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Home My WebLink About20191039.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 March 5, 2019 Dear Sir or Madam: RECEIVED MAR 1 1 2019 WELD COUNTY COMMISSIONERS On March 7, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - CHANDLER ST T3N-R64W-S15 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: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer V \eu,) 3/L31►c CG PL (TP) HL (5T), PWWM1ERK IGw) 3h‘ii9 2019-1039 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - CHANDLER ST T3N-R64W-S15 L01 - Weld County Notice Period Begins: March 7, 2019 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: CHANDLER ST T3N-R64W-S15 L01 Oil and gas exploration and production facility NENE Sec 15 T3N R64W Weld County The proposed project or activity is as follows: Source is requesting to vent existing LP and VRT separator streams to flare and no longer recycle the streams. 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 18WE1327 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 1 14 kuViet O(ADO sem?aanc.xnx Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carlssa `Mon Package #: 891''612' Received Date: 1211212018 Review Start Date: 2/20/2019, Section 01- Facility Information Company Name: Noble Energy, Inc. County AIRS ID: 123 Plant AIRS ID: ID3C Facility Name: CHANDLER ST€3N-R64WS#: Physical Address/Location: County: Type of Facility: Exploraioet&PmdecttonWell Pad What industry segment? Oil & Natural Ras Prodaction & Proceasiing Is this facility located in a NAAQS non -attainment area? ` Yes If yes, for what pollutant? ® Carbon Monoxide (CO) NENE quadrant of Section 15, Township 3N, Range 64W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NENE 15 3N ;:...... 64 Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point 6 Emissions Source Type Equipment Name Emissions Control? Permit 6 Issuance 6 Self Cert Required? Action Engineering Remarks 011 «: Se aratcrrrVenting I P & VRT Streams Yes 18WE1327 1 Yes Permit jiuttai_, Issuance '- Section 03 - Description of Project Noble is requesting to remove an existing engine and vapor recovery unit (VRU) that route gas streams from existing low pressure (LP) separators and existing vapor recovery towers (VRTs) and new route the streams to Rare instead of recycling to the pipeline. Noble is requesting to group the LP separators and VRTs into one AIRS point because the streams will be combined and routed to the same control device. Also, pressure differences can cause variations in emissions at the LP or VRT and Noble has tried to conservatively estimate emissions from the entire unit while acknowledging fluctuations between the LP separators and VRTs.The division has allowed this grouping at other facilities since it meets the grouping requirements and there isn't a regulatory (e.g, NSPS) emission limit for eachpiece of equipment. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Yes 502 NOx CO VOC PM2.5 PM10 TSP HAPs NOx El El CO VOC PM2.5 PM10 TSP HAPs Hee El El Separator Venting Emissions Inventory 011 Separator Venting Facility AIRS ID: 123 County 9D31 Plant Point Section 02 - Equipment Description Details Vet Detailed Emissions Unit Description: from three low. press Enclosed'if Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: -Limited Process Parameter Gas meter - • -s- ft Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Separator Actual Throughput = MMscf per year Requested Permit Limit Throughput = 9.9 MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU Is VRU process equipment: 10 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Rte_ 2611. Stu/scf scf/bbl Description the source'0500 a srtE^spectnce pressurized Poulos sample collected to/fa/cults iron HY ,t.1"lane left cnanol r State /4-165 Liquith To SheriC up a:riTOTO Van for me Cr,separator. trilissIonS ere men pawn on the tlnsns� values fo[ the flew of the.LP and VET streams. Noble used the composition of .lie VRT stream from the CYSTS report to estimate emissions from both the LP and ti RT streams. i. ca:tilted a tOC weight percent of 67.7%7T1 the separ�rtor stream based en the HY505 stream re port re the appl3caWon. Noble Isbemg conservative to use the VRT stream CompasltiW4mra{ assume 3both Streams haveaVOC weight. C. 82.4%. Weight % Helium CO2 111 N2 0.05 methane . 2 48! ethane : 14.04 pane 31 76': isobutane 7 7₹li n -butane 72 92 isopentane S 93i n -pentane 7 00'. cyclopentane 2.43 n -Hexane 1.83 yclohexane Other hexanes heptanes 1 63': methylcyclohexane 224 TMP Benzene U ?S! Toluene 0 2/ Ethylbenzene 0:.01. Xylenes - IIii0 C8+ Heavies Total VOC Wt % 100.00 82.37 Ib/Ib-mol Displacement Equation Ex=Q•MW'Xx/C Pollutant Separator Venting Uncontrolled (Ib/MMscf). Controlled (lb/MMscf) 5053.0409 NummEm 294.4591 EIMEREMINII IMMEMBEMIIEE=IMINIKIMMIMMII Emission Factor Source Pollutant 0.0000 0.0000 Primary Control Device Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled Ib/MMscf 0.0075 ... 0001 0.3100',SE, (Gas Throughput) Emission Factor Source 3 of 6 K:\PA\2018\18W E1327.CP1xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tans/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled {tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/months PM10 PM2.5 SOx NOx VOC CO 0.10 0.00 0.00 0.10 0.10 16 0.10 0.00 0.00 0.10 0.10 16 0.01 0.00 0.00 0.01 0.01 1 0.88 0.00 0.00 0.88 0.88 150 501.81 0.00 0.00 501.81 25.09 4262 4.02 0.00 0.00 4.02 4.02 683 Hazarious Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lhs/year) (Ibs/year) Source'svalries Uncontrolled (Ibs/yearl Controlled (Ibs/year) EF Uncontrolled lb/MMscf Controlled Ib/MMscf Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 3046 0 0 3046 152 3077 154 309.84 15.492 2924 0 0 2924 146 2904 145 292.42 14.621 122 0 0 122 6 122 6 12.269 0.6135 1218 0 0 1218 61 1115 56 112.28 5.6138 22297 0 0 22297 1115 22407 1121 2256.3 112.88 0 0 0 0 0 Section 06 - Regplatory Summary Analysis Regulation 3, Parts A, B Regulation 7,Section XVII.B, G Regulation 7,Section XVII.8.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is not subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e 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 w3hin 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? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permittedand 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? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based m, inlet and outlet concentration sampling Toss have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 4 of 6 K:\PA\2018\ 18WE1327.CP1.xlsm Separator Venting Emissions Inventory Section 08 -Technical Analysis Notes gully•dsffeseot h4rt'm€rt 1bSt'lhe APEN,"'taI l _.. AIRS Point # Process # SCC Code 011 01 3-10-001-60 Flares Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 19.45 0 lb/MMSCF PM2.5 19.45 0 lb/MMSCF SOx 1.54 0 lb/MMSCF NOx 177.55 0 lb/MMSCF VOC 101060.82 95 lb/MMSCF CO 809.41 0 lb/MMSCF Benzene 306.73 95 Ib/MMSCF Toluene 294.46 95 Ib/MMSCF Ethylbenzene 12.27 95 lb/MMSCF Xylene 122.69 95 Ib/MMSCF n -Hexane 2245.25 95 Ib/MMSCF 224 TMP 0.00 95 Ib/MMSCF 5 of 6 - K:\PA\2018\18WE1327.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B APEN and Permit Re ulrements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants front this individual source greater than 2 TPY (Regulation 3, PartA, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than lO TPY ar CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.317 Not enough Information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY (Regulation 3, Part A, Section l l.D.l.a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than SO TPY (Regulation 3, Part B, Section 11.0.21? !Source requires a permit Colorado Regulation 7. Section eVII 1. Was the well newly constructed, hydraulically fractured, or recomplated an or after August 1,2014? 'Source isnot subject to Regulation 7, Section 0011.8.2,0 Section )1VII.B.2— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 0011.0- Emissions Control Alternative Emissions Control (Optional section) a. is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) *at is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVI1.B.2.e Section OVII.B.2.a —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as recommend,"'may,"should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as mast' 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. Source Req Source Req IIIIMPtriThee control A3O n Contro c Healt CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1327 27 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Noble Energy, Inc. CHANDLER ST T3N-R64W-S15 L01 123/9D3C NENE SEC 15 T3N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP and VRT Separator 011 Venting of gas from three low pressure (LP) separators and one vapor recovery tower (VRT) Enclosed Flare 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, 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- ICOLORADO E Air Pollution Control Division DeOartMera P; tc mat: ti Ertwor;^* Page 1 of 9 nditions. to demo omplianc- ithin 180 of the p if certi ' do ` orm and . • ance on as rep sired by ;s per may be obtaine nline at tion Nu - 'art 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 Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO LP and VRT Separator 011 -- -- 25.1 4.0 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 shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall 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 shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. COLORADO Air Pollution Control Division x ' r Hen, » Fausrar :sit Page 2 of 9 7. ble belo •e opera - a maintain; with the as listed i . = - educe : ssio to less thor equal perm (Regula Numb . 3, Part B, Secti III.E.) Facility Equipment ID AIRS Point Pollutants Controlled Control Device LP and VRT Separator 011 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. 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, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LP and VRT Separator 011 Total gas vented from LP and VRT separators to flare 9.9 MMscf/yr Compliance with the annual throughput limits shall 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 shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall continuously monitor and record the total volumetric flow rate of gas vented from the LP separator(s) and VRT using the flow meter. The owner or operator shall 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 10. 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.) (State only enforceable) 11. 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 Number 1, Section II.A.5.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the COLORADO Air Pollution Control Division f.A: rif^.@rlaFtibtx: x3SLi4} F.,1a^.Tortnc$ Page 3 of 9 COM Rev n. (R TING A to compli-- an ongoi ' ith the r irements the OEtM ubject Div ion appro prior to umber Part B, tion II .7.) Initial Testing Requirements 14. The owner/operator shall 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 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 shall 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 shall 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 shall 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). 15. The owner or operator shall 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) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or COLORADO Air Pollution Control Division Page 4 of 9 eportabl incre by 50' •r five (5 ' ins per ar, whichever is s, above on N su• t• ision. • 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. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall 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 shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 18. 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. 19. 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. 20. 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 operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. 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. 22. 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 COLORADO Air Po€lution. Conirot Division Ll.'Xxrtr5Va9S :sE P, o r.44fmith l Eriv r4r 4ert Page 5 of 9 ce, this hall be d., �. -• . lenied ab io. This time pri ertifica i an final auth « ation by n (APC ' on gro set fo in the Colorad • r Quality and •ns - •ualit fission (Al - uding 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. 23. 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. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. for venting of gas from three LP separators and one VRT. COLORADO Air Pollution Control Division �a r;t- n¢'St a:w rar Kkatot, b EEVO,VM 3 enc Page 6 of 9 Notes t this per , ce: 1) Th- rmit hold s re•` ed ay fees f e p -ssing ti for his permit n invoice for se fe- l be i` ed a the • mit is i -d. Th ermit holder s pay the i � • in 30 da. • -' eip • Voice. • he invoic ult 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP and VRT Separator 011 Benzene 71432 3,077 154 Toluene 108883 2,904 145 Ethylbenzene 100414 122 6 Xylenes 1330207 1,115 56 n -Hexane 110543 22,407 1,121 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 011: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source N0x --- 177.55 177.55 AP -42 CO --- 809.41 809.41 AP -42 COLORADO Air Pollution Control Division Rte,atmeraROW €.,€nbFovNtm a Page 7 of 9 S # 1 ollut ' Weight ercen (%) i i rolled m Fac on (lb r led is n actors scf) rce VOC 82.4 101,061 5,053.0 Source (HYSYS) 71432 Benzene 0.25 309.84 15.492 Source (HYSYS) 108883 Toluene 0.24 292.42 14.621 Source (HYSYS) 100414 Ethylbenzene 0.01 12.269 0.6135 Source (HYSYS) 1330207 Xylene 0.10 112.28 5.6138 Source (HYSYS) 110543 n -Hexane 1.83 2256.3 112.88 Source (HYSYS) Note: The controlled emissions factors for this point are based on the enclosed flare 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 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 Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the 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 MACT 63.1-63.599 Subpart A - Subpart Z COLORADO Air Pollution Control Division rtfnertt 08 PA Y4it` d:¢:a;[r: £r Emvortmem Page 8 of 9 MACT MACT Subpart •' ;•art DDD . 440-QQ - 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division to 3aartr en; a w ac was: =s Emfoor.-was: Page 9 of 9 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options 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/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: (OWE I3Z7 7 AIRS ID Number: 123 /9D3C/ / 0 I/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information - Company Namei: Site Name: Site Location: Noble Energy, Inc. CHANDLER ST T3N-R64W-S15 L01 NENE SEC15 T3N R64W Mailing Address: 1625 Broadway, Suite 220 (Include Zip Code) y Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@nblenergy.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes 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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 r� nmnqn 1 ®y�COLORADO ��Viiii Permit Number: AIRS ID Number: 123 /9D3./ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR O 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 it Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: LP and VRT gas streams Company equipment Identification No. (optional): For existing sources, operation began on: 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: hours/day Will this equipment be operated in any NAAQS nonattainment area? 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 APCD-211 - Gas Venting APEN - Revision 7/2018 days/week weeks/year ❑✓ Yes ❑ No O Yes ❑✓ No ❑ Yes ❑✓ No COLORADO 2 I G uss rcq: PLLd¢ Hv._ih 6 EnvtY+:1m.C1. Permit Number: AIRS ID Number: 123 /9O3./ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: ' gal/min Leak Rate: Scf/hr/pist 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? ❑ Yes Gas Venting - Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No _ — --- Vent Gas eating Value: _2611 BTU/SCF Requested: 9.9►5 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 46.50 VOC (Weight %) 82.37 Benzene (Weight %) 0.25 Toluene (Weight %) 0.24 Ethylbenzene (Weight w_1 0.00 Xylene (Weight %) 0.09 n -Hexane (Weight %) 1.84 2,2,4-Trimethylpentane (Weight %) 0.00 Additional Required Information: ❑ Attach a representative gas analysis (including BTEX li n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX 8 n -Hexane, temperature, and pressure) E 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I AY' , ti. ,.e COLORADO Permit Number: AIRS ID Number: 123 /9O3c1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.2311, -104.5282 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) ❑✓ Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: tV �V 1tAV V Form APCD-211 - Gas Venting APEN - Revision 7/2018 Permit Number: AIRS ID Number: 123 /9D3./ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit 5 Emission Limit(s) Pollutant - . - Uncontrolled -. Units Source - (AP -42, Uncontrolled - Emissions - Controlled - Emissions 6 _ Uncontrolled- Emissions Controlled:. Emissions Basis Mfg., etc.) (tons/year) (tons/year) (tons/year)- (tons/year). PM 7.6 Ib/mmscf AP -42 0.00 0.00 SOx 0.6 Ib/mmscf AP -42 0.00 0.00 NO. 0.068, 100 lb/mscf AP -42 0.90 0.90 CO 0.31, 84 lb/mscf AP -42 4.04 4.04 VOC 101.0846, 0.0055 lb/mscf HYSYS/AP-42 502.79 25.14 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) ( ) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units . Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year)., Benzene 71432 0.3093 lb/mscf HYSYS/AP-42 3,077 154 Toluene 108883 0.2919 lb/mscf HYSYS/AP-42 2,904 145 Ethylbenzene 100414 Xylene 1330207 0.1121 lb/mscf HYSYS/AP-42 1,115 56 n -Hexane 110543 2.2524 lb/mscf HYSYS/AP-42 22,407 1,121 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5I AY COLORADO Huth u Env Izonmhet Permit Number: AIRS ID Number: 123 /9O3C/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Urnmaa S Sign ture of Legally Authorize 1 Person (not a vendor or consultant) 12/11/2018 Date Janessa Salgado Environmental Engineer Name (please 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 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.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 6IAV!�P - Y.c.:r46 Ervirminvnr Hello