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Home My WebLink About20194258.tiff RECEIVED -- . COLORADO SEP 25 2019 ' 'V Department(idPublic WELD COUNTY "� Heatth&Environment COMMISSIONERS Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 September 17, 2019 Dear Sir or Madam: On September 19, 2019, the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy, Inc. - Fiscus Federal LD15 Et Castor Federal LD Econode. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /1 ' JAVA- k„,...70t3C-k1.2,,,,' Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure , \Hk*-- 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Fzw C, Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director ly p Publ:C Rev:ew CC:PL(Tp) tIL(LK),P.s(5M/cR/cH/cK), 2019-4258 q/3o/19 oG(5Ml O9/2-5/iq ew�M�M Air Pollution Control Division —Y- Notice of a Proposed Project or Activity Warranting Public CDPHE .M Comment Website Title: Noble Energy, Inc. - Fiscus Federal LD15 Et Castor Federal LD Econode - Weld County Notice Period Begins: September 19, 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: Fiscus Federal LD15 &t Castor Federal LD Econode Oil and gas exploration and production facility NENW Sec 15 T9N R 58W Weld County The proposed project or activity is as follows: Source is requesting to vent gas from an existing vapor recovery tower (VRT) to a flare during times when the vapor recovery unit is not operating. 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 14WE1115 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 'COLORADO 1 I gel Departmento:PubUc Setith @ Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carissa Moloney Package U: 399982 Received Date: 5/23/2019 Review Start Date: 8/6/2019 Section 01 - Facility Information Company Name: Noble Energy Inc. Quadrant Section Township Range County AIRS ID: 123 NENW 1 c 9N 58 Plant AIRS ID: 9CEA Facility Name: Fiscus Federal LD15 & Castor Federal LD Econode T9N-R58W-S15 101 Physical Address/Location : NENW quadrant of Section 15, Township 9N, Range 58W County: Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non-attainment area? No If yes, for what pollutant? Carbon Monoxide (CO) ❑ Particulate Matter (PM) Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application Emissions Self Cert Engineering AIRs Point # Emissions Source Type Equipment Name Permit # Issuance # Action Control? Required? Remarks This is a new point that will be added to ar, Permit Initia' existing facilit, Sep?r•=1`nr Venting 14WE1115 Issuance wide permit • Section 03 - Description of Project Noble stated they determined the VRT stream requires a permit because when the VR r VRU compressor is down, the VRT stream is routed to flare. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? _ 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? t:S If yes, indicate programs and which pollutants : SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) J ■ J Non-Attainment New Source Review (NANSR) Colorado Air Permitting Project Is this stationary source a major source? If yes, explain what programs and which pollutants herE SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non-Attainment New Source Review (NANSR) Separator Venting Emissions Inventory 018 Separator Venting Facility AIRS ID: 123 "C≥. 018 County Plant Point Section 02 - Equipment Description Details One vapor recovery tower (VRT) Detailed Emissions Unit Description: Enclosed flare Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Natural Gas Vented Gas meter Yes, Meter Is currently inttatled and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = MMscf per year Requested Permit Limit Throughput = 3.56 MMscf per year Requested Monthly Throughput = 0 MMscf per month Potential to Emit (PTE) Throughput = 3.56 MMscf per year Process Control (Recycling) Equipped with a VRU: No The stream flow listed here is only during VRU downtime Is VRU process equipment: Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: 2850 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: scf/bbl Control Device Pilot Fuel Use Rate: 437.5 scfh 3.8 MMscf/yr Pilot Fuel Gas Heating Value: 1000 Btu/scf 3832.500 MMBTU/yr Section 04 - Emissions Factors & Methodologies Description Noble collected a site-specific pressurized liquids sample from the LP separator (sample collected 5/13/2014). Noble then entered this sample into HYSYS to back-calculate the saturated HP stream. Noble then created a separate HYSYS model using the back-calculated HP stream as the HP liquid for the model which was then used to estimate emissions from the LP separator and VRT. Noble used the stream composition and stream flow rate for the HYSYS stream report labeled " VRT Gas" to estimate emissions. I also compared the VRT stream composition from the first model with the LP sample input to the VRT stream composition used for emissions. The VRT stream composition used for emissions has a slightly higher VOC weight % at 85.44 wt% vs 81.58 wt% for the other stream. The stream used for requested emissions also has a higher flow at 9.7623 MSFC vs 1.8263 MSFC. Noble used the most conservative (i.e. higher emissions) for the requested permit limits. MW 51.3723 Ib/Ib-mol Displacement Equation Ex = 0 • MW * Xx / C Weight % Helium CO2 N2 methane 2.74 ethane 10.44 propane 23.11 isobutane 3.22 n-butane 10.29 isopentane 32.4 n-pentane 2.42 cyclopentane 1.33 n-Hexane 1.27 cyclohexane '1.48 Other hexanes heptanes 2.43 methylcyclohexane 224-TMP 0.18 Benzene 0.45 Toluene 0.32 Ethylbenzene 0.04 Xylenes 0.09 C8+ Heavies 1.41 Total 100.00 VOC Wt % 85.44 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 115806.8051 5/90.3 HYSYS Benzene 603.4510 30.173 HYSYS Toluene 428.7866 21.439 HYSYS Ethylbenzene 47.6542 2.3827 HYSYS Xylene 127.6888 6.3844 HYSYS n-Hexane 4427.9669 221.40 HYSYS 224 TMP 248.5986 12.430 3-fYSYS Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source 3 of 7 K:\PA\2014\14WE1115.CP3 Separator Venting Emissions Inventory (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 21.237 - AP-42 Table 1.4-2 (P Rj0/PM.Ft PM2.5 0.0075 21.237 AP-42 Table 1.4-2 (PM30,/PM,2.5) SOx 0.0006 1.677 AP-42 Table 1.4--2 (5Ox) NOx 0.0680 193.812 AP-42 Chapter 13.5 Industrial Flares (NOrij CO 0.3100 883.553 AP-42 Chapter 13.5 industrial Flares (CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 7.6000 AP-42 Table 1.4-2 PM2.5 0.0075 7.6000 AP-42 Table 1.4-2 SOx 0.0006 0.6000 AP-42 Table 1.4-2 NOx 0.0980 100.0000 AP-42 Table 1.4-1 CO 0.0824 84.0000 AP-42 Table 1.4-1 4 of 7 K:\PA\2014\14WE1115.CP3 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.05 0.00 0.00 0.05 0.1 9 PM2.5 0.05 0.00 0.00 0.05 0.1 9 SOx 0.00 0.00 0.00 0.00 0.0 1 NOx 0.53 0.00 0.00 0.53 0.5 91 VOC 206.34 0.00 0.00 206.34 10.3 1752 CO 1.73 0.00 0.00 1.73 1.7 294 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 2150 0 0 2150 108 Toluene 1528 0 0 1528 76 Ethylbenzene 170 0 0 170 8 Xylene 455 0 0 455 23 n-Hexane 15779 0 0 15779 789 224 TM P 886 0 0 886 44 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is not subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? No. This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site-specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 90 tons per year? IIIIIIIIII If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? Nc, If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 5 of 7 K:\PA\2014\14WE1115.CP3 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes While Noble is back-calculating the pressurized liquids stream composition, this is an acceptable method from HYSYS. Noble will have to sample the gas to determine actual VOC and HAP stream composition is lower than values used in the application. Noble will also be required to use a flow meter to measure actual flow rate from the VRT. I also confirmed with Noble that the wells were constructed/completed prior to 8/1/2014 so the VRT is not subject to Reg 7, Section XVII.G. �„y yyyyyy11 �. „tai: ,e - 1 ;:r& x.lJa:{t'F.I .IF..s� .F..x..a u'.>-_.-nit z_u;,roc i_ x�:asx-s=cam:: to Tali -'"._.-JP=a .!�<as �`sa.«1Srr{rT'l.'.i.T '.''l'T.�[Z.'L'3p[ ... Fx4,4. Its: �,_ ' mgr.., ._x.. {cL�s_ �w'sidl:t< Jca::r' rn 4 k naaa.:s _..ae-mss u.->e . ra.� aera15x: '''''"{IZFi—Sfrn%H �..< x.linri_il Fn .—S LZ' L.. 3 Y" i-s Y Ii 1i�lir nit �r! II"- Nt XST`gL rf �, tl � � -�F- �6 ��" � 'e r �i°.�'�'}E'i�'ttf�ii fl I � '� n�.� ' 1 . -. Rink ng �{3'¢ 'n'^r.� j x Enr zi ata `uxr • .� hll I it Iw is: r--+� fc`� bt I{Ivc.x wi a xczr.„.._� ra Iv F 71 ya :rs�i Ir F l"C Ilt-1 k'tfi i .�, y I�. x_ y,, N x r..ik.lt x In x a x - sx ii- i .a E--,a x • !1 Jt :u ,7 - �nuii' Il • Fk 17iii1 xiiila x,zi. li,ni!iii.ii '{: i i n �. c e[^h::xi. r. Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point # Process # SCC Code Pollutant Factor Control % Units 018 01 3-10-001 -60 Flares PM10 21.24 0 Ib/MMSCF PM2.5 21.24 0 Ib/MMSCF SOx 1.68 0 lb/MMSCF NOx 193.81 0 lb/MMSCF VOC 115806.81 95 lb/MMSCF CO 883.55 0 Ib/MMSCF Benzene 603.45 95 Ib/MMSCF Toluene 428.79 95 Ib/MMSCF Ethylbenzene 47.65 95 Ib/MMSCF Xylene 127.69 95 lb/MMSCF n-Hexane 4427.97 95 Ib/MMSCF 224 TMP 248.60 95 Ib/MMSCF 6 of 7 K:\PA\2014\14WE1115.CP3 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? r u; Source Req 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? Ye: Source Req Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source is in the Attainment Area Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? No Source is n' Source is not subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section' a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The contro The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of 'he Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandatory language such as 'recommend, " 'may. " 'should, "and "can. "is intended to describe APCD interpretations and recommendations_ Mandatory terminology such as 'must" and 'required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy County AIRS ID 123 History File Edit Date 8/6/2019 Two separate packages were received May 2019 Plant AIRS ID 9CEA Ozone Status Attainment Facility Name Fiscus Federal LD15 & Castor Federal LD15 Econode EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.7 0.7 0.0 0.3 65.2 588.4 1 . 1 106.2 45.4 0.7 0.7 0.0 0.3 14.7 37.8 1 . 1 55.9 3.3 Based on May 2019 tab for Points 001-003, 005, 010-011 ,015-017 Previous Permitted Facility total 0.1 0.1 0.0 0.3 62. 1 588.3 0.0 103. 1 45. 1 0. 1 0. 1 0.0 0.3 12.4 37.7 0.0 52.9 3.2 This total included Point 016 which is incorrect. I've corrected the permitted facility total in row 34 001 14WE1115 Condensate Storage Tanks 243.0 6.8 , 12.2 , 0.3 002 14WE1115 Produced Water Storage Tanks 98.3 10.9 _ 5.0 0.5 003 14WE1115 Condensate Loadout 232.5 24.8 _ 11 .7 i 1 .2 004 CANCELED Wellhead gas flaring 0.0 0.0 005 14WE1795.XA Fugitives _ 1 . 1 0. 1 1 . 1 0.0 006 GP02.CN 370 HP 0.0 _ 0.0 Cancellation received 11/17/2017 007 , GP02.CN 370 HP - _ 0.0 0.0 008 GP02.CN 88 HP - GM 5.7L _ 0.0 0.0 Cancellation Received 4/19/2016 009 GP02 84 HP 0.0 _ 0.0 Cancelled 5/28/2019, No Longer Exists 010 GP02 690HP 3.4 10.4 21 .4 2.2 3.4 4.70 13.4 0.6 011 GP02 400 HP , 45.5 2.70 , , 45.5 , 0.3 3.9 2.70 7.8 , 0.4 012 GP02 75 HP NG-fired RICE _ _ 0.0 0.0 Cancelled 6/10/2019, No Longer Exists 013 GP06.CN 76 HP NG-fired RICE 0.0 0.0 Cancellation received 5/4/2017 014 GP06.CN RICE Diesel 107 HP 0.0 0.0 Cancellation received 12/14/2017 015 GP06 Cummings 110 HP Diesal RICE 0.0 0.0 , 0.3 2.7 0.20 4.0 0.0 0.0 0.0 0.3 2.7 0.20 4.0 0.0 016 19WE0401 .XP Kubota DF972 23.6hp SN: 5N5385 0.0 0.0 0.0 0.4 0.74 24.3 0.0 0.0 0.0 0.0 0.4 0.74 24.3 0.0 .XP Pilot Program, Not Reviewed 017 GP02 GM 4.3L 75hp SN: 13214 0. 1 0. 1 0.0 , 10. 1 0.51 8.0 0.1 0. 1 0. 1 0.0 , 2.0 0.51 3.5 0.1 018 14WE1115 VRT Sepaarator 0. 1 0. 1 0.5 _ 206.3 1 .7 , 10.5 , 0. 1 0. 1 0.5 10.3 1 .7 0.5 New point - .XA (6) Seperator Heaters 0. 1 0. 1 , 0.7 0.0 0.6 0.0 0. 1 . 0. 1 0.7 0.0 0.6 0.0 - .XA (8) VOC Burners 0.5 . 0.5 0.9 0.0 0.7 0.2 0.5 0.5 _ 0. 1 0.0 0.6 0.0 - .XA (5) Light Towers 0.0 0.0 1 .5 0. 1 1 .8 0.0 0.0 0.0 1 .5 _ 0. 1 1 .8 0.0 FACILITY TOTAL 0.7 0.7 0.0 0.3 65.7 794.7 1 .1 107.9 55.9 0.7 0.7 0.0 0.3 15.2 48.1 1 .1 57.6 3.8 VOC : Syn Minor (PSD and OP) NOx: True Minor (PSD and OP) CO: Syn Minor (OP), True Minor (PSD) HAPS: (Syn Minor n-hexane & total) 7777: Area Permitted Facility Total 0. 1 0. 1 0.0 , 0.3 62.2 , 793.9 0.0 80.6 55.6 0. 1 0. 1 _ 0.0 , 0.3 12.5 47.3 0.0 30.4 3.7 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0. 1 9.6 0.0 -22.6 Public Comment is required to establish new I_ synthetic minor limit. Total VOC Facility Emissions (point and fugitive) 49.2 Facility is eligible for GP02 because < 90 tpy (A) Change in Total Permitted VOC emissions (point and fugitive) 9.6 _ _Project emissions less than 50 tpy Note 1 Note 2 Page 1 of 3 Printed 9/10/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Noble Energy County AIRS ID 123 Plant AIRS ID 9CEA 0 Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 2.5 0.2 0.2 5. 1 4.7 1 .4 4.0 25.3 0.0 2 . 3 0 45.6 001 14WE1115 Condensate Storage Tanks 1260 860 10800 720 6 .8 002 14WE1115 Produced Water Storage Tanks 5250 16500 10 . 9 003 14WE1115 Condensate Loadout 3510 8468 2717 7909 23220 3871 24 .8 004 CANCELED Wellhead gas flaring 0 .0 005 14WE1795 .XA Fugitives 57 0 . 1 006 GP02 . CN 370 HP _ 0.0 007 GP02 .CN 370 HP 0 .0 008 GP02 .CN 88 HP - GM 5 .7L 0 .0 009 GP02 84 HP 0 .0 010 GP02 690HP 3731 378 2 .2 011 GP02 1400 HP 534 _ 0 .3 012 GP02 75 HP NG-fired RICE 0 .0 013 GP06.CN 76 HP NG-fired RICE 0 .0 014 GP06 .CN RICE Diesel 107 HP 0 .0 015 GP06 Cummings 110 HP Diesal RICE 0 .0 016 19WE0401 .XP Kubota DF972 23.6hp SN : 5N5385 38 5 5 3 0.0 017 GP02 GM 4 .3L 75hp SN : 13214 108 15 14 8 16 0 . 1 018 14WE1115 VRT Sepaarator 2150 1528 455 15779 886 10.5 - .XA (6) Seperator Heaters 24 39 0 .0 - .XA (8) VOC Burners 9 214 97 0 .2 - .XA (5; Light Towers 2 0 .0 0 .0 TOTAL (tpy) 2.2 0.2 _ 0. 1 6. 1 5.5 1 .4 4.2 33.3 0.5 2.3 0.0 0.0 55 . 9 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0.8 0.3 0.2 0.3 0.2 0.1 0.2 1 .3 0.0 0 . 1 0 0 3.5 001 14WE1115 Condensate Storage Tanks 63 _ 43 540 36 0 .3 002 14WE1115 _ Produced Water Storage Tanks 263 825 0 .5 003 14WE1115 Condensate Loadout 176 423 136 395 1161 194 1 .2 004 CANCELED Wellhead gas flaring 0 .0 2 1239CEA 9/ 10/2019 L. COLORADO DEPARTMENT OF PUBLIC HEALTH ANI) ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Noble Energy County AIRS ID 123 Plant AIRS ID 9CEA 0 005 14WE1795 .XA Fugitives 0 . 0 006 GP02 .CN 370 HP 0 .0 007 GP02 .CN 370 HP _ 0 .0 008 GP02 .CN 88 HP - GM 5 .7L 0 .0 009 GP02 84 HP _ 0 .0 010 GP02 690HP 666 378 232 20 0 .6 011 GP02 400 HP 534 73 68 41 0 .4 012 GP02 75 HP NG-fired RICE 0 .0 013 GP06 . CN 76 HP NG-fired RICE 0 .0 014 GP06. CN RICE Diesel 107 HP 0 .0 015 GP06 Cummings 110 HP Diesal RICE 0 .0 016 19WE0401 .XP Kubota DF972 23 .6hp SN : 5N5385 38 5 5 3 0 .0 017 GP02 GM 4. 3L 75hp SN : 13214 108 15 14 8 16 0 . 1 _ 018 14WE1115 VRT Sepaarator 108 76 789 44 0 .5 - .XA (6) Seperator Heaters 24 39 0 .0 .XA (8) VOC Burners 1 27 12 0 .0 - .XA (5; Light Towers 2 1 0 . 0 . 0 . 0 TOTAL ;tpy) 0.7 0.2 0.2 0.3 0.3 0. 1 0.2 1 .7 0. 1 0. 1 0.0 0.0 3 .8 3 1239CEA 9/ 10/2019 CDPHE ` COLORADO CO Air Pollution Control Division Department nt Tvb?c Health S Ereoronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 14WE1115 Issuance: 3 Date issued: Issued to: Noble Energy, Inc. Fiscus Federal LD15 £t Castor Federal LD Econode T9N-R58W- Facility Name: S15 L01 Plant AIRS ID: 123/9CEA Physical Location: NENW, Section 15, T9N, R58W County: Weld County Description:. Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Equipment Description Emissions Control iD Point Description Tank Sixteen (16) 538 bbl and one (1), 300 bbl 001 Enclosed flare Battery condensate storage tanks PW 002 Four (4) 538 bbl and Two (2) 60 bbl Enclosed flare produced water storage tanks TLO 003 Truck Condensate Loadout Enclosed flare VRT 018 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. AIRS ID 018: 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, bar 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. AIRS ID 018: 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 Page 1 of 13 4CDPHE COLORADO CO ' Air Pollution Control Division Department of Pub'c Health&l nv3ronment Dedicated to protecting and improving the health and environment of the people of Colorado must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. AIRS ID 018: This permit must expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 4. AIRS ID 018: The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type Tank Battery 001 --- --- 12.2 --- Point PW 002 --- --- 5.0 --- Point TLO 003 --- --- 11.7 --- Point VRT 018 --- --- 10.3 --- Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 13 CDPHE COLORADO CO ' Air Pollution Control Division Depamrent of rub'c He filth,t motonment Dedicated to protecting and improving the health and environment of the people of Colorado Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Control Device Pollutants Point Controlled Tank Battery 001 Enclosed Flare VOC and HAP PW 002 Enclosed Flare VOC and HAP TLO 003 Enclosed Flare VOC and HAP VRT 018 Enclosed Flare during Vapor Recovery VOC and HAP Unit (VRU) downtime PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Tank Battery 001 Condensate Throughput 1,800,000 BBL PW 002 Produced Water Throughput 750,000 BBL TLO 003 Oil Loaded 1,800,000 BBL VRT 018 Natural Gas Venting to Flare during 3.56 MMscf VRU downtime Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and Page 3 of 13 CDPHE COLORADO CO Air Pollution Control Division Depamnent o Pt:b';c Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. AIRS ID 018: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) to the enclosed flare during VRU downtime using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. AIRS Points 001, 002, and 003: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or,combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. AIRS Point 001: The storage tanks covered by this permit are subject to the emission control requirements in Regulation No. 7, Section XVII.C.1.a. The owner/operator must install and operate air pollution control equipment that achieves an average control efficiency of 95% for VOC's. The source shall follow the inspection requirements of Regulation No. 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. 15. AIRS Points 001, 002: The storage tanks covered by this permit are subject to the emission control requirements in Regulation No. 7, Section XVII.C.1.b. The owner/operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. The source shall follow the inspection requirements of Regulation No. 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control must be achieved according to the following schedule: Page 4 of 13 CDPHE ' COLORADO CO ( Air Pollution Control Division u ( Depamnent o r-i.h c Health&tnvaronment Dedicated to protecting and improving the health and environment of the people of Colorado o If storage tank was constructed on/after May 1, 2014, within 90 days of the date that the storage tank commences operation; o If storage tank was constructed before May 1, 2014, by May 1, 2015. 16. AIRS Points 001, 002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation No. 7, Section XVII.C.2. This storage tank shall be operated without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. The owner/operator must develop, certify, and implement a documented STEM plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet these requirements. Compliance is required on the following schedule: o A storage tank constructed on/after May 1, 2014 must comply and implement a STEM Plan within 90 days of the storage tank commencing operation; o A storage tank constructed before May 1, 2014, must comply and implement a STEM Plan by May;,1, 2015. Approved instrument monitoring method inspections must begin within ninety(90)days of the Phase-In Schedule in Table 1, or within thirty(30)days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 - Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method ("AIMM") Emissions (tpy) Inspection Frequency > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 The owner/operator shall maintain records in accordance with Regulation No. 7, Section XVII.C.3. and make them available to the Division upon request. The owner or operator shall maintain records of STEM, including the plan, any updates, and the certification, for the life of the storage tank. The owner/operator will maintain records of all required inspections and monitoring for a period of two years. 17. AIRS Point 003: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): Page 5 of 13 `��E COLORADO C Air Pollution Control Division t}epamrent of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with above condition. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 18. AIRS Point 003: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 19. AIRS Point 003: Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part,B, III.E) OPERATING£t MAINTENANCE REQUIREMENTS 20. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OitM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 21. AIRS ID 018: The owner/operator must complete an initial site specific extended',gas analysis ('Analysis")`within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4- trimethylpentane content (weight fraction)of this emission stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. ADDITIONAL REQUIREMENTS 22. All previous versions of this permit are cancelled upon issuance of this permit. 23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Page 6 of 13 cot COLORADO CO IV. Air Pollution Control Division Department of tt:t tc Health Er Eraaronreent Dedicated to protecting and improving the health and environment of the people of Colorado • 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 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. 24. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in j any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 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 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 Page 7 of 13 +, CDPHE COLORADO CO Air Pollution Control Division Department a€ptah{tc Health&);nvuniin3ef12 Dedicated to protecting and improving the health and environment of the people of Colorado 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 30. Section 25-7-114.7(2)(a), C.R.S. requires that ail 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: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 2/23/2015 Issued to Noble Energy, Inc. for Points 001 - 004 Page 8 of 13 CDPHE COLORADO CO 4" Air Pollution Control Division Cepamnent of rib';c Health h Env4tonment Dedicated to protecting and improving the health and environment of the people of Colorado Issuance 2 12/28/2015 Final Authorization of Issuance 1, including removing point 004 which was never installed. Issuance 3 This Issuance Adding new point, AIRS 018 for VRT venting. Page 9 of 13 CDPHE 1COLORADO CO Air Poltution Control Division • Department of ra:b';c Health 6 Envaranment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants'!are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS# Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,260 63 n-Hexane 110543 10,800 540 Tank Battery 001 Toluene 108883 860 43 224 TMP 540841 720 36 Benzene 71432 5,250 263 PW 002 n-Hexane 110543 16,500 825 Benzene 71432 3,506 175 n-Hexane 110543 23,171 1,159 Toluene 108883 8,468 423 TLO 003 Xylenes 1330207 7,909 395 224 TMP 540841 3,871 194 Ethylbenzene 100414 2,717 136 Benzene 71432 2,149 107 VRT 018 Toluene 108883 1,527 76 Page 10 of 13 CDPHE COLORADO 4' Air Pollution Control Division CO Depamrent et'ri.b$c Health 6.rnvwonment Dedicated to protecting and improving the health and environment of the people of Colorado Ethylbenzene 100414 170 8 Xylenes 1330207 455 23 n-Hexane 110543 15,775 795 2,2,4- 540841 885 44 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 001: Emission Factors Uncontrolled Pollutant lb/BBL Source Condensate Throughput VOC 0.27 WinSim n-Hexane 0.006 WinSim. Benzene 0.0007 WinSim Toluene 0.0005 WinSim 224 TMP 0.0004 WinSim Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 002: Emission Factors Uncontrolled Pollutant lb/BBL Produced Source Water Throughput VOC 0.262 CDPHE n-Hexane 0.022 CDPHE Benzene 0.007 CDPHE Note: The controlled emissions for this point are based on the flare control efficiency of 95%. Point 003: Emission Factors - Uncontrolled Pollutant lb/BBL Source loaded VOC 0.2585 AP-42 Benzene 0.002 AP-42 n-Hexane 0.0129 AP-42 Toluene 0.0047 AP-42 Xylenes 0.0044 AP-42 Page 11 of 13 c s COLORADO CO Air Pollution Control Division Depamnent of 1 v rtv e Health h tnvecnment Dedicated to protecting and improving the health and environment of the people of Colorado The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.9 psia M (vapor molecular weight) = 62 lb/lb-mol T (temperature of liquid loaded) = 519.67 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Point 018: Uncontrolled Controlled Emission Emission CAS # Pollutant Source Factors Factors (lb/MMscf) (lb/MMscf) NOx 301.50 301.50 AP-42 CO 974.01 974.01 AP-42 VOC 115,880 5,794.0 Source (HYSYS) 71432 Benzene 603.78 30.189 Source (HYSYS) 108883 Toluene 429.04 21.452 Source (HYSYS) 100414 Ethylbenzene 47.682 2.3841 Source (HYSYS) 1330207 Xylene 127.76 6.3881 Source (HYSYS) 110543 n-Hexane 4,432.5 221.63 Source (HYSYS) 540841 248.75 12.437 Source (HYSYS) Trimethyipthylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on modeled high pressure separator temperature of 90°F and separator pressure of 115 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Page 12 of 13 CDPHE COLORADO Air Pollution Control Division co Depamrent of rt:b'T Health,Environment Dedicated to protecting and improving the health and environment of the people of Colorado Applicable Status Requirement Operating Permit Synthetic Minor Source of: CO, VOC and HAP PSD 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 following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP /OLT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN Subpart XXXXXX Page 13 of 13 �`""CPI-I, kir31019 °P"E' Gas Venting APEN - Form APCD-2 : ', I«« Air Pollutant Emission Notice (APEN) and CO Vf 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 wilt not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 14WE1115 AIRS ID Number: 123 /9CEA f T13D' [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: FISCUS FEDERAL LD15&CASTOR FEDERAL LD ECONODE T9N-R58W-S15 L01 Site Location Site Location: NENW SEC15 T9N R58W Weld County: NAICS or SIC Code: 1311 Mailing Address: 1625 Broadwa Suite 2200 (Include Zip Code) y� Denver, CO 80202 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E-Mail Address2: a.satterfield@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. • 399.973 -- COLORADO ©© Cepa®enl o[Wbe Form APCD-211 - Gas Venting APEN Revision 7/2018 1 I m� Permit Number: 14WE1115 AIRS ID Number: 123 /9CEA/TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action O 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) -Ch- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE) Additional Info& Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-1O6)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: VRT gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 3/25/2014 For new, modified, or reconstructed sources, the projected start-up date is: g Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS O Yes 0 No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes ❑ No Section XVII.G? COLORADO Form APCD-211 - Gas Venting APEN Revision 7/2018 2 �j� r :, E OLOR,�: Permit Number: 14WE1115 AIRS ID Number: 123 I 9CEA/TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator o Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes O No Vent Gas 2850 BTU/SCF Gas Venting Heating Value: Process Parameterss: Requested: 3.56 MMSCF/year Actual: MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters Molecular Weight: 51.3734269 VOC (Weight%) 85.44% Benzene (Weight%) 0.45% Vented Gas Toluene (Weight%) 0.32% Properties: Ethylbenzene (Weight%) 0.04% Xylene (Weight%) 0.09% n-Hexane (Weight%) 3.27% 2,2,4-Trimethylpentane(Weight%) 0.18% Additional Required Information: ❑ Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure) El pressure) a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s)should consider future process growth. pe COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 ®oa 1 �M Permit Number: 14WE1115 AIRS ID Number: 123 /9CEA/TBD [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.754757, -103.851655 Discharge Height, Operator -- -- Temp Flow Rate Velocity Above Ground Level, Stack ID No (Feet) (`F) (AcFA9 (ft/sec) Leed Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑Downward ❑ Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): D Other(describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: ❑ VRU: Requested Control Efficiency: % VRU Downtime or Bypassed: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: ❑ Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: pp cow C 0,1 Oni2, Form APCD-211 - Gas Venting APED! Revision 7/2018 4 m� 'hF Permit Number: 14WE1115 15 AIRS ID Number: 123 /9CEA/TBD [Leave blank unless APCD has already assigned a permit M and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): Overall R_ equested Pollutant Description of Control Method(s) Control Efficiency (%reduction in emissions) PM SO. NO. CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Permit Requested Annual Emission Factor Actual Annual Emissions Annual t — Emission Limit(s)5 Pollutant': Source Uncontrolled. Controlled Uncontrolled Controlled Uncontrolled_ _- 5- - -- Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.,etc - _r (tons/year) (tons/year) (tons/year) _(tons/year) PM 7.6 lb/MMscf AP-42 0.01 0.01 SOx 0.6 lb/MMscf AP-42 0.00 0.00 NO. 0.068, 100 lb/MEIN,lb/MMscf AP-42 0.54 0.54 CO 0.31,84 Ib/MMBN,Ib/MMscf AP-42 1.73 1.73 VOC 115.8741667,0.0055 lb/mscf,Ib/MMscf Model,AP-42 206.20 10.32 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract -Chemical Name -_ Uncontrolled Source Uncontrolled Controlled Service CAS -__ (__� Units (AP 41, Emissions Emissions Basin - ---- Number --- I Mfg.,etc.) (pounds/year) t (P Ye I (Pounds/year) Benzene 71432 0.60377 lb/mscf Model/AP-42 2149 107 Toluene 108883 0.42903 lb/mscf Model/AP-42 1527 76 Ethylbenzene 100414 0.04768 lb/mscf Model/AP-42 170 8 Xylene 1330207 0.12776 lb/mscf Model/AP-42 455 23 n-Hexane 110543 4.43058 lb/mscf Model/AP-42 15775 795 2,2,4- 540841 0.2487 lb/mscf Model/AP-42 885 44 Trimethylpentane 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. © -.COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 I ��y b" `Pub"` Hua.[h b Er rli cnmon1 Permit Number: 14WE1115 AIRS ID Number: 123 /9CEA/TBD [Leave blank unless APCD has already assigned a permit n"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. ` ' l( 05/21/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (please print) Title Check the appropriate box to request a copy of the: ❑r 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 or(303) 692-3148 APCD-SS-B 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver, CO 80246-1530 (303) 692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd p 4 COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I MgE ,c,7,417:;,,72',,:t t Hello