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Home My WebLink About20192225.tiffQ,Qy 1 (9/I-7/ G\ COLORADO Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 June 4, 2019 Dear Sir or Madam: RECEIVED I"N I.1 WELD COUNTY COMMISSIONERS On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health >:t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC -PLC -VP), Hk(37), PWCjC- I'CV") LPltt MCI 2019-2225 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 - Weld County Notice Period Begins: June 6, 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: G35 CENTENNIAL STATE ECONODE T4N-R65W-535 L01 Exploration Et Production Well Pad SENE Sec 35 T4N R65W Weld County The proposed project or activity is as follows: This facility -wide permit is for a newly constructed well pad facility located in Weld County. The facility began operation 07/12/2018. The facility -wide permit is for a condensate tanks battery, produced water storage, heater treater and vapor recovery tower, condensate truck load -out and fugitive emissions. The facility is synthetic minor for VOC, benzene, toluene, n -hexane, and total HAPs. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1093 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 ' COLORADO . N.aSth6Enallonro.nt. COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1093 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: Noble Energy, Inc. 1 G35 CENTENNIAL STATE ECONODE T4N-R65W-535 L01 123/A001 SENE SEC 35 T4N R65W Weld County Well Production Facility Equipment or activity subject. to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tanks ' 001 Eighteen (18) 538 bbl tanks for the storage of condensate liquids and two (2) 538 bbl tanks for the storage of off -spec condensate liquids Enclosed Combustion Device Produced Water Storage 002 Four (4) - 500 bbl tanks used for the storage of produced water Enclosed Combustion Device Fugitives 003 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility None Heater TreaterNRT 004 Heater Treater (LP) and Vapor Recovery Tower (VRT) Enclosed Combustion Device Truck Load- Out 005 Truck loadout of condensate by submerged fill 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 Page 1 of 16 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 Condensate Tanks 001 --- --- 20.2 3.1 Point Produced Water Storage 002 --- 3.4 12.0 15.3 Point Page 2 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Fugitives 003 --- --- 1.4 --- Fugitive Heater TreaterNRT 004 --- 1.4 43.1 6.5 Point Truck Load- out 005 --- --- 1.7 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month, a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensate Tanks 001 Enclosed Combustion Device V0C and HAP Produced Water Storage 002 Enclosed Combustion Device V0C and HAP Heater TreaterNRT 004 Emissions from the heater treaterNRT are routed to the same enclosed combustion device V0C and HAP Truck Load- out 005 Enclosed Combustion Device V0C and HAP 8. Point 003: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas and liquids analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. Page 3 of 16 COLORADO Air Pollution Control Division Department of Pubtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 9. 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 Condensate Tanks 001 Condensate Throughput 2,861,201 bbl/year Produced Water Storage 002 Produced Water Throughput 1,835,000 bbl/year Heater TreaterNRT 004 Natural Gas Venting 14.50 MMSCF Truck Load- out 005 Condensate Loaded 286,120 bbl/year 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. 10. Point 004: 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 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Points 001, 002, 004: 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) 13. Points 001, 002, 004: The combustion devices covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall 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; Page 4 of 16 COLORADO Air Pollution Control Division Department of Public Health El Environment 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. 14. Point 001, 002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. Point 001, 002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 16. Point 001: This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: Comply with the recordkeeping, monitoring, reporting requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 17. Point 003: Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. .A.1. Et 4.) 18. Point 003: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. and emission control 19. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection Et Maintenance as described below shall satisfy the requirement to apply RACT. Page 5 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado i. Auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,00O ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened using AVO to determine if the leak is repaired. The following records shall be maintained for a period of two years: The name of the site screened via AVO inspection and the name of the inspector. Components evaluated with the gas detector. Repair methods applied. Dates of the AVO inspections, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post -repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. 20. Point 004: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 21. Point 005: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 22. Point 005: 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. Page 6 of 16 COLORADO Air Pollution Control Division Department of Pubic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. Point 005: 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.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (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. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 24. Point 005: For this controlled loading operation, 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.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING a MAINTENANCE REQUIREMENTS 25. Points 001, 002, 004, 005: 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.) 26. Point 003: This source is not required to follow a Division -approved operating and maintenance plan. Page 7 of 16 COLORADO Air Pollution Control Division Department of Pubx Heath 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 27. Points 001, 002, 004, 005: 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 XII.C, XVII.B.2. and XVII.A.17) 28. Point 003: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples and extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 29. Point 003: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 30. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 31. 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 For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 8 of 16 COLORADO Air Pollution Control Division Department of Pubthc Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 32. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID AIRS Point Equipment Descrip Description P Pollutant Emissions - tons per year Threshold Current Permit Limit Condensate Tanks 001 Eighteen (18) 538 bbl tanks for the storage of condensate liquids and two (2) 538 bbl tanks for the storage of off -spec (specification) condensate liquids . VOC 100 20.2 Produced Water Storage 002 Four (4) - 500 bbl tanks used for the storage of produced water 12.0 Fugitives 003 Equipment leaks (fugitive VOCs) from a natural gas exploration and production facility 1.4 Heater Treater/VRT 004 Heater Treater (LP) and Vapor Recovery Tower (VRT) 43.1 Page 9 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Truck Load -Truck loadout of Out 005 condensate by submerged fill 1.7 GENERAL TERMS AND CONDITIONS 33. 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. 34. 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 iILG. 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. 35. 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. 36. 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. 37. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 38. 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. 39. 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 Page 10 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 11 of 16 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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) Condensate Storage Tanks 001 Benzene 71432 5,211 261 Toluene 108883 9,213 461 Ethylbenzene 100414 186 9 Xylenes 1330207 2,792 140 n -Hexane 110543 37,131 1,857 Produced Water Storage 002 Benzene 71432 12,845 642 n -Hexane 110543 40,370 2,019 Heater Treater/VRT 004 Benzene 71432 12,251 613 Toluene 108883 22,945 1,147 Ethylbenzene 100414 399 20 Xylenes 1330207 7,483 374 n -Hexane 110543 87,872 4,394 Truck Load- Out 005 Benzene 71432 374 19 Toluene 108883 660 33 n -Hexane 110543 2,662 133 Page 12 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068 0.068 AP -42, Chapter 13.5 CO 0.31 0.31 VOC 0.28257 1.41 E-02 Flash Emissions from HYSYS Model based on a pressurized liquid sample taken 8/28/2018 from each well that feeds the process, Working/Breathing Emissions Tanks 4.0.9d Model 71432 Benzene 1.82E-03 9.10E-05 108883 Toluene 3.22E-03 1.61E-04 100414 Ethylbenzene 7.0E-05 3.50E-06 1330207 Xylene 1.0E-03 5.00E-05 110543 n -Hexane 0.01298 6.49E-04 : Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95% and waste gas heat content of 2,830 BTU/scf. Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0680 0.0680 AP -42, Chapter 13.5 CO 0.31 0.31 VOC 0.2620 0.0131 State Approved Emission Factors 71432 Benzene 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 Point 003: Component Gas Service Heavy Oil Light Oil SWater/Oil ervi Service Connectors 3,291 215 1,631 330 Flanges 558 0 353 38 Open-ended Lines 4 0 0 0 Pump Seals 0 0 5 0 Valves 1,962 83 1,442 249 Other* 489 0 197 81 Page 13 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado VOC Content (wt. fraction) 0.4 1.0 1.0 1.0 Benzene Content (wt. fraction) 0.0018 0.0074 0.0074 0.0074 Toluene Content (wt. fraction) 0.0005 0.0023 0.0023 0.0023 Ethylbenzene (wt. fraction) 0.0001 0.0004 0.0004 0.0004 Xylenes Content (wt. fraction) 0.0001 0.0005 0.0005 0.0005 n -hexane Content (wt. fraction) 0.0064 0.0268 0.0268 0.0268 2,2,4 Trimethylpentane (wt. fraction) 0.00 0.00 0.00 0.00 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06' Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E-05 NA 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 198.62 198.62 AP -42, Chapter 13.5 CO 893.79 893.79 VOC 118,846.6 5,942.3 HYSYS Model based on a pressurized 71432 Benzene 845.0 42.25 Page 14 of 16 COLORADO Air Pollution Control Division Department of Public Wealth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source liquid sample taken 8/28/2018 from each well that feeds the process 108883 Toluene 1,582.6 79.13 100414 Ethylbenzene 27.5 1.375 1330207 Xylene 516.1 25.805 110543 n -Hexane 6,061.0 303.05 Note: The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95% and a separator gas heating value of 2871 BTU/scf. Point 005: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 2.80E-04 2.80E-04 AP -42, Chapter 13.5 CO 1.19E-03 1.19E-03 VOC 0.2331 1.17E-02 AP -42, Chapter 5.2, Equation 1* Benzene 71432 0.0013 6.5E-05 HAP Speciation from HYSYS Model* Toluene 108883 0.0023 1.15E 04 n -Hexane 110543 0.0093 4.65E-04 *The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.94 psia M (vapor molecular weight) = 64 lb/lb-mol T (temperature of liquid loaded) = 511 °R **The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP, as determined by the HYSYS tank flash emission speciation, by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 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. Page 15 of 16 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of:• VOC, Benzene, Toluene, n=Hexane, Total HAPs NANSR Synthetic Minor Source of: VOC MACT HH Area Requirements: Not Applicable 10) 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.g0V Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z 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 16 of 16 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Lauraleigh Lakocy 388937 10/12/2018 3/14/2019 Section 01 - Facility Information Company Name: Noble Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range a^� , J Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: A001 G35 CENTENNIAL STATE ECONODE T4N-R6SW-535 LO1 SENE quadrant of Section 35, Township 4N, Range 65W Weld County Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank Condensate Tank Battery 18WE1093 Yes Permit Initial Issuance Point consist of 18 condensate tanks and 2 off - spec 002 Produc. : Water Tank Produced Water Storage 18WE1093 Yes Permit Initial Issuance 003 Fugitive Component Leaks Fugitives 18WE1093 Permit Initial Issuance Separator Venting Heater treater (LP) and vapor recovery tower (VRT) 18WE1093 1 Permit Initial Issuance Liquid Loading Condensate Truck Load -Out 18WE1093 Permit Initial Issuance Section 03 - Description of Project This is a permit application for a facility -wide permit for the newly constructed G35 CENTENNIAL STATE ECONODE 14N-R65W-535 L01 well pad facility located in Weld County. The facility began operation 07/12/2018. The application consists of a condensate tanks battery, produced water storage, heater treater and vapor recovery tower, condensate truck load -out and fugitive emissions. This facility is an affected well -pad facility per NSPS OOOOa, but is not a storage vessel affected facility as the VOC emissions for single storage vessels do not exceed 6 tpy. It is a synthetic minor source for VOC's, benzene, toluene, n -hexane, and total HAPs. 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? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes N 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 502 NOx Is this stationary source a major source? If yes, explain what programs and which pollutants her€ S02 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) --1 CO VOC PM2.5 PM10 TSP HAPs NOx CO u VOC PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 A001 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Eighteen (18) 538 bbl tanks for the storage of condensate liquids and two (2) 538 bbl tanks for the storage of off -spec Description: (specification) condensate liquids Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Enclosed Combustion Device 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 0 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 0 Requested Permit Limit Throughput = 2,861,201 Barrels (bbl) per year Requested Monthly Throughput = 243006 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput Secondary Emissions - Combustion Device(s) Heat content of waste gas = Maximum Gas Burned Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 3,433,441 2830 19.07 Barrels (bbl) per year Btu/scf Mscf/day Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Y4n 0 MMBTU per year 19,698 MMBTU per year 19,698 MMBTU per year Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 2.83E-01 1.41E-02 Site Specific ES. (Includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes €lash) Site Specific ES, (includes flash) Benzene 1.82E-03 9.10E-05 Toluene 3.22E-03 1.61E-04 Ethylbenzene 7.00E-05 3.50E-06 Xylene 1.00E-03 5.00E-05 Site Specific ES. (includes flash) n -Hexane 1.30E-02 6.49E-04 Site Specific E.F. (includes flash) Site Specific ES. (includes flash) 224 TMP 0.00E+00 0.00E+00 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0004 . ,: ..: Table 1A-2 (PM10/PM.2.S: AP -42 Table 1.4-2 (PM10/PIVl.2„5 AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 0.0004 NOx 0.0680 0.0037 CO 0.3100 0.0167 Section 05 - Emissions Inventory ( rntena Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrclled Controlled (tons/year) (tons/year) i Requested Monthly Limits Controlled (lbs/month) VOC 425.1 0.0 0.0 404.2 20.2 3433 PM10 0.1 0.0 0.0 0.1 0.1 12 PM2.5 0.1 0.0 0.0 0.1 0.1 12 NOx 0.7 0.0 0.0 0.7 0.7 114 CO 3.1 0.0 0.0 3.1 3.1 519 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 6249 0 0 5207 260 11056 0 0 9213 461 240 0 0 200 10 3433 0 0 2861 143 44566 0 0 37138 1857 0 0 0 0 0 Section 06 - Regulatory Summa ry Anal}sis Barrels (bbl) per year Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Secticn XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII. B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2of20 K:\PA\2018\18NE1093.CP1 Condeisate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. -4 If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01 Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and Dutlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # SCC Code 01 4-04-003-1? F;Aed roof Talk Cory;ietwattipt voriqrjr br ting+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.01 0 lb/1,000 gallons condensate throughput VOC 6.7 95 lb/1,000 gallons condensate throughput CO 0.05 0 Ib/1,000 gallons condensate throughput Benzene 0.04 95 lb/1,000 gallons condensate throughput Toluene 0.08 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 Ib/1,000 gallons condensate throughput Xylene 0.02 95 lb/1,000 gallons condensate throughput n -Hexane 0.31 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 20 K:\PA\2018\18WE1093.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the NonAttainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TV/ (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. 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 II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulatien 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions g eater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment,'maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compresso station or natural gas dnp station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII.C F Yes Yes Yes Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C.2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? 'Storage Tank is not subject to Regulation 7, Secti on XII.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C1 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII. B, C.1 & C 3 Yes Yes No Yes No Yes Yes Section XVII.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels I. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m1) (-472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ('10,000 BBL] used fer petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.11lb? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"3 as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi] a' d without emissions to the atmosphere (60.11ob(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 (-'950 BBL) and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.11ob(b))?; or c. The design capacity is greater than or equal to 75 M3 ("472 BBL] but less than 151 m3 ('950 BR] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? N.) Source Req Go to next Source Req Continue -' Continue -' Source is st Continue -' Storage Tar Source is st Continue -' Go to then Go to the n Source is st Source is st Go to then Storage Tar Storage Tank is not subject to NSPS K b Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 4.0 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Trans mission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2 between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel" per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Storage Tank is not subject to NSPS OOOO ye, Nis Subpart A, General Provisions per 560.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following _nteria: a. A facility that processes, upgrades or stores hydrocarbon liquids2 (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"3 per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Storage Tank is not subject to MAC HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law. regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act., its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non-mandator/language such as "recommend, - 'may,' "should, " and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminclogy such as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and All Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue-' Storage Tar Continue Storage Tar Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 A001 002 County Plant Foint Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Four (4) - 500 bbl tanks used for the storage of produced water Enclosed Combustion Device 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 0 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 0 Requested Permit Limit Throughput = 1,835,000 Barrels (bbl) per year Requested Monthly Throughput = 155849 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 36 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 2,202,000 Barrels (bbl) per year Btu/scf 0 MMBTU per year 98,826 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 118,591 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water Throughput) (Produced Water Throughput) VOC 0.262 0.01 .duced Water State E.F. (includes flash) - Front :.duced t 'ater State ES. (includes ftas`I - Fs, -.111 Benzene 0.007 0.000 Toluene 0.000 .duced Water State E.F. (includes flash) - Front Ethylbenzene 0.000 Xylene 0.000 n -Hexane 0.001 224 TMP 0.000 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM10 0.0075 0.0004 .-42 Table 1.4-2 (PM1O/P:VI.2.S 42 Table 14-2 (PM10/PM.2,5) -42 Chapter 13.5 Industrial Flares (NOx) -42 Chapter 13.5 Industrial Flares (CO` PM2.5 0.0075 0.0004 NOx 0.0680 0.0037 CO 0.3100 0.0167 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) VOC P M 10 PM2.5 NOx CO 288.5 0.0 0.0 240.4 12.0 2042 0.4 0.0 0.0 0.4 0.4 63 0.4 0.0 0.0 0.4 0.4 63 4.0 0.0 0.0 3.4 3.4 571 18.4 0.0 0.0 15.3 15.3 2602 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 15414 0 0 12845 642 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 48444 0 0 40370 2019 224 TMP 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO (See regulatory applicability worksheet for detailed analysis) 5 of 20 K:\PA\2018\18W E1093.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site spec fic emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. NO Does the company request a control device efficiency greater than 95% for a flare or combustion device? IIass If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Per PS Memo 14-03, Question 5.7, the Division does not have an emissions threshold for requiring facilities to develop site -specific emissions factors for produ ced water tanks. This site used the Division provided produced water heat content and gas -to -water ratio as detailed in PS Memo 14-03. Source is not subject to NSPS Kb as it meets the exception of total volume prior to custody traisfer. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 Ib/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 Ib/1,000 gallons liquid throughput Benzene 0.17 95 Ib/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 Ib/1,000 gallons liquid throughput n -Hexane 0.52 95 Ib/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 6 of 20 K:\PA\2018\18WE 1093.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -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. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or Z0 emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? i',as No Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank1 located at an oil and gas exploration and production operation , well production facility, natural gas compressor station' or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? No Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Err issions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted .vith Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions? from the individual storage vessel greater than or equal to 6 to is per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"1 per 60.5430? Yes No NA N.� Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emssions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per &0.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law. regulation. or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend, "'may. " 'should "and 'can, "is intended to describe APCD interpretations and recommendations Mandatory terminology such as "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 Source Req Go to next Source Req Continue - Continue - Go to the n Source is si Source is si Continue - Storage Tar Colorado Department of Public Health Environment Air Pollution Control Division Preliminary Analysis - Emissions from Fugitive Cornponenets Division Information Engineer: Lauraleigh Lakocy Control Engineer: Review Date: 03/27/2019 Application Date: 10/12/2018 Facility Identifiers Permit No. 18WE1093 AI Rs County # 123 Weld Facility # A001 Point # 003 Facility Equipment ID Fugitives :acility Type: ]gas exploration and production facility Section 01: Administrative Information Potentially located in ozone nonattainment area Company Name: Noble Energy Inc. Source Name: G35 CENTENNIAL STATE ECONOD T4 Source Location: SENE Sec 35 T4N R65W SIC: 1311 Mailing Address City, Address Address State 1: 2: Zip: Noble 1625 Denver, Broadway, Energy CO 80202 Inc. Suite 2200 Person Contact To Phone: Name: Email: Fax: Allison 303-228-4137 Satterfield a.satterfield@nblenergy.com Section 02: Requested Action New Permit Mod to Existing Permit Self Certification Required? Issuance Number: (Section 03: Permit Language Source Description: Natural gas exploration and production facility known as the G35 CENTENNIAL STATE ECONOD T4N-R65W-S35 L01, located in the SENE Sec 35 T4N R65W, Weld County, Colorado. Printed 4/22/2019 Page 8 of 20 Colorado Department of Public Health Environment Air Pollution Control Division Operation (hrs/y 8760 SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Fugitive Component Counts & Emissions The default list of TOC emissions factors are based on Table 2-4 "Average Emissions Factors" of the EPA Protocal for Fugitive Equipment Leaks. If the company qualifies to use Table 2-8 "Less than 10,000 ppmv" emissions factors based on provisions of Regulation 7, Section XVII.F, you must update and manually enter the Table 2 -8 emissions Service Component Type Count TOC EF lb/hr- source TOC EF kg/hr- source Contr of (%) VOC Benzene Toluene Ethylbenzene Xylene n -Hexane Uncontrolle d (tpy) Controlled (tpy) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Uncontrolle d (lb/yr) Controlled (lb/yr) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Gas Valves 1962 5.51E-05 2.50E-05 0.0% 0.19 0.2 1.7 1.7 0.5 0.5 0.1 0.1 0.1 6.1 0.1 6.1 Pump Seals 0 0.00E+00 r 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Others 489 2.65E-04 1.20E-04 0.0% 0.23 0.2 2.0 2.0 0.6 0.6 0.1 0.1 7.3 7.3 0.1 0.1 Connectors 3291 2.20E-05 1.00E-05 0.0% 0.13 0.1 1.1 1.1 0.3 0.3 0.1 0.1 0.1 0.1 4.1 4.1 Flanges 558 1.26E-05 5.70E-06 0.0% 0.01 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.4 0.4 Open-ended line 4 3.31 E-05 1.50E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Light Oil Valves 1442 4.19E-05 1.90E-05 0.0% 0.26 0.3 3.9 3.9 1.2 1.2 2.1 2.1 0.3 0.3 14.2 14.2 Pump Seals 5 1.12E-03 5.10E-04 0.0% 0.02 0.0 0.4 0.4 0.1 0.1 0.2 0.2 0.0 0.0 1.3 1.3 Others 197 2.43E-04 1.10E-04 0.0% 0.21 0.2 3.1 3.1 1.0 1.0 1.7 1.7 0.2 0.2 11.2 11.2 Connectors 1631 2.14E-05 0.70E-06 0.0% 0.15 0.2 2.3 2.3 0.7 0.7 1.2 1.2 0.2 0.2 8.2 8.2 Flanges 353 5.29E-06 2.40E-06 0.0% 0.01 0.0 0.1 0.1 0.0 0.0 0.1 0.1 0.0 0.4 0.4 0.0 Open-ended line 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Heavy Oil Valves 83 1.85E-05 8.40E-06 0.0% 0.01 0.0 0.1 0.1 0.0 0.0 0.1 0.1 0.0 0.0 0.4 0.4 Pump Seals U Others 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 215 1.65E-05 7.50E-06 0.0% 0.02 0.0 0.2 0.2 0.1 0.1 0.1 0.1 0.0 0.0 0.8 0.8 Flanges 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended line 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water/Oil Valves 249 2.14E-05 9.70E-06 0.0% 0.02 0.0 0.3 0.3 0.1 0.1 0.2 0.2 0.0 0.0 1.3 1.3 Pump Seals 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 U.0 0.0 U.0 0.0 Others 81 1.30E-04 5.90E-05 0.0% 0.05 0.0 0.7 0.7 0.2 0.2 0.4 0.4 0.0 0.0 2.5 2.5 Connectors 330 2.20E-05 1.00E-05 0.0% 0.03 0.0 0.5 0.5 0.1 0.1 0.3 0.3 0.0 0.0 1.7 1.7 Flanges 38 6.39E-06 7.90E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 Open-ended line 0 0.00E+00 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 With safety factor: 0.01 Emission Factor Source: EPA -453/R-95-017, Table 2-8 Stream VOC Fraction (wt Gas 0.4000 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 Regulatory Considerations Reg. 3 Reg. 6 Reg. 7 Stream HAP Components (wt fraction HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.002 0.007 0.007 0.007 Toluene 5E-04 0.002 0.002 0.002 Ethylbenzen 1 E-04 0.004 0.004 0.004 Xylene 1E-04 0.001 0.001 0.001 n -Hexane 0.006 0.027 0.027 0.027 0.00 Is this source located in an ozone non -attainment area or attainment maintenance area? Yes If yes, is this source subject to leak detection and repair (LDAR) requirements per Regulation 7, Section XVII.F or XII.G or 40 CFR, Part 60, Subparts KKK or OO Yes If you repond "yes" to the first question and "no" to the second, this source is subject to Regulation 3, Part B, Section 111.0.2, Reasonably Available Control Technology (RACT) requirements and must implemE leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7, Section XVII.F. Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.6 No Did this source commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23 No If you answer "yes" to both questions above, this source is subject to the provisions of 40 CFR, Part 60, Subpart KKK "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Pro Plants" contained in Regulation 6, Part A. Did this source commences construction, reconstruction, or modification after August 23, If you answer "yes" to question #1 and #3 this source is subject to the provisions of 40 CFR, Part 60, Subpart OOOO "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution". Specifically, review subpart 60.5400 for fugitive component leaks and 60.5380 and 60.5385 if the operator reports compressors. It is possible for an onshore natural gas processing plant to have portions of the facility subject to NSPS KKK and portions subject to NSPS OOOO based on the specific dates of construction of those _portions of the facility. If this is the case, the operator will need to report each of those respective fugitive component emissions on separate APENs and obtain unique emissions points from the Division. Is this source located in an ozone non -attainment area or attainment maintenance area? Yes Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.6 No If you answer "yes" to both questions above, this source is subject to the provisions of Regulation 7, Section XII.G regardless of the date of construction Reg. 8 Is this source at a "natural gas processing plant" as defined in 40 CFR, Part 63.761? Ito Is this facility considered a "major source" of HAP as specifically defined in 40 CFR, Part 63.761 for sites that are not prodcution field ft No If you repond "yes" to both questions above, further review if the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply N/A Printed 4/22/2019 Page 9 of 20 Colorado Department of Public Health Environment Air Pollution Control Division Summary of Preliminary Analysis - Fugitive Components Source Company Name Noble Energy Inc. Facility Name G35 CENTENNIAL STATE ECONOD T4N-R65W-S35 L01 Permit No 18WE1093 AIRS 123/A001/003 Permit Engineer Lauraleigh Lakocy Application Date 1 ###ttttt#tt Review Date 3/27/2019 Summary of Emissions VOC (tpy) Benzene (I b/yr) Toluene (l b/yr) Ethylbenzne (I b/yr) Xylenes (I b/yr) n -Hexane (l b/yr) Uncontrolled Requested Emissions 1.3 17 5 7 1 60 1.3 17 5 7 1 60 Controlled Requested Emissions Reportable? No No No No No Total HAP, Uncontrolled (tpy) 0.0 Total HAP, Controlled (tpy) 0.0 Highest HAP, Uncontrolled (tpy) 0.0 n -Hexane Emission Factors Emission Factor Source: Controls Stream VOC Fraction: Gas 0.4000 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 EPA -453/R-95-017, Table 2-8 Control Efficiencies from Table 5-3, quarterly monitoring (EPA -453/R-95-017) Stream HAP Components (wt frac) HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.0018 0.0074 0.0074 0.0074 Toluere 0.0005 0.0023 0.0023 0.0023 Ethylbenze 0.0001 0.0040 0.0040 0.0040 Xylene 0.0001 0.0005 0.0005 0.0005 n -Hexane 0.0064 0.0268 0.0268 0.0268 Comments/Notes: Source estimated the component count and source also estimated the stream HAP components to be conservative based on typical stream values seen in the field. Source will have initial testing requirements to demonstrate compliance with an extended gas and liquids analyses (as these were not submitted as required with APEN) and a hard count of components. Permit condition for applying RACT (per Reg 3, Part B, III. D.2.a) is listed as "Minor sources" because of how the regulation reads. This is the appropriate distinction per the regulation, there are minor and major sources. This source, while denoted as synthetic minor, is included in this "minor source" designation and shall apply RACT. Printed 4/22/2019 Page 10 or 20 Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County A001 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Heater treater (LP) and vapor recovery tower (VRT) Emission Control Device Description: Enclosed Combustion Device (VOC Burner) Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter ! U 4 Gas Vented fres, rneti-.!r is currently instaHt'd and operatinnai Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 0.0 MMscf per year 95 Requested Permit Limit Throughput = 14.5 MMscf per year Requested Monthly Throughput = 1 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: No Is VRU process equipment: 15 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 Description 2871 Btu/scf scf/bbl The source developped a HYSYS model based on 2 -pressurized liquid samples taken 8/28/2018 from each well that feeds the system. The source calculated the emission factors for the heater treater and VRT using the mole % and separator gas heating value of the VRT to provide a conservative estimate of the emissions. MW 51.5 Weight Helium 0.00 CO2 1.02 N2 0.01 methane 2.00 ethane 9.51 propane 24.25 isobutane 9.10 n -butane 22.94 isopentane 7.33 n -pentane 4.97, cyclopentane 0.00 n -Hexane 4.46 cyclohexane 0.00 Other hexanes 6.19 heptanes 4.21 methylcyclohexane 0.00 224-TMP 0.00 Benzene 0.62 Toluene 1.16 Ethylbenzene 0.02 Xylenes 0.37 C8+ Heavies 1.84 Total 100.00 VOC Wt % 87.46 Ib/Ib-mol Displacement Equation Ex=Q"MW*Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (Ib/MMscf) Emission Factor Source (Gas Throughput) (Gas Throughput) VOC 118844.0633 5942.2032 HYSYS Benzene 342.4302 42.1240 HYSYS HYSYS HYSYS HYSYS HYSYS Toluene 1576.2533 78.8127 Ethylbenzene 27.1768 1.3588 Xylene 502.7704 25.1335 n -Hexane 6060.4222 303.0211 224 TMP 0.0000 0.0000 HYSYS Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 21.392 v.? -42 fable 1.4-2 (P!S/114/PM.2.S) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares'(NOx) AP -42 Chapter 13.5 nrdusttlai Flares (CO) ,., PM2.5 0.0075 21.392 SOx 0.0006 1.689 NOx 0.0680 195.228 CO 0.3100 890.010 11 of 20 K:\PA\2018\18WE1093.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emiss ons 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 0.16 0.00 0.00 0.16 0.16 26 0.16 0.00 0.00 0.16 0.16 26 0.01 0.00 0.00 0.01 0.01 2 1.42 0.00 0.00 1.42 1.42 240 861.62 0.00 0.00 861.62 43.08 7318 6.45 0.00 0.00 6.45 6.45 1096 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 12216 0 0 12216 611 Toluene 22856 0 0 22856 1143 Ethylbenzene 394 0 0 394 20 Xylene 7290 0 0 7290 365 n -Hexane 87876 0 0 87876 4394 224 TM P 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section 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? 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 app ication 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. Yes: 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? No 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 rpplication. -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 You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 12 of 20 K:\PA\2018\18W-11093.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes I Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point it 004 Process it SCC Code 01 3-10-001-60 Flares V Uncontrolled Emissions Pollutant Factor Control % Units PM10 21.39 0 lb/MMSCF PM2.5 21.39 0 Ib/MMSCF SOx 1.69 0 Ib/MMSCF NOx 195.23 0 Ib/MMSCF VOC 118844.06 95 lb/MMSCF CO 890.01 0 lb/MMSCF Benzene 842.48 95 lb/MMSCF Toluene 1576.25 95 lb/MMSCF Ethylbenzene 27.18 95 Ib/MMSCF Xylene 502.77 95 lb/MMSCF n -Hexane 6060.42 95 lb/MMSCF 224 TMP 0.00 95 lb/MMSCF 13 of 20 K:\PA\2018\18AA E1093.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -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 TPY or :0 emissions greater than 10 TPY (Regulation 3, Part B, Section II.D3)? Not enough information Yes 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 11.0.2)? Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1 2014? Yes Source is 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 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 the Clean Air Act„ its implementing regulations. and Air Quality Control Commission regulations, the language Df 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. Mandatcry 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 Source Req Source Req Source is si The contro Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading Facility AIRs ID: 123 County A001 Plant 005 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Truck Loadout of Condensate Enclosed Combustion Device Yes 100.0 95 Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 0 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 0 Barrels (bbl) per year Requested Permit Limit Throughput = 286,120 Barrels (bbl) per year Requested Monthly Throughput = 24301 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 343,344 Barrels (bbl) per year 2830 Btu/scf 395284 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46*S*P*M/T 0 MMBTU per year 1,119 MMBTU per year 1,342 MMBTU per year A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0.6 ,*e' AP -42 Chapter S. , ,-4L.:.; P True Vapor Pressure P 5.93769 psia r< True Vapor P:.-..,._ <. ._,._.:I,..,,__;;_:::. Tanks 4.09dRur;::...:�...t 1- M Molecular Weight of Vapors 64 Ib/Ib-mol Determined from Tanks 4.09d Run using RVP 12 T Liquid Temperature 511.4625 Rankine Operating Temperature as Specified by Operator L Loading Losses 5.554602553 lb/1000 gallons Calculated Value 0.233293307 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.0056 0.001306443 Ib/bbl HYSYS Model speciation of HAPs from tank flash emissions Toluene 0.0099 0.002309604 Ib/bbl HYSYS Model speciation of HAPs from tank flash emissions Ethylbenzene 0.0002 4.66587E-05 lb/bbl HYSYS Model speciation of HAPs from tank flash emissions Xylene 0.0057 0.001329772 lb/bbl HYSYS Model speciation of HAPs from tank flash emissions n -Hexane 0.0399 0.009308403 lb/bbl HYSYS Model speciation of HAPs from tank flash emissions 224 TMP 0 0 lb/bbl HYSYS Model speciation of HAPs from tank flash emissions Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 2.33E-01 1.17E-02 Site Specific - AP -42: Chapter 5.2, Equation 1 Benzene 1.31E-03 6.53E-05 Site Specific- AP -42: Chapter 5.2, Equation 1 Toluene 2.31E-03 1.15E-04 Site Specific - AP -42: Chapter 5.2, Equation 1 Ethylbenzene 4.67E -0S 2.33E-06 Site Specific - AP -42: Chapter 5.2, Equation 1 Xylene 1.33E-03 6.65E-05 Site Specific - AP -42: Chapter 5.2, Equation 1 n -Hexane 9.31E-03 4.65E-04 Site Specific - AP -42: Chapter 5,2, Equation 1 Site Specific- AP -42: Chapter 5.2, Equation 1 224 IMP 0.00E+00 0.00E+00 Pollutant Control Device Emssion Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (Ib/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 2.91E-05 AP -42 Table 1.4-2 (P1(110/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (50x) AP -42 Chapter 135 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 2.91E-05 SOx 0.0006 2.30E-06 NOx 0.0680 2.66E-04 CO 0.3100 1.21E-03 15 of 20 K:\PA\2018\18WE1093.CP1 Hycrocarbon Loadout 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 (Ibs/month) P M 10 PM2.5 SOx NOx VOC 0.01 0.00 0.00 0.00 0.00 1 0.01 0.00 0.00 0.00 0.00 1 0.00 0.00 0.00 0.00 0.00 0 0.05 0.00 0.00 0.04 0.04 6 40.05 0.00 0.00 33.37 1.67 283 CO 0.21 0.00 0.00 0.17 0.17 29 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 449 u 0 374 19 Toluene 793 0 0 661 33 Ethylbenzene 16 0 0 13 1 Xylene 457 0 0 380 19 n -Hexane 3196 0 0 2663 133 224 IMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? No If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes The HAP speciation was based on the tank flash emission speciation. The source submitted a stabilized liquid sample analysis. Using the speciati on directly from that analysis results in more conservative HAP emissions; however, using a calculation based on partial pressures based on the stable oil sample analysis, the speciation submitted on the APEN is more conservative than that estimation, so the method requested by the source is accepted and no initial testing requirements for this point are required. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 Ib/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.03 95 lb/1,000 gallons transferred Toluene 0.05 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 Ib/1,000 gallons transferred Xylene 0.03 95 lb/1,000 gallons transferred n -Hexane 0.22 95 lb/1,000 gallons transferred 224 TMP 0.00 95 Ib/1,000 gallons transferred 16 of 20 K:\PA\2018\18.WE1093.CP1 Hydrocarbon loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -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. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Pan B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs} of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emiss)ons from any criteria pollutants from this individual source greater 0 -an 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallor s (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility 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)? Source requires a permit Yes No No No Yes 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Yes The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a parAcular 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 enfoneable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as -recommend," 'may, " "should," and 'can," is intended to describe APCD interpretations and recommendations. Mandahry 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 Go to next Go to the n Go to next Go to next Go to next The loadou The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy Inc County AIRS ID 123 Plant AIRS ID A001 Facility Name G35 CENTENNIAL STATE ECO History File Edit Date 4/22/2019 Ozone Status Non -Attainment ODE T4N-R65W-S35 L01 EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year . POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC VOC Fug 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 Jew Facility - No Previous 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 Previous Permitted Facility total 001 18WE1093 Condensate Tanks (18 + 2 off- 0.8 404.3 2.1 27.3 0.8 20.2 2.1 1.5 Newly requested emission point 002 18WE1093 Produced Water Tanks (4)-500 0.4 0.4 3.4 240.4 15.3 26.6 0.4 0.4 3.4 12.0 15.3 1.3 Newly requested emission point ,003 18WE1093 Fugitives 1.4 0.0 1.4 0.0 Newly requested emission point 004 18WE1093 Heater TreaterNRT 0.0 0.0 1.4 861.5 6.5 65.5 0.0 0.0 1.4 43.1 6.5 3.3 Newly requested emission point 005 18WE1093 Condensate Truck Load -Out 33.4 2.0 1.7 0.1 Newly requested emission point 0.0 0.0 APPEN Exempt/Insignificant 0.0 0.0 Heater Treater 0.1 0.1 0.7 0.0 0.6 0.0 0.1 0.1 0.7 0.0 0.6 0.0 Prom Form APCD-102 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.5 0.5 0.0 0.0 6.3 1,539.6 1.4 24.5 121.4 0.5 0.5 0.0 0.0 6.3 77.0 1.4 24.5 6.2 IOC: Syn NOx: True CO: True Minor HAPS: Syn Hexane, Total) Minor Minor (PSD Minor (NANSR (NANSR (Benzene, and and and OP) Toluene, OP) OP) n - Permitted Facility Total 0.5 0.5 0.0 0.0 6.3 1,539.6 1.4 24.5 121.4 0.51 0.5 0.01 0.0 1 6.3 77.0 1.41 24.51 6.2 Excludes units exempt from (A) Change in Permitted Emissions 0.5 0.5 0.0 0.0 6.3 77.0 1.4 24.5 Pubcorn required because project emissions/synthetic minor limis. Modeling not required based on division guidelines. Total VOC Faci ity Emissions (point and fugitive 78.4 Facility is eligible for GP02 because < 90 "A) Change in Total Permitted VOC emissions (point and fugitive 78.4 Project emissions greater than 25 tpy Note 1 Note 2 Page 18 of 20 Printed 4/22/2019 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 A001 Facility Name G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) IPreviousFACILITYTOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1093 Condensate Tanks (18 + 2 off -spec tanks) 5211 9213 186 2792 37131 0 27.3 002 18WE1093 Produced Water Tanks (4)-500 bbl 12845 40370 26.6 003 18WE1093 Fugitives 0.0 004 18WE1093 Heater Treater/VRT 12251 22945 399 7483 I 87872 0 65.5 005 18WE1093 Condensate Truck Load -Out 374 661 380 2663 0 2.0 0.0 APPEN Exempt/Insignificant 0.0 Heater Treater I 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 15.3 16.4 0.3 5.3 84.0 0.0 0.0 0.0 0.0 121.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes McOH TOTAL (tPY) n -Hexane 224 TMP H2S !Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0.0 0 0 0 001 18WE1093 Condensate Tanks (18 + 2 off -spec tanks) 261 461 _ 140 1857 1.5 '-I 002 18WE1093 Produced Water Tanks (4)-500 bbl 642 2019 1.3 003 18WE1093 Fugitives 0.0 004 18WE1093 Heater Treater/VRT 613 1147 20 374 4394 3.3 005 18WE1093 Condensate Truck Load -Out 19 33 r 19 133 0.1 0 0.0 APPEN Exempt/Insignificant 0.0 [Heater Treater 0.0 19 18WE1093.CP1 4/22/2019 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 A001 Facility Name G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.8 0.8 0.1 0.3 4.2 0.0 0.0 0.0 0.0 6.2 20 18WE1093.CP1 4/22/2019 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AR 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 tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 'SUE (,G}'3 AIRS ID Number: /23 �4el�1 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 Site Location: SENE SEC35 T4N R64W - R6sty Be -C. le /Is!«a Mailing Address: (include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388931 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 'COLORADO 1 I M. _ of Putbc b Health E £mi Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action • NEW permit OR newly -reported emission source a Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 8 Notes: This point includes 18 condensate tanks and 2 off -spec condensate tanks. Oil that is rejected from the condensate tanks is sent to the off -spec tank, which is then returned to the heater treater. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate Tanks 07/15/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: El Exploration & Production (E&P) site weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? MI Yes ■ No Are Flash Emissions anticipated from these storage tanks? 19 Yes IN No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? • Yes O No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • D Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIN emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 • oewn� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual. Annual Amount (bbl %year) Requested Annual Permit Limits' (bb!/year) Condensate Throughput: From what year is the actual annual amount? Average API gravity of sales oil: 61.10 degrees ❑ Internal floating roof Tank design: Q Fixed roof 2,861,201 RVP of sales oil: 89(Ran tanks at 12) 0 External floating roof Storage, Tank ID # of Liquid Manifold Storage' Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production_j (month/year).-' 18 9684 7/2018 2 1076 7/2018 API Number Wells Serviced by this Storage Tank or Tank Battery6 (ErtP Sites Only) Name of Well Newly Reported Well SEE ATTACHED 0 0 0 0 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.269, -104.6223 Operator Stack ID No. > Discharge Height Above Ground Level (feet) Temp. (°F) i Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) El Upward O Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular ❑ Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ;COLORADO 3I AV ,nc� kaatlh E£mvnnm.nt Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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: Vapor O Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion ✓ Device: Pollutants Controlled: Rating: Type: Enclosed Burner MMBtu/hr Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 95 % Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 4 psig Describe the separation process between the well and the storage tanks: Liquids go from well to HP separators, then to LP separators (heater treaters), then to a vapor recovery tower, then to storage tanks, then to a LACT. Off -spec oil is sent to an off spec oil tank and returned to the heater treater. The pilot emissions from burners associated with condensate and water tanks and load -out are accounted for in heater treater and vapor recovery tower calculations (shared burners). Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 I COLORADO 4 Ay c—p.hus fiuhb bEnvvenm.nl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the • YC1 U.. .,i ..,,...,,..._.., Pollutant ---_ — ...WI iv.. vs ,i • ••.,....“...., ,,_.----•—••,- Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95% NOx CO HAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? VOC Criteria Pollutant Emissions Inventory Emission Factor? Uncontrolled Basis •8.3843 lb/bbl Actual Annual Emissions, Requested Annual Perm_ it_ Emission Limit(s)5 Source (AP -42, Mfg. etc) HYSYS/ranks 4.0.9d Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions (Tons/year) 404.25 Controlled Emissions (Tons/year) 20.21 NOx Co 4903° bffb-uee AR�2 RP-�12 0.00 0.81 O. 0.0099• 1Ib/Ib VOC +I CDPHE 0.00 2.06 3. lb I- _ _ __ Non Criteria ReportableFollutant Emissions Inyentoiy-. - Chemical Name _, Chemical Abstract (CAS) Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled; 1` - -Units- { Source - , (AP -42, Uncontrolled = Emissions (Pounds/year) Controlled Emissions s (Pounds/year) Basis Mfg. etc) Benzene 71432 0.00182 lb/bbl HYSYS/ranks4.0.9d 5211.33 260.57 Toluene 108883 0.00322 lb/bbl HYSYS/ranks4.0.9d 9212.89 460.64 Ethylbenzene 100414 0.00007 lb/bbl HYSYS/Tanks4.0.9d 186.12 260.57 Xylene 1330207 O' 3 C , -6:90010- lb/bbl HYSYS/ranks4.0.9d 2791.78 139.59 n -Hexane 110543 0.01298 lb/bbl HYSYS/ranks4.0.9d 37130.74 1856.54 2'2'4 Trimethylpentane 540841 0.0000 Ib/bbl HYSYSrranks4.0.9d 0.00 0.00 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. rentLi neck 7 mu) mRa.k 9 3I2o12C19. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5I A. Department COLORADO flea Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will beperated in full compliance with each condition of the applicable General Permit. 10/12/2018 Signature of Le ally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6I A. I COLORADO ue,w, E&i�OonnPails1 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID ISIA) E (013 Number: 12-3 /1‘00 1 ' 0O2, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy Inc. Site Name: G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 Site Location: SENE SEC35 T4N 4G4W • R45 Site Location County: Weld $cc to/rg/c c per L.167(4 NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Phone Number: E -Mail Address2: Allison Satterfield 303-228-4137 a.satterfield@nbienergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388932 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I mVF! '°'�nu7,="' n enaon..m !COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source El Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 o Change permit limit 0 Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft 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: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 7/15/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week El Exploration Et Production (E&P) site 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ■ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No U MI Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ■ Yes MI No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualISI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 cO LORADO 2IA- FULLh EEnavnimsnl ❑✓ Upward O Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Produced Water Throughput: From what year is the actual annual amount? Tank design: ❑✓ Fixed roof N/A O Internal floating roof Requested Annual Permit Limits (bbl/year) 1,835,000 O External floating roof -- Storage - Total Volume of Storage Tank bbO - Installation Date of Most ' Recent Storage Vessel to l Date_ of First Production," (month/ ear — n ------------- # of Liss - d ---- Manifold TankStorage: Vessels in Storage Tank Tank I - Storage Tank (month/year) ? 4 2000 7/2018 Wells Serviced by this Storage Tank or. Tank.Battery6 (EB P Sites On 111 API Number Name of Well Newly Reported Welh SEE ATTACHED 5 Requested values will become permit limitations. Requested Limit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates _ _ _ _ (LatitudeILongitude or UTM) rT 40.269, -104.6223 Operator Stack ID No. Discharge Height Above , Temp. (°F) Flow Rate (ACFM) Velocity Ground Level (feet) - (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): El Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 3 1 A.;`, hC.si�IihE&�viror Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor 0 Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Burner Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95 95 % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? — 300, 25, 2 psig 41. Describe the separation process between the well and the storage tanks: Liquids from wells go to HP separators, LP separators (heater treaters), and vapor recovery tower and all feed into the produced water storage tanks. The pilot emissions from burners associated with condensate and water tanks and load -out are accounted for in heater treater and vapor recovery tower calculations (shared burners). Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO of PcbUc pn oi 1ad*on5 ,Cia, 312O11q• -LL-0.4°D VOC Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Description of Control Method(s) Overall, Requested Control Efficiency I% reduction in emissions) Enclosed Burner 95% NOx CO HAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant , Uncontrolled Basis 0.2620 lb/bbl CDPHE Source (AP 42, Mfg., etc.), Actual Annual Emissions Requested Annual Permit Emission Limrt(s)5 Uncontrolled Emissions (tons/year) Controlled` Emissions 8- -(tons/year) Uncontrolled Emissions 4 (tons/year) Controlled r' Emissions (tons/year) VOC NOx CO 60 9:9e3� o •C1billa-k , -R 0.0094 O 31 Ib/fb VOC 10-42 CDP44g prp_k? 240;39 0.00 0.00 12.02 -s 44 . Chemical Name Benzene Non -Criteria Reportable Pollutant Emissions Inventory - === Chemical Abstract Service (CAS) `Number 71432 Emission Factor Uncontrolled Basis 0.007 Units lb/bbl Source (AP -42, Mfg., etc.) CDPHE Actual Annual Emissions Uncontrolled Emissions (pounds/year) 12,845.00 Controlled Emissions8 (pounds/year) 642.25 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbl CDPHE 40, 370.00 2018.50 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 3.3(0 15.32 Form APCD-207 - Produced Water Storage Tank(sj APEN - Revision 7/2018 wCOLORADO 5 1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in fu compliance with each condition of the applicable General Permit. L Signature of Legally Authorized Allison Satterfield 10/12/2018 Berson (not a vendor or consultant) Date Environmental Scientist Name (print) Title Check the appropriate box to request a copy of the: Q Draft permit prior to issuance �r Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 © COLORADO 6 I m.- r"...aultErEnvttt Fugitive Component Leak Emissions APEN _ = ry Form APCD-203 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 fugitive component leak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/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: IgkEI0c13 AIRS ID Number: 123 'Am) 1603 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 ocation Site Location: SENE SEC35 T4N R6' R,SW Site County: 13C.e.- it. It e/ l 8 rev La -I1 NAICS or SIC Code: Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Weld 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388933 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 � COLORADO 1 I m@�'' i«�Erufrnnnrn:o«� l;wM46„ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) -OR- ❑ MODIFICATION to existing permit (check each box below that applies) El Change process or equipment El Change company name3 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source o Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t 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 Company equipment Identification No. (optional): For existing sources, operation began on: Fugitives 7/15/2018 For new or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ❑✓ Well Production Facility5 0 Natural Gas Compressor Stations 0 Natural Gas Processing Plants ❑ Other (describe): hours/day days/week weeks/year 5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 2 I AV,!` °`"°13`` h 1h �ProWfm+. Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 4 - Regulatory Information What is the date that the equipment commenced construction? Will this equipment be operated in any NAAQS nonattainment area? Will this equipment be located at a stationary source that is considered a Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? Is this equipment subject to 40 CFR Part 60, Subpart 0000? Is this equipment subject to 40 CFR Part 60, Subpart 0000a? Is this equipment subject to 40 CFR Part 63, Subpart HH? Is this equipment subject to Colorado Regulation No. 7, Section XII.G? Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? 7/15/2018 ❑✓ Yes o Yes p Yes ❑ Yes ❑ Yes ❑✓ Yes o Yes o Yes ❑✓ Yes ❑✓ Yes ❑ No ❑✓ No ❑ No ❑✓ No ❑✓ No ❑ No ❑✓ No ❑✓ No ❑ No ❑ No Section 5 - Stream Constituents ❑ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. V0C ! -- i (wt %) ; , Benzene_ (wt %) i Toluene- (wt %) Ethylbenzene (wt %) Xylene (wt %) , n -Hexane. (wt %) - 2'2'4 Stream Trimethylpentane (wt %) Gas 40.00 0.18 0.05 0.01 0.01 0.64 0.00 Heavy Oil (or Heavy Liquid) 100 0.74 0.23 0.04 0.05 2.68 0.00 Light Oil (or Light Liquid) 100 0.74 0.23 0.04 0.05 2.68 0.00 Water/Oil 100 0.74 0.23 0.04 0.05 2.68 0.00 Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.269, -104.6223 Attach a topographic site map showing location Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 AV [COLORADO FULLI;_ En�n.ervruei Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: O No LDAR Program 6 Attach other supplemental plan to APEN form if needed. aa _ COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 4 I m. °`°$""`°`"`° ` HvaIU:EEnvGtnn+ael oili ntd Pp^ >r„p°n`H-151^u- _ k_ ° 11 Gas Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. 0 Table 2-4 was used to estimate emissions. ❑✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: O Estimated Component Count o Actual Component Count conducted on the following date: Equipment Type Flanges._ Open -Ended Lines Pump Seals. 1962 Valves 489 Counts 3291 558 1O.269, 104.6223 0 Emission Factor 1.00E-5 5.70E-6 1.5E-5 2.50E-5 1.20E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Heavy Oil= (or Heavy Liquid) Count8 215 0 0 0 83 0 Emission Factor 7.50E-6 8.40E-6 Units kg/hr/source kg/hr/source Light Oil (or Light Liquid) _ Counts 1631 353 0 5 1442 197 Emission Factor 9.70E-6 2.4E-6 5.10E-4 1.90E-5 1.10E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Water/Oil, Counts 330 38 0 0 249 81 Emission Factor 1.00E-5 2.90E-6 9.70E-6 5.90E-5 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 5 I t er.r. orron:ro Fwuh Efifaieunme.�f Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: ulate these emissions Chemical Name CAS' Number, I - Actual Annual Emissions Requested Annual Permit Em_ission LLGmit(s)- : Uncontrolled : Controlled10 . Uncontrolled (tons/year) , Controlled ! (tons/year) • (tons/year) i (tons/year) VOC 1.35 1.35 Does the emissions source have any actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ❑✓ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Requested Annual Permit Emission Limit(s)11 Chemical Name Benzene CAS Number 71432 Actual Annual Emissions Uncontrolled (lbs%year) Controlled10 Ohs/year) Uncontrolled_ (Ibs/year) Controlled (lbs/year) Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 COLORADO 6 I AV �" ° Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/12/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (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: 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.Rov/cdphe/apcd Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 7I AY COLORADO C,paf mtnX of Putac 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-2O0) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.aov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of 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: ISIVElt>33 AIRS ID Number: iZ3 /,.9/ OD Lt [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy Inc. Site Name: G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 Site Location Site Location: SENE SEC35 T4N R64W— ,.c IW County: /II i t Y t.trf.?" /Lee NAICS or SIC Code: Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Weld 1311 Denver, CO 80202 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388934 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I AV !COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: streams Heater treater (LP) and vapor recovery tower (VRT) Company equipment Identification No. (optional): For existing sources, operation began on: 7/15/2018 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year 0 Yes 0 Yes 0 Yes ❑ No ❑✓ No ❑ No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I AV COLORADO L' n, ofPut c Hkulu.= &:vvvruwn Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information El Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: El Yes 0 No Vent Gas Heating Value: 2878 BTU/SCF Requested: 14.50 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 51.50 VOC (Weight %) 87.46% Benzene (Weight %) 0.62% Toluene (Weight %) 1.16% Ethylbenzene (Weight %) 0.02% Xylene (Weight %) 0.38% n -Hexane (Weight %) 4.46% 2,2,4-Trimethylpentane (Weight %) 0.00% Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach 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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 'AV COLORADO Cam: of Yu Hw.....vffnnlxnf 0 Upward ❑ Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.269, -104.6223 Discharge Height" = " ' Operator Temp I ( F) Flow Rate t - (ACFM) Velocity;. Above Mound Level ~ Stack ID No _ (ftlsec) i (Feet) ' Indicate the direction of the stack outlet: (check one) O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) O Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: MMBtu/hr Type: VOC Burner Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 I COLORADO 4IA' !=Tr FULY.6 Er.�irenmu�l Benzene Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): PM Overall Requested Control Efficiency (% reduction in emissions) SOX 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 Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit _,_ Emission .Limit(s)5,_ Uncontrolled Basis Ib/MMscf :i Source (AP -42 Uncontrolled Emissions (torts/year) Controlled Emissions6 (tons/year)- Uncontrolled _ .r Emissions (tons/year) ontrolled • Emissions =� (tons/year) PM 7.6 AP -42 0.00 0.00 SOx 0.6 lb/MMscf AP -42 0.00 0.00 NO. 0.1957, 0.1 lb/Mscf HYSYS, AP -42 1.44 - 1.44 CO 0.8921, 0.084 lb/Mscf HYSYS, AP -42 6.48 6.48 VOC 118.8466, 0.0055 lb/Mscf HYSYS, AP -42 861.51 43.08 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis lb/Mscf Source (AP -42 Mfg., etc.) Uncontrolled Emissions (pounds/year) _ Controlled Emissions6 (pounds/year) 71432 0.8450 HYSYS/AP-42 12250.67 612.53 Toluene 108883 1.5826 lb/Mscf HYSYS/AP-42 22944.68 1147.23 Ethylbenzene 100414 0.0275 lb/Mscf HYSYS/AP-42 399.43 19.97 Xylene 1330207 0.5161 lb/Mscf HYSYS/AP-42 7483.33 374.17 n -Hexane 110543 6.0610 lb/Mscf HYSYS/AP-42 87872.37 4394.24 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 AVCOLORADO 5 I m, :,moEFr.o Fa,Yh �urnmeni Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/12/2018 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: 0 Draft permit prior to issuance 0 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.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 AV ,COLORADO 6 I .. r Nng Pnn� Fe.i•F E Envinenewnl Hydrocarbon Liquid Loading AP7EN„, Form APCD-208 Air Pollutant Emission Notice (APEN) and r-..6% CY 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 hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/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: / SUE/093 AIRS ID Number: 1Z3 /AO J / 60 -5 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy Inc. Site Name; G35 CENTENNIAL STATE ECONODE T4N-R65W-S35 L01 Site Location: Site Location SENE SEC35 T4N -Res-iii/ County: Weld 13CC-It. 4l S/I K Pav L +/i'1r7nq NXICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 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. 388935 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 1 I AV Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 9 NEW permit OR newly -reported emission source 0 Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 o Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: NOx and CO emissions are accounted for in condensate tank calculation because there are shared burners. 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: Truck load -out of condensate Company equipment Identification No. (optional): For existing sources, operation began on: 7/12/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? MI Yes I No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • 13 Does this source load gasoline into transport vehicles? ■ Yes MI No Is this source located at an oil and gas exploration and production site? Yes No l9 ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • Does this source splash fill less than 6750 bbl of condensate per year? Yes No MI ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ O Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 2 ern,�v�wes� .- �He.itl�_Errobenmu:f Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 9 Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 286,120 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 517925 . °F True Vapor Pressure: 5.93769 Psia @ 60 °F Molecular weight of displaced vapors: 6 ^ `F lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3 /truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I '1COLORADO .,�� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.269, -104.6223 pe O rator �. Discharge Height Above - Ground Level . Velocity Temp Flow Rate Stack ID No. ( F) �FM) (ft/sec) (feet) Indicate the direction of the stack outlet: (check one) ▪ Upward O Horizontal o Downward o Other (describe): Indicate the stack opening and size: (check one) El Circular O Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Burner Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 COLORADO un„ma.= of e=rs° Health zEnvi Ine. PM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Description of Control Method(s) Overall Requested Control Efficiency (%—reduction in emissions) SOX NO. CO VOC Enclosed Burner 95% HAPs Enclosed Burner 95% Other: ❑ Using State Emission Factors (Required for GP07) ❑ Condensate ❑ Crude VOC 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene 0.00041 Lbs/BBL 0.00018 Lbs/BBL n -Hexane 0.0036 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant; Source (AP -42, Mfg., etc.) Uncontrolled €- Emissions (tons/year) ontrolled eq_• nested Annual' Permit_ Emission Limit(s)5 Uncontrolled; Basis Units missions" I'I (tons/year) Jncontrolied Emissions . (tons/year) Controlled- Emissions`;. T" - (tons/year) PM SOX NOx CO VOC 0.2331 lb/bbl AP -42 33.35 1.67 Benzene Chemical Name .; Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS)' Number Emission Factor Actual Annual Emissions Uncontrolled Basis lb/bbl Source (AP -42, Mfg., etc.) Uncontrolled Emissions (Pounds/year) _ Controlled Emissions6 (pounds/year) 71432 0.0013 AP -42 374 19 Toluene 108883 0.0023 lb/bbl AP -42 660 33 Ethylbenzene Xylene 100414 1330207 n -Hexane 110543 0.0093 lb/bbl AP -42 2662 133 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 51 AV COLORADO Department «Pot Hea._Envimmne l Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for c verage under General Permit GP07, I further certify that this source is and will be operated in full omp[lance with�ach condition of General Permit GP07. 10/12/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 � COLORADO 6 I & of ntiic HwYl.tr&fviwnme. Hello