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Home My WebLink About20190922.tiffCOLORADO Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 February 21, 2019 Dear Sir or Madam: RECEIVED FEB 2 8 2019 WELD COUNTY COMMISSIONERS On February 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc - REI FED BEEBE DRAW OVIATT. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 1 )b\\c P�ev�e 3! (ol la► 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC. PLC TP), 441-C ST), P' . leikIcWcW� 2/28/Iq 2019-0922 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc - REI FED BEEBE DRAW OVIATT Weld County Notice Period Begins: February 28, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Noble Energy, Inc Facility: REI FED BEEBE DRAW OVIATT Oil and gas exploration and production facility SWSW Sec 10 T3N R65W Weld County The proposed project or activity is as follows: Source is requesting to vent existing separator stream to flare and no longer recycle the stream. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1067 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 6 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Carissa Monte':.' Package #: ;38S3&4•..: Received Date: .1O/2jlo18 IrlII:'ift Review Start Date: :2/1:1/20,19;;:3 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical - Address/Location: SWSW quadrant of Section 10, Township 3N, Range 65W County: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (CO) bin Ene 'Weld County Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Quadrant I J I Ozone (NOx & VOC) Section Township Range AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks O03 -u A av WV Section 03 - Description of Project Noble IS requesting toaemove an exis hg l.:(llpotne.: Muhli ivided a revises! application bn,2/14/2019 Theapphcattoq now roughput lnstead'of metering sae vented to flare. Gable provwd� Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Mgt slops to flar instead of recycling to the VRU):fhom an existing low pre e (LP) separatbr'anti np rdute the e Also, Noble is cow requesti hg to use eas y'synfhetic. mihd3•#acuity for VOC but true minor &M plan to reflect'llquids metering instead of gas met Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. 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) 4 SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants hurt SO2 NOx CO VOC PM2.5 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) 88 El El PM10 TSP HAPs ❑ ❑ Separator Venting Emissions Inventory 003 Separator Venting Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter ,..,✓/rte l rN-l/ Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = . 4. Barrels (bbl) peryear IRequested Permit Limit Throughput = Guff Barrels (661) peryear Requested Monthly Throughput= 1395 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 16,425 Barrels (bbl) peryear Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL o liquids throughput: Section 04- Emissions Factors & Methodologies Description MW 40,50, �3 .3427: Weight % Helium CO2 N2 methane ethane 4. 20:46 propane isobutane n -butane Isopentane n -pentane cyclopentane n -Hexane cyclohexane Other hexanes heptanes methylryclohexane 224-TMP Benzene Toluene Ethylbenzene Xylenes CS+ Heavies ra 3,i ,-2290. 5,52 4134 3:9s' 72'. 1.97' 235' Total VOC Wt % 100.00 54.90 Btu/scf scf/bbl Ib/Ib-mol Displacement Equation E1Q'MW•Xx/C Emission Factors Separator Venting Pollutant - Uncontrolled Controlled (16/bbl) (16/661) (Liquid Throughput) (Liquid Throughput) Emission Factor Source VOC 5.6890 0.2844 0.0018 0.0013 0.0000 0.0005 0.0102 0.0004 Benzene 0.0363 Toluene 0.0259 Ethylbenzene 0.0000 Xylene 0.0104 n -Hexane 0.2041 224 TMP 0.0073 Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (lb/MMBtu) lb/bbl (Waste Heat Combusted) (Gas Throughput) PM10 0.0071 PM2.5 0.0075 0.002 0.002 0.000 0.0141 Sox 0.0006 NOx 0.0600 3 of 7 K:\PA\2018\18 W E1067.CP1.xl sm Separator Venting Emissions Inventory Co I O5 O: "I 0.0642 4 of 7 K:\PA\2018\ 18WE1067.CP1.xlsm Separator Venting Emissions Inventory Section 05 - Emissions Inventory A 50% emission factor was aoolied to V0C & HAPS 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 fibs/month) Source's Values Uncontrolled Controlled (tons/year) (tons/year) ted Month Controlled lbs/month EF Uncontrolled lb/bbl 8.5504 PM10 PM2.5 SOx NOx VOC CO 0.01 0.00 0.00 0.01 0.01 2 0.01 0.00 0.00 0.01 0,01 2 0,00 0.00 _ 0.00 0.00 0.00 0 0.12 0.00 0.00 0.12 0.12 20 46.72 0.00 0.00 70.08 3.50 595 70.2 3.5 596 0.53 0.00 0,00 0.53 0.53 89 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Source's Values Uncontrolled Controlled (lbs/year) (lbs/year) EF Uncontrolled lb/bbl Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM P 596 0 0 894 45 873 44 0.0532 426 0 0 638 32 618 31 0.0376 0 0 0 0 0 0 0.0000 170 0 0 255 13 237 12 0.0144 3353 0 0 5029 251 5071 254 0.3087 119 0 0 179 9 170 9 0.0104 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVILB,'U Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is not subject to Regulation 7, Section XVII.B.2, IS The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements You have indicated above the monitored process parameter is Liquid Througput. The following question does not requi a an Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based on a pressurized liquid sample (Sampled upstream of the equipment covered underthis AIRs ID) and process simulation to estimate emissions? This sample should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to collect a site -specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 5 of 7 K:\PA\2018\ 18WE1067.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes h 1 i Original applicatwn included ap. 9114 HAI's. I deve/opeda lgandd t, 640 110W— a'I glpgtg;ligpidstt Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 003 01 3-10-001-29 Oil & Gas Production: Gas/liquid separation Uncontrolled Emissions Pollutant Factor Control % Units PM10 1.54 0 lb/10006bl PM2.5 1.54 0 lb/1000bbl SOx 0.12 0 Ib/1000bbl NOx 14.07 0 Ib/1000bbl VOC 5688.95 95 Ib/1000bb1 CO 64.15 - 0 ib/1000661 Benzene 36.27 95 Ib/100013bl Toluene 25.91 95 Ib/1000bbl Ethylbenzene 0.00 95 ib/1000bbl Xylene 10.36 95 lb/1000bbl n -Hexane 204.14 95 Ib/1000bbl 224 TMP 7.25 95 Ib/1000bbl 6 of 7 K:\PA\2018\ 18WE1067.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re. lation3 Parts Aand B- APEN and Permit Requirements (Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, PartA, Section ll.O.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, N0n greaser than 10TPY or CO emissions greater than 10TPY (Regulation 3, Part 0, Section 11.0.3)7 Not enough Information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation3, Part A, Section ll.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NO% greater tham5 WY or CO emissions greater than 10 TPV (Regulation3, Part B, Section 11.0.2)? (Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2914? 'Source is not subject to Regulation 7, Section XV11.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 Sectlonj a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? (The control device for this. separator Is not subject to Regulation 7, Section )011.82.0 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 Acf„ its implementing regulations, and Air Quality Control Commission regulations, the language off statute or regulation will control. The use of 000 -mandatory language such as recommend"inay,"should,"and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as'must and -required" are intended to describe controlling requirements underthe terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does cot establish legally binding requirements in and of itself. Source Re? Source Req The control COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy, Inc. 123 3199 REI FED BEEBE DRAW OVIATT History File Edit Date Ozone Status 2111/2019 Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 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 39.7 0.0 24.3 0.0 Existing facility but no previous history file. Points 001 and 002 were existing 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 39.0 0.0 0.0 0.0 001 GP01 Condensate Tanks 52.0 0.9 39.0 - 0.0 Based on facility -wide form. Not sure # of tanks or 002 16WE0410.XP 24 bph Kubota engine 0.0 0.D 0.4 0.7 24.3 0.0 0.0 0.0 0.4 0.7 24.3 0.0 Based on 2016 APEN 003 18WE1067 LP separator venting 0.0 0.0 0.1 70.2 0.5 3.5 0.0 0.0 0.1 3.5 0.5 0.2 New point 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 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.5 122.9 0.0 24.8 4.4 0.0 0.0 0.0 0.0 0.5 43.2 0.0 24.8 0.2 VOC: Syn Minor (NANSR and OP) NOx: True Minor (NANSR and OP) CO: True Minor (PSD and OP) HAPS: True Minor Permitted Facility Total 0.0 0.0 0.0 0.0 0.1 122.2 0.0 0.5 4.4 0.01 0.0 0.0 0.0 0.1 42.5 0.0 0.5 0.2 Excludes units exempt from permits/APENs (5) Change in Permitted Emissions 0.0I 0.0 0.0 0.0 0.1 3.5 0.0 0.5 Pubcom required for new syn minor limit Note 1 Total VOC Facility Emissions (point and fugitive (5) Change in Total Permitted VOC emissions (point and fugitive) 43.2 Facility is eligible for GP02 because c 90 tpy Project emissions less than 25/50 tpy 3.5 Note 2 Page 1 of2 Printed 2/21/2019 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 3199 Facility Name REI FED BEEBE DRAW OVIATT Emissions - uncontrolled (lbs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate Tanks 182 1593 0.9 002 16WE0410.XP 24 bph Kubota engine 38 5 5 3 0.0 003 18WE1067 LP separator venting 873 618 237 5071 170 3.5 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALJtpy) 0.0 0.0 0.0 0.5 0.3 0.0 0.1 3.3 0.0 0.1 0.0 0.0 4.4 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP01 Condensate Tanks 9 80 0.0 002 16WE0410.XP 24 bph Kubota engine 38 5 5 3 0.0 003 18WE1067 LP separator venting 44 31 12 254 9 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTALJtpy) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.2 2 1233199.xlsx 2/21/2019 Apo Contro is Heal CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1067 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Noble Energy, Inc. REI FED BEEBE DRAW OVIATT T3N-R65W-S10 L01 123/3199 SWSW SEC 10 T3N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LP Separator 003 Venting of gas from one low pressure (LP) Separator Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the, permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 COLORADO lotion Control Envision Page 1 of 9 of the pe elf certi orm and ance on e as reqis per ma be obtaine • nline rat • ermit-a p if certi tion. ( • ulation Numbe , Part B, 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO LP Separator 003 -- -- 3.5 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device 'Pollutants Controlled LP Separator 003 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division Page 2 of 9 8. is source ll be '`a° ite• the foil•. ing m. um pr• ` ssin- rate as li d below. roce ng rate all be . intained by th ner or and ma • ". ble . " - sion - • • on reque . - . • lation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LP Separator 003 Condensate throughput 16,425 bbl/yr Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) OPERATING £t MAINTENANCE REQUIREMENTS 12. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O8M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 13. The owner or operator shall complete an initial site specific analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific, emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" COLORADO Air Pollution Control Division Dee rt::'n at PU i::{i Btu it F,m,,Tenrnea+i Page 3 of 9 all s ,T'. e Division •0 days, • i meframe greed to a ermit m•.. - to addrthese inacacy(ies). 14. a own opera shall onst a compl a wit '•acity standard sing EPA e Metho• , + C. ` . ".'1, Ape - • " A, •' ermine th ' •' ce or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or 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. 16. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 17. 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 COLORADO Air Pollution Control Division Page 4 of 9 t B, Secti pon a re a ", R transfer o nership al APEN any: lied fee 18. his •e " speci;, .11y s .-s tha mat aut been grantee then the r of t , � � itio � .. pplic."r° - �• t �:�:. ,, the iss - •, this construction permit does rot 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. 19. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 20. 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. 21. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 22. 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. 23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Issuance 1 This Issuance Issued to Noble Energy, Inc. for venting of gas from one LP separator. D ription COLORADO Air Pot:lin:ion Control Division 31 rfton: SiP } aLitli HtNiR i $Y'",rwao ".':5t^�'.C Page 6 of 9 Notes t ermit Hol at t'. iii this per ce: 1) Th - rmit hold s re• : ed ;ay fees f e p sling ti for ' his permit . n invoice for -se fe l be ed a the •::` mit is i ;:-d. Th enmit holder s pay the in 30 da' . eip s: oice. . he invoic ult in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/ pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP Separator 003 Benzene 71432 873 44 Toluene 108883 618 31 Xylenes 1330207 237 12 n -Hexane 110543 5,071 254 2,2,4- Trimethylpentane 540841 170 9 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 003: CAS # Pollutant Weight Percent of Gas eh)(lb/bbl) Uncontrolled Emission Factors Controlled Emission Factors (lb/bbl) Source NOx --- 0.0141 0.0141 AP -42 CO --- 0.0642 0.0642 AP -42 COLORADO Air Pollution Control Division Kum Vvaormeet Page 7 of 9 ollut Weight ercen (%) 8.5504 led is on actors bbl) Source (HYSYS) VOC 54.9 0.4274 71432 Benzene 0.35 0.0532 0.0027 Source (HYSYS) Source (HYSYS) Source (HYSYS) Source (HYSYS) Source (HYSYS) 108883 Toluene 0.25 0.0376 0.0019 1330207 Xylene 0.10 0.0144 0.0007 110543 n -Hexane 1.97 0.3087 0.0154 540841 2,2,4- Trimethylpentane 0.07 0.0104 0.0005 Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z COLORADO Aix Poltrzi n Contml Bivisicm d7 .;k'.:?Wi=n �5f }'; '.• �a�rrFa'"tnt.rs5r.me Page 8 of 9 MACT MACT Subpart •art DDD . " 440 • .. < �! QQ - 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Contact Division Page 9 of 9 W)s\ Gas Venting APEN Form APCD-211 Air Pollutant Emission Notice (APEN1 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/cdphei aped.. 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: 123 /3199 / [Leave blank un eas APCD has already assigned a permit # and AIRS ID; Section 1 - Administrative Information Company Namel: Noble Energy, lne: Site Name: REt FED BEEBE DRAW Cr/IATTT3N-R65W-Si0 L01 site Location: SWSW SEC10'?3'1 R65W Mailing Address: 1625 Broadway, Suite 220 (Include Zip Code) 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.sagado©nblenergy.eom 1 Use the full, legal company name registered wth the Colorado Secretary of State. This is the company name that will appear on alt documents issued by the APCD: Any changes wilt require additional paperwork. 2 Permits, exemption letters, and any processinginvoices will be issued by the APCD via e-mail to the address provided, A F 3r in A'RC0-211 Gas Venting APEN - Revision 7/2018 1 Permit. Number: AIRS ID Number: 123 /3199 / [Leave blank unless APCO has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name 0 Add point to existing permit O Change permit limit ❑ Transfer of ownership4 O Other (describe below) ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - [D Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PIE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted. For, transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: LP gas stream Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: O 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.O? 0 days/week weeks/year Yes ❑ Yes Yes Form APCD•211 Gas Venting APEN - Revision 7/2018 2 I ❑ No ❑✓ No No Permit Number: AIRS ID Number: 123 /3199/ e bank unless APCD has already assigned a permit # and AIRS I0 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: O Other Description: Serial #: # of Pistons: Volume per event: Capacity: Leak Rate: gal/min Scf/hr/pist 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? ❑ Yes Gas Venting Process Parameters5: No Vent Gas Heating Value: BTU/SCF Requested: MMSCF/year Actual: MMSCF/year Liquid Throughput Process Parameters5: Vented Gas Properties: -OR- Requested: 16,425 bbl/year Actual: bbl/year Molecular Weight: 34.37 VOC (Weight %) 54,89 Benzene (Weight %) 0.34 Toluene (Weight %) 0.24 Ethylbenzene (Weight on 000 Xylene (Weight %) 0.09 n -Hexane (Weight %) 1.98 2,2,4-Trimethylpentane (Weight %). 007 Additional Required Information: O Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 Gas Venting APEN Revision 7/2018 3 fS#.a1AALeO Permit Number: AIRS ID Number: 123 /m,/ [Leave Mark unless APCD has alrea+dy assignec and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.2338, -104.656 Cltschrgezletght z ;dIz**;I 3✓a �, � C :.�'"y� �''. 3d rz n„ Indicate the direction of the stack outlet: (check one) Upward O Horizontal 0 Downward 0 Other (describe): Indicate the stack opening and size: (check one) Circular ❑ Other (describe): Interior stack diameter (inches): 0 Upward with obstructing raincap Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Modet: Combustion Device: Pollutants Controlled: VOC, RAPS Rating: MMBtu/hr Type: Enclosed Combustor Make/Modet: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑ Yes a No Pilot burner Rating: MMBtuf hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 • Gas Venting APEI'I - Revision 7/2018 a 1' Benzene PM Permit Number: AIRS ID Number: 123 /3199 / [Leave blank unless APCD has already assigned a permit # and AIRS 10] 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 SOS NOS CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions.InventorY Emission Factor :ual Annual Emissions Requested Annual Permit Emission;,Ltmit(s)5 Uncontrolled Basis Ibtbbt Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Ernissionss (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) 0.0007 -- fi43-42 0.00 -- 0-00 - Sox 0.0001 lb/bbl AP -42 0.00 0.00 NOs 0.0152 lb/bbl AP -42 0.12 0.12 CO 0.0652 lb/bbl AP -42 0.54 0.54 VOC 8.5506 lb/bbl HYSYS/AP-42 70.22 3.51. Nor-Crit Chemical Abstract Service (CAS) Number is Reportable Pollutant Emissions, Inventory Emission Factor Actual Annual Emissions Uncontrolled Basis lb/bbl Source (AP -42, Mfg., etc-) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) 71432 0.0531 HYSYS 873 44 Toluene 108883 0.0376 lb/bbl HYSYS 618 31 Ethylbenzene 100414 Xytene 1330207 n -Hexane 110543 0.3087 Ibtbbl HYSYS 5,071 254 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD 211 - Gas Venting APEN - Revisbn 7:2018. 5 i A COL 0.57 Ci0 Permit Number: AIRS ID Number: 123 /3199/ [Leave blank unless APCD has already assigned a permit ±t 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. Meg Si ature of Legally Aut orized Person (not a vendor or consultant) 02/14/2019 Date Janessa Salgado Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: • Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II. C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/aped Form APCD-211 Gas Venting, APEN - Revision 7/2013 6 I ilek Hello