3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment LL se ;COIORApO L;1'4l) Ma�1.FbEn1n nrmmt Hello