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Home My WebLink About20190923.tiffCOLORADO Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 February 22, 2019 Dear Sir or Madam: RECEIVED FEB 282019 WELD COUNTY COMMISSIONERS On February 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Scooter. 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., Deriver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pvbvc P\e J eMj 3lcoltq C`'.PL(T(3),1{L(ST), pux-s nttrgtt atttc.Y0 2/2S/19 2019-0923 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Scooter - Weld County Notice Period Begins: February 28, 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: Scooter Oil and gas exploration and production facility NWNW Sec 18 T3N R64W Weld County The proposed project or activity is as follows: Source is requesting to vent existing low pressure separator stream to flare and no longer recycle. 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 17WE0366 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 fADO Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package It Received Date: Review Start Date: 10/5/20 2/12/201a.,' Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Explora iptF$ P dutt ors elIPad What industry segment?*A.,... 1I .,... Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? D Carbon Monoxide (CO) NWNW quadrant of Section 18, Township 3N, Range 64W Field County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range N5htts€V":.:.: S."`. 3N-:.: &articulate Matter (PM) r - E Ozone (NOx @. VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Sees s°or nfitag L eparai;or ...: Yes ". F.. 3: . < 13WE035 i Z' esi .,. ,Prmtt �b [ ocCFtcat os ' Addlevi point -to testing Permit ......: � ..:.:. ',. .. ..Fir, _. ... .:. �,,, - - - Section 03 - Description of Project rec; ues,tipg rvlot,ie.arsexis'tingeggi Noble had removed the existng'ehgine aild'N/R to-addthe LP separator venting to tl}e.parpe perm€t; Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? =Requesting,.Eynt.1tetc,Miper Perrrrit• d under Ped it'27 ing Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? liter 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) Is this stationary source a major source? CO VOC PM2.5 PM10 TSP HAPs ❑J Colorado Air Permitting Project If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) - Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ia o❑ Separator Venting Emissions Inventory 012 Separator Venting 'Facility AIRs ID: County G Plan TESZ Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates MMscf per year Requested Permit Limit Throughput= „ .61'. MMscf per year Requested Monthly Throughput= MMscr per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU Is VRU process equipment: 10 MMscr per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Valum Volume of waste gas emitted per BBL o liquids throughput: Section 04 - Emissions Factors & Methodologies Helium CO2 N2 methane ethane Weight % 2i propane isobutane n -butane isopentane n -pentane cyclnpentane n -Hexane cyclohexane Other hexanes heptanes methylcyclohexane 224 -IMP Benzene Toluene Ethylbenzene Xylenes C8* Heavies ;0„62 Total VOC Wt % 100.00 - 61.26 Btu/scf scf/bbl Ib/Ib-mol Displacement Equation Ex =Q' MW °)(X /C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 64217.9 492.69 335.45 10.4828 125.79 3123.89 73.3799 32109 24.635 16.7726 0.5241 6.2897 156.194 3.6690 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) ,°-0.0075 (Gas Throughput) PM10 PM2.5 15,320 15.320 1.210 0;007 __:it 5Ox NOx CO 139.819 637.410 3 of 6 K:\PA\2017\17W E0366.CP2.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.07 0:00 0.00 0.07 0.1 12 PM2.5 0.07 0.00 0.00 0.07 0.1 12 100 0.01 0.00 0.00 0.01 0.0 1 NOx 0.67 0.00 0.00 0.67 0.7 114 VOC 307.71 _ 0.00 _ 0.00- 30771 15.4 2613 CO 3.05 0.00 0.00 3.05 3.1. 519 For comparison: Potential to Emit Actual Emissions Requested Permit Limits Source's Values Hazardous. Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Uncontrolled .. Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 4722 0 0 4722 236 4743 237 Toluene 3215 0 0 3215 161 3264 163 Ethylbenzene 100 0 0 100 5 0 Xylene 1206 0 0 1206 60 1343 67 n -Hexane 29938 0 0 29938 1497 29871 1494 224 TRIP 703 0 0 703 35 578 29 SectionRegryulatoSummary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G 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 Source requires a permit Source is not subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific =sample from theequipment 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 being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installediand operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efflciercy 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 answe 4 of 6 K:\PA\2017\ 17WE0366.CP2.,dsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Based on the PA for VAT venting atthis site (Point 010};; AIRS Point # 012 Section 09 - Inventory 5CC Coding and Emissions Factors Process 8 01 5CC Cade 3-10-001-60 Flares eparation equipment is not subje Uncontrolled . Emissions Pollutant Factor Control % Units PM10 15.32 0 Ib/MMSCF PM2.5 15.32 0 Ib/MMSCF 5Ox 1.21 0 lb/MMSCF NOx 139.82 0 lb/MMSCF VOC 64217.94 95 lb/MMSCF CO 637.41 0 Ib/MMSCF Benzene 492.69 95 lb/MMSCF Toluene 335.45 95 Ib/MMSCF Ethylbenzene 10.98 95 lb/MMSCF Xylene 125.79 95 Ib/MMSCF n -Hexane 3123.89 95 lb/MMSCF 224 TMP 73.38 95 lb/MMSCF Sof 6 K:\PA\2017\17 W E0366.CP2.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re Alation 3 Parts A and B-APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulaton 3, Part A, Section Hata)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, MN greater than 10 TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.0.3)? 'Not enough Information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1 TPY (Regulation 3, Part A, Section 111.1.0)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NO% greater than 5TPY or CO emissions greater than 10 TPY (Regulation?, Part B, Section 11.0.2)? 'Source regalres a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 20147 'Source is not subject to Regulation 7, Section X011.0.2, G Section XVII.e.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section( Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that is not enclosed? 'The controldevice for thls separator is not subject to Regulation 7, Section )(1/118.2.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 orregula ion will control. The use of non -mandatory langsage such as 'recommend,"may,' 'should," and 'can,'is intended to describe APCO interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the terns of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Req Source Req [WORMS. u me is ni The control CONSTRUCTION PERMIT Permit number: Date issued: Issued to: ADO Contro on is Healt ..viro-n 17WE0366 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 2 Noble Energy, Inc. Scooter 123/9CDD NWNW SEC 18 T3N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 010 Venting of gas from one Vapor Recovery Tower (VRT) Enclosed Flare LP Separator 012 Venting of gas from one low pressure (LP) 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. AIRS ID 012: 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. AIRS ID 012: 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 COLORADO Aix Pollution Control Division DAe n:. f F: nC Hea b Env,r.nlIvm Page 1 of 8 ado.Qo acifi .he/ai .•ermit-se ertifica . (Regulation N •er 3, Part B, II.G.2 3. AIRS ID 012: 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. AIRS ID 012: The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO VRT 010 --- --- 5.5 --- Point LP Separator 012 --- --- 15.4 3.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT 010 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division Ek. ;€tf-`ent b+ratal b F vsrn-rfze Page 2 of 8 PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit VRT 010 Liquids Throughput 148,446 bbl LP Separator 012 Gas Venting 9.6 MMscf Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. AIRS ID 010: The owner or operator must use monthly condensate/crude oil throughput records, calculation methods detailed in the OEtM 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. 10. AIRS ID 012: The owner or operator shall continuously monitor and record the volumetric flow rate of gas vented from the LP separator(s) to the flare 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 is 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 tie 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) OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) 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 OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. AIRS ID 012: The owner/operator shall complete an initial site specific extended gas analysis 'Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in ,COLORADO Air Pollution Control Division EVootr`ertt,f s4{,V:ikr r.E,VICr.RtV1. 1Y Page 3 of 8 MMSC ;s ven ision ap• ed met °•s. Results of th- alysis shall be ed to t a,,a, ,.n a .„ self i _ ust demon. F- 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 shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 16. AIRS ID 012: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) ADDITIONAL REQUIREMENTS 17. All previous versions of this permit are cancelled upon issuance of this permit. 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: • • • • For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. 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 `COLORADO Pollution Control Tiivision mmt Page 4 of 8 ownership and t ,;,submittal of a APEN qui 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 September 14, 2017 Issued to Noble Energy, Inc. for one vapor recovery tower. Issuance 2 This Issuance Adding Point 012 for venting of low pressure separator. COLORADO Pollution Control Division Page 5 of 8 Not o Permi -'' der e permit holder is required to pay ees or the processing time or this permit. n invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) VRT 010 Benzene 71432 1,462 73 Toluene 108883 906 45 Ethylbenzene 100414 18 1 Xylenes 1330207 318 16 n -Hexane 110543 9,184 460 2,2,4- Trimethylpentane 540841 194 10 LP Separator 012 Benzene 71432 4,722 236 Toluene 108883 3,215 161 Ethylbenzene 100414 100 5 Xylenes 1330207 1,206 60 n -Hexane 110543 29,938 1,497 2,2,4- Trimethylpentane 540841 703 35 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates equal to or greater than 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Page 6 of 8 wing emission f CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source NOx 0.0030 0.0030 AP -42, Table 13.5-1 CO 0.0136 0.0136 AP -42, Table 13.5-1 VOC 1.4850 0.0742 Source (HYSYS) 71432 Benzene 0.0098 0.0005 Source (HYSYS) 108883 Toluene 0.0061 0.0003 Source (HYSYS) 100414 Ethylbenzene 0.0001 0.00001 Source (HYSYS) 1330207 Xylene 0.0021 0.0001 Source (HYSYS) 110543 n -Hexane 0.0619 0.0031 Source (HYSYS) 540841 2'2'4- Tnmethylpentane 0.0013 0.0001 Source (HYSYS) Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Point 012: CAS # Pollutant Weight Percent of Gas (%) Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx --- 139.82 139.82 AP -42 CO --- 637.41 637.41 AP -42 VOC 61.26 64,218 3,210.9 Source (HYSYS) 71432 Benzene 0.47 492.69 24.635 Source (HYSYS) 108883 Toluene 0.32 335.45 16.773 Source (HYSYS) 100414 Ethylbenzene 0.01 10.483 0.5241 1330207 Xylene 0.12 125.79 6.2897 Source (HYSYS) 110543 n -Hexane 2.98 3,123.9 156.19 Source (HYSYS) 540841 2'2'4 Trimethylpentane 0.07 73.380 3.6690 Source (HYSYS) Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. 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, HAPs NANSR Synthetic Minor Source of: VOC COLORADO isllution Control Division Page 7 of 8 Title Prot ._ •n of e websi a - , bel http://ecfr.gpoaccess.gov/ e of Federal R .'lations can be Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart )00XXX COLORADO Air Pollution Control Division Page 8 of 8 OCT _92018 AvCD Statin{3mrY sources 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.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 17WE0366 AIRS ID Number: 123 / 9CDD /' 0/2- [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Noble Energy, Inc. SCOOTER T3N-Rf4W-S18 L01 NWNW SEC18 T31V R64W Mailing Address: 1625 Broadway,Suite 2200 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Allison Satterfield Phone Number: 303-228-4137 E -Mail Address2: a.satterfield@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388660 Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I AV COLORADO Hw".K of Public N F TOMDUM I Permit Number: 17WE0366 AIRS ID Number: 123 / 9CDD / 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 El 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: Combustion of LP Gas Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: p Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year Yes Yes Yes No No No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I A_ I COLORADO I CcyutmrnlaE I YNic I kvailltSEnvfianmall Permit Number: 17WE0366 AIRS ID Number: 123 / 9CDD / TBD [Leave blank unless APCD has already assigned a permit # and MRS ID] Section 4 - Process Equipment Information ❑r 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: ❑✓ Yes ❑ No Vent Gas Heating Value: 2056.16 BTU/SCF Requested: 9583.44 MMSCF/year Actual: NA MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 39.709918 VOC (Weight %) 61.25 Benzene (Weight %) 0.47 Toluene (Weight %) 0.32 Ethylbenzene (Weight %) 0.00 Xylene (Weight %) 0.13 n -Hexane (Weight %) 2.97 2,2,4-Trimethylpentane (Weight %) 0.06 Additional Required Information: ❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 AV COLORADO 3 I ```� "�"`°Ptli` I R�h��v�� Permit Number: 17WE0366 AIRS ID Number: 123 I 9CDD / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) F" 40.2312, -104.5988 Operator Suck ID No Discharge Height Above Ground Level , z Temp { F) Flow Ra te (ACFM 6{ Veloc1tyt t/sec �' () (Feetj i ,- Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: Type: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: Waste Gas Heat Content: Btu/scf MMBtu/hr Make/Model: 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 4I COLORADO tcpammv.-ss of Ps&ic i fter`I}.EF . franmavxt Permit Number: 17WE0366 AIRS ID Number: 123 / 9CDD / TBD Benzene [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% rEduction): PM Description of Control Methods) Overall Requested Control Efficiency (% reduction in emissions). ! , so. NOX CO VOC Enclosed Combustor 95 HAPs Enclosed Combustor 95 Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory `. PM >>' Source (AP 42, Mfg., etc.); Actual Annual Emissions Uncontrolled Emissions (tons/year) Controlled Emissions6 }; (tons/year). equested Annual Permit Emission Limit(s)5 0.68 0.68 SOX NO. 100, 0.068 Ib/MMSCF, tb/MMBIu AP -42 CO 84, 0.31 Ib/MMSCF, Ib/MMBtu AP -42 3.06 3.06 VOC 5.5, 64.212 Ib/MMSCF, Ib/mscf AP-42/HYSYS 307.68 15.38 Non -Criteria Reportable Pollutant Emissions Inventor _Chemical Abstract Service (CAS) Number 71432 Emission Factor Uncontrolled,; Basis 0495 _Units Ib/MSCF j Source (AP -42, Mfg,etc) HYSYS/AP42 Actual Annual Emissions Uncontrolled Emissions (pounds/year) 4742.89 Controlled Emissions6 (Pounds/year)'' 237.14 Toluene 108883 0.341 Ib/MSCF HYSYS/AP42 3263.66 163.18 Ethylbenzene Xylene 100414 0.000 Ib/MSCF HYSYS/AP42 0.00 0.00 1330207 0.140 Ib/MSCF HYSYS/AP42 1343.01 67.15 n -Hexane 110543 3.117 lb/MSCF HYSYS/AP42 29870.78 1493.85 2,2,4- Trimethylpentane Other: 540841 0.060 Ib/MSCF HYSYS/AP42 578.02 28.90 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 ©V Co LORADO 5 I m`C7 F hfr EIU Th,1YMI Permit Number: 17WE0366 AIRS ID Number: 123 / 9CDD / TBD [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/5/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Allison Satterfield Environmental Scientist Name (please print) Title Check the appropriate box to request a copy of the: ❑ 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: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Rov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 61 I COLORADO crone of toxic HaaliA 5 Envflenmml Hello