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HomeMy WebLinkAbout20192299.tiffCOLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 June 11, 2019 Dear Sir or Madam: RECEIVED WELD COUNTY COMMISSIONERS On June 13, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - HARPER-KONA A21 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 Ft 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. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 1 A0t Re -view OCo r &LI (9 cc PL_CTP), i�ICJT), PwC aR(CH/SM/CKZ) OCn!I7 / l9 2019-2299 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - HARPER-KONA A21 ECONODE - Weld County Notice Period Begins: June 13, 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: HARPER-KONA A21 ECONODE Exploration Et Production Well Pad NWSW SEC21 T06N R64W Weld County The proposed project or activity is as follows: This project is for a newly constructed facility that began operation on 2/3/2018. This point is for flash gas from the condensate knock -out scrubber which is routed to an enclosed combustion device. In addition to this point, the source has also requested general permit coverage for 3- natural gas engines at the facility. The facility is located within the non -attainment area for ozone and is synthetic minor for VOC (NANSR and OP) and CO (OP, only). 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 18WE0484 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: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 LORAPO COLORADO Air Pollution Control Division Health f; Ef- vroncrlef,. Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE0484 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. Harper Kona A21 Econode 123/9FBE NWSW SEC 21 T6N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Enclosed Burner 004 Flash Gas from 2 -Phase Separator known as Condensate Knock -Out Scrubber Enclosed Combustion Device This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result Page 1 of 9 COLORADO Air Pollution Control Division Hcalth Environment Dedicated to protecting and improving the health and environment of the people of Colorado in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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 Enclosed Burner 004 --- 1.1 29.8 5.1 Point Note: See "Notes to Permit Holder" for information on emiss.on 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. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Page 2 of 9 COLORADO Air Pollution Control Division ,t of Ptab!.=.+:,-.,.,_,fn % E.v orwrIe=t Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Control Device Pollutants Controlled Enclosed Burner 004 Flash gas from the condensate knock -out scrubber is routed to an enclosed combustion device 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 Enclosed Burner 004 Natural Gas Throughput 13.14 MMSCF 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 volumetric flow rate of natural gas vented from the separator(s) 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. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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 shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; Page 3 of 9 COLORADO Air Pollution Control Division nt ofP:..'oErvi,orTnent Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering tine or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M 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 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) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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 (NOr) 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 Page 4 of 9 COLORADO Air Pollution Control Division Department .fIt.a.: Hean£;F io.- e . Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR) 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 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. Page 5 of 9 COLORADO Air Pollution Control Division >_c'srt rat of Pl.₹) :.t't £r F i. r,,rrteni Dedicated to protecting and improving the health and environment of the people of Colorado 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ob initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Page 6 of 9 'COLORADO [ Air Pollution Control Division Depfiftment of P.t.a)';t Health & F t - _.,rani Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Enclosed Burner 004 Benzene 71432 6,775 339 Toluene 108883 9,734 487 Ethylbenzene 100414 4,522 226 Xylenes 1330207 5,573 279 n -Hexane 110543 46,891 2,645 2,2,4- Trimethylpentane 540841 3,115 156 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. Page 7 of 9 COLORADO Air Pollution Control Division of P:.f H:ifin a Ervironmerft Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 172.00 172.00 AP -42, Chapter 13.5 CO 776.26 776.26 VOC 90, 818.1 4,540.9 HYSYS Model based off a site specific pressurized liquid sample taken 71432 Benzene 515.6 25.8 108883 Toluene 740.8 37.0 100414 Ethylbenzene 344.2 17.2 1330207 Xylene 424.1 21.2 110543 n -Hexane 3,568.6 178.4 540841 2'2'4-04/25/2018 Trimethylpentane 237.1 11.9 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The combustion emissions were calculated based on a separator gas heating value of 2484 BTU/scf. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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, CO, n -Hexane, total HAP 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: //www.ecfr.Rov 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 Page 8 of 9 COLORADO Air Pollution Control Division Departmert.tF',.,r...Hean Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh Lakocy Package #: 378512 Received Date: 5/7/2018 Review Start Date: 12/11/2018. Section 01- Facility Information Company Name: Noble Energy, Inc County AIRS ID: 123 Plant AIRS ID: 9FBE Facility Name: HARPER-KONA A21 ECONODE Physical Address/Location: County: Type of Facility: Exploration & Production Welk Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoade (Co) NWSW quadrant of Section 21, Township 06N, Range 64W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range NWSW 21 06N 64 Ozone (NOn & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cart Required? Action Engineering Remarks 004 ; Separator Venting, Enclosed Burner Yes 18WE0484 1 --- Permit Initial. +? Issuance Section 03 - Description of Project This project is for a newly constructed E & P facility that began operation on 2/3/2018. In addition to the point covered by this permit analysis, the source has also requested general permit coverage for 3- natural gas engines at the facility. The facility is located within the non -attainment area for ozone and is synthetic minor for VOC (NANSR and OP) and CO (OP, only). Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement. Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes 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) No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (P50) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No NOx CO VOC PM2.5 ❑ ❑✓ PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County 940E Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Flash gas from the condensate knock -out scrubber is routed to an enclosed combustion device Enclosed combustor Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter atonal Gag -Vented' Gas meter Yes. meteris @urientiy installed attd opeta8 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput 13.1 MMscf per year 13.1 MMscf per year 95 Requested Permit Limit Throughput = Requested Monthly Throughput = 1 MMscf per month Potential to Emit (PTE) Throughput = Is VRU process equipment: 13 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 248.4 Btu/scf scf/bbl Description Using apressurized gas sample analysis from the HP separator, taken 4/25/2018 at 138 F and 289 P51G, this sample was inputted into a HYSYS model which modelled the separation units (knock -out scrubber). Using the vapor stream from the knock -out scrubber ("Misc Vap to Bruner 21, the emission factors were determined based on the standard gas flow calculated in the HYSYS model. Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 90118.1 45afl-9050 Benzene Toluene Ethylbenzene 720.7 344.2 424.1 3558.4 237.1 25.7500 37,0400 17.21_00 71.213F42 172.4300 11.85`;0 Xylene n -Hexane 224 TMP Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 SOx 0.511{} Oaks NOx 0.0680 168.412 1;0 .04o t AP -42 a:Aga:43.5lttdustrial Flares (Gtk) i AP -42G eeY3:S tndustriahflkres (fl CO 0.3100 2 of 8 K:\PA\2018\18WE0484.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.05 0.05 0.05 0.05 0.05 8 0,05 0.05 0.05 0.05 0,05 8 0.00 0.00 0.00 0.00 0.00 1 1.11 1.11 1.11 1.11 1.11 189 596.67 596.67 29.83 596.67 29.83 5068 5.06 5.06 5.06 5.06 5.06 859 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled Ohs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 6775 6775 339 6775 339 9734 9734 407 9734 487 4523 4523 226 4523 226 5573 5573 279 5573 279 46891 46891 2345 46891 2345 3115 3115 156 3115 156 Section 06- Reg_ulatory§ummq Analgpis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet far detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance ect to Regulation 7, Section XVIi.0,2, 6 The control device for this separator is not sub}act to Regulation 7, Section XVll.0.2.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 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 pemtitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will corrtain: -. -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? 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 3 of 8 K:\PA\2018\18WE0484.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes 7777.... 7777. 7777.. _7.777. 7777..... 7.77_7 __7777 777_7.. 7777 _. 7777 7777. 7777... 7777... 7777..... The emission factors for particulate matter and SOx came from AP -42 Table 1.4-2 (Emissions factors for criteria pollutants and greenhouse gases from natural gas combustion), which are given in lb/10"6 sit. The source elected to use the emission factor for PM (Total) to represent thie PM10 and PM2.5 emissions. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 0 004 Process 0 SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 f..,.. 0 IbiMMSCF PM2.5 7.00 0 lbfMMSCF 5Ox 0.00 0 Ib/MMSCF NOx 008.91 0 lb/MM5Cf VOC 9091.8.10 90 I4;MMS:;3 CO 7,1..13 0 €4,1M05(1 Benzene 515.50 95 IbiMMSLF Toluene 740.30 05 €6/0051 Ethylbenzene 344.21 95 I0/00511 xylene 424.1= 95 18/00544 n -Hexane 3050.40 95 Ib/0051.1 224 TMP 037.10 90 Ibi MMSC/ 4 of 8 K:\PA\2018\18WE0484.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and 8 - APEN and Permit Requirements ionr,n is in the `Jon -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)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPV or CO emissions greater than 10 TRY (Regulation 3, Part Et, Section II.D.31? Nut enough irrtcrnaacion NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section 11.0.1. a(? 2. Are total facility uncontrolled VOC emissions from the greater than 2 IP?, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2(? 'Source n.tern, e pentit Colorado Regulation 7, Section sVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? 'Sour, isubject to ::Seg:niaiioni Section 0551!.6.2, .3 Section YVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section eVII.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? I'he eontroi device for this aeperator is :mt suu;ect :0 2+nulat: Sc'.. Scotch Section %VII.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 (he 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 ARCO interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to descnbe 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 Yes 1 Source Req Yes -.:I Source Req Yet COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy Inc 123 9FBE HARPER-KONA A21 ECONODE History File Edit Date Ozone Status 4/26/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP02 Caterpillar 205 HP 4SRB RICE 0.2 0.2 30.6 1.4 30.6 0.4 0.2 0.2 2.0 1.4 4.0 0.4 New GP02 Request 002 GP02 PSI D8.1L 236 HP 4SRB RICE 0.2 0.2 20.6 1.6 34.6 0.2 0.2 0.2 2.3 1.6 4.7 0.2 Cancelled 8/30/2018 003 GP02 PSI D8.1L 236 HP 4SRB RICE 0.2 0.2 20.6 1.6 34.6 0.2 0.2 0.2 2.3 1.6 4.7 0.2 Cancelled 8/30/2018 004 18WE0484 Natural Gas Venting - Enclosed Burner 0.1 0.1 1.1 596.7 5.1 38.3 0.1 0.1 1.1 29.8 5.1 1.9 New permit request 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.7 0.7 0.0 0.0 72.9 601.3 0.0 104.9 39.1 0.7 0.7 0.0 0.0 7.7 34.4 0.0 18.5 2.7 VOC: Syn Minor (NANSR and OP) NOx: Tue Minor (NANSR and OP) CO: Syn Minor (OP), True Minor (PSD) HAPS: Syn Minor n -hexane Permitted Facility Total 0.7 0.7 0.0 0.0 72.9 601.3 0.0 104.9 39.1 0.7 0.7 0.0 0.0 7.7 34.4 0.0 18.5 2.7 Excludes units exempt from (A) Change in Permitted Emissions 0.7 0.7 0.0 0.0 7.7 34.4 0.0 18.5 Pubcom required because requesting a new synthetic minor permit. Modeling not required based on division guidelines Note 1 Total VOC Faci A) Change in Total Permitted VOC ity Emissions (point and fugitive emissions (point and fugitive 34.4 _ Facility is eligible for GP02 because < 90 Project emissions less than 25 tpy 34.4 Source submitted multiple APEN addendums for permit 18WE0484. Data presented here reflects the most recently received APEN addendum for the initial issuance for permit #18WE0484 Note 2 Page 6 of 8 Printed 4/29/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy Inc 123 9FBE HARPER-KONA A21 ECONODE Emissions - uncontrolled (Ibs er year POIN1 PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Caterpillar 205 HP 4SRB RICE 832 0.4 002 GP02 PSI D8.1 L 236 HP 4SRB RICE 381 0.2 003 GP02 PSI D8.1L 236 HP 4SRB RICE 381 0.2 004 18WE0484 Natural Gas Venting - Enclosed Burner 6775 9734 4522 5573 46891 3115 38.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.8 0.0 0.0 3.4 4.9 2.3 2.8 23.4 0.0 1.6 0.0 0.0 39.1 *Total Reportable = all HAPs where uncontrolled emissions > de minim'IR yelltec Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02 Caterpillar 205 HP 4SRB RICE 832 0.4 002 GP02 PSI D8.1 L 236 HP 4SRB RICE 381 0.2 003 GP02 PSI D8.1 L 236 HP 4SRB RICE 381 0.2 004 18WE0484 Natural Gas Venting - Enclosed Burner 339 487 226 279 2346 156 1.9 0.0 0.0 0.0 0.0 7 18WE0484.CP1 4/29/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Noble Energy Inc County AIRS ID 123 Plant AIRS ID 9FBE Facility Name HARPER-KONA A21 ECONODE 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.8 0.0 0.0 0.2 0.2 0.1 0.1 1.2 0.0 0.1 0.0 0.0 2.7 8 18WE0484.CP1 4/29/2019 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: wvwr.colprado.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: 18WE0484 AIRS ID Number: 123 /9FBE /004 ( ease blank unless APCD has already a_-i ned a permit = and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy, inc. Site Name: Harper Kona A21 Econode Site Location: NWSW S21 T6N R64W Mailing Address: 1625 Broadway,Suite 2200 (include Zip Code) Site Location Weld County: NAICS or SIC Code: 1311 Contact Person: Shaun Higgins Phone Number: 720-587-2459 E -Mail Address2: shaun.higgins@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 alt 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. OLORADO Farm APCD-21 I- G3; V il`_ n APED Fe,'isicn 7/2013 1 Permit Number: 18WE0484 AIRS ID Number; 123 / 9IFBE / 004 [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 D Transfer of ownership4 ❑ Other (describe below) ^OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 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: E nclosed Burner Company equipment identification No. (optional): For existing sources, operation began on: 02/03/2018 For new, modified, or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation; Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-21 I ... Gas /enLinm APEN Revision 7/2018 days/week weeks/year El Yes ❑ No ❑ Yes ❑✓ No ❑ Yes El No tc7 L+J RSD? Permit Number: 18WE0484 AIRS ID Number: 123 /9FBE/004 [Leave blank unless APCD has Already assigned a permit = and AIRS ID] Section 4 - Process Equipment Information D Gas/Liquid Separator O Well Head Casing ❑ Pneumatic Pump Make: Model: Compressor Rod Packing Make: Model: Serial #: # of Pistons: Capacity: Leak Rate: gal/min Scf/hr/pint ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event Q Other Description: Control device for flash gas from knock out scrubber 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? J Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: 2484 BTU/SCF Requested: 13.14 WASCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual.: bbl/year Molecular Weight: 44.28 VOC (Weight %) 77:68 Benzene (Weight %) 0.44 Toluene (Weight %) 0.63 Ethytbenzene (Weight %) 0.29 Xylene (Weight %) 0.36 n -Hexane (Weight %) 3.05 2,2,4-Trimethylpentane (Weight %) 0.20 Additional Required Information: ❑ Attach a representative gas analysis (including BTEX E n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) El 5 Requested values will become permit limitations. Requested-limit(s) should -consider future process growth. . _r n A.PCD-21 1 - Gas Venting APEN Revision 7/2018 31 COLORADO Permit Number: 18WE0484 AIRS ID Number: 123 / 9FBE / 004 [Leave h Ink unto _ OPCD has. ei.r_ad, signed 0 permit = and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) Operator -. _r_ _- _ Stack ID No. • Discharge Height �; Above Ground Level (Feet) Temp ( F); Ftav� Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section, ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: Enclosed Burner MMBtu/hr Make/Model: Requested Control Efficiency: 95% % Manufacturer Guaranteed Control Efficiency: 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: 0 Form / CD -21 i • Gan \/zn(. FJL .,..ice 'n Permit Number: 18WE0484 AIRS ID Number: 123 / 9FBE / 004 [Leave bi.a.rik.untess A.PCD he_. already assigned permitant! AIRS It 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 Sax NOx CO VOC V0C Burner 95% HAPs V0C Burner 95% Other: From what year is the following reported octual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit ...- . Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mf3-. etc,) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tonslyear) Controlled Emissions (tans/year) -PM — �-63-. Ib/MMSCF .--AP-42 -- 0.00--0 QS__-_ 0.00 .o sox , 0.6 lb/MMSCF AP -42 0.00 0.00 NOx 100/0.068 "...',''',..sA,. AP -42 1.13 1.13 CO 84/0.31 ®:.m,on-ir,,;' AP -42 5.08 5,08 VOC 90.8181 lb/mscf HYSYS/AP42 596.67 29.83 Non -Criteria Reportable Pollutant Emissions inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units ............. Source (AP -42, Mfg., etc.) Uncontrolled Emissions (Founds/year) Controlled Emissions 6 (poundslyear) Benzene 71432 0.5156 Ib/mscf HYSYS 6775.02 338.75 Toluene 108883 0.7408 lb/mscf HYSYS 9733.56 486.68 Ethylbenzene 100414 0.3442 lb/mscf HYSYS 4522.28 226.11 Xylene 1330207 0.4241 lb/mscf HYSYS 5573.04 278.65 n -Hexane 110543 3.5686 Ib/mscf HYSYS 46890.60 2345.15 2,2,4- Trimethylpentane 540841 0.2371 Ib/mscf HYSYS 3114.92 155.75 Other: 5 Requested values will become permit Limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. �PLD._11 GanVeci0 7/2018 51 CLORADC Permit Number: 181/1/E0484 AIRS ID Number: 123 / 9FBE / 004 (Leave blank. urt- - APCD ! a., at a J andAIRS DI p:�rr Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct, Signature of Legally Authorized Person (not a vendor or consultant) Date Shaun Higgins Air Permitting Supervisor Name (please print) Title Check the appropriate box to request a copy of the: o 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-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www.colorado.gov/cdphe/apcd n APCD-21 Gas venting APED Revision 7/201E 6I L1 Hello