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Home My WebLink About20192220.tiffPub\c P-\eMJ COII 1/I'i COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 May 30, 2019 Dear Sir or Madam: RECEIVED JUN Q 5 20;9 WELD TY COMMISSIONERS N On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Shoemaker T6N-R64W-S12 L02. 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 Wotk, MD, MSPH, Executive Director and Chief Medical Officer t. pLc-cf) tAtfrc) c(JMl Ict'1Ic;") Ci/itltc1 �F • Cq� it -77 h( 1.---z7 ..o; 2019-2220 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Shoemaker T6N-R64W-S12 L02 - 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: Shoemaker T6N-R64W-S12 L02 Oil and Gas Exploration and Production Facility NESE SEC12 T6N R64W Weld County The proposed project or activity is as follows: Separation Equipment The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0101 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.wv/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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO •r ums eminnnmet. Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Timothy Sharp 357721 1/25/2017 3/21/2017 Section 01 - Facility Information Company Name: County AIRS ID: Noble Energy Inc Quadrant Section Township Range 123 `Weld I NESE 12 6N 64w Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application 9920 Shoemaker T6N-R64W-512 L02 NESE quadrant of Section 12, Township 6N, Range 64wW, in Weld County, Colorado Exploration & Production Well Pad Oil & Natural Gas Production & Processing Yes ❑ Particulate Matter (PM) IN Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Separator Venting P Separator 7WEOI! 1 Permit Initial Issuance • Section 03 - Description of Project Installation of VRT due to engine cancellation at syn-minor facility. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Colorado Air Permitting Project Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes 5O2 NOx CO ❑ ❑ ❑ ❑ n ❑ El N ;a, VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ ❑ el I SO2 NOx CO VOC PM2.5 PM10 TSP ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ I HAPs Separator Venting Emissions Inventory Separator Venting Facility AIRs ID: - County 9920 Plant 007 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: LP Separator Venting ECD Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 9.2 MMscf per year 95 Requested Permit Limit Throughput = 9.2 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: 9 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 1986 Description Aspen Hysis model used to evaluate emisisons. MW Ib/Ib-mol Displacement Equation Ex = Q * MW * Xx / C Weight % Helium 0.00 CO2 2.75 N2 0.07 methane 11.36 ethane 25.75 propane 33.11 isobutane 6.00 n -butane 15.39 isopentane 2.34 n -pentane 1.84 cyclopentane 0.49 n -Hexane 0.35 cyclohexane 0.00 Other hexanes C heptanes 0.24 methylcyclohexane 0.00 224-TMP 0.03 Benzene 0.05 Toluene 0.04 Ethylbenzene 0.00 Xylenes 0.01 C8+ Heavies 0.18 Total 100.00 VOCWt% 60.0% Btu/scf scf/bbl Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 56186.8470 2809.3423 i `; `r > Benzene 46.7678 2.3384 Toluene 37.4142 1.8707 Ethylbenzene 0.0000 0.0000 Xylene 9.3536 0.4677 n -Hexane 327.3747 16.3687 224 TMP 28.0607 1.4030 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 10 0.000 PM2.5 0.000 SOx 0.000 NOx 135.048 f K:\PA\2017\17WE0101.CP1:xlsm Separator Venting Emissions Inventory I CO 1 0.3100 j 615.660 AP -42 Chapter 133 Industrial Flares (CO) 4 of 6 K:\PA\2017\17WE0101.CP1.xIsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.62 0.62 0.62 0.62 0.62 106 258.46 258.46 12.92 258.46 12.92 2195 2.83 2.83 2.83 2.83 2.83 481 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) 2.15E-01 1.72E-01 0.00E+00 4.30E-02 1.51E+00 1.29E-01 Benzene Toluene Ethylbenzene 430 430 22 430 22 344 344 17 344 17 0 0 0 0 0 Xylene n -Hexane 86 86 4 86 4 3012 3012 151 3012 151 224 TMP 258 258 13 258 13 Section 06 - Regulatory Summary Analysis 1.08E-02 8.61E-03 0.00E+00 2.15E-03 7.53E-02 6.45 E-03 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 XVll.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? Yes This sample should represent the gas outlet of the equipment covered under this AIRs ID, and sh )uld have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas, sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment oeing permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? No 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 combustioh 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 You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 5 of 6 K:\PA\2O17\17WE0101.CP1.xlsm Sepa-ator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 3-10-001-60 Flares Pollutant PM10 PM2.5 SOx NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.00 135.05 56186.85 615.66 46.77 37.41 0.00 9.35 327.37 28.06 Control % Units 0 Ib/MMSCF 0 Ib/MMSCF 0 Ib/MMSCF 0 Ib/MMSCF 95 lb/MMSCF 0 Ib/MMSCF 95 Ib/MMSCF 95 Ib/MMSCF 95 lb/MMSCF 95 Ib/MMSCF 95 lb/MMSCF 95 Ib/MMSCF 6 of 6 K:\PA\2017\17WE0101.CP1.xlsm Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health £t Environment CONSTRUCTION PERMIT 17WE0101 DRAFT Noble Energy, Inc Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Shoemaker T6N-R64W-S12 L02 123/9920 NESE SEC12 T6N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Separator 007 Low Pressure Separator Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution PreVention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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/pacific/cdphe/other-air-permitting- notices. 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/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Departtrrrtt of Public Heals & Environment Page 1 of 8 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) estimated in the permit application. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO LP Separator 007 --- 1.0 13.0 2.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria 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. 8. 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 LP Separator 007 Emissions from the Separator are routed to an Enclosed Flare VOC and HAP CDPHE COLORADO Air Pollution Control Division Department of Public Health Et Environment Page 2 of 8 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 LP Separator 007 Natural Gas Venting 9.2 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Upon installation of the flow meter, 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. 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) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 15. 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. COLORADO Air Pollution Control Division Department. of Publtc Health & Environment Page 3 of 8 OPERATING & MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping formatapproved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal COLORADO Air Pollution Control Division Departrrent of Public Health & Elwonment. Page 4 of 8 program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. 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. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. 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. 24. 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. 25. 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. 26. 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. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer COPHE COLORADO Air Pollution Control Division Department of Public Heath & Environment Page 5 of 8 Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. at a synthetic -minor facility. COLORADO Mr Pollution Control Division Department of Public Health & Environment Page 6 of 8 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 (tPY) Controlled Emissions (tPY) LP Separator 007 Benzene 71432 2.15E-01 1.08E-02 Toluene 108883 1.72E-01 8.61E-03 n -Hexane 110543 1.51E+00 7.53E-02 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons per year (tpy) 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 007: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Source NOx 3.70E-03 lb/lb- VOC AP 42 CO 9.40E-03 lb/lb- VOC AP -42 VOC 56,186 Source (Promax/HYSYS) 71432 Benzene 46.76 Source (Promax/HYSYS) 108883 Toluene 37.41 Source (Promax/HYSYS) 110543 n -Hexane 327.37 Source (Promax/HYSYS) Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division Department of Publte health & Environment Page 7 of 8 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD or NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix 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 COyyPHE C.l COLORADO Air Pollution Control Division Department of Public Health 5 Enwon neat Page 8 of 8 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Venting' Permit Number: C1 \JE O W U Facility Equipment ID: LP Separator 007 . [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 9920 / FBD- Section 01— Administrative Information Company Name: Noble Energy, Inc. [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Source Name: Shoemaker T6N-R64W-S12 L02 Source Location: NESE SEC12 T6N R64W Mailing Address: 1625 Broadway, Suite 2200 Denver, CO NAICS, or SIC Code: 1311 County: WELD Elevation: 4,600 Feet ZIP Code: 80202 Person To Contact: Gabriela Vega Phone Number: 303-228-4475 E-mail Address: gabriela.vega@nblenergy.com Section 03 — General Information For existing sources, operation began on: Normal Hours of Source Operation: General description of equipment and purpose: LP Separator Fax Number: 303-228-4286 24 hours/day Section 02 — Reuuested Action (check applicable request boxes) Request for NEW permit or newly reported emission source O Request MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name Change permit limit ❑ Transfer of ownership O Other ❑ Request to limit HAPs with a Federally enforceable limit on PTE ❑ Request APEN update only (check the box below that applies) ❑ Revision to actual calendar year emissions for emission inventory Additional Info. & Notes. Update 5 -Year APEN term without change to permit limits or previously reported emissions For new or reconstructed sources, the projected startup date is: 7 days/week 52 weeks/year Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Section 04 — Processing Equinment Information Description of Source2: ❑ Well Head Casing ® Gas/liquid Separator O Pneumatic Pump: ❑ Compressor Rod Packing ❑ Blowdowns: Other: Description: Make: Make: # of events: Model: Model: Volume: ® Yes O No Serial #: Capacity: # of pistons: Leak rate: MMscf/event ❑ Don't know gal./min. Scf/hr/pist. Maximum Vent Rate (scf/hr) Actual Volume (MMscf/yr) Requested Volume3 (MMscf/yr) Vent Gas Heating Value (Btu/scf) Process Parameters: 1050 9.2 1986 Molecular Wt. VOC (mole %) Benzene (mole %) Toulene (mole %) Ethylbenzene (mole %) Xylene (mole %) n -Hexane (mole %) Vented Gas Properties: 35.45 60.07 0.05 0.04 0.01 0.35 ® Submit a representative gas analysis (including BTEX & n -Hexane) to support calculations You will be charged an additional APEN fee if APEN is filled out incorrectly or missing information and requires re -submittal. 'Only one source type may be reported per APEN. 'Requested values will become permit limitations. Requested level shall be a "not to exceed value". Colorado Department of Public Health and Environment Air Pollution Control Division (APCD) This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change, s made (increase production, new equipment, change in fuel type, etc). " Mail this form along with a check for $152.90 to: 40 Colorado Department of Public Health & Environment?,s APCD-SS-B1 4300 Cherry Creek Drive South o "."0T6 '(re• Denver, CO 80246-1530 s For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms:http://www.colorado.gov/cdphe/oilgaspermits Application status:http://www.colorado.gov/cdphe/permitstatus ® Check box to request copy of draft permit prior to issuance. ® Check box to request copy of draft permit prior to public notice. FORM APCD-211 357719 Page 1 of 2 AP Form-APCD-211-Natural-Gas-Venting-APEN (2) AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Natural Gas Ventingl Permit Number: Emission Source AIRS ID: 123 / 9920 / TBD Section 05 — Stack Information (Combustion stacks must be listed here) Operator Stack ID No. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) Direction of stack outlet (check one): ❑ Vertical Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) -104.4908 40.4992 0 Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): 0 Circular: Inner Diameter (inches) = Section 07 — Control Device Information ❑ Horizontal 0 Down 0 Other: Length (inches) = ❑ Other (Describe): Width (inches) = ■ VRU used for control of: /1 Combustion Device used for control of: LP Separator Gas Rating: MMBtu/hr Size: Make/Model: Type: VOC Burner Make/Model/Serial #: Cimmaron Requested VOC & HAP Control Efficiency: % VOC & HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: % Annual time that VRU is bypassed (emissions vented): % Minimum temp. to achieve requested control: °F Waste gas heat content: Btu/scf The VRU recycles venting emissions to: Constant pilot light? • ' Yes ■ No Pilot burner rating: MMBtu/hr ❑ Describe Any Other: V 1 Section 08 — Emissions Inventory Information & Emission Control Information Attach any emission calculations and emission factor documentation to this APEN form. ® Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput above (e.g. 2007): Pollutant Control Device Description Overall Collection Efficiency Control Efficiency (% Reduction) Emission Factor Actual Calendar Year Emissions4 Requested Permitted Emissions Estimation Method or Emission Factor Source Primary Secondary Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) VOC VOC Burner 95% 56.21 lb/Mscf 258.2 12.91 Hysys NOx 3.70e-03 lb/lb-VOC 0.96 0.96 CDPHE CO 9.40e-03 Ib/Ib-VOC 2.43 2.43 CDPHE SOx Benzene VOC Burner 95% 0.048 lb/Mscf 437.39 21.87 Hysys Toulene VOC Burner 95% 0.036 lb/Mscf 326.48 1632 Ethylbenzene t Xylene n -Hexane VOC Burner 95% 0.329 lb/Mscf 3025.98 151.61 Hysys Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. + You will be charged an additional APEN fee if APEN is filled out incorrectly or missing information and requires re -submittal. "Annual emission fees will be based on actual emissions reported here. Section 09 —Applica ' t Certification - I hereby certify that all infor ati n contained herein and information submitted with this application is complete, true and correct. N/A na e of Person Legally Au ci o ' ed to Supply Data e Gabriela Vega Name of Legally Authorized Person (Please print) Title Environmental Engineer III FORM APCD-211 Page 2 of 2 AP Form-APCD-211 Natural-Gas-Venting_APEN (2)- _ - Hello