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Home My WebLink About20192077.tiffCOLORADO Department of Public Health £t Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 May 29, 2019 Dear Sir or Madam: RECEIVED JUN 0 3 2010 WELD COUNTY COMMISSIONERS On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Shufly State Y34 -16-A Econode. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer cc.'. PL(TA) Nt_.CJT) Public P;eVie PW(JMIERtokicA (.o/lo/lq Cor3Itc 2019-2077 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Shufly State Y34 -16-A Econode - Weld County Notice Period Begins: May 30, 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: Shufly State Y34 -16-A Econode Oil and gas well production facility SESE Sec 34, T2N, R64W Weld County The proposed project or activity is as follows: Applicant is requesting a facility -wide permit for a new well production facility to include emissions associated with condensate storage, produced water storage, condensate truck loadout, and limited flaring of production gas. 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 18WE1159 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Qov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ........... COLORADO Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Bradley Eades Package #: 389792 Received Date: 11/1/2018 Review Start Date: 4/9/2019 Section 01 - Facility Information Company Name: Noble Energy Inc. County AIRS ID: 123 Quadrant Section Township Range SESE 34 2N 64 Plant AIRS ID: Facility Name: Physical Address/Location: County: A008 Shufly State Y34 -16-A Econode SESE quadrant of Section 34, Township 2N, Range 64W Weld County Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank Tanks Yes 18WE1159 1 Yes Permit Initial Issuance 002 Produced Water Tank PW Tanks Yes 18WE1159 1 Yes Permit Initial Issuance 003 Liquid Loading Loadout Yes 18WE1159 1 Yes Permit Initial Issuance 004 Separator Venting Separators Yes 18WE1159 1 Yes Permit Initial Issuance 005 Natural Gas RICE ENG-6NB05107 Yes GP02 GP No No Action Requested New GP02 006 Natural Gas RICE ENG-R6501713 Yes GP02 GP No No Action Requested New GP02 Section 03 - Description of Project Applicant is requesting a facility -wide permit for a new well pad servicing 1 well. Applicant is also requesting GP02 coverage for two (2) natural gas engines (point 005 & 006) associated with package 389707. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants her€ 5O2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 No Yes NOx CO VOC PM2.5 PM10 TSP HAPs No NOx CO VOC J PM2.5 _ PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRs ID: 123 County A008 Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Three (3) 500 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed combustor 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = Requested Permit Limit Throughput = 246,375 Barrels (bbl) per year Reluested Monthly Throughput = 20925 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 = 246,375 Barrels (bbl) per year 2822.77 2.316157849 Btu/scf 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 = Heat content of pilot gas = Volume of Pilot gas combusted = No. of burners = Requested flow of Pilot gas routed to combustion device = Section 04 - Emissions Factors & Methodologies 20.83333333 Will this storage tank emit flash emissions? Yes Btu/scf scf/hr = HHV molar(btu/Itmol) / 379 (scf/lbmol) 0 MMBTU per year 1,611 MMABTU per year 1,611 MMBTU per year 0.55 MMSCF/yr 547.5 MMABTU per year Emission Factors Condensate Tank Pollutant Uncontrolled :ontrolled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 0.2732 0.0137 Site Specific E.F. (includes flash) Benzene 1.29E-03 6.44E-05 Site Specific E.F. (includes flash) Toluene 1.14E-03 5.68E-05 Site Specific E.F. (includes flash) Ethylbenzene 8.78E-05 4.39E-06 Site Specific E.F. (includes flash) Xylene 3.51E-04 1.76E-05 Site Specific E.F. (includes flash) n -Hexane 6.75E-03 3.37E-04 Site Specific E.F. (includes flash) 224 TMP 0.000 Site Specific E.F. (includes flash) Pollutant Control Device (Waste Stream) Uncontrolled Uncontrolled Emission Factor Source (Ib/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 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (WOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 0.0000 NOx 0.0680 0.0004 CO 0.3100 0.0020 Control Device (Pilot) Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) ( b/MMSCF) (waste heat combusted) (Condensate Throughput) PM10 0.0075 7.4510 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-1 (NOx) AP -42 Table 1.4-1 (CO) PM2.5 0.0075 7.4510 NOx 0.0980 98.0392 CO 0.0824 82.3529 Section 05 - Emissions Inventory Flash VOC Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled itons/year) (tons/year) Requested Pernit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 33.7 0.0 0.0 33.7 1.68 235 0.0 0.0 0.0 0.0 0.0 1 0.0 0.0 0.0 0.0 0.0 1 0.1 0.0 0.0 0.08 0.08 14 0.2 0.0 0.0 0.27 0.27 46 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Pernit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 317 0 0 317 16 280 0 0 280 14 22 0 0 22 1 87 0 0 87 4 1663 0 0 1663 83 224 TMP 0 0 0 0 0 0.166 0.001 0.001 0.000 0.000 0.004 W&B Total 0.107270294 0.000505699 0.000443636 3.44795E-05 0.000137918 0.002654921 Barrels (bbl) per year 0.273 lb/bbl 0.00129 lb/bbl 0 00113 lb/bbl 0.000 lb/bbl 0.000 lb/bbl 0.007 lb/bbl 2 of 18 K:\PA\2018\18W E 1159.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory 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 OOOO Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MAR HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions?111111 If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tor s 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. 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 Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point t$ 001 Process ti SCC Code 01 laildifixed Roof Tank, Condensate, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM 10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.02 0 Ib/1,000 gallons condensate throughput VOC 6.5 95 lb/1,000 gallons condensate throughput CO 0.05 0 lb/1,000 gallons condensate throughput Benzene 0.03 95 lb/1,000 gallons condensate throughput Toluene 0.03 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 0.16 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 18 K:\PA\2018\18WE1159.CP1.xlsm Condensate Tank 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 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, Section II.D.2)? Source rtgwrt5 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 Yes Yes Yes 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 I. 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 noes this storage tank exhibit "Flash" (e g storing non -stabilized liquids) emi«innc and have rtnrnntrnlled artnal nmitsions greater than or equal to ] tons per year VOC? Storage Tank Is not subject to Regulation 7, Section XII.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 — 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 facility', 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 ti, (.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 condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 1, 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 Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ("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 m3 (10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 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"' in 60.11lb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 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 (60.11ob(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 M3 (`472 BBL] but less than 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.110b(b))? Yes Yes No Yu No Yes Yes Yes [No Yes Yes Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Continue - You have indicated the site attainment status on the project summary sheet. Continue - You have indicated the facility type on the project summary sheet. Source is subject Continue - You have determined facility attainment status on the Project Summary sheet. Storage Tank is not subject to Regulation 7, Section XII.G - You have indicated facility type on project summary sheet. Suutce is subject Continue - You have indicated the source category on the Project Summary sheet. Go to the next question - You have indicated facility type on project summary sheet. Go to the next question Source is subject to parts of Regulation 7, Sections XVII.B&C. Go to the next question Source is subject to all provisions of Regulation 7, Section XVII, Subsections B & C Go to the next question Storage Tank is not subject NSPS Kb. Storage Tank is not subject to NSPS Kb Subpart A, General Provisions 560.112b - Emissions Control Standards for VOC §60.113' - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart OOOO, 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 emissions 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 HH? Storage Tank is not subject to NSPS OOOO Yes No No Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures 460.5395(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) 40 CFR, Part 63, Subpart MACT HH, 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"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Stoi,rge lank Is not subject to MACI HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards 463.773 - Monitoring §63.774 - Recordkeeping 463.775 - Repui ling Yes No 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 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 - You have indicated the source category on the Project Summary sheet. Storage Tank is not subject NSPS OOOO - This tank was constructed outside of the applicability dates. Storage Tank is not subject NSPS OOOO. Continue - You have indicated the source category on the Project Summary sheet. Storage Tank is not subject MACT HH - There are no MACT HH requirements for tanks at area sources Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 A008 County Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: One (1) 500 barrel fixed roof produced water storage vessels. Five ;5) vessels are connected via liquid manifold. Enclosed Flare 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 215,820 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 215,820 Requested Permit Limit Throughput = 215,820 Barrels (bbl) per year Requested Monthly Throughput = 18330 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 = 215,820 Barrels (bbl) per year 1496 Btu/scf 36 scf/bbl Actual heat content of waste gas routed to combustion device = 11,623 MMBTU per year Requested heat content of waste gas routed to combustion device = 11,623 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 11,623 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water Throughput) (Produced Water Throughput) VOC 0.262 0.01 Produced Water State E.F. (includes flash) - Front Benzene 0.007 0.000 Produced Water State E.F. (includes flash) - Front Toluene 0.000 Produced Water State E.F. (includes flash) - Front Ethylbenzene 0.000 Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Xylene 0.000 n -Hexane 0.022 0.001 Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front 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-42tabte1.42(PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial =tares (NOx) AP -42 Chapter 13.5tndustrial =tares (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 PM10 PM2.5 NOx CO 28.3 28.3 1.4 28.3 1.4 240 0.0 0.0 0.0 0.0 0.0 7 0.0 0.0 0.0 0.0 0.0 7 0.4 0.4 0.4 0.40 0.40 67 1.8 1.8 1.8 1.80 1.80 306 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 1511 1511 76 1511 76 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 4748 4748 237 474.8 237 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit 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 OOOO (See regulatory applicability worksheet for detailed analysis) 6 of 18 K:\PA\2018\18WE1159.CP1.xlsm 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. YN:nwi-�, r6'Hc?cmurYF,'YF;! 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 destructicn efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 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 lb/1,000 gallons liquid throughput PM2.5 0.01 0 lb/1,000 gallons liquid throughput NOx 0.09 0 lb/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 lb/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 7 of 18 K:\PA\2018\18WE1159.CP1.xlsm 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 Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (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 5 TPY, NOx greater than 10 WY 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 8, 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 facility, natural gas compressor station' 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? Storage tank is subject to Regulation 7, Section XVII, B, C.184 C.3 Yes No Yes 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 Yes 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? Nn Yc•s No No Storage Tank is not subject to NSPS 00OO 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 RAG 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 individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. in the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should, "and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Continue - You have indicated the source category on the Project Summary sheet. Continue - You have indicated the facility type on the Project Summary sheet. Go to the next question Source is subject to parts of Regulation 7, Sections XVII.B&C. Go to the next question Source is subject to all provisions of Regulation 7, Section XVII, Subsections B & C Continue - You have indicated the source category on the Project Summary sheet. Storage Tank is not subject NSPS OOOO - This tank was constructed outside of the applicability date. Storage Tank is not subject NSPS OOOO. Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading 'Facility AIRs ID: 123 County A008 003 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Truck loadout of condensate via submerged fill. Enclosed Flare g5.CC'' Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 246,375 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 246,375 Barrels (bbl) per year Requested Permit Limit Throughput = 246,375 Barrels (bbl) per year Requested Monthly Throughput = 20925 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 = 246,375 Barrels (bbl) per year 2822.7 Btu/scf 240900 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 680 MMBTU per year 680 MMBTU per year 680 MMBTU per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor St AP -42 Chapter 5.2 Table 5.2-1 Submerged Loading: Dedicated Normal Service (S=0.6) P True Vapor Pressure 3.6568 psia AP -42 Chapter 7 Figure 7.1-2 M Molecular Weight of Vapors 68 Ib/Ib-mol AP -42 Chapter 7 Figure 7.1-2 T Liquid Temperature 511.8843116 Rankine L Loading Losses 3.631630167 lb/1000 gallons 0.152530567 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.0048 0.0007 lb/bbl Modeled Flash Gas Composition (HYSYS) Toluene 0.0041 0.0006 lb/bbl Modeled Flash Gas Composition (HYSYS) Ethylbenzene 0.0005 0.0001 lb/bbl Modeled Flash Gas Composition (HYSYS) Xylene 0.0019 0.0003 lb/bbl Modeled Flash Gas Composition (HYSYS) n -Hexane 0.0257 0.0039 lb/bbl Modeled Flash Gas Composition (HYSYS) 224 TMP 0.0000 0.0000 lb/bbl Modeled Flash Gas Composition (HYSYS) Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 0.1525 0.0076 Site Specific - AP -42: Chapter 5.2, Equation 1 Benzene 7.30E-04 3.65E-05 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Toluene 6.25E-04 3.13E-05 Ethylbenzene 7.63E -0S 3.81E-06 Xylene 2.90E-04 1.45E-05 n -Hexane 3.92E-03 1.96E-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 2.06E-05 AP -42 Table 1.4-2 (PM10/PM.2.5) PM2.5 0.0075 2.06E-05 AP -42 Table 1.4-2 (PM10/PM.2.5) AP --42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 industrial Flares (CO) SOx 0.0006 1.62E-06 NOx 0.0680 1.88E-04 CO 0.3100 8.56E-04 90118 K:\PA\2018\18W E 1159.CP1.xlsm 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 Un:ontrolled Controlled (tens/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.02 0.02 0.02 0.02 0.02 4 18.79 18.79 0.94 18.79 0.94 160 0.11 0.11 0.11 0.11 0.11 18 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (:bs/year) (lbs/year) Benzene 180 180 9 180 9 Toluene 154 154 8 154 3 Ethylbenzene 19 19 1 19 1 Xylene 71 71 4 71 4 n -Hexane 966 966 48 966 43 224 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 The loadout must be operated with submerged fill to satisfy RACT. (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? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction effic.ency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes 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 0.00 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 Ib/1,000 gallons transferred Benzene 0.02 95 lb/1,000 gallons transferred Toluene 0.01 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 0.09 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 10 of 18 K:\PA\2018\18WE1159.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet utaro own and e-Pp6NPerRequirements mbinxM x.maminman.nd t nnqmb AU3INM€M i. y oireda yam,. foam Mbindivldual score greater than 3 Tar (Regulator, 3, PaNNSctlon II.O.Le)? 2. let. loadoutll lvetd et enexploretlan andprdu¢ton site re.b pad)(Regularlon 3, Pmte.Sedon 10.1.1)? • Me loader operation loading less than 10.000 gallons (238 ets)of, crude oll par day an as annual average harts? 4. lathe loadoutoperatlon Iodine less than 6,]50666 per year of codensatee vplash RIP 5. Is the loadut operation loading less than 16,208 labia per year of condensate via submerged fill procedure} 6. Are total facidty Ynty luncontrolled�d than.. greater than SIMI Nox greater than 10 TPI, CO emlsslom greater than 101PY(Regulatlon 3, Part 3, Sector Il.03)? . bin On Nowanaba n o Area 6,06.1-rMeltIMNI L Are unmmdl�ed emisYwe from any criteria pollute. from Mrs iMm'dual source greater Oran ll'PV(Regulatim 3,PartA sacral Mt..), a Is the Hadortloot& atan molar.. and productIon site len..vrdi pad)(RyWadon 3, Part a, Sca. nDd.gy Is.!Mout operatco loading lass than 10.000 gallorsig38 BOW of rendetll per day on an annual average basis? Istlrloado topeaaor loading lira than 6,)50 blab pr year Orrmtlensatevia stash RII} Is the !ardour peraIon loading less thanI6,306 hick peryear&condensate Na submerged 60 pradue? 6. Aramalfacile, uncontrolleduncontrolledWCembsbrsfrom thegreaterWn2TPY. NOrt greater than5 TPywro emissions greater than 10 TN (Regulation 3, Part 3, Section lln.3)? IS y. Parr- Are uncontrolled VerCernisstons from the laadout operation greater than 30 toy (Regulation 3, Part e, Serum M.0.2.0, H.. 'ardour mart ago tad with aubman. Hlmsmbfy PALT. Disclaimer This document assists operatorswi. &shoal ugapicaaliydcataln reguirementsdtie Clean irAcl,lts implementing regulations. and RYQualify Control Commission regulations. This craumeetlsnot a5We a regulation, and the analysis itcmisiirs may not apply lo a particular situation based upon the lorryidislhcts and dmumsHnces.T/usdocuma5dms no, change or substitute for any law, regulation, or any other legally beefing requirarementasd isrollegayso/ncaabls It Ma event 03y pct between the lalguagaditts daumentet rte languagedlha Clean NrAct, Its ImpkmettergralWaiars, ant AirouohlyCOVrd Commission regulations, nn language at statute areguiatonwlnwroot The use4fmNmerrdattsykrgtege stsh as Yxonmana"may,'shoud and tars' is ereJm�lro cYscnb3 Ana Weprelatb23S t55ommedatinns. Maretdytermialogy such asgnu, and -required are Wended, Wscn0e corarreirnneiulrma4suu 55555 terms of Ina Clmn Air/Warr Air Qu dy contra Commission regulations. butWYs document clues not estWishlega454345ig rairaremarlsInane ditself rex Go to next Go w thenett�euan'm Go to next question Go to nest quest. Go to next cl.,45to The loaout requresa permit Hoe. c✓,'The Iodout court be spsstd too submer3d no to wee corr. Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County A008 Plant 004 Point Section 02 - Equipment Description Details Flaring of gas from the low pressure separators and vapor recovery towers (VRTs) during vapor recovery unit (VRU) downtime. Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 12.62 MMscf per year Requested Permit Limit Throughput = 12.62 MMscf per year Recuested Monthly Throughput = 1 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Yes Is VRU process equipment: Yes 12.62 MMscf per year Uncontrolled and controlled emiss ons 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: Pilot Flow Rate: Pilot fuel HHV: Section 04 - Emissions Factors & Methodologies Description 2842 Btu/scf scf/bbl 0.37 MMscf/yr 1000 btu/scf 2846.965699 Gas from the low pressure separators and VRTs are combined prior to being routed to the combustor. In the event of LP compressor downtime or VRT compressor downtime, gas is routed to the flare. A single meter is installed that measures the total flow rate of gas to the combustor (i.e. LP gas + VRT gas). Noble I; conservatively calculating emissions assuming the entirety of the gas is represented by the VRT stream composition as predicted in the ProMax model (VRT stream has higher stream VOC weight %). MW 50.64 Weight % Helium 0.00 CO2 0.57 N2 0.02 methane 1.31 ethane 8.95 propane 31.11 isobutane 6.92 n -butane 24.59 isopentane 6.66 n -pentane 8.79 cyclopentane 3.38 n -Hexane 2.47 cyclohexane Other hexanes heptanes 2.95 methylcyclohexane 224-TMP 0.00 Benzene 0.46 Toluene 0.44 Ethylbenzene 0.04 Xylenes 0.15 C8+ Heavies 1.20 Total 100.06 VOC Wt % 89.15 lb/lb-mol Disp acement Equation Ex = Q * MW * Xx / C 12 of 18 K:\PA\2018\18WE1159.CP1.xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 119121.91 5956.10 HYSYS Benzene 618.63 30.93 HYSYS Toluene 583.83 29.19 HYSYS Ethylbenzene 56.04 2.80 HYSYS Xylene 196.17 9.81 HYSYS n -Hexane 3298.97 164.95 HYSYS 224 TMP 0.00 0.00 HYSYS Pollutant Primary Control Device (Waste Gas) Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 21.176 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM1O/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 21.176 SOx 0.0006 1.672 NOx 0.0680 193.256 CO 0.3100 881.020 Primary Control Device (Pilot) Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 7.451 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Table 1.4-1 (NOx) AP -42 Table 1.4-1 (CO) PM2.5 0.0075 7.451 SOx 0.0006 0.588 NOx 0.0980 98.039 CO 0.0824 82.353 Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 0.13 0.13 0.13 0.13 0.13 23 PM2.5 0.13 0.13 0.13 0.13 0.13 23 SOx 0.01 0.01 0.01 0.01 0.01 2 NOx 1.22 1.22 1.22 1.24 1.24 210 VOC 751.46 751.46 37.57 751.16 37.57 6382 CO 5.56 5.56 5.56 5.57 5.57 947 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 7805 7805 390 7805 390 Toluene 7366 7366 368 7366 368 Ethylbenzene 707 707 35 707 35 Xylene 2475 2475 124 2475 124 n -Hexane 41622 41622 2081 41622 2081 224 TMP 0 0 0 0 0 13 of 18 K:\PA\2018\18WE1159.CP1.xlsm Separator Venting Emissions Inventory 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? No If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is 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 Section O8 - Technical Analysis Notes • The gas stream composition used to calculate emissions is based on the modeled VRT flash gas composition from the HYSYS model. Noble is conservatively estimating emissions from the entirety of the metered volume (low pressure separator gas as well as VRT gas) based on the VRT gas composition. This is conservative since the VOC content and molecular weight of the LP gas stream is significantly lower than that of the VRT gas stream. The operator provided a site - specific extended gas analysis collected from the outlet of the VRT. The VOC stream composition HAP composition and MW all w ere lower than what was modeled in the HYSYS simulation and used to develop emission factors and calculate emission limits. As such, there will be no initial sampling requirements included with this permit 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 21.18 0 lb/MMSCF PM2.5 21.18 0 lb/MMSCF SOx 1.67 0 lb/MMSCF NOx 193.26 0 lb/MMSCF VOC 119121.91 95 lb/MMSCF CO 881.02 0 lb/MMSCF Benzene 618.63 95 Ib/MMSCF Toluene 583.83 95 lb/MMSCF Ethylbenzene 56.04 95 Ib/MMSCF Xylene 196.17 95 lb/MMSCF n -Hexane 3298.97 95 Ib/MMSCF 14 of 18 K:\PA\2018\18WE1159.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Non-rIltoinment 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. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit Yes Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Source is subject to Regulation 1, Section XVII.B.2, Ci Yes 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? The control device for this separator is not subject to Regulation 7, Section XV1I.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Yes 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 hehneen the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend." "may," "should," and "can, "is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Source Requires an APEN. Go to the next question Source Requires a permit Source is subject, go to next question The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Noble Energy Inc County AIRS ID 123 Plant AIRS ID A008 Facility Name Shufly State Econode History File Edit Date 4/9/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL New Facility - No Previous Total Previous Permitted Facility total 001 18WE1159 Condensate Tanks 0.1 33.7 0.3 1.1 0.1 1.7 0.3 0.1 New CP 002 18WE1159 Produced water tanks 0.4 28.3 1.8 3.1 0.4 1.4 1.8 0.2 New CP 003 18WE1159 loadout 0.0 18.8 0.1 0.7 0.0 1.0 0.1 0.0 New CP 004 18WE1159 LP/VRT Venting 1.3 751.4 5.6 30.0 1.3 37.6 5.6 1.5 New CP 005 GP02 RICE ENG-6NB05107 0.2 0.2 49.9 2.2 49.9 0.7 3.2 2.3 6.5 0.7 New GP02 006 GP02 RICE ENG-R6S01713 19.5 1.4 19.5 0.5 1.4 1.0 2.8 0.5 New GP02 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 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 0.0 0.0 0.0 0.0 XA Fugitives 0.7 0.7 XA Heaters (2) 0.5 0.4 0.5 0.4 XA FACILITY TOTAL 0.2 0.2 0.0 0.0 71.7 835.8 0.7 77.6 36.1 0.0 0.0 0.0 0.0 6.9 45.0 0.7 17.5 2.9 VOC: Syn Minor (PSD and OP) NOx: Minor CO: Minor HAPS: Syn Minor: n -hexane, total HH: Syn Minor + no TEG dehy ZZZZ: Syn Minor Emissions from all APEN reportable emissions points 0.0 0.0 0.0 0.0 6.4 45.0 0.0 17.1 2.9 Permitted Facility Total 0.0 0.0 0.0 0.0 6.4 45.0 0.0 17.1 2.9 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 6.4 45.0 0.0 17.1 Pubcom required based on new synthetic minor limits. Modeling not required based on project emissions Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 45.7 Facility is eligible for GP02 because < 90 tpy 45.0 Project emissions greater than 25 tpy Note 1 Note 2 Page 16 of 18 Printed 5/1/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy Inc 123 A008 Shufly State Econode 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 18WE1159 Condensate Tanks 317 280 1663 1.1 002 18WE1159 Produced water tanks 1511 4748 3.1 003 18WE1159 loadout 180 966 0.7 004 18WE1159 LP/VRT Venting 7805 7366 707 2475 41622 30.0 005 GP02 RICE ENG-6NB05107 1218 61 57 34 67 0.7 006 GP02 RICE ENG-R6S01713 840 33 31 19 36 0.5 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 0.0 0.0 XA Fugitives TOTAL (tpy) 1.0 0.0 0.0 4.9 3.9 0.4 1.3 24.5 0.1 0.0 0.0 0.0 36.1 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus 17 18WE1159.CP1.xlsm 5/1/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name Noble Energy Inc 123 A008 Shufly State Econode Description 004 005 18WE1159 18WE1159 18WE1159 Condensate Tanks Emissions with controls lbs • er ear Formaldehyde 0 Acetaldehyde 0 Acrolein 0 Benzene 0 16 Produced water tanks loadout 18WE1159 GP02 RICE ENG-6NB05107 RICE ENG-R6S01713 Fugitives 1218 840 61 33 76 9 390 34 19 Toluene 0 14 Ethylbenzene 0 Xylenes 0 n -Hexane 0 368 35 124 83 237 48 2082 McOH 0 224 TMP 0 H2S 0 0 TOTAL (tpy) 1.0 1 0.0 1 0.0 1 0.3 0.2 0.0 0.1 1.2 1 0.1 0.0 0.0 0.0 2.9 18 18WE1159.CP1.xlsm 5/1/2019 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 18WE1159 Issuance: 1 Noble Energy, Inc. Facility Name: Plant AIRS ID: Physical Location: County: Description: Shufly State Y34 -16-A Econode 123/A008 SESE SEC 34 T2N R64W Weld County Well Production Facility Equipment or activity, subject to this permit: Facility Equipment ID AIRS Point Equipment Description' Emissions Control Description Oil Tanks O01 Three (3) 500 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed Flare Produced Water 002 One (1) 500 barrel fixed roof produced water storage vessels. Five (5) vessels are connected via liquid manifold. Enclosed Flare TLO 003 Truck loadout of condensate via submerged fill . Enclosed Flare LP a VRT 004 Flaring of gas from the low pressure separators and vapor recovery towers (VRTs) during vapor recovery unit (VRU) downtime. 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 the specific general terms and conditions included in this document and the following specific terms and conditions. Page 1 of 12 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 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 periodof 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.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Oil Tanks 001 --- --- 1.7 --- Point Produced Water 002 --- --- , 1.4 1.8 Point TLO 003 --- --- 1.0 --- Point Page 2 of 12 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 LP &t VRT 004 --- 1.3 37.6 5.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the liimits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Oil Tanks 001 Enclosed Flare VOC and HAP Produced Water 002 Enclosed Flare VOC and HAP TLO " 003 Enclosed Flare VOC and HAP LP Et VRT 004 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Oil Tanks 001 Condensate throughput 246,375 barrels Produced Water 002 Produced water throughput 215,820 barrels TLO 003 Condensate loaded 246,375 barrels Page 3 of 12 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit LP Et VRT 004 Natural gas venting 12.62 MMSCF The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. Point 004: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented to the enclosed flare from the low pressure separators and vapor recovery towers (VRTs) using an operational continuous flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Point 001, 002, 004: 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) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. Point 001: This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: 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) 13. 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 shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter upon installation of the combustion device. 14. Point 001, 002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and Page 4 of 12 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 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 shall 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. 15. 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. 16. 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 shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B; III.D.2) 17. Point 003: All hydrocarbon liquid loading 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. 18. Point 003: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): The owner or operator shall 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 shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. All compartment hatches at the facility (including thief hatches) shall 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 shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall 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. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 19. Point 003: For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. Page 5 of 12 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado c. 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. 20. 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 pol{ution 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. OPERATING £t MAINTENANCE REQUIREMENTS 21. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 22. Point 001, 002, 004: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R.: Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 23. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 24. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30`h whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t 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 Page 6 of 12 COLORADO Air Pollution Control Division Department of Public Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 25. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 26. 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. 27. 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. 28. 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. 29. 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. Page 7 of 12 COLORADO Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado 30. 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. 31. 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. 32. 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. Bradley Eades Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Synthetic minor well production facility Page 8 of 12 COLORADO Air Pollution Control Division Department of Public Health E) 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tb/yr) Controlled Emissions (lb/yr) Oil Tanks 001 Benzene 71432 317 16 Toluene 108883 280 14 Ethylbenzene 100414 22 1 Xylenes 1330207 87 4 n -Hexane 110543 1,663 83 Produced Water 002 Benzene 71432 1,511 76 n -Hexane 110543 4,748 237 TL0 003 Benzene 71432 180 9 Toluene 108883 154 8 Ethylbenzene 100414 19 1 Xylenes 1330207 71 4 n -Hexane 110543 966 48 Page 9 of 12 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) LP £t VRT OO4 Benzene 71432 78O5 39O Toluene 1O8883 7366 368 Ethylbenzene 1OO414 7O7 35 Xylenes 1330207 2475 124 n -Hexane 11O543 41622 2O82 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportab e 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 OO1: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source. VOC 0.2732 0.0137 Flash Emissions: HYSYS model based on a pressurized liquid sampled 71432 Benzene 1.29E-3 6.44E-5 108883 Toluene 1.14E-3 5.68E-5 9/13/18. Working/Breathing Emissions: Tanks 4.0.9d Model 110543 n -Hexane 6.75E-3 3.37E-4 Note: The controlled emissions factors for this point are based on the enclosed flare control efficiency of 95%. Point OO2: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.2620 0.0131 CDPHE PS Memo 14-03 71432 Benzene 0.007 3.5E-04 110543 n -Hexane 0.022 1.1E-03 Point OO3: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.1526 0.0076 AP 42 n -Hexane 110543 3.92E-3 1.96E-4 Page 10 of 12 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado *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 S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.66 psia M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 512 °R **The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP, as determined by the HYSYS tank flash emission speciation, by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95%. Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 193.26 193.26 AP 42, Chapter 13.5 CO 881.02 881.02 VOC 119,121.91 5,956.10 71432 Benzene 618.63 30.93 HYSYS Model based on a pressurized liquid sample taken 9/13/2018 108883 Toluene .i 583.83 29.19 100414 Ethylbenzene 56.04 2.80 1330207 Xylene 196.17 9.81 110543 n -Hexane 3,298.97 164.95 Note: ! The controlled emissions factors for this point are based on the enclosed combustion device control efficiency of 95%. NOx and CO factors were converted to lb/mmscf using a separator gas heating value of 2,842 BTU/scf. 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 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. Page 11 of 12 COLORADO Air Pollution Control Division Department of Pubilc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane, total HAP NANSR Et PSD Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA Subpart DDD MACT 63:1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 12 of 12 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: �SvJEII51 AIRS ID Number: I 73 /4 008'/ 1)&1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy Inc. Site Name: SHUFLY STATE Y34 -16-A ECONODE T2N-R64W-S34 L01 Site Location: SESE SEC34 T2N R64W 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 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. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 389785 1 ��COLORAUO VVVVVV ofP"^ 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 O Request coverage under a General Permit ❑ GP01 O 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) O Change in equipment ❑ Change company name3 O Change permit limit 0 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 It 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: Condensate Tanks Company equipment Identification No. (optional): For existing sources, operation began on: 08/04/2018 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 Et Production (EEtP) site weeks/year O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? GI Yes ■ No Are Flash Emissions anticipated from these storage tanks? 0 Yes • 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: 0.000251 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 U SI Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualO emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 2 I amCOLORADO I Haa�FiiM1iFxWa t, 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) Condensate Throughput: From what year is the actual annual amount? Average API gravity of sales oil: 57.2 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof 246,375 RVP of sales oil: 7.8 (Ran Tanks at 7.8) O 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 08/2018 API Number Wells -Serviced by this Storage Tank or Tank Battery6 (EEtP Sites Only)~ - Name of Well Newly Reported Well 05 - 123 - 45621 SHUFLY STATE Y34-714 0 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP 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) 40.0885, -104.5308 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F)„ Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑� Upward 0 Downward ❑ Horizontal 0 Other (describe): Indicate the stack opening and size: (check one) ❑p Circular 0 Square/rectangle 0 Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLOR ADO 3 `=r,= F o.:ihi mL•vnncnt Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit tt 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 D Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: VOC & HAPs Rating: MMBtu/hr hr Type: Enclosed Burner(s) Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light:❑ Yes El 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£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 4 psig Describe the separation process between the well and the storage tanks: Liquids go from well to HP separators, then to LP separator, then to VRT, then to the tanks. The pilot emissions associated with the condensate and produced water tanks and load -out are accounted for here (shared) (burners for all). Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 AMY AlpgflcoLoRADo a ofP. Permit Number: AIRS ID Number: VOC [Leave blank unless APCD has already assigned a permit # 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): Description of Control:Method(s) Overall Requested Control Efficiency (% reduction in emissions), 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 Chemical Name VOC Uncontrolled Basis 0.27318 lb/bbl HYSYS/Tanks 4.0.9d Source (AP -42, Mfg. etc) Actual Annual Emissions .> Requested Annual Permit Emission Limit(t) Uncontrolled Emissions (Tons/year) Controlled Emissions$ (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) 33.65 1.68 NOx - 1151b-lf6s- E -0.27 0.2 is CO 0'80'94 Ib/Ib Vee CDPI tE: n�6 Jon Criteria Reportable Pollutant Emissions Inventory - 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 0.00129 lb/bbl HYSYS/Tanks 4.0.9d 317 16 Toluene 108883 0.00114 lb/bbl HYSYS/Tanks 4.0.9d 280 14 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.00675 lb/bbl HYSYS/Tanks 4.0.9d 1,663 83 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 COLORADO ➢ lin ira Pn0lbc Kaaah6E�Mn�nnv.nt 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 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. 11/01/2018 Signature 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: ❑� 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 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-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 I COLOR ADO xuuhs rs 0.-}wtmsnv vof ur.. .uan,nE 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: 1StAIE 115 1 AIRS ID Number: 1Z3 /46Og/6O2. [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: SHUFLY STATE Y34 -16-A ECONODE T2N-R64W-S34 L01 Site Location: SESE SEC34 T2N R64W 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. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I 389787 COLORADO HwVl.b Emitcnmavti Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action Q NEW permit OR newly -reported emission source p 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) O 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 - :I 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 are accounted for in condensate calculations because they are shared burners. 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 08/04/2018 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 a Production (E&P) site weeks/year 0 Midstream or Downstream (non EEtP) 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 2 I mY COLORADO Minna.. o[ ecPutt.F'v�Mw Envhanm mt 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 Limit5 (bbl/year) Produced Water Throughput: 215,820 From what year is the actual annual amount? Tank design: Fixed roof N/A ❑ Internal floating roof O 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 -1 1 500 08/2018 —TIrt ----6— —509.._. -887'Z6a-8— _ Wells Serviced by -this Storage Tank or Tank Battery6 (EEtP Sites On y) API, Number!:... Name of Well .I Newly Reported Well 05 -123 -45621 SHUFLY STATE Y34-714 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EfxP 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) 40.0885, -104.5308 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) ' Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward O Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ['Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 3I 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: MMBtu/hr Type: Enclosed Burner(s) Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ 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£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —145, 25, 4 psig Describe the separation process between the well and the storage tanks: Liquids from well go to HP separators and LP separator feed into the produced water storage tanks. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 4 I A• 'COLORADO x.um r u��r,,.�n� Permit Number: AIRS ID Number: Benzene VOC [Leave blank unless APCD has already assigned a permit # and AIRS ID] 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 overall (or combined) control efficiency (% reduction): Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) 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 Uncontrolled Basis 0.2620 lb/bbl CDPHE Source (AP -42, Mfg., etc.) Actual Annual Emissions Requested Annual Permit Emission Limt(s)5 Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled. Emissions (tons/year) VOC 28.27 1.41 NOx CO 0.0037 0.0094 lb/lb VOC lb/lb VOC CDPHE CDPHE '@-+s©vc1 0.10 0,41 _:'_ .__Non Criteria Repor_table_P_ollutantrEmissions_inventory Chemical Abstract Service (CAS), Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions$ (pounds/year) 71432 0.007 lb/bbl CDPHE 1,511 76 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbl CDPHE 4,748 237 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 O 5 I A� I r &tvi l -- L'e,,L,h& of R:Nc Fi.�.I�H 6 Eml�anm.-t. 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. 1VAI-fA 11/01/2018 Sig ture of Legally Authoriz 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: 0 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-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/cdphe/apcd Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 ( COLORADO 6, AY iF EEm4a emn"i Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU 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: j D N/ [ II51 AIRS ID Number: /7_ /4g/ ©03 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: SHUFLY STATE Y34 -16-A ECONODE T2N-R64W-S34 L01 Site Location: SESE SEC34 T2N R64W 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 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. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 389786 COLORADO E Depatenentof weut Fitr4111B Enaitrneunl 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 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) 0 Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below) OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: c for in condensate tar =e shared burners 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: Truck load -out of condensate Company equipment Identification No. (optional): For existing sources, operation began on: 08/04/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No SI ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • FA Does this source load gasoline into transport vehicles? Yes No ■ 12 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 • A 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 ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2I COLORADO Ilepartn.n1 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: 246,375 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: 3.6568 Psia @ 60 °F Molecular weight of displaced vapors: O 68 lb/lb-mot 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 AAY 'c i ti T:=° 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) 40.0885, -104.5308 Operator Stack 1D No. Discharge Height Above Ground Level. (feet) Temp. (°E) Flow Rate (ACFM) Velocity (ft/sec)- Indicate the direction of the stack outlet: (check one) ❑✓ Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Other (describe): 0 Upward with obstructing raincap Section 6 - Control Device Information ® Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Burner Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr 0 Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I Lpr? (COLORADO Cc vcr _n oCPnl 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: ErnissiOns_Inventory.. - ..._:...-_..:::=:: .:.. __:... - : _:.: - Pollutant_ -. -_.. ...-- Emission Factor .. Actual Annual Emissions . Requested Annual Permit Emission Limit(s)5 .. . .,r.: . , --Uncontrolled_..._ - • - Basis ._.____._.. - Units . $ ource�� __...-- -- -_. _. AP. -4 ( - Mfg., etc.) ' .. Ubcontrolled _ Emissions - (tons/year) .-. Controlled :... Emissions (tons/year) . llncontroiled_;. Emissions:- .. (tons/year) _.m.. ,..... . _Controlled:.__.. .:.Emissions -.. (tons/year) PM SOX NOx CO VOC 0.1526 lb/bbl AP -42 18.79 0.94 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 Emissions 6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0039 lb/bbl AP -42 966 48 2,2,4- Trimethylpentane 540841 Other: 5 Requested values wilt 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 5 IA. COLORADO IIecsstm=n: of P.±& F.., a Emllalrt�url 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. Mature of Legally Authori eCC (not a vendor or consultant) Date 11/01/2018 Janessa Salgado Environmental Engineer Name (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 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 1 AszkvWHuatilt6 EnWoflnxrt 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: 1SwE11-9 AIRS ID Number: 113 /4608'/ 17°4 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Noble Energy Inc. Site Name: SHUFLY STATE Y34 -16-A ECONODE T2N-R64W-S34 L01 Site Location: SESE SEC34 T2N R64W Mailing Address: 1625 Broadway,Suite 2200 (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.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 wilt be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 1 I 389788 COLORADO Depmmern of Put+. HealthE.snmar.Auc4 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 -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: LP and VRT gas streams Company equipment Identification No. (optional): For existing sources, operation began on: 08/04/2018 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Wilt this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year ❑✓ Yes ❑ No ❑ Yes ❑✓ No ❑✓ Yes O No Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 I COLORADO fia•11iu, F7n": 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 #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ Yes ❑ No Vent Gas Heating Value: 2842 BTU/SCF Requested: 12.62 MMSCF/year Actual: MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 50.64 VOC (Weight %) 89.14 Benzene (Weight %) 0.46 Toluene (Weight %) 0.44 Ethylbenzene (Weight %) 0.04 Xylene (Weight %) 0.14 n -Hexane (Weight %) 2.47 2,2,4-Trimethylpentane (Weight %) 0.01 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX It n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Ft 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 wirCOLORADO 3 I e� !=7,= ,;, 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)_ 40.0885, -104.5308 Qperator Stack ID No Discharge Height Above Ground Level (Feet) Temp (, F7 Flow Rae (ACFIvi) loci (fit/sec) Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ® Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: VOC Burner(s) Make/Model: MMBtu/hr Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 4I COLORADO 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 ned) control efficiency (% reduction): Pollutant Description of Control Method(s) ' Overall Requested. Control Efficiency . (% reduction in emissions) PM SOx NOx CO VOC VOC Burner 95% HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory . ,__..._..._ Emission Factor- • :.._._.:.__._ - Actual Annual Emissions , _.._.. _•._. �:•. •.__ ._.•. Requested Annual Permit • Emission.Limit(s,) '-_._.._... .... -Pollutant:::.:.:.:-.P__ _._....._....._...w__....w. _.:...• ..e ..... .:.:.; .. <. - - .. .. ......... _:.__. .... _ ..... :.__...:...._._._.._ ..._....... ,...,._._....e.: _,.... m.. uncontrolled .. .:..:.... .... .... .__ _ _ ::' a;a. :, _..._ Units.., . : _. _;_.. __.. •::: —. ,.__._.._._...__._ '. Source,:;;.:-UncoritrolCed:`:..:" 42, . =. etc.)::: ,..,;-.412,,i _ _.a.__..__.__...____.._..__�.._._-_.._... iss ns•. . Emissions ; __ (tans/year). : .:Coitrolleds iii 6 ... Em7ssions.: =a '{fbrislyear).::E _.__..._.__._-._-.___....._-._._ _.".lJncontrsrlTea` — Emissions.'.... torisl ear ::. ( 3 ). ::' _ `Contolle `':. _ _= .... Emassrons.::.. font .ear . ' t. .. 3� .. -::' PM 7.6 Ib/MMscf AP -42 0.00 0.00 SOx 0::6 lb/MMscf AP -42 0.00 0.00 NOx 0.068, 100 ib/MMBtu,Ib/MMscf AP -42 1.24 1.24 CO 0.31, 84 tb/MMBIu, Ib/MMscf AP -42 5.57 5.57 VOC 119.1116, 0.0055 Ib/Mscf HYSYS, AP -42 751.40 37.57 Non -Criteria Reportable Pollutant Emissions Inventory • ' Chemical Name Chemical. . Abstract Service CA5 • ( ) Number ' Emission Factor ' . Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.). Uncontrolled Emissions (pounds/year) Controlled Emissiions 5" (poundslyear): Benzene 71432 0.6186 Ib/Mscf HYSYS/AP-42 7,805 39D Toluene 108883 0.5838 Ib/Mscf HYSYS/AP-42 7,366 368 Ethylbenzene 100414 0.0561 Ib/Mscf HYSYS/AP-42 707 35 Xylene 1330207 0.1962 Ib/Mscf HYSYS/AP-42 2,475 124 n -Hexane 110543 3.2989 Ib/Mscf HYSYS/AP-42 41,622 2,082 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 - Revision 7/2018 5I A COLORADO Dewy ed of Public HnaUh Ernsio,vlant 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. ovntONA 11/01/2018 Sig ature of Legally Aut orized 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 ❑✓ 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: For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 �y.ICOLORADO 6 I - - ! w Pr—;. Hello