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Home My WebLink About20193765.tiffa COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 August 13, 2019 Dear Sir or Madam: RECEIVED AUG 1 9 20T WELD COUNTY COMMISSIONERS On August 22, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Wahlert AC33 Econode. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 • Attention: Clara Gonzales Regards, 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.cotorado.gov/cdphe Public Rev euJ ©gl 8g /19 Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director e (7-r ) , ocDC cM ), Pw(M/C HiE.R IC(c) g/zl/i 2019-3765 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Wahlert AC33 Econode - Weld County Notice Period Begins: August 22, 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: Wahlert AC33 Econode Oil and gas production well pad NWSW, Section 33, T7N, R63W Weld County The proposed project or activity is as follows: Applicant is requesting a construction permit to allow for flaring of gas from the low pressure separators at an existing well production facility. Gas is combusted in the enclosed flare(s) when the LP VRU compressor is down. 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 19WE0608 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.Qov/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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 , eel COLORADO Department of Public Health b Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Bradley Eades Package #: 399610 Received Date: 5/16/2019 Review Start Date: 7/17/2019 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Noble Energy, Inc. Wahlert AC33 Econode..: NWSW quadrant of Section 33, Township 7N, Range 63W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application xcxxx x11{{ifg�F 11nk%xkHaK,c�t�ixxx x w `hY'.tY>tHlix% t1! %J1fxYax%SYy4A 1`MA'T. � �%LTX'Y`tz1.YizFat •YT'C1.�.L Particulate Matter (PM) J Quadrant Section Township Range NWSW 33 7N 63 Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 020 Separator Venting LP gas stream Yes 19WE0608 1 Yes Permit Initial Issuance Section 03 - Description of Project Applicant is requesting a construction permit to allow for flaring of gas from the low pressure separators at an existing well production facility. Gas is combusted in the enclosed flare(s) when the LP VRU compressor is down. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement' Yes Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 No Yes NOx CO Is this stationary source a major source? No If yes, explain what programs and which pollutants her€ SO2 NOx CO Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP HAPs VOC PM2.5 PM10 TSP J HAPs Separator Venting Emissions Inventory 020 Separator Venting Facility AIRs ID: 123 County 9959 Plant 020 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Gas venting from low pressure separators to enclosed combustor during VRU downtime. Enclosed Combustor Emission Control Device Description: Requested Overall VOC & HAF Control Efficiency %: Limited Process Parameter Liquid Throughput Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separato- Actual Throughput = 13,127.0 Barrels (bbl) per year 95 Requested Permit Limit Th-oughput = 13,127.0 Barrels (bbl) per year Requested Monthly Throughput = 1115 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yes 13,127 Barrels (bbl) per year .A.0.:. A. ".: �x 2.844164632 Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted oer BBL of liquids throughput: 216.6652421 scf/bbl Section 04 - Emissions Factor! & Methodologies Description 2060 Btu/scf Applicant pulled a pressurized liquid sample in 2012 from the LP separator at 36 psig, 88F. Applicant used ProMax software to estimate the equilibrium gas composition at the LP separator pressure and temperature and the composition of the pressurized liquid to "re -saturate" the liquid stream at the pressure and temperature upstream of the LP separator (250 psig, 90 F). This provides an estimate of the upstream liquid composition which was subsequently modeled in a separate ProMax simulation to estimate the LP gas stream flow and composition, as reflected below: MW 37.1734 Weight % Helium CO2 2.99 N2 0.46 methane 12.89 ethane 20.51 propane 27.73 isobutane 3.40 n -butane 10.07 isopentane 1.81 n -pentane 1.91 cyclopentane 1.74 n -Hexane 4.60 cyclohexane 5.84 Other hexanes heptanes 2.65 methylcyclohexane 0.77 224-TMP 0.18 Benzene 0.78 Toluene 0.42 Ethylbenzene 0.03 Xylenes 0.12 C8+ Heavies 1.29 Total '/OC Wt % Ib/Ib-m of Displacement Equation Ex=Q*MW*Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Liquid Throughput) (Liquid Throughput) VOC 13.4631 0.6732 Benzene 0.1656 0.0083 Toluene 0.0895 0.0045 Ethylbenzene 0.0069 0.0003 Xylene 0.0249 0.0012 n -Hexane 0.9777 0.0489 224 TMP 0.0379 0.0019 2 of 6 K:\PA\2019\19WE0608.CP1.xlsm Separator Venting Emissions Inventory Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 0.003 AP -42 Table 1.4-2 (PM10/PM.2.5) 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 Industrial Flares (CO) PM2.5 0.0075 0.003 SOx 0.0006 0.000 NOx 0.0680 0.030 CO 0.3100 0.138 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 0.02 0.02 0.02 0.02 0.02 4 PM2.5 0.02 0.02 0.02 0.02 0.02 4 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx VOC CO 0.20 0.20 0.20 0.20 0.20 34 88.36 88.36 4.42 88.36 4.42 750 0.91 0.91 0.91 0.91 0.91 154 Hazardous Air Pollutarts Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Uncontrolled (lbs/year) Limits Controlled (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 2174 2174 109 2174 109 1175 1175 59 1175 59 91 91 5 91 5 327 327 16 327 16 12835 12835 642 12835 642 497 497 25 497 25 6 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is not subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered under this AIRs ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample 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. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit wil 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 Applicant used a pressurized liquid analysis of a 2012 sample from the LP separator (36 psig, 88F) at the Wahlert AC33 Econode. Applicant indicates that facility is not currently operational and that this sample was used as best available approach at estimating emissions for purposes of obtaining a construction permit. Upon issuance and startup, applicant indicates that source will agree to pull a pressurized liquid sample from upstream of the LP separator to verify the VOC weight % of the LP gas stream as well as the flash "scf/bbl". This requirement is reflected in initial testing requirements section of the permit. Applicant utilized ProMax prescribed methodology to saturate the known downstream liquid composition at the known upstream pressure and temperature. i was able to closely replicate the results in the submitted simulation using ProMax. This methodology is not generally an approved methodology for this type of simulation (the Division generally requires that a sample is pulled upstream of the emitting equipment). However, I took into consideration that this facility was not operational prior to this application (preventing the ability to pull a new sample from upstream equipment)along with the fact that this is a methology prescribed by BR&E for such a situation. In addition, facility -wide emissions are not such that small variations in flow and/or composition will result in triggering a significant regulatory threshold (e.g. PSD, NNSR, Title V, etc.). As such, I will approve the proposed methodology under the condition that the emission rates are confirmed using an upstream sample prior to final approval. Applicant indicates that all well at this facility were completed prior to August 1, 2014. Applicant indicates that the "VOC burner" is an enclosed combustor. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 020 Process # SCC Code 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation Uncontrolled Emissions Pollutant Factor Control % Units PM10 3.33 0 Ib/1000bbl PM2.5 3.33 0 Ib/1000bbl SOx 0.26 0 Ib/1000bbl NOx 30.35 0 Ib/1000bbl VOC 13463.09 95 Ib/1000bbl CO 138.36 0 lb/1000bbl Benzene 165.63 95 Ib/1000bbl Toluene 89.49 95 Ib/1000bbl Ethylbenzene 6.91 95 Ib/1000bb1 Xylene 24.89 95 lb/1000bbl n -Hexane 977.75 95 Ib/1000bbl 224 TMP 37.88 95 lb/1000bbl 3 of 6 K:\PA\2019\19WE0608.CP1.xlsm 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 I. 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 CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 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 II.D.2)? 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? Source is not subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Sectionl a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? Yes No No Tho 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 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 Requires an APEN. Go to the next question Source Requires a permit Source is not subject, do not go to next question The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e 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 9959 Facility Name Wahlert AC33 Econode History File Edit Date 7/17/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.3 0.0 0.0 0.0 12.8 44.1 0.0 36.4 1.6 Previous Permitted Facilit total 0.0 0.0 0.0 0.0 0.9 39.6 0.0 1.8 0.3 001 GP02.CN RICE - Waukesha F18GSI 0.0 0.0 Cancellation request received 08/27/2.014 002 GP02.CN RICE - Waukesha F1SGSI 0.0 0.0 Cancellation request received 08/27/2014 003 GP02.CN RICE - Caterpillar G3408TA 0.0 0.0 Cancellation request received 08/27/2014 004 GP02.CN RICE - Caterpillar G3408TA 0.0 0.0 Cancellation request received 08/27/2014 005 GP02.CN RICE - Arrow VRG330 0.0 0.0 Cancellation request received 08/27/2014 006 GP02.CN RICE - Arrow VRG330 (VRU2) 0.0 0.0 Cancellation request received 01/31/2017 007 12WE2083.CN RICE - Red River Compression CB57 0.0 0.0 Cancellation request received 08/27/2014 008 GP01 Condensate Storage Tank (10 vessels) 54.7 2.4 39.0 0.1 No change 009 12WE2779.XP Produced Water Storage Tank 20.0 2.2 1.0 0.1 No change 010 GP02 RICE - Caterpillar G3408TA CN received 2/13/19 011 16WE0988.XP RICE - Arrow L-795 1.6 0.4 1.2 0.2 1.6 0.4 1.2 0.2 No change 012 16WE0962.XP RICE - Arrow L-795 1.6 0.4 1.2 0.2 1.6 0.4 1.2 0.2 No change 013 16WE0960.XP RICE - Arrow L-795 1.6 0.4 1.2 0.2 1.6 0.4 1.2 0.2 No change 014 16WE0959.XP RICE - Arrow L-795 1.6 0.4 1.2 0.2 1.6 0.4 1.2 0.2 No change 015 16WE0965.XP RICE - Arrow L-795 1.6 0.44 1.2 0.2 1.6 0.44 1.2 0.2 No change 016 16WE0964.XP RICE - Arrow L-795 1.6 0.44 1.2 0.2 1.6 0.44 1.2 0.2 No change 017 GP02.CN RICE - Arrow VRG330 0.0 0.0 Cancellation received March 27, 2018. 018 18WE0186.XP RICE - Kubota DF972 0.4 0.7 24.3 0.0 0.4 0.7 24.3 0.0 no change 019 GP02 RICE - Caterpillar G3304NA 19.3 0.6 12.0 0.2 0.9 0.6 1.8 0.2 No change 020 19WE0608 LP Separator Venting 0.2 88.4 0.9 8.5 0.2 4.5 0.9 0.4 newly permitted point 0.0 0.0 APEN Exempt/Insignificants 0.0 0.0 XA Separator Heaters (13) 0.1 1.5 0.10 1.2 0.0 0.1 1.5 0.10 1.2 0.0 From APCD102 XA VOC Burners (3) 0.2 0.3 0.1 1.9 0.0 0.2 0.3 0.1 1.9 0.0 From APCD102 FACILITY TOTAL 0.3 0.0 0.0 0.0 31.4 167.2 0.0 47.5 14.5 0.3 0.0 0.0 0.0 13.0 48.6 0.0 37.3 2.0 VOC: Synthetic Minor NOx: True Minor CO: True Minor HAPS: Syn Minor (n -hexane) HH: Area Source (Syn Minor) 7777: Area Source (Syn Minor) Permitted Facility Total 0.0 0 0 0.0 0 0 19 3 55.3 0 0 12.0 2.6 0.0 0.0 0.0 0.0 0.9 39.6 0.0 1.8 0.3 Excludes units exempt from permits/APENs hi Permitted Emissions 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Pubcom & modeling not required Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 48.6 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25 tpy 0.0 19WE0608 will go to public notice since its addition makes the plant newly synthetic minor. , Note 2 Page 5 of 6 Printed 8/6/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy, Inc. 123 9959 Wahlert AC33 Econode Emissions - uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) I Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02.CN RICE - Waukesha F18GSI 0.0 002 GP02.CN RICE - Waukesha F18GSI 0.0 003 GP02.CN RICE - Caterpillar G3408TA 0.0 004 GP02.CN RICE - Caterpillar G3408TA 0.0 005 GP02 CN RICE - Arrow VRG330 0.0 006 GP02.CN RICE - Arrow VRG330 (VRU2) 0.0 007 12WE2083.CN RICE - Red River Compression CB57 0.0 008 GP01 Condensate Storage Tank (10 vessels) 505 4208 2.4 009 12WE2779.XP Produced Water Storage Tank 1069 3359 2.2 010 GP02 RICE - Caterpillar G3408TA 0.0 011 16WE0988.XP RICE - Arrow L-795 296 42 42 10 0.2 012 16WE0962.XP RICE - Arrow L-795 296 42 42 10 0.2 013 16WE0960.XP RICE - Arrow L-795 296 42 42 10 0.2 014 16WE0959.XP RICE - Arrow L-795 296 42 42 10 0.2 015 16WE0965.XP RICE - Arrow L-795 296 42 42 10 0.2 016 16WE0964.XP RICE - Arrow L-795 296 42 42 10 0.2 017 GP02.CN RICE - Arrow VRG330 0.0 018 18WE0186.XP RICE - Kubota DF972 0.0 019 GP02 RICE - Caterpillar G3304NA 349 0.2 020 19WE0608 LP Separator Venting 2174 1175 327 12835 497 8.5 0 0 3 0.0 APEN Exempt/Insignificants 0.0 0 XA Separator Heaters (13) 0.0 0 XA VOC Burners (3) 0.0 TOTAL (tpy) 1.1 0.1 0.1 1.9 0.6 0.0 0.2 10.2 0.0 0.2 0.0 0.0 14 5 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL rtpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP02.CN RICE - Waukesha F18GSI 0.0 002 GP02.CN RICE - Waukesha F18GSI 0.0 003 GP02.CN RICE - Caterpillar G3408TA 0.0 004 GP02.CN RICE - Caterpillar G3408TA 0.0 005 GP02.CN RICE - Arrow VRG330 0.0 006 GP02.CN RICE - Arrow VRG330 (VRU2) 0.0 007 12WE2083.CN RICE - Red River Compression CB57 0.0 008 GP01 Condensate Storage Tank (10 vessels) 210 0.1 009 12WE2779.XP Produced Water Storage Tank '� 0.1 010 GP02 0.0 RICE - Caterpillar G3408TA 011 16WE0988.XP RICE - Arrow L-795 296 42 I'3 0.2 012 16WE0962.XP RICE - Arrow L-795 296 42 10 0.2 013 16WE0960.XP RICE - Arrow L-795 296 42 ' 0 0.2 014 16WE0959.XP RICE - Arrow L-795 296 42 10 0.2 015 16WE0965.XP RICE - Arrow L-795 296 42 10 0.2 016 16WE0964.XP RICE - Arrow L-795 296 42 10 0.2 017 GP02.CN RICE - Arrow VRG330 0.0 018 18WE0186.XP RICE - Kubota DF972 0.0 019 GP02 RICE - Caterpillar G3304NA 349 0.2 020 19WE0608 _P Separator Venting 109 59 16 642 25 0.4 0.0 APEN Exempt/Insignificants 0.0 XA Separator Heaters (13) 0.0 XA VOC Burners (3) 0.0 TOTAL (tpy) 1.1 0.1 0.1 0.1 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 2.0 6 19WE0608.CP1.xlsm 8/6/2019 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0608 Issuance: Noble Energy, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Wahlert AC33 Econode 123/9959 NWNW, Section 33, T7N, R63W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point! Equipment Description Emissions Control. Description LP Gas Stream 020 Venting of gas from the low-pressure separators to an enclosed combustor during vapor recovery unit (VRU) downtime. Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air%manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 10 COLORADO Air Pollution Control Division Department of Pubhc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO,t VOC CO LP Gas Stream 020 --- --- 4.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled LP Gas Stream 020 Emissions from the LP Separators are routed to an Enclosed Flare during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND RECORDS, 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit LP Gas Stream 020 Condensate Throughput 13,127 bbl/yr Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. 11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Flealth b Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section I I I. E.) (State only enforceable) 13. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must 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.) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) 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&tM 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 16. The owner or operator must complete an initial site specific analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 17. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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) must 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) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 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. Page 6 of 10 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 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: Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc New emission point at existing facility. Page 7 of 10 COLORADO Air Pollution Control Division Department of Pubic Health & 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E 1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants art estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Gas Stream 020 Benzene 71432 2,174 109 Toluene 108883 1,175 59 Ethylbenzene 100414 91 5 Xylenes 1330207 327 16 n -Hexane 110543 12,837 644 2,2,4- Trimethylpentane 540841 497 25 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source VOC 13.4636 0.6732 ProMax 71432 Benzene 0.1656 0.0083 108883 Toluene 0.08995 0.0045 1330207 Xylene 0.0249 0.0012 110543 n -Hexane 0.9777 0.0489 540841 2'2'4-0.0379 Trimethylpentane 0.0019 Note: The controlled emissions factors for this point are based on a control efficiency of 95%._ The emission factors listed above are based on modeled LP separator temperature of 120 °F and separator pressure of 30 psig, and a HP separator temperature of 90 F and separator pressure of 250 psig. Factors in the table above are based on mode outputs including the following: VOC Weight % of LP gas, stream: 63.4 % MW of LP gas stream: 37.2 lb/lbmol Volume of LP gas emitted per BBL of liquids throughput: 216.7 scf/bbl 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Page 9 of 10 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 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 10 of 10 Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. This emission notice is.valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: f� w o(Qdg' [Leave blank unless APCD has already assigned a permit # and AIRS ID] 020 123 / 9959 /T -13a AIRS ID Number: Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: Wahlert AC33 Econode T7N-R63W-S3 L01 Site Location: NWSW SEC33 T7N R63W Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Denver, CO 80202 Site Location Weld County: 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. 399609 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 COLORADO Ccparrmxra of F tiic r:4wn a Emlocim,rrti Permit Number: AIRS ID Number: 123 /9959 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR ❑ 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: LP gas stream Company equipment Identification No. (optional): For existing sources, operation began on: 5/3/2012 For new, modified, or reconstructed sources, the projected start-up date is: ❑r Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN,- Revision 7/2018 days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No 'i 4 COLORADO 2 I lT� LeuKtsene of k'et91c iir KeaGnvicewronmom Permit Number: AIRS ID Number: 123 /9959 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: 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: O Yes El No Vent Gas Heating Value: 2060 BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 13,127 bbl/year Actual: bbl/year Molecular Weight: 37.1734 VOC (Weight %) 63.16% Benzene (Weight %) 0.78% Toluene (Weight %) 0.42% Ethylbenzene (Weight %) 0.03% Xylene (Weight %) 0.12% n -Hexane (Weight %) 4.59% 2,2,4-Trimethylpentane (Weight %) 0.18% Additional Required Information: ❑ Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX ft n -Hexane, temperature, and pressure) a 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 31 • COLORADO Geear.cmatE Nic • Fnai1T'e fnW.>ani o -n1 Permit Number: AIRS ID Number: 123 / 9959 / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.5290, -104.4502 Operator Stack ID No Discharge Height Temp - ( E) Flow Rate (ACFM) -- Velocity _ Above Ground Level J (Feet) (ft/sec),. Comm 48" Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal 0 Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 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: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 = Gas Venting APEN - Revision 7/2018 41 COLORADO c<y.,na:-m oe Pmb, iiwan F EiMolmo. Permit Number: AIRS ID Number: 123 / 9959 / TBD [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 mbined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency , (% reduction in emissions) PM SOX NO), CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Units Source (AP -42, _ Uncontrolled Emissions Controlled .. Emissions Uncontrolled Emissions Controlled Emissions Basis Mfg., etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM 7.6 Ib/MMscf AP -42 0.00 0.00 SOx 0.6 lb/MMscf AP -42 0.00 0.00 NOX 0.068, 100 Ib/MMBtu,lb/MMscf AP -42 0.26 0.26 CO 0.31, 84 Ib/MMBtu,Ib/MMscf AP -42 0.96 0.96 VOC 13.4636, 0.0055 lb/bbl, Ib/MMscf Model, AP -42 88.37 4.42 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source , (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled 6 Emissions (pounds/year) Benzene 71432 0.1656 lb/bbl Model/AP-42 2174 109 Toluene 108883 0.0895' lb/bbl Model/AP-42 1175 59 Ethylbenzene 100414 0.0069 lb/bbl Model/AP-42 91 5 Xylene 1330207 0.0249 lb/bbl Model/AP-42 327 16 n -Hexane 110543 0.9779 lb/bbl Model/AP-42 12837 644 2'2'4 Trimethylpentane 540841 0.0379 lb/bbl Model/AP-42 497 25 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 5' COLORADO Depaxersene al Public HEW!), 41s., .m+M1 Permit Number: AIRS ID Number: 123 / 9959 / TBD Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contaiied herein and information submitted with this application is complete, true, and correct. 05/09/2019 Signature of Legally AuthorizePerson (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (please print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: 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: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 61 fksommont of Puler. COLORADO Hv.Lh -FmMenreent Hello