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Home My WebLink About20193761.tiffa COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 August 14, 2019 RECEIVED AUG 1 9 2010 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On August 22, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - EMMY STATE H25 -14-A T3N-R65W-S25 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �vtotic �ev�ecv ogste13-/I9 Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director cc=PL(-rP), £.1-1(3't),ocoCJM}, ewf€Rtarn (c HI CK) 2019-3761 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - EMMY STATE H25 -14-A T3N-R65W-S25 L01 - 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: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Exploration and Production Well Pad SWSW Sec 25 T3N R65W Weld County The proposed project or activity is as follows: This permit package is requesting permit coverage for a well pad production facility that began operation 2/19/2019. The facility has requested permit coverage for condensate tanks, condensate loadout, produced water tanks, separator venting, and fugitive component teaks. The facility is synthetic minor for VOC and HAP's (total and n -hexane). The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0560 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 „me (COLORADO Department of Public Health E Envlroanunt 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 19WE0560 Issuance: 1 Noble Energy Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: EMMY STATE H25 -14-A T3N-R65W-525 L01 123/A04F SWSW Section 25 T3N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Tanks 001 Three (3) 500 barrel fixed roof storage vessels used to store condensate Enclosed Combustion Device PH Tanks 002 Four (4) 500 barrel fixed roof storage vessels used to store produced , water Enclosed Combustion Device Condensate Truck Loadout 003 Truck loadout of condensate by submerged fill Enclosed Combustion Device Heater Treater/Surge Drum Gas Stream 004 Gas Venting from Heater Treater and Surge Drum Separation Units during Vapor Recovery Compressor Downtime Enclosed Combustion Device Fugitives 005 Equipment leaks (fugitive VOCs) from natural gas well pad production facility None 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.Qov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Page 1 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 NOX VOC CO Tanks 001 -- --- 0.7 - Point PW Tanks 002 3.7 13.1 16.7 Point Condensate Truck Loadout 003 --- --- 1.0 --- Point Heater Treater/Surge Drum Gas Stream 004 --- 1.3* 32.7 5.1* Point Fugitives 005 --- --- 1.6 --- Fugitive• *The combustion emissions related to the pilot gas fuel are included in point 004's NOx and CO emissions limits. Page 2 of 14 4,, COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: 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. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 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 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 Tanks 001 Enclosed Combustion Device VOC and HAP PW Tanks 002 Enclosed Combustion Device VOC and HAP Condensate Truck Loadout 003 Enclosed Combustion Device VOC and HAP Heater Treater/Surge Drum Gas Stream 004 Emissions from both the heater treater and surge drum gas stream are routed to an enclosed combustion device during vapor recovery compressor 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.) Page 3 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Tanks 001 Condensate Throughput 262,253 barrels PW Tanks 002 Produced Water Throughput 2,000,000 barrels Condensate Truck Loadout 003 Condensate Loaded 262,253 barrels Heater Treater/Surge Drum Gas Stream 004 Natural Gas Venting 11.50 MMSCF The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a roping 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. Point 004: The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. his source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 13. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 14. Points 001, 002, 004: 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 III.E.) (State only enforceable) 15. Point 001, 002, 004: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined Page 4 of 14 a, - COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 16. Point 001: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved', by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 17. Point 001, 002: The storage tank covered by ! this permit is subject to the emission control requirements in Regulation Number 7, Section XVI I.C.1. The owner or operator must install and operate air pollution control, equipment that achieves an ' average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion •device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made. available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 18. Point 001, 002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 19. Point 003: 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.) 20. Point 003: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 21. Point 003: All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. Page 5 of 14 alto COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. Point 003: The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 23. Point 003: For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. 24. Point 004: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first. production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 25. Point 005: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). Leak Detection and Repair (LDAR), as required by Condition No. 26, shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). d. Page 6 of 14 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 26. Point 005: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. OPERATING a MAINTENANCE REQUIREMENTS 27. Points 001, 002, 003, 004: Upon startup of these points, the owner or operator must 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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 28. Point 005: This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING. Initial Testing Requirements 29. Point 001, 002, 004: The owner or operator must 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) 30. Point 005: Within one hundred and eighty days ('180) of the latter of commencement of operation or issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil' service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 31. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 32. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in Page 7 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 33. 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). GENERAL TERMS AND CONDITIONS 34. 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. 35. 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. 36. 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 Page 8 of 14 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 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. 37. 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. 38. 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. 39. 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. 40. 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. Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy Inc. Page 9 of 14 a COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder 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 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 sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Tanks 001 Benzene 71432 110 6 Toluene 108883 214 11 n -Hexane 110543 913 46 PW Tanks 002 Benzene 71432 14,000 700 n -Hexane 110543 44,000 2,200 Condensate Truck Loadout 003 Benzene 71432 136 7 Toluene 108883 264 13 Xylene 1330207 112 6 n -Hexane 110543 1,129 56 Heater Treater/Surge Drum Gas Stream 004 Benzene 71432 5,928 296 Toluene 108883 12,307 615 Ethylbenzene 100414 322 16 Xylene 1330207 5,801 290 Page 10 of 14 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado n -Hexane 110543 49,710 2,491 2,2,4- Tremethylpentan e 540841 253 13 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.53E-04 1.53E-04 AP -42, Chapter 13.5 CO 8.39E-04 8.39E-04 VOC 0.1033 5.165E-03 HYSYS Modelling and EPA Tanks 4.0.9d Modelling based on site- s 19 taken eic sampling 209 and 4/5/2019 110543 n -Hexane ' 0.0035 1.75E-04 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 66E-03 3 .061602E26 -2203 3.66E-03 AP -42, Chapter CO 0.0167 0.0167 13.5 VOC 0.262 0.0131 "' State Emission 71432 Benzene 0.007 3.5E-04 Factors 110543 n -Hexane 0.022 1.1E-03 (PS Memo 14-03) Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.56E-04 1.56E-04 AP -42, Chapter 13.5 CO 7.12E-04 7.12E-04 VOC 0.1526 7.63E-03 AP -42, Chapter 5.2, Equation 1 Toluene 108883 0.0010 5.0E-05 n -Hexane 110543 0.0043 2.15E-04 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T Page 11 of 14 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.6568 psia M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 511 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the flash vapors of the site -specific HYSYS model by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 219.13 219.13 AP -42, 13.5 Chapter CO 892.17 892.17 VOC 113, 571.3 5,678.6 HYSYS Modelling and EPA Tanks 4.0.9d Modelling site - based on ng specific /4/2019 taken 4/4/2019 and 4/5/2019 71432 Benzene 515.5 25.78 108883 Toluene 1,070.3 53.52 100414 Ethylbenzene 28.0 1.4 1330207 Xylene 504.5 25.2 110543 n -Hexane 4,323.2 216.2 540841 2,2,4- Trimethylpentane 22.0 1.1 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The combustion emissions for the enclosed combustion device pilot gas for the facility have been included in the requested emission limits for point 004 as all controlled sources are routed to the same two (2) enclosed combustion devices. Point 005: Component Gas Service Heavy Oil Light Oil SWater/Oil Service ervi Connectors 5,451 353 1,730 882 Flanges 748 0 454 26 Open-ended Lines 11 0 0 0 Pump Seals 0 0 3 0 Valves 2,327 118 1,883 306 Other* 622 0 117 108 VOC Content (wt. fraction) 40.0 100 100 100 Page 12 of 14 1t COLORADO Air Pollution Control Division Department of Public Health Fi Environment Dedicated to protecting and improving the health and environment of the people of Colorado Benzene Content (wt. fraction) 0.10 0.25 0.25 0.25 Toluene Content (wt. fraction) 0.05 0.13 0.13 0.13 Ethylbenzene (wt. fraction) 0.05 0.13 0.13 0.13 Xylenes Content (wt. fraction) 0.05 0.13 0.13 0.13 n -hexane Content (wt. fraction) 0.20 0.50 0.50 0.50 2,2,4- Trimethylpentane 0.05 0.13 0.13 0.13 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil il Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07! 2.4E-06 2.9E-06 Open-ended Lines ' 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E-04 _ NA 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Page 13 of 14 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https: //www.federalreRister.gov/documents/2016/06/03/2016-11971 /oil -and - natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP NANSR Synthetic Minor Source of: VOC PSD True Minor Source 10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.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 Part 63: National Emission Standards for Categories Hazardous Air Pollutants for Source MACT 63.1-63.599 Subpart A - Subpart Z MALT 63.600-63.1199 Subpart AA - Subpart DDD MAC 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 14 of 14 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh Lakocy Package #: 399101 Received Date: 5/9/2019 Review Start Date: 7/2/2019 Section 01 - Facility Information Company Name: Noble Energy Inc. County AIRS ID: 123 Quadrant Section Township Range SWSW 65 Plant AIRS ID: A04F Facility Name: Physical Address/Location: County: Type of Facility: 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) EMMY STATE 1-125-14-A T3N-R65W-S25 Llaj. SWSW quadrant of Section 25, Township 3N, Range 65W Weld County Exploration & Production Well Pad Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ornne (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank Tanks Yes 19WE0560 Permit Initial Issuance 002 Produced Water Tan!. PW Tanks Yes 191W!E0560 Permit Initial Issuance 003 Liquid Loading Loadout Yes 19WE0560 Permit Initial Issuance 004 Separator Venting ' ,r/Surge L Yes 19WE0560 Permit Initial Issuance Fugitive Component Leaks Fugitives permit Initial Issuance Section 03 - Description of Project This permit package is requesting permit coverage for a well pad production facility that began operation 2/19/2019. The facility has requested permit coverage for condensate tanks, condensate loadout, produced water tanks, separator venting, and fugitive component leaks. The facility is synthetic minor for VOC and HAP's (total and n - hexane). All of the sources which are controlled (Tanks, PW Tanks, Loadout, Heater Treater/Surge Drums) are routed to the same two enclosed combustion devices. This facility is Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 NOx Prevention of Significant Deterioration (PSD) SO2 No Yes NOx CO VOC J Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) PM2.5 PM10 TSP HAPs • r CO VOC PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County A04F Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Three (3) 500 bbl fixed roof storage tanks used for the storage of condensate liquids (off spec tanks) Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Zeeco HREC Enclosed Combustion Device 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 262,253 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 262,253 Barrels (bbl) per year Requested Permit Limit Throughput = 262,253 Barrels (bbl) per year Requested Monthly Throughput = 2'274 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquids produced = 262,253 Barrels (bbl) per year 2697.95 Btu/scf 0.969380026 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? 686 MMBTU per year 686 MMBTU per year 686 MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 0.10 0.01 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Benzene 0.000 0.000 Toluene 0.001 0.000 Site Specific E.E. (includes flash) Ethylbenzene 0.000 0.000 Site Specific E.F (includes flash) Xylene 0.000 0.000 Site Specific E.F. (includes flash) n -Hexane 0.003 0.000 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) 224 TM P 0.000 0.000 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0000 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM1O!PM.2.5) AP -42 Chapter 13.S industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM 2.5 0.0075 0.0000 NOx 0.0680 0.0002 CO 0.3100 0.0008 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx 13.5 _ 13.5 0.7 13.5 0.7 115 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 , 0.0 4 CO 0.1 0.1 0.1 0.1 0.1 18 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 110 110 6 110 6 Toluene 214 214 11 214 11 Ethylbenzene 7 7 0 7 0 Xylene 91 91 5 91 5 n -Hexane 914 914 46 914 46 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2of18 K:\PA\2019\19WE0560.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? No If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Yes Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes The emission factors for this tank battery were based on a facility -wide HYSYS model to determine the weight fraction of the flash gas to calculate the flash gas and a Tanks 4.0.9d run to estimate the working/breathing emissions. The HYSYS model was based on 4 -pressurized liquid samples taken upstream of the separation processes 4/4/2019 and 4/5/2019. Source calculated mass flow by using the speciated mass fractions to determine the volume of each component using it's molecular weight and the ideal gas law conversion factor (379 ft^3/Ib-mol). From this, the maximum volume of gas burned for working and breathing emissions was calculated to determine the gas to oil ratio. The emission factors were determined using the mass fractions, ideal Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 Process # SCC Code 01 4-04.-003_1i Fixed Rc:of Tank. Condensate, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 2.5 95 lb/1,000 gallons condensate throughput CO 0.02 0 lb/1,000 gallons condensate throughput Benzene 0.01 95 lb/1,000 gallons condensate throughput Toluene 0.02 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 Ib/1,000 gallons condensate throughput Xylene 0.01 95 lb/1,000 gallons condensate throughput n -Hexane 0.08 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 18 K:\PA\2019\19WE0560.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B • APEN and Permit R uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Sectior II.D.2)? Source requires a permit Yes No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII.C-F Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII G Yes Yes Yes Yes Yes No Section XII.G.2 - Emissions Control Requirements Section XII.C1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 7, Section XVII.C-2 Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the indrvrduai storage vessel capacity greater than or equal to 75 cubic meters (m') ('472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' ['10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111'? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ['29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' (`950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' ['472 BBL] but less than 151 m3 ("950 BBL) and stores a liquid with a maximum true vapo- pressure' less than 15.0 kPa(60.110b(b))? Yes No Yes Yes Yes No Yes Yes NA NA NA NA Source Req Go to next Source Req Continue -' Continue -' Source is st Continue.' Storage Tai Source is st Continue-' Go to then Go to the n Source is sL Source is st Go to the n Storage Tar Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emrssions2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart H H? Storage Tank is not subject to NSPS 0000 NA NA NA Yes No NA NA Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §603395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Note: If a storage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63. Subpart MACT FIFI, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63361? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? NA •c's Nc N-, NA NA Storage Tank is not subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RAG requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend" 'may.' 'should," and 'can," is intended to describe APCD interpretations and recommendations Mandatory terminology such as -must' and -required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue Storage Tai Continue - Star age- I ir Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 A04F County Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Produced Water Tanks (3) - 500 bbl each Zeeco HREC Enclosed Combustion Device 93 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 2,000,000 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 1,630,000 Requested Permit Limit Throughput = 2,000,000 Barrels (bbl) per year Requested Monthly Throughput = 169863 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 36 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 2,000,000 Barrels (bbl) per year Btu/scf 87,785 MMBTU per year 107,712 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 107,712 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled Emission Factor Source (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 0.262 0.01 Produced Water State E.F. (includes flash) - Fron• Benzene 0.007 0.000 Produced Water State E.F. (includes flash) - From Toluene 0.000 Produced Water State F.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Ethylbenzene 0.000 Xylene 0.000 n -Hexane " " ' 0.001 224 TMP 0.000 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM10 0.0075 0.0004 AP-42I:zu; 1.4-2(PM10/PM.2.5) AP -42 Table 1.42 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (N0x) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 0.0004 NOx 0.0680 0.0037 CO 0.3100 0.0167 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC 262.0 _ 252.0 59.1 262.0 13.1 2225 PM10 0.4 0.3 0.3 0.4 0.4 68 PM2.5 0.4 0.3 0.3 0.4 0.4 68 NOx 3.7 r 3.0 3.0 3.7 3.7 622 CO 16.7 13.6 13.6 16.7 16.7 2836 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 14000 14000 3161 14000 700 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 44000 44000 9933 44000 2200 224 TMP 0 0 0 0 0 Section 06 - Reg_ulatory Summary Analysis Regulation 3, Parts A, B Source requires apermit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 5of18 K:\PA\2019\19W E0560.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling No Section 08 - Technical Analysis Notes Source has requested to use all default values to estimate emissions. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 Ib/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 Ib/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.40 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 Ib/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 6 of 18 K:\PA\2019\19WE0560.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II. D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes No Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? Yes No Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions] from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Storage Tank is not subject to NSPS OOOO Source Req Go to next Source Req Continue - Continue - Go to the n Source is st rill=Source is st Yes No Yes Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the indiv dual 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 establ sh legally binding requirements in and of itself Yes Continue - Storage Tar Storage Tai Go to the n Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading Facility AIRs ID: 123 County A04F Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Condensate Truck Load out Zeeco HREC Enclosed Combustion Device Yes 100.0 95 Requested Overall VOC & HAP Control Efficiency %: 95.00 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 262,253 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 262,253 Barrels (bbl) per year Requested Permit Limit Throughput = 262,253 Barrels (bbl) per year Requested Monthly Throughput = 22274 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 262,253 Barrels (bbl) per year 2697.95 Btu/scf 2)-1134 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46*S*P*M/T 602 MMBTU per year 502 MMBTU per year 602 MMBTU per year No No A site specific stabil.zed hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 Chapter S.2 Table 5.2-1 Submerged Loading: Dedicated Normal service (S= 6) P True Vapor Pressure 3.6568 psia AP -42 Chapter 7, Table 7.1-2 M Molecular Weight of Vapors 68 Ib/Ib-mol AP -42 Chapter 7, Table 7.1-2 T Liquid Temperature 511.4625 Rankine Operational Design L Loading Losses 3.634675274 lb/1000 gallons 0.152656362 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.0034 U.LuuS19032 lb/bbl Based on tank flash emission speciation from HYSYS Model Toluene 0.0066 0.001007532 lb/bbl Based on tank flash emission speciation from HYSYS Model Ethylbenzene 0.0002 3.05313E-05 lb/bbl Based on tank flash emission speciation from HYSYS Model Xylene 0.0028 0.000427433 lb/bbl Based on tank flash emission speciation from HYSYS Model n -Hexane 0.0282 0.004304909 lb/bbl Based on tank flash emission speciation from HYSYS Model 224 TMP 0 0 lb/bbl Based on tank flash emission speciation from HYSYS Model Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 1.53E-01 7.63E-03 ,° Specific- AP -42: Chapter 5.2, Equation 1 Benzene 5.19E-04 2.60E -0S Specific - AP -42: Chapter 5.2, Equation 1 Toluene 1.01E-03 5.04E -0S Specific- AP -42: Chapter 5.2, Equation 1 ?Specific - AP -42: Chapter 5.2, Equation 1 Ethylbenzene 3.05E-05 1.53E-06 Xylene 4.27E-04 2.14E -0S _ Spedfic-AP-42 Chapter 5.2, Equation 1 _ Specific- AP -42: Chapter 5.2, Equation 1 ! Specific- AP -42: Chapter 5.2, Equation 1 n -Hexane 4.30E-03 2.15E-04 224 TMP 0.00E+00 0.00E+00 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 1.71E-05 AP -42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2S) PM2.5 0.0075 1.71E-05 SOx 0.0006 1.35E-06 AP -42 Table 1.4.2 (50x) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 industrial Flares (CO) NOx 0.0680 1.56E-04 CO 0.3100 7.12E-04 8 of 18 K:\PA\2019\19W E0560.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 NOx 0.02 0.02 0.02 0.02 0.02 3 VOC 20.02 20.02 1.00 20.02 1.00 170 CO 0.09 0.09 0.09 0.09 0.09 16 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 136 136 7 136 7 Toluene 264 264 13 264 13 Ethylbenzene 8 8 0 8 0 Xylene 112 112 6 112 6 n -Hexane 1129 1129 56 1129 56 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a i'=e loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? No If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Source is required to be controlled by a flare (enclosed combustion device). Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # 01. SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.o0 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 3.6 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.02 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.01 95 lb/1,000 gallons transferred n -Hexane 0.10 95 Ib/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 9 of 18 K:\PA\2019\19WE0560.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions 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)? Yes Yes No No No Yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? Yes The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a 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 Go to next Go to the n Go to next Go to next Go to next The loadou The loadou Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 12_3 County A041 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Gas Vented from Heater Treater & Surge Drum during vapor recovery compressor downtime Emission Control Device Description: 2 -Enclosed Combustion Devices Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes. meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 11.5 MMscf per year 95 Requested Permit Limit Throughput = 11.5 MMscf per year Requested Monthly Throughput = 1 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yes 12 MMscf per year 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 per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description 2797 Btu/scf scf/bbl The information presented below (except for 2,2,4 TMP) was taken from the HYSYS model based on the site -specific facility model, based on pressurized liquid samples taken 4/4/2019 and 4/5/2019. The values are from the Surge Drum Vapors to VRU stream. It was determined that the emissions from the Surge Drum would be more conservative than using the emissions from the Heater Treater in order to group these sources on a single point. MW 50.12 Weight % Helium 0.00 CO2 1.12 N2 0.00 methane 2.25 ethane 10.80 propane 25.39 isobutane 8.11 n -butane 21.53 isopentane 7.79 n -pentane 9.20 cyclopentane 4.30 n -Hexane 3.27 cyclohexane 0.00 Other hexanes 0.00 heptanes 2.95 methylcyclohexane 0.00 224-TMP 0.02 Benzene 0.39 Toluene 0.80 Ethylbenzene 0.02 Xylenes 0.37 C8+ Heavies 1.71 Total VOC Wt % 100.02 85.85 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C 'See Technical Analysis Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 113527.2220 5676.3611 HYSYS Benzene 515.7467 25.7873 HYSYS Toluene 1057.9420 52.8971 HYSYS Ethylbenzene 26.4485 1.3224 HYSYS Xylene 439.2982 24.4649 HYSYS n -Hexane 4324.3377 216.2169 HYSYS 224 TMP 23.2747 1.1637 HYSYS Primary Control Device Uncontrolled Uncontrolled Emission Factor Source Pollutant (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 20.840 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM1O/PM.2:51 AP -42 Table 1.4-2 (5Ox) AP -42 Chapter 13,5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 20.840 SOx 0.0006 1.645 NOx 0.0680 190.196 CO 0.3100 867.070 11 of 18 K:\PA\2019\19WE0560.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC 0.12 0.12 0.12 0.12 0.12 20 0.12 0.12 0.12 0.12 0.12 20 0.01 0.01 0.01 0.01 0.01 2 1.09 1.09 1.09 1.09 1.09 186 652.78 652.78 32.64 652.78 32.64 5544 CO 4.99 4.99 4.99 4.99 4.99 847 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Umits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 931 5931 297 5931 297 Toluene 12166 12166 608 12166 608 Ethylbenzene 304 304 15 304 15 Xylene 5627 5627 281 5627 281 n -Hexane 49730 49730 2486 49730 2486 224 TMP 268 268 13 268 13 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas, sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the 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. Yes If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? 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. No -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process • arameter is natural : as vented. The following questions do not require an answer. 12 of 18 K:\PA\2019\19WE0560.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Based on the HYSYS model, there was no 2,2,4-trimethylpentane modelled in the gas vented from the separation devices. Upon taking a site specific Surge Drum Gas sample analysis (taken 4/2/2019), 2,2,4-trimethylpentane was present. Using the weight fraction from that sample, an emission factor was developped to estimate emissions. The source had requested that the heater treater and surge drum be grouped sources. Per Regulation 3, Part A, 11.6.4, this source meets the requirements to be grouped, by using the more conservative emissions factors from the surge drum tank to estimate total emissions. The streams from these separators are combined and measured by the same volumetric flaw meter prior to reaching the enclosed combustion devices. This is anticipated to over -estimate the total r. -ri%GJi�: 4n.wi.:4:ti�t.{1.yrvn ..Frvn:.:•:. a...nw. •w'... •.• rvnn�." •' .ti • :+v.nWmv%w:.i..{wrvm(w>.vm.mv.G..M 4....w } Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 20.84 0 Ib/MMSCF PM2.S 20.84 0 Ib/MMSCF SOx 1.65 0 Ib/MMSCF NOx 190.20 0 lb/MMSCF VOC 113527.22 95 Ib/MMSCF CO 867.07 0 lb/MMSCF Benzene 515.75 95 lb/MMSCF Toluene 1057.94 95 Ib/MMSCF Ethylbenzene 26.45 95 Ib/MMSCF Xylene 489.30 95 Ib/MMSCF n -Hexane 4324.34 95 lb/MMSCF 224 TMP 23.27 95 lb/MMSCF 13 of 18 K:\PA\2019\19WE0560.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non -Attainment Area ATTAINMENT 1. 2. 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)? Are total facility uncontrolled VOC emissions greater than S TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3 Part B, Section II.D.3)? INot 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 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 (Regu ation 3, Part B, Section II.D.2)? Yes Yes _'.;rce requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yos Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? :'i:u The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e - Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances_ This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may" "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 it and of itself Source Req Source Req Source is si The contro Colorado Department of Public Health Environment Air Pollution Control Division Operation (hrs/yi SCC Code: 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Fugitive Component Counts & Emissions The default list of TOC emissions factors are based on Table 2-4 "Average Emissions Factors" of the EPA Protocal for Fugitive Equipment Leaks. If the company qualifies to use Table 2-8 "Less than 10,000 ppmv" emissions factors based on provisions of Regulation 7, Section XVII.F, you must update and manually enter the Table 2 -8 emissions Service Component Type Count TOC EF Ibihr- source TOC EF kg/hr- source Contr of (%) VOC Benzene Toluene Ethylbenzene Xylene n -Hexane Uncontrolle d (tpy) Controlled (tpy) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Uncontrolle d (lb/yr) Controlled (lb/ r y ) Uncontrolle d Ib/ r ( y ) Controlled (Ib/ r y ) Uncontrolle d Ib/ r ( y ) Controlled (Ib/yr) Uncontrolle d (Ib/yr) Controlled (Ib/yr) Gas Valves 2327 5.51E-05 2.50E-05 0.0% 0.22 0.2 1.1 1.1 0.6 0.6 0.6 0.6 0.6 0.6 2.2 2.2 Pump Seals 0 7.72E-04 3.50E-04 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Others 622 2.65E-04 1.20E-04 0.0% 0.29 0.3 1.4 1.4 0.7 0.7 0.7 1 0.7 0.7 0.7 2.9 2.9 Connectors 5451 2.20E-05 1.00E-05 0.0% 0.21 0.2 1.1 1.1 0.5 0.5 0.5 0.5 0.5 0.5 2.1 2.1 Flanges 748 1.26E-05 5.70E-06 0.0% 0.02 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.2 Open-ended line 11 3.31 E-05 1.50E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Light Oil Valves 1883 4.19E-05 1.90E-05 0.0% 0.35 0.3 1.7 1.7 0.9 0.9 0.9 0.9 0.9 0.9 3.5 3.5 Pump Seals 3 1.12E-03 5.10E-04 0.0% 0.01 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 Others 117 2.43E-04 1.10E-04 0.0% 0.12 0.1 0.6 0.6 0.3 0.3 0.3 0.3 0.3 0.3 1.2 1.2 Connectors 1730 2.14E-05 9.70E-06 0.0% 0.16 0.2 0.8 0.8 0.4 0.4 0.4 0.4 0.4 0.4 1.6 1.6 Flanges 454 5.29E-06 2.40E-06 0.0% 0.01 0.0 0.1 0.1 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 Open-ended line 0 3.09E-05 1.40E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Heavy 01 Valves 118 1.85E-05 8 40E-06 0.0°4, 0.01 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 Pump Seals Others 0 7.05E-05 3.20E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Connectors 353 1.65E-05 7.50E-06 0.0% 0.03 0.0 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.3 0.3 Flanges 0 8.60E-07 3.90E-07 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended line 0 1.59E-05 7.20E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Water/O1 Valves 306 2.14E-05 9.70E-06 0,0% 0.03 0.0 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.3 0.3 Pump Seals 0 5.29E-05 2.40E-05 0.0°%% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Others 108 1.30E-04 5.90E-05 0.0% 0.06 0.1 0.3 0.3 0.2 0.2 0.2 0.2 0.2 0.2 0.6 0.6 Connectors 882 2.20E-05 1.00E-05 0.0°/U 0.09 0.1 0.4 0.4 0.2 0.2 0.2 0.2 0.2 0.2 0.9 0.9 Flanges 26 6.39E-06 2.90E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Open-ended line 0 7.72E-06 3.50E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 With safet factor: TOTALS (tpy) TOTALS lb/ r Emission Factor Source: EPA -453/R-95-017, Table 2-4 Stream VOC Fraction (wt Gas 0.4000 Light Oil 1.0000 Heavy Oil 1.0000 Water/Oil 1.0000 Regulatory Considerations Reg. 3 Reg. 6 Reg. 7 Stream HAP Components (wt fraction 0.00 HAP Gas Light Oil Heavy Oil Water/Oil Benzene 0.001 0.003 0.003 0.003 Toluene 5E-04 0.001 0.001 0.001 Ethylbenzen 5E-04 0.001 0.001 0.001 Xylene 5E-04 0.001 0.001 0.001 n -Hexane 0.002 0.005 0.005 0.00L 2,2,4 TMP 5E-04 0.0013 0.0013 0.0013 0.00 0.00 0.00 0.01 Is this source located in an ozone non -attainment area or attainment maintenance area? If yes, is this source subject to leak detection and repair (LDAR) requirements per Regulation 7, Section XVII.F or XII.G or 40 CFR, Part 60, Subparts KKK or OO Yes If you repond "yes" to the first question and "no" to the second, this source is subject to Regulation 3, Part B, Section III.D.2, Reasonably Available Control Technology (RACT) requirements and must implem€ leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7, Section XVII.F. Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.6 No Did this source commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23 If you answer "yes" to both questions above, this source is subject to the provisions of 40 CFR, Part 60, Subpart KKK "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Pro Plants" contained in Regulation 6, Part A. Did this source commences construction, reconstruction, or modification after August 23, If you answer "yes" to question #1 and #3 this source is subject to the provisions of 40 CFR, Part 60, Subpart OOOO "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution". Specifically, review subpart 60.5400 for fugitive component leaks and 60.5380 and 60.5385 if the operator reports compressors. It is possible for an onshore natural gas processing plant to have portions of the facility subject to NSPS KKK and portions subject to NSPS OOOO based on the specific dates of construction of those ,portions of the facility. If this is the case, the operator will need to report each of those respective fugitive component emissions on separate APENs and obtain unique emissions points from the Division. Is this source located in an ozone non -attainment area or attainment maintenance area? Yes Is this source at an onshore "natural gas processing plant" as defined in 40 CFR, Part 60.6 No If you answer "yes" to both questions above, this source is subject to the provisions of Regulation 7, Section XII.G regardless of the date of construction Reg. 8 Is this source at a "natural gas processing plant" as defined in 40 CFR, Part 63.761? No Is this facility considered a "major source" of HAP as specifically defined in 40 CFR, Part 63.761 for sites that are not prodcution field ft No If you repond "yes" to both questions above, further review if the provisions of 40 CFR, Part 63.769 "Equipment Leak Standards" apply N/A Printed 8/14/2019 Page 15 of 18 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 A04F Facility Name EMMY STATE H25 -14-A T3N-RI History File Edit Date 7/2/2019 Ozone Status Non -Attainment 5W -S25 L01 EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0560 Condensate Tanks (3-500 bbl) 0.0 13.5 0.1 0.5 0.0 0.7 0.1 0.0 Off -Spec Tanks, New source 002 19WE0560 Produced Water Tanks (4-500 3.7 262.0 16.7 29.0 3.7 13.1 16.7 1.5 New source requesting state emission 003 19WE0560 Loadout (Condensate) 0.0 20.0 0.1 0.7 0.0 1.0 0.1 0.0 Newly requested source 004 19WE0560 Heater Treater/Surge Drum 1.3 653.0 5.1 37.2 1.3 32.7 5.1 1.9 Newly requested source 005 19WE0560 Fugitives 1.6 0.0 1.6 0.0 Newly requested source 0.0 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 0.0 Heater Treaters (2) 0.1 0.1 1.3 0.1 1.1 0.0 0.1 0.1 1.3 0.1 1.1 0.0 From Form APCD-102, Grouped for displasr HP Heaters (12) 0.2 0.2 3.0 0.20 2.5 0.1 0.2 0.2 3.0 0.20 2.5 0.1 ONLY 0.0 0.0 0.0 _ 0.0 FACILITY TOTAL 0.3 0.3 0.0 0.0 9.3 948.8 1.6 25.6 67.4 0.3 0.3 0.0 0.0 9.3 47.8 1.6 25.6 3.5 VOC: Syn Minor NOx: True Minor (NANSR CO: True Minor (PSD HAPS: Syn Minor (NANSR and and and OP) n -hexane & OP) OP) Total 0.0 0.0 0.0 0.0 5.0 948.5 1.6 22.0 67.3 0.01 0.01 0.01 0.0 5.01 47.51 1.61 22.01 3.4 Excludes units exempt from Permitted Facility Total (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 5.0 47.5 1.6 22.0 Pubcom required emissions and Modelling not guidelines. because of change in new syn minor permit limits. required based on Division Note 1 Total VOC Faci ity Emissions (point and fugitive 49.4 Facility is eligible for GP02 because < 90 y _ IA) Change in Total Permitted VOC emissions (point and fugitive_ 49.1 _ Project emissions not less than 25 tpy* This permit will require public comment because of project emissions. Note 2 Page 16 of 18 Printed 8/14/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Noble Energy Inc. County AIRS ID 123 Plant AIRS ID AO4F Facility Name EMMY STATE H25 -14-A T3N-R65W-S25 L01 Emissions - uncontrolled (lbs per year) POIN PERMIT I Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL (tpY) Previous FACILITY TOTAL 0 0 _ 0 0 0 0 0 0 0 0 0 0 0.0 I I 001 19WE0560 Condensate Tanks (3-500 bbl) 913 0.5 _ 002 19WE0560 Produced Water Tanks (4-500 bbl) 14000 44000 29.0 003 19WE0560 Loadout (Condensate) 264 1128 0.7 004 19WE0560 Heater Treater/Surge Drum Gas 5928 12307 322 5801 49710 253 37.2 005 19WE0560 Fugitives 0.0 0.0 0.0 APEN Exempt/Insignificant Sources 0.0 Heater Treaters (2) 49 0.0 HP Heaters (12) 109 0.1 0.0 0.0 TOTAL (tpy) 0.0 I 0.0 0.0 10.1 6.2 0.2 2.9 48.0 0.0 0.1 0.0 0.0 67.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene TOTAL (tpY) Xylenes n -Hexane McOH 224 TMP H2S (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 19WE0560 Condensate Tanks (3-500 bbl) 0.0 46 002 19WE0560 Produced Water Tanks (4-500 bbl) 700 1.5 2200 003 19WE0560 Loadout (Condensate) 13 0.0 56 004 19WE0560 Heater Treater/Surge Drum Gas 296 615 16 290 2491 1.9 13 005 19WE0560 Fugitives 0.0 _ 0.0 0.0 APEN Exempt/Insignificant Sources _ 0.0 17 19WE0560.CP1 8/14/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Noble Energy Inc. County AIRS ID 123 Plant AIRS ID A04F Facility Name EMMY STATE H25 -14-A T3N-R65W-S25 L01 Heater Treaters ;2) 49 0.0 HP Heaters (12) 109 0.1 i 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.5 0.3 0.0 0.1 2.5 0.0 0.0 3.5 0.0 0.0 18 19WE0560.CP1 8/14/2019 MAY -92079 APcD �.'irlr7ar Eby' Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: I2-' /\0F/ i 0 t [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Noble Energy Inc. Site Name: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Site Location: SWSW SEC25 T3N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Janessa Salgado 303-228-4196 janessa.salgado@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. r 359095 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 1IAY == - Hv.:th S Emile=vux, RECp rs Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑r NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.5O must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 O Change permit limit O Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate Tanks (Off Spec Tanks) 02/19/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year 0 Exploration £t Production (EEEP) site O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes al No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? SI Yes • No If "yes", identify the stock tank gas -to -oil ratio: 0 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • D Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • p Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 /\VCOIORADO fi- Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r`' and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 262,253 From what year is the actual annual amount? Average API gravity of sales oil: 49.84 degrees Tank design: ❑✓ Fixed roof ❑ Internal floating roof RVP of sales oil: 5.636 (Tanks Ran at 7.5) ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Tanks 3 1500 02/2019 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites On y) API Number Name of Well Newly Reported Well - SEE ATTACHED ■ - ■ ■ _ ■ - - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.19009, -104.61708 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustors 30 Variable Variable Variable Indicate the direction of the stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑+ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 162 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I A_ COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: 0/0 ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: Zeeco, H REC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 0/0 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Btu /scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EFtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3 psig Describe the separation process between the well and the storage tanks: Liquids go from well to HP separators, then to LP separators (heater treaters), then to surge drum, then to LACT. These tanks only take off -spec oil rejected from the LACT. The pilot emissions from burners associated with tank, PW and load -out are accounted for in heater treater and surge drum calculations (shared burners). Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I A_ COLORADO Crwrtmen: of Gut, figA. S Ervit:.anati Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95% NOx CO HAPs Enclosed Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) ) Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.1033 lb/bbl HYSYS/Tanks4.0.9d 13.54 0.68 NOx 0.068 lb/MMBtu AP -42 0.02 0.02 CO 0.310 Ib/MMBtu AP -42 0.11 0.11 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 Emissions8 (Pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0035 lb/bbl HYSYS/Tanks4.0.9d 913 46 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5 I AY COLORADO ti 12,-urtmcnt FI,Ita I Enrn-. ..nct Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 00414 .Chi Sig ature of Legally Alithorized Person (not a vendor or consultant) Date 05/09/2019 Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance LI Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado. gov/cdphe/apcd Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 I A` COLORADO A P - se_c_ re._ CA �LX Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 167 WE 056a) AIRS ID Number: (Z /APIF/ 002 -- [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Site Location: SWSW SEC25 T3N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@nblenergy.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on 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. 399006 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I A COLOR ADO of Pa. lc ErtordirO, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source El Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit. Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Er Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 02/19/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 0 Exploration Et Production (EEtP) site weeks/year ❑ Midstream or Downstream (non MP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No / Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2I A COLORADO Ccputc:.2VVY *t �✓ Upward ❑ Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Produced Water Throughput: 1,630,000 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof N/A ❑ Internal floating roof El External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW Tanks 4 2000 02/2019 Wells Serviced by this Storage Tank or Tank Battery° (EEtP Sites On y) API Number Name of Well Newly Reported Well - SEE ATTACHED ❑ - ❑ - ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EftP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.19009, -104.61708 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustors 30 Variable Variable Variable Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/rectangle ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 162 Interior stack width (inches): Interior stack depth (inches): COLORADO Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 7/2018 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % % ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr Q C Type: Enclosed Combustor(s) Make/Model: Zeeco, H REC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Waste Gas Heat Content: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EELP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -- 300, 25, 3 psig Describe the separation process between the well and the storage tanks: Liquids from the wells go to HP separators, LP separators (heater treaters), and surge drums and all feed into the produced water storage tanks. Note, combustor pilot emissions are accounted for in the heater treater/surge drum APEN because the combustors are shared. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I A_ COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit k and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor - 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions g (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.2620 lb/bbl CDPHE 213.53 10.68 NOx 0.068 lb/MMBtu AP -42 2.98 2.98 CO 0.310 Ib/MMBtu AP -42 13.61 13.61 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor7 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 11,410 571 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl CDPHE 35,860 1,793 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank{s) APEN - Revision 7/2018 5 I A.. COLORADO Ccuartown: o' Put Vk Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. S0,640, Signature of Legally Authorized Person (not a vendor or consultant) Date 05/09/2019 Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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. gov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 6 I Lam` ,COLORADO Depsrmen, of Putt. Mc., M1. 5 Envlr,nmac. Produced Water Storage Tanks) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal, This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc:). In addition;. the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, iLC. for revised APEN requirements. Permit Number: 19W E0560 AIRS ID Number:' 123 / A04F / 002, [Leave blank uniess APCD has aiready:assigned a permit # and AIRS ID] Section i Administrative Information Company Name1: Noble Energy Inc. Site Name; EMMY STATE H25 -14-A T3N-R65W-S25 1.01 Site Location: SWSW SEC25 T3N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@nblenergy.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on 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., COLOR Do Form APCD-207 • PiKlcitpopd WILE,S as Revi n• 7 2018 Permit Number:. 19WE0560 [Leave -Lank udte s Apco Nis acre AIRS ID Number: 123 / AO44F / 002 y ar;signedu permit t and AIP.S 10,1 Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source Q Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312,50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑. Change company name3 ❑ Change permit limit O Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exemptlgrandfathered source El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Es Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1 06) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted_ Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage 02/19/2019 For new or reconstructed sources, the projected start-up date. is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 Exploration & Production (E&P) site. weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS norattainment area? I Yes ❑ No Are Flash Emissions anticipated from these storage tanks? Q Yes ❑ No Are these storage tanks Located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No © Do these storage tanks contain Less than 1% by volume crude oil on an annual average basis? O Yes Q No Are these storage tanks subject to Colorado Oil arid Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD.-105. ❑ Yes No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ? 6 ton/yr (per storage tank)? ❑✓ Yes ❑ No Form„aPCD 2£0' P.l C _IC . Water Sf. a e Tank APEI-i - Revision .1_01S 2) Upward ].Horizontal Permit Number:. 19WE0560 AIRS ID Number: 123 I AO4F/ 002 - • rL e .,e• bteink APCD. ha air_a^1 a_.>i ned r. pai ntft # and AIRS ID]. Section 4 - Storage Tank(s) Information Actual Annual Amount (bbllyear) Produced Water Throughput: Requested Annual Permit Limit5 (bbllyear) 2,000,000 From what year is the actual annual amount? Tank design: ✓❑ Fixed roof N/A D Internal floating roof External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels inManirage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent. Storage Vessel in Storage Tank (month/year) Date of First Production (monthlyear) PW Tanks 4 2000 02/2019 Wells Serviced by this Storage Tank or Tank Battery6 (E£tP Sites On y) API Number Name of Well Newly Reported Well - - SEE ATTACHED ❑ ■ Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEiP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack information Geographical Coordinates (Latitude/Longitude orUTM) 4.0.19009, -104.61708 Operator Stack. ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate - (ACFM) Velocity. (ft/sec) Enclosed, Combustors 30 Variable Variable Variable. Indicate the direction of the stack outlet: (check one) O Downward [(Other (describe): O Upward with obstructing raincap Indicate the stack opening and size; (check one) Circular Interior stack diameter (inches):. 1 62 O Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches):. J7 P a. _t'_`Stora3e 712012 tzar c IAA0 3l Permit Number: 19WE05j60 AIRS ID Number: 123 r AO4F'/ 002 [Leave ,.Lark unto s A CO ha's _'rady assigned a: permit ' and AIRS ID] Section 6 - Control Device Information El Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor O Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency; % VRU Downtime or Bypassed (emissions vented):. ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustors) Make/Model: Zeeco, H REC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑ Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: Other: Pollutants Controlled:. Description: Control Efficiency Requested: Section 7 Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to thestorage tank(s)? — 300, 25, 3 psig Describe the separation process between the well and the storage tanks: Liquids from the wells go to HP separators; LP separators (heater treaters), and surge drums and all feed into the produced water storage tanks. Note, combustor pilot emissions are accounted for in the heater treater/surge drum APEN because the combustors are shared. APCD 207 ed. Water St?.,,,..T K.13iA._ ; 7,20 8 4i AV Permit Number: 19WE0560 AIRS ID Number: 123 I AO4F / 002 l_2u,e b an unless APCD t! haE,:atreai a c.; rmt ' and AIRS ;0 Section 8 Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the verall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC. Enclosed Combustor 95%, NOx CO HAPs Enclosed Combustor .95 Other: From what year is the following reported actual annual emissions data? N�A Criteria Pollutant Emissions :Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc..) . Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.2620 lb/bbl CDPHE 262.00 13.10 NOx 0.068 lio/MMEitu AP -42 3.66 3.66 CO 0.310 lb/NIMBtu AP -42 16.70 16.70 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Emission Factor7 Actual Annual Emissions Abstract Service (CAS) Number Uncontrolled Basis Units Source {AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions s (pounds/year) Benzene 71432 0.0070 lb/bbl CDPHE 14,000 700 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0220 lb/bbl CDPHE 44,000 2,200 2,2,4- Trimethylpentane 540841 5 Requested values will become permit. limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requestingsite specific emissions factors according to the guidance in PS Memo 14-03. a Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Fnrin ,, :_[ .:.' P ed .E:rS _ 7120:1.3 5. Permit Number: 19WEO5560 AIRS ID Number: 123 /AO4l=/ 002 E iaVe.L1. .. uiiU2A:POD.. has already ss d..d permiit . and F II'RS Section 9 Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage raider General Permit GP05 or GP08, i further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. c i attire of Legally Authorize 07/10/2019 d Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to. issuance LI 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 missions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No, 3, Part A, II.C, for revised APBs" requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call:. Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303).692-3150 Or visit the APCD website at: https: f /www. colorado. gov /edphe /aped 3:127�a�r• APCD_0.` E A _ ..? _ _ r .. _ ....:_a.J I. .1 APEN - ..,. _sn _ _ 6 I Hydrocarbon Liquid Loading APEN Form APCD-208 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 hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: RECEIVED NiAY - 9 2019 APCD St«tiongsy Soutc.r, / I weo.§-6 e AIRS ID Number: l2?j Ott -Ft dF 3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Site Location: SWSW SEC25 T3N R65W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address: janessa.salgado@nblenergy.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on 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. 3`3097 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I A. COLORADO Gwrteren, uY PuhWc Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r+ and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Pilot emissions from enclosed combustors are included in heater treater and surge drum calculations. 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: Condensate Truck Loadout Company equipment Identification No. (optional): For existing sources, operation began on: 02/19/2019 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No Ol ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No I O Does this source load gasoline into transport vehicles? Yes No ■ 0 Is this source located at an oil and gas exploration and production site? Yes No O ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • p Does this source splash fill less than 6750 bbl of condensate per year? Yes No p ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ NI Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2I A_ COLORADO ors E.,. _ Pnv �iavnt Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 262,253 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: �.6 Average temperature of bulk liquid loading: 51.7925 °F True Vapor Pressure: Q 3 6568 . Psia @ 60 ° F Molecular weight of displaced vapors: U 6 Q lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 I A COLORADO De5rartgrsat ° etc Hua[5N> EnV5555Yset Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.19009, -104.61708 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) Enclosed Combustors 30 Variable Variable Variable Indicate the direction of the stack outlet: (check one) ❑✓ Upward 0 Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): 1 62 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC and HAPs Rating: 83 MMBtu/hr Type: Enclosed Combustor(s) Make/Model: Zeeco, HREC Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I �_ ;COLORADO _ emu. 6 E.,° ,.� mw.,,. Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC Enclosed Burner 95% HAPs Enclosed Burner 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) . Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions° (tons/year) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions tons/ ear (tons/year) ) PM 7.60 lb/MMscf AP -42 0.00 0.00 SOx 0.60 lb/MMscf AP -42 0.00 0.00 NOx 0.068 lb/MMBtu AP -42 0.02 0.02 CO 0.310 Ib/MMBtu AP -42 0.11 0.11 VOC 0.1526 lb/bbl AP -42 20.00 1.00 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 Emissions6 (pounds/year) Benzene 71432 Toluene 108883 0.0010 lb/bbl AP -42 264 13 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0043 lb/bbl AP -42 1,128 56 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 5 I �y=E Rm«v,,=, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. &t It S 05/09/2019 Sig ature of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: ID Draft permit prior to issuance ✓l Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 ,COLORADO 6 I a/yet 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: MAY - 9 2019 .M. CD Stationary ' IAEt 6, 0, AIRS ID Number: (23 1A0F1 60 (,,.1,, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Site Location: Noble Energy Inc. SWSW SEC25 T3N R65W Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Vanessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@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. 3(49098 Form APCD-211 - Gas Venting APEN - Revision 7/2018 AYGOLOR 1DO Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit i+ 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 - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: streams Heater treater and surge drum gas Company equipment Identification No. (optional): For existing sources, operation began on: 02/19/2019 For new, modified, or reconstructed sources, the projected start-up date is: Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? G? days/week weeks/year Yes Yes Yes ❑ No O No ❑ No COLORADO Form APCD-211 - Gas Venting ADEN - Revision 7/2018 Permit Number: AIRS ID Number: [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 #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist 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: 2797 BTU/SCF Requested: 11.50 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 50.12 VOC (Weight %) 85.82% Benzene (Weight %) 0.39% Toluene (Weight %) 0.81 % Ethylbenzene (Weight %) 0.02% Xylene (Weight %) 0.38% n -Hexane (Weight %) 3.27% 2,2,4-Trimethylpentane (Weight %) 0.02% 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 'COLORADO 3 I AY L "�`,° ., �r� Permit Number: AIRS ID Number: / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.19009, -104.61708 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec)I Enclosed Combustors 30 Variable Variable Variable 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 162 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 83 MMBtu/hr hr Type: Enclosed Combustor(s) Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Zeeco, HREC Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.195 MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4 I AVCOLORADO .,.r n., . Hryr,F 5 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r 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): 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 Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions° (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 7.6 Ib/MMscf AP -42 0.01 0.01 SOx 0.6 Ib/MMscf AP -42 0.00 0.00 NO. 0.068, 100 Ib/MMEIW,Ib/MMsd AP -42 1.26 1.26 CO 0.31, 84 Ib/MMOW, Ib/MMsd AP -42 5.13 5.13 VOC 113.5713 Ib/Mscf HYSYS, AP -42 652.95 32.66 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 Emissions6 (pounds/year) Benzene 71432 0.5155 Ib/Mscf HYSYS/AP-42 5,928 296 Toluene 108883 1.0703 Ib/Mscf HYSYS/AP-42 12,307 615 Ethylbenzene 100414 0.0280 Ib/Mscf HYSYS/AP-42 322 16 Xylene 1330207 0.5045 lb/Mscf HYSYS/AP-42 5,801 290 n -Hexane 110543 4.3232 Ib/Mscf HYSYS/AP-42 49,710 2,491 2,2,4- Trimethylpentane 540841 0.0220 Ib/Mscf HYSYS/AP-42 253 13 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 :COLORADO 5 I AY�n��: P�:��., Hewt��,b Env1:-inrver Permit Number: - AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. tibvitIJA S c 05/09/2019 Signiture of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www. Colorado. Roy /cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I A_ COLORADO caar of ue RECEIVED MAY -92019 Fugitive Component Leak Emissions APEN Form APCD-203 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for fugitive component leak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ct INE(/).5.60 ARS ID Number: 1Z3 VI 65 APCD S,tetion ry [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Noble Energy Inc. Site Name: EMMY STATE H25 -14-A T3N-R65W-S25 L01 Site Location: SWSW SEC25 T3N R65W Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Y Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: 1311 Contact Person: Janessa Salgado Phone Number: 303-228-4196 E -Mail Address2: janessa.salgado@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. X99095 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 1 I AVCOLORADO ',:.tter_,. Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit 1- and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source (check one below) -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change process 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 - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: Estimated emissions include separators to be installed in the future. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): For existing sources, operation began on: Fugitives 02/19/2019 For new or reconstructed sources, the projected start-up date is: Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ID Well Production Facility5 ❑ Natural Gas Compressor Stations ❑ Natural Gas Processing Plants ❑ Other (describe): hours/day days/week weeks/year s When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 2 I COLORADO 46h Er...,6,m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Regulatory Information What is the date that the equipment commenced construction? 09/05/2018 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Will this equipment be located at a stationary source that is considered a ❑ Yes 0 No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes ❑ No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑ Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑ Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.FT 0 Yes ❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? 0 Yes ❑ No Section 5 - Stream Constituents ❑ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. Stream VOC (wt %) Benzene (wt %) Toluene (wt %) Ethylbenzene (wt %) Xylene (wt %) n -Hexane (wt %) 2,2,4 Trime(wt %)ntane (wt %) Gas 40.00 0.10 0.05 0.05 0.05 0.20 0.05 Heavy (or Heavy LiqOiluid) 100 0.25 0.13 0.13 0.13 0.50 0.13 il (or LLightight LiqOuid) 100 0.25 0.13 0.13 0.13 0.50 0.13 Water/Oil 100 0.25 0.13 0.13 0.13 0.50 0.13 Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UT/N) 40.19009, -104.61708 Attach a topographic site map showing location Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 ®Y'tOLCRkD6 3 I ;in � Ertu'texmwst' Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump ❑ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa ❑ Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: ❑ No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-2O3 - Fugitive Component Leak Emissions APEN - Revision 7/2018 COLORADO 4 I c�r.RA�: �e o, ca� EianVh 5=malra:�mec� Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. ❑ Table 2-4 was used to estimate emissions7. ❑✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑✓ Estimated Component Count ❑ Actual Component Count conducted on the following date: Service Equipment Type Connectors Flanges Open -Ended Lines Pump Seals Valves Other9 Gas Counts 5451 748 11 2327 622 Emission Factor 1.00E-5 5.70E-6 1.5E-5 2.50E-5 1.20E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Heavy Oil (or Heavy Liquid) Counts 353 0 0 0 118 0 Emission Factor 7.50E-6 8.40E-6 Units kg/hr/source kg/hr/source Light Oil (or Light Liquid) Counts 1730 454 0 3 1883 117 Emission Factor 9.70E-6 2.4E-6 5.10E-4 1.90E-5 1.10E-4 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source kg/hr/source Water/Oil Counts 882 26 0 0 306 108 Emission Factor 1.00E-5 2.90E-6 9.70E-6 5.90E-5 Units kg/hr/source kg/hr/source kg/hr/source kg/hr/source 7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APED! - Revision 7/2018 //��!� 'COLOR ADO. Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: data reported in Section 8 to calculate these emissions. Chemical Name CAS Number Actual Annual Emissions Requested Annual Permit Emission Limit(s)11 Uncontrolled (tons/year) Controlled10 (tons/year) Uncontrolled (tons/year) Controlled (tons/year) voc 1.61 1.61 Does the emissions source have any actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? ❑ Yes ✓❑ No ng table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name CAS Number Actual Annual Emissions Requested Annual Permit Emission Limit(s)11 Uncontrolled (lbs/year) Controlled 1° (lbs/year) Uncontrolled (lbslyear) Controlled (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 � 'COLOR 6 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Muu 05/09/2019 Sig ature of Legally Authorized Person (not a vendor or consultant) Date Janessa Salgado Environmental Engineer Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance E✓ 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.gov/cdphe/apcd COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 Hello