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Home My WebLink About20181253.tiffCOLORADO Department of Public Health & 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 April 10, 2018 Dear Sir or Madam: RECEIVED APR 1 3 2018 WELD COUNTY COMMISSIONERS On April 12, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - Cecil USX A01-63-1HN. 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 & 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 bh RV;Q.t� ©t -if )2f ( ' c.c.. Pt_Cmrvn/ TP), Ht_C3 i ), PW C /3-M/C.K) O -1P19(1$' 2018-1253 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Cecil USX A01-63-1HN - Weld County Notice Period Begins: April 12, 2018 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: Cecil USX A01-63-1 HN Exploration and production SWSW Sec1 T6N R64W Weld County The proposed project or activity is as follows: Existing EF±P facility. For this project, Noble Energy plans to remove the vapor recovery unit (VRU) and route vapors from the LP separator to flares. A new vapor recovery tower (VRT) has also been installed to provide an additional stage of gas/liquid separation. Emissions from the VRT are routed to flares. Noble is also requesting to cancel the GP01 for the condensate tanks at Point 005 and instead permit them with an individual permit. Two engines permitted under GP02s have been removed. 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 17WE0130 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. Any such comment must be submitted in writing to the following addressee: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1LEI ADO Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Betsy Gillard 358097 2/15/2017 4/6/2017 Company Name: Noble Energy, Inc. County AIRS ID: 123 Plant AIRS ID: 9A1E Facility Name: Cecil USX A01-63-1HN Physical Address/Location: SWSW quadrant of Section 1, Township 6N, Range 64W, in Weld County, Colorado 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? Yes If yes, for what pollutant? ❑Carbon Monoxide (CO) OParticulate Matter (PM) phone (NOx & VOC) Weld Quadrant Section Township Range SWSW 6N 64 Section 02 - Emissions Units In Permit Application AIRS Point It Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Natural Gas RICE GP02 Cancellation These points no longer exist at facility 004 Natural Gas RICE GPO2 Cancellation 005 Condensate Tank Condensate Tanks Yes 17WE0132 1 Yes Permit Initial Issuance Previously GPO? 010 Vapor Recovery Tower (VRT) VRT Yes 17WE0132 1 Yes Permit Initial Issuance 011 Separator Venting LP Separator Yes 17WE0132 1 Yes Permit Initial Issuance Section 03 - Description of Project Existing E&P facility. For this project, Noble Energy plans to remove the vapor recovery unit (VRU) and route vapors from the LP separator to flar es. A new vapor recovery tower (VRT) has also been installed to provide an additional stage of gas/liquid separation. Emissions from the VRT are routed to flares. Noble is also requesting, to cancel the GP01 for the condensate tanks at Point 005 and instead permit them with an individual permit. Two en gines permitted underlGP02s have been removed. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Yes Requesting Synthetic € inor Per Section 05 - Ambient Air Impact Analysis Requirements 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? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: SO2 N0x CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ ❑ ❑ O ❑ ❑ ❑ ❑ Non -Attainment New Source Review (NANSR) O 01 Condensate Storage Tank(s) Emissions Inventory Section 01 - Administrative Information (Facility AIRs ID: 123 9A1E 005 County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Six (6) 500 -bbl fixed -roof condesate storage tanks connected by lrquid manifold. Description: Emission Control Device Open Flare Description: Requested Overall VOC & HAP Control Efficiency %: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= 10,200 Barrels (bbl) per year Requested Permit Limit Throughput = 50,200. Barrels (bbl) per year Potential to Emit (PTE) Condensate Throughput = 59,200 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2566. Btu/scf Volume of waste gas emitted per BBL of liquids produced = 6.8 scf/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = Actual Condensate Throughput While Emissions Controls Operating = 50,200 Barrels (bbl) per year 876 MMBTU per year 876 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 876 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) )Ib/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC Benzene Toluene 2.21 0.007 0.006 0.000 0.002 0.039 0.004 0.11 0.00033 0.00029 Ethylbenzene 0.000 0.000 Xylene n -Hexane 224 TMP 0.00196 0.000 Control Device Emission Factor Source Pollutant Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 PM2.5 NOx CO 0.0680 0.3100 0.0000 0.0000 0.0012 0.0054 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) VOC PM10 PM2.5 NOx CO 55.4 55.4 2.8 55.4 2.8 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 0.1 0.1 0.1 0.1 0.1 Hazardous Air 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 Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 0.1657 0.1657 0.0083 0.1657 0.0083 331 17 0.1431 0.1431 0.0072 0,1431 0.0072 286 14 0.0075 0.0075 0.0004 0.0075 0.0004 15 1 0.0502 0.0502 0.0025 0.0502 0.0025 100 5 0.9814 0.9814 0.0491 0.9814 0.0491 1963 98 0.0929 0.0929 0.0046 0.0929 0.0046 186 9 2009 K:\PA\2017\17 W E0130.CP 1. xlsm Condensate Storage Tank(s) Emissions Inventory Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XII.C, D, E, F Regulation 7, Section XII.G, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACE Subpart HA (See regulatory applicability worksheet for detailed analysis) Non -attainment Storage Tank is not subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, Section XII.5 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a! Storage tank is subject to Regulation 7, Section XVII.C,2, as provide Storage Tank is not subject to NSPS Kb Storage Tank is not subject to NSPS 0000 Storage Tank is not subject to MACT RH Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions?Jdpys, If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? 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. Vt lino, 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? V 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 Tank flash emissions are based on a HYSYS Simulation and a site -specific pressurized liquid sample collected 6/O2016. WOO emissions are based on Noble's AP. -42 calculations. These emission factors are higherthan the output from the HYSYS simulation, as Noble opted to use the lb/hr value for flash emissions instead of the Ib/bl value, which results in more conservative emission estimates. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # SCC Code 01 4444041 fl Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.03 0 lb/1,000 gallons condensate throughput VOC 52.6 95 lb/1,000 gallons condensate throughput CO 0.13 0 lb/1,000 gallons condensate throughput Benzene 0.16 95 lb/1,000 gallons condensate throughput Toluene 0.14 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,C00 gallons condensate throughput Xylene 0.05 95 lb/1,000 gallons condensate throughput n -Hexane 0.93 95 lb/1,000 gallons condensate throughput 224 TMP 0.09 95 lb/1,000 gallons condensate throughput 3 of 9 K:\PA\2017\17WE0130.CP1.xlsm coal.Tank Regulatory Analysis workanees NON AllnixonENT Ito .a n,�ewa so cra ern m soeoan nk sum,rwal Performance lorwwuw °tick sn,rasm,aaeve,am • Van, nennmal lux, fun* Clisclaknor 41wNM,wrvrwwre„an ooa:, ralepalNenlaceanh m uw wan, dam cool., Pohwen the larqu.ge drnn ezn,nem dma clean n. Ad. it and An WIM cm avow cmbdeommraxm,apa.,�au eocumen doo3wslo.0 na cluonan lapaxYe.dg reprearrw, e^ rove Produced Natural Gas Venting/Flaring Preliminary Analysis Equipment Description This source vents natural gas from: a VRT Emissions from this source are: routed to an enclosed flare Natural gas venting from a VRT. Emissions from this source are routed to an enclosed flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Colorado Department of Public Health and Environment Air Pollution Control Division Maximum Vent Rate I 683 scf/hr RequestedThroughput (Q) 6 MMscf/yr 683.1 scf/hr I 0.000 MMscf/d I 0.51 MMscf/mol % Vented 100% MW 48.610 Ib/Ib-mol Component mole % MW lbx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 0.63 44.01 0.277 0.006 CO2 0.5 4378 2.19 N2 0 28.013 0.000 0.000 N2 0.0 0 0.00 methane 2.48 16.041 0.398 0.008 methane 0.7 6281 3.14 ethane 16.43 30.063 4.939 0.102 ethane 8.9 77987 38.99 propane 38.5 44.092 16.9754 0.349 propane 30.6 268024 134.01 isobutane 8.47 58.118 4.9226 0.101 isobutane 8.9 77722 38.86 n -butane 24.74 58.118 14.3784 0.296 n -butane 25.9 227019 113.51 isopentane 3.7 72.114 2.6682 0.055 isopentane 4.8 42128 21.06 n -pentane 3.37 72.114 2.4302 0.050 n -pentane 4.4 38371 19.19 cyclopentane 0.62 70.13 0.4348 0.009 cyclopentane 0.8 6865 3.43 n -Hexane 0.3900 86.18 0.3361 0.007 n -Hexane 0.6 5307 2.65 cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.46 100.21 0.4610 0.009 heptanes 0.8 7278 3.64 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.03 114.23 0.0343 0.001 224-TMP 0.1 541 0.27 Benzene 0.07 78.12 0.0547 0.001 Benzene 0.1 863 0.43 Toluene 0.05 92.15 0.0461 0.001 Toluene 0.1 727 0.36 Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00 Xylenes 0.014 106.17 0.0149 0.000 Xylenes 0.0 235 0.12 C8+ Heavies 0.25 95.574 0.2389 0.005 C8+ Heavies 0.4 3773 1.89 100 VOC mass fraction: 0.8845 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control Total unc. VOC Emissions (operator calcs) Controlled VOC emissions (operator calcs) 339.4 17.0 339.6 17.0 Notes Mole %, MW, and mass fractions from HYSYS analysis based off Cecil USX A-01-63-1HN high pressure liquid sample collected 6/1/2016. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. Due to minor rounding issues, these values are not exactly the same as operator calculations. I have included operator calculations to show that they are close enough and therefore considered acceptable. The permit reflects operator calculations. Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Equipment Description Flare to combust VRT c as. Serial Number Gas Heating Value Throughput 2524 15103.616 Btu/scf MMBtu/yr Combustion emission factor source: AP -42: Chapter 13.5 0.068 lb NOX/MMBtu tpy NOX 0.31 2.34 lb CO/MMBtu tpy CO 0.51 Emissions Summary Operator calcs 0.5 tpy NOX 1.3 Uncontrolled/PTE 2.3 tpy CO 3.2 339.4 tpy VOC 339.5 Controlled 17.0 tpy VOC 17.0 2723.12 1.724157078 Uncontrolled Total (Ib/yr) Scenario A Reportable? Controlled Total (lb/yr) Operator Calcs (Ib/yr) Benzene 863 Yes 43 889 44 Toluene 727 Yes 36 800 40 Ethylbenzene 0 No 0 48 2 Xylenes 235 No 12 196 10 n -hexane 5307 Yes 265 5289 264 224-TMP 541 Yes 27 511 26 Emission Factors for Permit meter installed: Uncontrolled NOX 423.0 lb/MMscf CO 1069.4 lb/MMscf VOC 113497 lb/MMscf Benzene 148.637 lb/MMscf Toluene 133.757 lb/MMscf Ethylbenzene 8.025 lb/MMscf Xylenes 32.770 lb/MMscf n -Hexane 884.300 lb/MMscf 224-TMP 85.437 lb/MMscf Controlled NOX 423.0 lb/MMscf CO 1069.4 lb/MMscf VOC 5675 lb/MMscf Benzene 7.43 lb/MMscf Toluene 6.69 lb/MMscf Ethylbenzene 0.40 lb/MMscf Xylenes 1.64 lb/MMscf n -Hexane 44.22 lb/MMscf 224-TMP 4.27 lb/MMscf Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 3 Part B: A permit is required for this source because uncontrolled VOC emissions from this facility exceed two tons per year in a nonattainment area for ozone. This source is subject to Section III.D.2 (Minor Source RACT) because it is located in a nonattainment area. RACT for this source has been determined to be the use of a flare to control emissions. Public comment? AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? no This separator is not subject to Reg 7 Section XVII.G Facility Status This facility is a synthetic minor source of VOC for Title V applicability. This facility is a synthetic minor source of VOC for NSR applicability. Public Comment Required 1 010 011 Uncontrolled Total Controlled Total NOx 1.27 1.79 3.06 3.06 tpy CO 3.2 4.53 7.73 7.73 tpy VOC 339.58 480.9 820.48 41.02 tpy B 889 1260 2149 107 lb/yr T 800 1132 1932 97 lb/yr E 48 67 115 6 lb/yr X 196 277 473 24 lb/yr n -Hex 5289 7491 12780 639 lb/yr 2,2,4-TMP 511 724 1235 62 lb/yr CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0130 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. Cecil USXA01-63-1HN 123/9A1 E SWSW SEC 1 T6N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tanks 005 Six (6) 500 -barrel fixed roof storage vessels used to store condensate Enclosed Flare VRT 010 Vapor Recovery Tower controlled by VOC burner Enclosed Flare LP Separator 011 Low Pressure Separator controlled by VOC burner 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. 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/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. 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 COLORADO Air Pollution Control Division Page 1 of 9 conditions. Failure de nstaCcomp wit da may result in revocation of the permit. A self cert catio orti aft gui.' nc on ho to self :' rtify compliance as required by this permit may e o ine me at ww 6lorado /pacific/cdphe/air-permit-self- certification. (Regulafforf Number 3,==:P t B, Sectfott 1E .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 period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Points 010 and 011: Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from the VRT and separator(s) covered by this permit. Until the flow meter is installed, the operator shall monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 288.8 scf/bbl estimated in the permit application. 5. 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.) 6. 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 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Condensate Tanks 005 -- -- 2.8 -- Point VRT 010 -- 3.1 41.0 7.7 Point LP Separator 011 Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria 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. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division Page 2 of 9 Facility Equipment ID AIRS r; t oint r - ntr Dice Pollutants Controlled Condensate Tanks 005 Enclosed Flare VOC and HAP VRT 010 Enclosed Flare VOC and HAP LP Separator 011 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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 Condensate Tanks 005 Condensate throughput 50,200 barrels VRT 010 Total natural gas vented from VRT and LP 14.5 MMscf LP Separator 011 separator 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. 10. Points 010 and 011: Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the VRT and separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. Point 005: 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 COLORADO Air Pollution Control Division L• Gm.u.r.r.x..+ Page 3 of 9 of visual obervatt f$t he ousj of t close combustion device, or by other means approved I ete , ine the her its operating properly. (Regulation Number 7, Jcti Mate my for .ble)' 14. Point 005: The s orage tan covere y Ifiis permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source 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 005: 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. 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 according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 17. Points 010 and 011: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 18. 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 19. 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) 20. Point 010 and 011: The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation COLORADO Air Pollution Control Division Page 4 of 9 or issuance of this er co ater, hen ral gas vented from the VRT in order to verify t VOC ' b e to. en et b zene: xylenes, n -hexane, and 2,2,4- trimethylpentane . ten we t cti; ) or- is ' ission st am. Results of the Analysis shall be used to calcul. sped fa e pol°its referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 21. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 22. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 23. 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. 24. 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 COLORADO Mr Pollution Control Division PUeA Page 5 of 9 permit must be seared f" m APCD iting ccord ce with the provisions of 25-7- 114.5(12)(a) C.R.S. nd A C e atio." u r er P rt B,--ction III.G. Final authorization cannot be granted til o ratfcln o : ctiv co mences 411d has been verified by the APCD as conforming in f spects;, he pea*. 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. 25. 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. 26. 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. 27. 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. 28. 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. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. COLORADO Air Pollution Control Division Page 6 of 9 Notes to Permit Holder at 1) The permit holder is re fees will be issued of .=r of receipt of the invoice. Failure o pay (Regulation Number 3, Part A, Section VI.B.) this permit. An invoice for these pay the invoice within 30 days in revocation of this permit. 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-reps 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 (Ib/yr) Controlled Emissions (lb/yr) TANK -1 005 Benzene 71432 332 17 Toluene 108883 288 14 Ethylbenzene 100414 16 1 Xylenes 1330207 100 5 n -Hexane 110543 1962 98 2,2,4- Trimethylpentane 540841 184 9 VRT a LP Separator 010 a* 011 (total) Benzene 71432 2149 107 Toluene 108883 1932 97 Ethylbenzene 100414 115 6 Xylenes 1330207 473 24 n -Hexane 110543 12,780 639 2,2,4- Trimethylpentane 540841 1235 62 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Page 7 of 9 5) The emission levels co Point 005: rmit a ing emission factors: CAS # ett1 Pollutant ro Emission Factors (lb/bbl) Co led Emission Factors (lb/bbl) Source V0C 2.21 0.11 HYSYS simulation based on site - specific HP gas sample 71432 Benzene 0.007 3.3E-4 108883 Toluene 0.006 2.9E-4 110543 n -Hexane 0.039 2.0E-3 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. Points 010 It 011: CAS # Pollutant Uncontrolled Emission Factors (Ib/MMscf) Controlled Emission Factors (lb/MMscf) Source N0x 423.0 423.0 AP -42 CO 1069.4 1069.4 V0C 113497 5675 HYSYS simulation based on site - specific HP gas sample 71432 Benzene 148.64 7.43 108883 Toluene 133.76 6.69 1330207 Xylenes 32.77 1.64 110543 n -Hexane 884.30 44.22 540841 2'2'4 Trimethylpentane 85.44 4.27 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 80 °F and separator pressure of 0.5 psig. 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. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: V0C NANSR Synthetic Minor Source of: V0C MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable COLORADO Air Pollution Control Division Page 8 of 9 9) Full text of the Title 4 found at the website lid http://ecfr.gpoaccess, e of Federal Regulations can be Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 9 of 9 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)' Permit Number: 17V/60/34D [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 / 9A1 E / 005 Facility Equipment ID: Condensate Tanks [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01— Administrative Information Company Name: Source Name: Noble Energy, Inc. Cecil USX A01-63-1HN Source Location: SWSW SEC1 T6N R64W Mailing Address: 1625 Broadway, Suite 2200 Person To Contact: Denver, CO NAICS, or 1311 SIC Code: County: WELD Elevation: 4,600 Feet ZIP Code: 80202 Gabriela Vega Phone Number: 303-228-4475 E-mail Address: Gabriela.Vega@nblenergy.com Fax Number: 303-228-4286 Section 03 — General Information For existing sources, operation began on: This Storage Tank is Located at: Exploration & Production (E&P) Site Will this equipment be operated in any NAAQS nonattainment area? Is actual annual average hydrocarbon liquid throughput > 500 bbl/day? ► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ► Are you requesting > 6 ton/yr VOC emissions, or are uncontrolled actual emissions > 6 ton/yr? General description of equipment purpose: Condensate Tank Battery Section 04 — StoraEe Tank(s) Information Condensate Requested Permit Limit: 50,200 bbl/year Throughput: Actual: bbllyear Average API Gravity of Sales Oil: 68.5 degrees Tank Design: Fixed Roof: ❑ Internal Floating Roof: / / 2012 Midstream or Downstream (Non-E&P) Site Yes ❑ No Yes El No Section 02 — Requested Action (Check applicable request boxes) ❑ Request for NEW INDIVIDUAL permit ❑ Request for coverage under GENERAL PERMIT ❑ GP01 El GP0S ❑ Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) O Change process or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership El Other ❑ APEN Submittal for Permit Exempt/Grandfathered source ❑ APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Info. Change existing GP01 to an Individual Permit & Notes: For new or reconstructed sources, the projected startup date is: hours/ day Are Flash Emissions anticipated at these tanks If "yes", identify the stock tank gas -to -oil ratio: Normal Hours of Source Operation: Actual While Controls Operational: RVP of Sales Oil O External Floating Roof: bbl/year 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) 6 3000 2012 Aug/2012 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 34657 CECIL USX A01-63-1HN ■ 05 - 123 - 34661 CECIL USX A01 -6311N ❑ 05 - 123 - 34664 CECIL USX A01-64-1HN 9 ■ CI 24 7 / / days/ week 52 weeks/ year ® Yes ❑ No 0.007 m3/liter ❑ Yes ® No • Yes ❑ No Colorado Department of Public Health and Environment Air Pollution Control Division (APCD)This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 per APEN for non- E&P, midstream and downstream sources or 52.90 for up to five (5) APENs for E&P sources and $250,rofeach general permit registration to: r' /. Colorado Department of Public Health&,Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For guidance on how to complete this APEN form: Air Pollution Control Division: (303) 692-3150 Small Business Assistance Program (SBAP): (303) 692-3148 or (303) 692-3175 APEN forms: http://www.colorado.gov/cdphe/oilgasAPENS Application status: http://www.colorado.gov/cdphe/permitstatus F -7 2017 FORM APCD-205 358095 Page 1 of 2 Condensate-Tanks-APEN AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Permit Number: Emission Source AIRS ID: 123 / 91AE / 005 Section 05 — Stack Information (For Midstream sites onl Operator Stack ID No. Stack Base Elevation (feet) Stack Height Above Ground Level (feet) Temp. (OF) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) Direction of stack outlet (check one): ❑ Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = ion 07 — Control Device Information Section 06 -Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Easting or Longitude (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) J -104.5069 40.5112 ❑ Horizontal El Down El Other: Length (inches) = ❑ Other (Describe): Width (inches) = • Vapor Recovery Unit (VRU) used for control of the Storage Tank(s) Size: Make/Model: /i/ Combustion Device used for control of the Storage Type: VOC Burner Tank(s) Make/Model 95 % Rating: MMBtu/hr Requested VOC & HAP Control Efficiency: % % VOC & HAP Control Efficiency: Requested: Minimum temp. to achieve requested control: Constant pilot light? ■ Yes ■ No Manufacturer Guaranteed: % Annual time that VRU is bypassed (emissions vented): °F Waste gas heat content: Btu/scf MMBtu/hr • Closed loop system used for control of the storage tank(s) Description: Pilot burner rating: ■ Describe Any Other: Section 08 — Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3 psig Please describe the separation process between the well and the storage tanks: Gas from well head to HP separator, then LP separator, then VRT and then storage tanks Section 09 — Emissions Inventory Information & Emission Control Information Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput in Sec. 04 (e.g. 2007): Pollutant Emission Factor Actual Calendar Year Emission2 Requested Permitted Emissions Emission Factor Data Source Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) (Tons/Year) Controlled (Tons/Year) NOx VOC 2.21 lb/bbl 55.41 2.77 Hysys / AP42 CO Benzene 0.007 lb/bbl 0.17 0.01 Hysys / AP42 Toluene 0.006 lb/bbl 0.14 0.01 Hysys / AP42 Ethylbenzene Xylenes n -Hexane 0.039 lb/bbl 0.98 0.05 Hysys / AP42 2,2,4-Trimethylpentane Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Section 10 —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 cpyerage 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. O/2eI1- C,k_ i 2 Gabriela Vega nature of Person Legally A rho 'zed to Supply Data Date Name of Legally Authorized Person (Please print) You may be charged an additional APEN fee for APEN re -submittal due to incorrectly filled -out APEN or missing information. Annual emissions fees will be based on actual emissions reported here. Additional Information Required: Attach a pressurized pre -flash condensate extended liquids analysis, RVP & API analysis of the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results) Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses Environmental Engineer HI Title Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. FORM APCD-205 Page 2 of 2 Condensate-Tanks-APEN Natural 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 Natural Gas Venting only. Natural 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. 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: 17WE0130 AIRS ID Number: 123 /9A1E/ E/ 010 [Leave blank unless APCD has already assigned a permit r7 and AIRS ID] Company equipment Identification: LP Separator [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: Cecil USX A01-63-1 HN Site Location: SWSW SEC1 T6N R64W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver CO 80202 E -Mail Address'-: gabriela.vega@nblenergy.com Site Location County: Weld NAiCS or SIC Code: 1311 Permit Contact: Gabriela Vega Phone Number: 303-228-4475 'Please 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 APCD via e-mail to the address provided. Form APCD-2O5 - Natural Gas Venting APEN - Rev 03/2017 COLORADO 1I Permit Number: 17WE0130 AIRS ID Number: 123 /9A1E/ / 010 [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 2- Requested Action Q NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below) -OR - ❑ APEN submittal for update only (Please 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: 3 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: VRT For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / / / 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 days/week Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions 52 weeks/year O Yes ❑ No O Yes 9 No COLORADO Farm APCD-205 Natural Gas Ve,3tina APEN Rev 03/2017 2 I Permit Number: 17WE0130 AIRS ID Number: 123 /9A1 Et / 010 [Leave blank unless APCD has already assigned a permit C and AIR'S ID] Section 4 - Process Equipment Information Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: # of Pistons: Volume per event: Capacity: Leak Rate: Gal/min Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 9 Yes 0 No Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: Maximum Vent Rate: 683 SCF/hr Vent Gas Heating Value: 2723 BTU/SCF Requested: 5.834 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbt/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 80.47 VOC (Weight %) 88.45 Benzene (mole %) Q.07 Benzene (Weight %) 0.12 Toluene (mole %) 0.05 Toluene (Weight %) 0.10 Ethylbenzene (mole %) 0.00 Ethylbenzene (Weight %) 0.01 Xytene (mole %) 0.01 Xyiene (Weight %) 0.03 n -Hexane (mole %) Q.39 n -Hexane (Weight %) 0.69 2,2,4-Trimethylpentane (mole %) 0.03 2,2,4-Trimethylpentane (Weight %) 0.07 Additional Required Information: • Attach a representative gas analysis (including BTEX 8 n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 0 Form ARCD-2O5 -Natural Gas Venting APEN Rev 03/2017 $ COio RADD Permit Number: 17WE0130 AIRS ID Number: 123 / 9A1 E / 010 [ e, -.Ye blank unless APCD has already assigned a permit 4 and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.5112, -104.5069 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity {pt/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): O Upward with obstructing raincap Section 6 - Control Device information O VRU: Pollutants Controlled: Size: Make /Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane Rating: MMBtu/hr Type: VOC Burner Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: 95% Waste Gas Heat Content Constant Pilot Light: O Yes O No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-205 -Natural Ga,'Yen:ing APEN - Rev 03!2017 4I COLORADO Permit Number: 17WE0130 AIRS ID Number: 123 / 9A1 Et 010 ['w ave blank unless APCD has already assigned a penrni' t? and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? [] Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO, NO. VOC VOC Burner 95% CO HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit , ErnISSion Ltmtt(s)5 _".. Uncontrolled (Tans/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM 0.000 lb/mscf HYSYS/AP42 0.00 0.00 SOx 0.000 lb/rnmSCf HYSYS/AP42 0.00 0.00 NO„ 0.423 lb/mscf HYSYS/AP42 1.266 1.266 VOC 113.5 lb/mscf HYSYS/AP42 339.583 16.98 CO 1.069 lb/mscf HYSYS/AP42 3.200 3.200 Benzene 0.149 lb/mSCf HYSYS/AP42 0.445 0.022 Toluene 0.134 lb/mscf HYSYS/AP42 0.400 0.020 Ethytbenzene 0.008 lb/mscf HYSYS/AP42 0.024 0.001 Xylenes 0.033 lb/mscf HYSYS/AP42 0.098 0.005 n -Hexane 0.884 lb/mscf HYSYS/AP42 2.645 0.132 2,2,4-0.085 Trimethylpentane0.256 lb/mscf HYSYS/AP42 0.013 Other: 5 Requested values will become permit limitations. Requested timit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 •Hatur a Gas Venting APEN Rev 03/2017 5l COLORADO Permit Number: 1 7WE01 30 [Leave blank unless APCD dv atread AIRS ID Number: 123 / 9A1 E / 010 geed a permit and AIRS ID] Section 8 - Applicant Certification I tyereby certify that all information contained herein and information submitted with this application is complete, true d cart- t. } Aignature of Legally Authorized Person (not a v ndor or consultant) Gabriela Vega 03/23/2017 Date 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) Send this form along with $152.90 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 Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting ADEN - Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/aped COLORADO Natural 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 Natural Gas Venting only. Natural 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. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/aocd. 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: 17WE0130 AIRS ID Number: 123 / 9A1 E/ 011 [Leave blank unless APCD has already assigned a permit u and AIRS ID) Company equipment Identification: LP Separator [Provide Facility Equipment ID to identify how this equipment is referenced within your organization} Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: Cecil USX A01-63-1 HN Site Location: SWSW SEC1 T6N R64W Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200 Denver CO 80202 E -Mail Address': gabriela.vega@nblenergy.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Gabriela Vega Phone Number: 303-228-4475 'Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on alt documents issued by the APCD. Any changes wilt require additional paperwork. Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. COLORADO Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 Permit Number: 17 WE0130 AIRS ID Number: 123 i 9A1 E / 011 [Leave blank unless :a.PCD has already assi red a permit 7 and AIRS ID] Section 2- Requested Action O NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership3 0 Other (describe below) -OR - [] APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 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 Separator For existing sources, operation began on: 1 / For new or reconstructed sources, the projected start-up date is: 1 / 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 hours/day 7 days/week Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions • Yes O Yes Form APCD-2O5 -Natural Gas Venting APEN Rev 03/2017 2 52 weeks/year ❑ No 0 No coLORADO Permit Number: 17WE0130 AIRS ID Number: 123 /9A1 E/ 011 [Leave blank unless A?CD has already assigned a permit r and AIRS ID] Section 4 - Process Equipment Information [j 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 Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 9 Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 967 SCF/hr Vent Gas Heating Value: 2723 BTU/SCF Requested: 8.474 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbt/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 80.47 VOC (Weight %) 88.45 Benzene (mole %) 0.07 Benzene (Weight %) 0.12 Toluene (mole %) 0.05 Toluene (Weight %) 0.10 Ethylbenzene (mole %) 0.00 Ethylbenzene (Weight %) 0.01 Xylene (mote %) 0.01 Xylene (Weight %) 0.03 n -Hexane (mote %) 0,39 n -Hexane (Weight %) 0.69 2,2,4-Trimethylpentane (mole %) 0.03 2,2,4 Trimethylpentane (Weight %) 0.07 Additional Required Information: • Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 3 no Permit Number: 17WE0130 AIRS ID Number: 123 / 9A1 E / 011 [Leave 5ar.k Limes s APCD has already assured a permit a and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.5112, -104.5069 Operator 9 Stack ID No. Discharge Height Above Ground Level (Feet) Temp '. (`F) Flow Rate (ACFM) Velocity �� (fusee) '. Indicate the direction of the stack outlet: (check one) [ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, Benzene, Hexane, Toluene, Xylenes, 224-Mpentane Rating: MMBtu/hr Type: VOC Burner Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Make/Model: 95% % Waste Gas Heat Content Constant Pilot Light: O Yes O No Pilot burner Rating Btu/scf MMBtu/ hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-205 -Natur <al. Gas Venting APED Rev 0312017 41 Permit Number: 17WEO13O AIRS ID Number: 123 r 9A1 Er 011 [Leave. blank unless APCD has already :. s igned .a uerr,mt and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Q Yes © No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM S0x NOx VOC VOC Burner 95% CO HAPs VOC Burner 95% Other: From what year is the following reported actual annual emissions data? N/A Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant PM Uncontrolled Emission Factor 0.000 Emission Factor Units lb/mscf Emission Factor Source (AP -42, Mfg. etc) HYSYS/AP42 Annual Emu Requested Antwat-Petri-1i sion Limit{s)s Uncontrolled (Tonsiyear) Controlled6 (Tons/year) Uncontrolled (Tons/year) 0.00 Controlled (Tons/year) 0.00 Sox 0.000 lb/mmscf HYSYS/AP42 0.00 0.00 NO), 0.422 lb/mscf HYSYS/AP42 1.788 1.788 VOC 113.5 lb/mscf HYSYS/AP42 480.912 24.046 CO 1.069 lb/mscf HYSYS/AP42 4.528 4.528 Benzene 0.149 lb/mscf HYSYS/AP42 0.630 0.031 Toluene 0.134 lb/mscf HYSYS/AP42 0.566 0.028 Ethytbenzene 0.008 lb/mscf HYSYS/AP42 0.034 0.002 Xyienes 0.033 lb/mscf HYSYS/AP42 0.139 0.007 n -Hexane 0.884 lb/mscf HYSYS/AP42 3.745 0.187 2,2,4- Trimethylpentane Other: 0.085 lb/mscf HYSYS/AP42 0.362 0.018 5 Requested values will become permit limitations. Requested limits) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting APED. Rev 03/2017 Awry COLORADO Permit Number: 17WE0130 AIRS ID Number: 123 / 9A1 E/ 011 [leave blank unless APCD has already assi?ned 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 andrelorrect. 03/23/2017 Signature of Legally Authorized Person (not a vendor or consultant) Date Gabriela Vega Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: [] Draft permit prior to issuance 9 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 6 Hello