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Home My WebLink About20182673.tiffCOLORADO Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 August 14, 2018 Dear Sir or Madam: RECEIVED AUG 2 0 2018 WELD COUNTY COMMISSIONERS On August 16, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - LC11-15 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 &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe John W. Hickenlooper, Governor I Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer R e vntA 02- A:1-18 c e : PL lAtitITPP, t+L(ST), p,J(ER! C14IThICK) pg-ao-l8 2018-2673 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - LC11-15 ECONODE - Weld County Notice Period Begins: August 16, 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: LC11-15 ECONODE Oil Et Gas Wellsite SWSE SEC 11 T9N R59W Weld County The proposed project or activity is as follows: Oil &t Gas separation 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 17WE1151 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: Christopher Kester Colorado Department of Public Hesalth and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Christopher tester Package if: 370530 Received Date: 10/30/2017 Review Start Date: 1/11/2018 Section 01 - Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: LC11-.15 ECONODE Physical Address/Locatio SWSE quadrant of Section 11, Township 9N, Range 59W, 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? No If yes, for what pollutant? Don Monoxide (CO) IiNiate Matter (PM) Dne (NOx & VOC) Noble Energy, Inc. 123 9FOE Weld Quadrant Section Township Range SWSE 11 RN 59 Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001-008 - Natural Gas RICE - Various Names Yes GP02 1 - - No Permit Initial Issuance 009 Produced Water Tank PW Tanks Yes 17WE1151 1 yes Permit Initial Issuance 010 - Hydrocarbon Liquid loading Truck Load Out Yes 17WE1151 1 Yes Pertotal Issuance - - 011 Separator Venting LP VOC Burners Cancellation CN before permit issued 012 - - Condensate Tank Cond Tanks Yes 17WE1151 1 Yes Permit initial Issuance 013 Separator Venting VRT VOC Burners Yes 17WE1151 1 Yes Permit initial Issuance Section 03 - Description of Project New synthetic minor well production facility proposed in an attainment area of Weld County. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Eye Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P50) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? Yes _..... SO2 NOx CO VOC PM2.5 PM10 TSP HAPs J El El Colorado Air Permitting Project If yes, explain what programs and which pollutants herr SO2 Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: 123 9F51 County Plan 009 Pant Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device losedqurnE Description: ; Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = ,GCO Barrels (bbl) per year S;Of,.. Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= )13 2948': Btu/scf Volume of waste gas emitted per BBL of liquid produced = d: scf/bbl Actual heat content of waste gas routed to combustion device Requested heat content of waste gas routed to combustion device = 3,242 MMBTU per year 3,242 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 3,242 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 0.013100 0.000350 0.000000 0.000000 0.000000 0.001100 Benzene Toluene #0, Ethyibenzene Xylene n -Hexane 224 TMP 0.000 Control Device Pollutant Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (Produced (waste heat Water combusted) Throughput) Emission Factor Source PM10 PM2.5 0.0000 0.0000 0.0000 0.0000 NOx CO 0.0680='_.. 0.3100..... ,.... 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 124.5 124.5 6.2 124.5 6.22 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 0.5 0.5 0.5 0.5 0.5 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 Toluene . Ethylbenzene Xylene n -Hexane 224TMP 6650 6650 333 6650 333 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 20900 20900 1045 20900 1045 0 0 0 0 0 Section 06 - Regulate Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C3 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 HOPS 0000 (See regulatory applicability worksheet for detailed analysis) Summa Analysis 3 of 16 K:\PA\2017\ 17WE1151.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, an 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 fadlity has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. r. 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. 7 Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point it Process ti 5CC Code 009 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.01 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.03 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 16/1,000 gallons liquid throughput 4 of 16 K:\PA\2017\17W E1151.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 Re ug lotion 3 Parts A and B - APEN and Permit Requirements 'Source is in the 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 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'Source requires a permit 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 5 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area 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 stations 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.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements S. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. IStorage tank is subject to Regulation' 7, Section XV€I.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, 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? I Storage Tank is not subject to NSPS OOOO Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures §60.5395(8) - 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 NSP5 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)(2j even if potential VOC emissions drop below 6 tons per year] RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the 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. No Yes Yes IN Source Req Go to next Source Req Continue -' Continue -' Go to then Source Is st Continue -' Storage Tar Hydrocarbon Loadout Emissions Inventory Section 01- Administrative Information Facility AIRs ID: nlf Plant Poin Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: densafeT: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = 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 rotted to combustion device = 500' Barrels (bbl) per year Barrels (bbl) per year 00: Barrels (bbl) per year Btu/scf 40999 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 I = 12.46•S•P•M/T Actual Volume Loaded While Emissions Controls Operating = 53 MMBTU per year 53 MMBTU per year 53 MMBTU per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor 0.6 .5 ��'//�ii%,.,.%/iry. " AP�§z<Lf&-gster 9t�F1j"1� � .., -�r32il'5ef`SG2 P True Vapor Pressure 2.82296 psia ilP-i#2 g11111,'�i''a M Molecular Weight of Vapors ,l,.'69' +Ib/Ib-mol AP -42..'.'.;.... T Liquid Temperature %S.12:1228 < Rankine P. frt02t-" L Loading Losses 2.843473931lb/1000 gallons 0.119425905 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.01359 0.001820423 lb/bbl Flash Emission Specsatson Toluene 0.00467 0.000625561 lb/bbl FlasSt's.ErniSSionSpeciation Ethylbenzene 0.00039 5.22417E-05 lb/bbl Flash Emission 5petiat, on Xylene 0.00106 0.00014199 lb/bbl Hash Emission Specsation n -Hexane 0.06945 0.009303044 lb/bbl Flash : a s' nn Speciation 224TMP 0.00207 0.000277283 lb/bbl Hash EmissionSpedation Emission Factors Pollutant VOC 0:1194 0.005971 Hydrocarbon Loadout Uncontrolled Controlled (Ib/bbl) (Volume Loaded) Benzene i 0.0018 Toluene - -0.0006 (Ib/bbl) (Volume Loaded) 0.000091 0.000031 0.000003 0.000007 0.000465 0.000014 Ethylben ere 0.00005 Xylene 0.000141. n -Hexane 224 TMP 0:009: 0.000. 8'd Pollutant PM10 Control Device Uncontrolled (Ib/MMBtu) Uncontrolled (Ib/bbl) (Volume Loaded) 0.00800 Emission Factor Source Emission Factor Source 6 of 16 K:\PA\2017\17 W E1151.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 Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 Sox NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.73 3.73 0.19 3.73 0.19 0.01 0.01 0.01 0.01 0.01 Hazardous Alr 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 Toluene Ethylbenzene Xylene n -Hexane 224TMP 114 114 6 114 6 39 39 2 39 2 3 3 0 3 0 9 9 0 9 0 581 581 29 981 29 17 17 1 17 1 Section 06- Reevulatory Summary Analyyis Regulation 3, Parts A, B Source requires a permit RACF- Regulation 3, Part B, Section I II.D.2.a In attainment area, RACF does not apply (See regulatory applicability worksheet for detailed analysis) Section 07- Initial and PeriodicSampling 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 efficiency of the combustion device based on inlet and outlet concentration sampling Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process# 5CC Code 010 01 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 5Ox 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 2.8 95 lb/1,000 gallons transferred CO 0.01 0 lb/1,000 gallons transferred Benzene 0.04 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 0.00 95 lb/1,000 gallons transferred n -Hexane 0.22 95 lb/1,000 gallons transferred 224 TMP 0.01 95 lb/1,000 gallons transferred 7 of 16 K:\PA\2017\ 17WE1151.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPS, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? IYou have indicated that source is in the Attainment Area 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? YES �x� tz� Not enough information Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Go to next Go to the n Go to next Go to next Go to next The loadou Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughpu 2S00,000i Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = '1Barrels (bbl) per year ,000; Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas- 2948,2.S.i Btu/scf Volume of waste gas emitted per BBL of liquids produced = cf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 6,812 MM BTU per year 6,812 MM BTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 6,812 MMBTU per year Section 04- Emissions Factors & Methodologies Will thisstorage tank emit flash emissions? Pollutant Nowarr Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Condensate Throughput) 0.35850 0.00257 00088' 0.00007 0.00013...... Pollutant 0.00050 (Condensate Throughput) 0.00843 0.00013 0.00004 0.00000 0.00001 0.00066 0.00003 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (lb/bbl) 0:31B0 (Condensate Throughput) 0.0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source 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 210.6 210.6 10.5 210.6 10.5 PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 NOx 0.2 0.2 0.2 0.2 0.2 CO 1.1 1.1 1.1 1.1 1.1 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled _ Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 6419 6419 321 6419 321 Toluene 2205 2205 110 2205 110 Ethylbenzene 186 186 9 186 9 Xylene 337 337 17 337 17 n -Hexane 32811 32811 1641 32811 1641 224 IMP 1250 1250 63 1250 63 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 not 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, NIPS Subpart Kb Storage Tank is not subject to NIPS Kb Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Not enough information (See regulatory applicability worksheet for detailed analysis) 9 of 16 K:\PA\2017\17WE1151.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons V0C per year? „q 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 maybe 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 combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 -Technical Analysis Notes A NYSVS simu4tiomwas generated psing4inputstreams from representative samples.These streams are then flashed at the LP separators, V0RT, and finally theTanlrs In the.sfmulation to estimate the composition and emission factors of each of these paints. AIRS Point # Process # SCC Code 012 01 ivy Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 Ib/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput N0x 0.00 0 Ib/1,000 gallons condensate throughput V0C 4.0 95 lb/1,000 gallons condensate throughput CO 0.02 0 lb/1,000 gallons condensate throughput Benzene 0.06 95 lb/1,000 gallons condensate throughput Toluene 0.02 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.00 95 lb/1,000 gallons condensate throughput n -Hexane 0.31 95 lb/1,000 gallons condensate throughput 224 TMP 0.01 95 lb/1,000 gallons condensate throughput 10 of 16 K:\PA\2017\17 W E1151.CP1.xl sm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Sounsr is in the 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 ll.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 5 TPY, NOx greater than 10 TPV or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? ISeurcei requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation3, Part A, Section ll.D.I.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 from the greater than 2 TPV, N0x greater than 5 TPY or CO emissions greater than 5 TPV (Regulation 3, Part B, Section II.D.2)? 'Yon have indicated that source is in the Attainment Area 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 not subject to Regulation 7, Section X.il.C-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII,C.2 — Emission Estimation Procedures Section XII.D— Emissions Control Requirements Section XII.E -Monitoring Section XII.F—Recordkeeping and Reporting Colorado Regulation 7, Section 111.0 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. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? 'Storage 'Tank is not subject to Regulation 'l, Sectier, 011.0 Section X11.1.2 - Emissions Control Requirements Section XIl.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? I Storage tank is subject 3:o Regulation 7, Secrinn 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? IStorage tank is sinb(r:ct to Regulation 7, Section 0011.0.2 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 (m') ("472 Kits)? 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 m5 (-10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) afterluly 23, 1984? 4.Does the tank meet the definition of "storage vessel' in 60.11167 5, Does the storage vessel store a "volatile organic liquid (VOW' as defined in 60.1116? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 kPa ("29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity Is greater than or equal to 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.1106(6))7; or c. The design capacity is greater than or equal to 75 Ma (`472 BBL) but less than 151 ms ]-950 BBL] and stares a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11oh(b))? "Storage Yang in not ilj,f.t to NOPS Kb Subpart A, General Provisions 460.112h - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations fin Ye=. No No No Yes MINIM Source Req Go to next Source Req Storage Tar Storage Tar Storage Tao continue-' Go to then Go to then Source Is st Storage Tar 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC 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 stora a vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art 66? I5tarage 'Foch is not subject to NIPS 0000 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 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NIPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACE 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: e. A facility that processes, upgrades or stores hydrocarbon liquids' (63.7601a)(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 toe final end user' (63.760(")(3))? 2. Is the tank located at a facility that Is major' for OAPs? 3. Does the tank meet the definition of "storage vessel"' In 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Not enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards 463.773 - Monitoring §63.774-Recordkeeping §63.775 - Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review 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 note 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 Yen Continue -' Storage Tar Continue -' Separator Venting Emissions Inventory Section 01- Administrative Information 'Facility AIRS ID: 123 9F6E Plant Point Section 02 - Equipment Description Details One (1) Vapor Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: t??. Tower (VRT) 21,0 MMscf per year 21.D' MMscf per year 21 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04- Emissions Factors & Methodologies Displacement Equation Ex=Q"MW"00/C MW ..... 47-45 Weight % Helium CO2 ,074 N2 1,48 methane 2.01:. ethane 2,03 O propane 33:11. isobutane : 631 n -butane ......23.34 isopentane 6,31 n -pentane 8.44 cyclopentane 0.44 n -Hexane 1.85 cyclohexane 0.47. Other hexanes 2.27'. heptanes 1 40 methylcyclohexane 0.13! 224-TMP 0.02 Benzene 0.23- Toluene 0..25: Ethylbenzene 0.30 Xylenes 0.01 C8+ Heavies 0.14 Total VOC Wt % 110.00 80.26 Btu/scf scf/bbl b/Ib-mol •d at the. LP separators, VRT„and finally!the Tanks in the simola ate the co pasitionand'-- 13 of 16 K:\PA\2017\17WE1151.CP1xlsm Separator Venting Emissions Inventory Emission Factors Separator Venting Pollutant Uncontrolled Controlled (Ib/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) Emission Factor Source VOC 106839 315.514 63.779 5.639 17.041 5342 15.776 3.189 0.282 0.852 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 2317.738 115.887 21.803 1.090 Emission Factor Source Pollutant Primary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 0.0000000 0.0000000 0.0000000 505 005 CO 182.766 833.199 100'' Section 05 - Emissions Inventor/ 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) PM10 PM2.5 SOx 000 VOC CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.92 1.92 1.92 1.92 1.92 1121.81 1121.81 56.09 1121.81 56.09 8.75 8.75 8.75 8.75 8.75 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Em scions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year( fibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 6626 6626 331 6626 331 1339 1339 67 1339 67 118 118 6 118 6 358 358 18 358 18 48672 48672 2434 48672 2434 458 458 23 458 23 Section 06 - Regulator/ Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVIl.8.2.e 107329 5366.45 315.7 15.785 2318.8 115.94 63.7 3.185 5.6 0.28 17.1 0.855 21.7 1.085 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. 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?n 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? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas yen The following questions do not require an answe tjt-'""I'" 14 of 16 K:\PA\2017\17W E1151.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 013 Process # 5CC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 Ib/MMSCF PM2.5 0,00 0 Ib/MMSCF 5Ox 0.00 0 Ib/MMSCF NOx 182.77 0 lh/MMSCF VOC 106838.84 95 Ib/MMSCF CO 833.20 0 lb/MMSCF Benzene 315.51 95 Ib/MMSCF Toluene 83.78 95 Ib/MMSCF Ethylhenzene 5,64 95 Ib/MMSCF Xylene 17.04 95 Ib/MMSCF n -Hexane 2317.74 95 lb/MMSCF 224 TMP 21.80 95 Ib/MMSCF 15 of 16 K:\PA\2017\ 17WE1151.CP1.xlsm Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the 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. 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)? 'Source requires a permit 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 5 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area 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 7, Section XVII.R.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control 'Optional Section). a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this separator is not subject to Regulation 7, Section XVIl.B.2.e Section XVII.B,2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "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 Req Source Req The control 1 Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 17WE1151 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. LC11-15 Econode 123/9F6E SWSE SEC 11 T9N R59W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description PW Tanks 009 Four (4) 500 bbl fixed roof above ground produced water storage tanks Enclosed Flare Truck Loadout 010 Truck loadout of condensate by submerged fill Enclosed Flare Condensate Tanks 012 Twelve (12) 500 bbl fixed roof above ground condensate storage tanks Enclosed Flare VRT/LP VOC Burners 013 One (1) vapor recovery tower (VRT), low pressure gas from the upstream separators can be sent through the VRT during downtime of the vapor recovery unit designed to recover gas from the low pressure separators 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.cotorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air COLORADO Air Pollution Control Division (1) Page 1 of 11 Regulation Number 3, Part B, Section III.G.1. and can result 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 revocati ""' permit. A self certification form and guidance on how to self -certify compliance required by this permit may be obtained online at www.colorado. ;.v/pacific/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 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.) F.4. ) 4. Point 013: Upon issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas routed to the enclosed flare from the VRT covered by this permit. 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 Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type pM2.5 NO, VOC CO PW Tanks 009 --- --- 6.3 --- Point Truck Loadout 010 --- --- 3.8 --- Point Condensate Tanks 012 --- --- 10.6 --- Point VRT/LP VOC Burners 013 --- 2.0 56.4 8.8 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. COLORADO Air Pollution Control Division trn,,r t rf Punfuf Heigh oEnvironment Page 2 of 11 s,for both criteria and hazardous air pollutants, shall be 'nen oll • two, a month total. By the end of each month a new twelve month total is ca cu ate• eased on e 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 eq ' s listed in order to reduce emissions to less than or equal to the limits established in t `-s permit. (Regulation Number 3, Part B, Section IlI.E.) Facility Equipment I AIRS • oint Control Device Pollutants Controlled PW Tanks 009 Enclosed Flare VOC and HAP Truck Loadout 010 Enclosed Flare VOC and HAP Condensate Tanks 012 Enclosed Flare VOC and HAP VRT/LP VOC Burners 013 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 PW Tanks 009 Produced Water throughput 950,000 bbl Truck Loadout 010 Condensate loaded 62,500 bbl Condensate Tanks 012 Condensate throughput 2,500,000 bbl VRT/LP VOC Burners 013 Volume of gas routed from the VRT to the enclosed flare 21 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 compliance record on site or at a local field office with site responsibility, for Division review. 9. Point 010: Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) COLORADO Air Pollution Control Division osirotmers P=41:ts:. He.3<th AEnvironment Page 3 of 11 10. Poi 01.. ` e ow ,•per Or .hall continuously monitor and record the volumetric flow enclosed flare from the VRT using the flow meter. The owner or opera or sha use mon y roughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERA TORY REQUIREMENTS 11. The permit nu er 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 _`I.E.) (State only enforceable) 12. Point 010: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. Point 010: 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. 15. Point 010: 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. 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. b. 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 routed to the control device 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. 16. Point 010: 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. 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. COLORADO Air Pollution Control Division Department of Hmit t FnriranmMt Page 4 of 11 17. �� Poi I, ',"��' 12 •: Th Coy bustion devices covered by this permit are subject to , Se < ion 11.8.2. General Provisions (State only enforceable). If a flare or other combus ion 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 r by other convenient means approved by the Division, determine whether it is operati g to the followin • Alt comb operati p- ly. This flare must be equipped with an operational auto -igniter according chedule: tion devices installed on or after May 1, 2014, must be equipped with an uto-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. 18. Points 009 a 012: The storage tanks covered by this permit are 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 fora 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. 19. Points 009 £t 012: 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. 20. Point 013: The separators covered by this permit are 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 & MAINTENANCE REQUIREMENTS 21. Points 009, 010, 012, & 013: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) 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 0&M 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. Points 009, 010, 012, & 013: These sources are not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 23. Points 009, 010, 012, & 013: These sources are not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. COLORADO Air Pollution Control Division i .. aamrnt tX Palle;; }feazh. F.h:irrr'tns nx Page 5 of 11 ADDIT ,_ 24.,_.. vis otice (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 an criteria pollutant: For sour (5) tons emitting less than 100 tons per year, a change in actual emissions of five r year or more, above the level reported onthe last APEN; or For vol •' organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 25. 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. 26. 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. 27. 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. COLORADO. Air Pollution Control Division Department :h Pubtin SEE. al;ti Y envirivt;ramt Page 6 of 11 28. y� sc . ally ,« othm e, the general and specific conditions contained in this eter ned the APCD to be necessary to assure compliance with the provisions of Sec ion 25- )(a), C.R.S. 29. Each and every condition orf 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 :" prior to self -certification and final authorization by the Air Pollution Control Divisio = (A CD) on grounds set forth in the Colorado Air Quality Control Act and regulations of t '`- Air Quality Control Commission (AQCC), including failure to meet any express term or condit n of the permit. If the Division denies a permit, conditions imposed upon a permit are co ed 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. 30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (ADEN) 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. 31. 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. COLORADO Air Pollution Control Division RA—tS: Fftwat 8 E1+tll'ClsaTdMt Page 7 of 11 mit issuance: 1) T it h = is -d 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 based on the consum upon request of the control regulation or and complete appli terial processing limits and emission limits contained in this permit are on rates requested in the permit application. These limits may be revised ner or operator providing there is no exceedance of any specific emission y ambient air quality standard. A revised air pollution emission notice (APEN) 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 009 Benzene 71432 6,650 333 n -Hexane 110543 20,900 1,045 010 n -Hexane 110543 581 29 012 Benzene 71432 6,419 321 Toluene 108883 2,205 110 Ethylbenzene 100414 186 9 Xylenes 1330207 337 17 n -Hexane 110543 32,811 1,641 2,2,4- Trimethylpentane 540841 1,250 63 013 Benzene 71432 6,630 331 Toluene 108883 1,338 67 Ethylbenzene 100414 118 6 Xylenes 1330207 359 18 n -Hexane 110543 48,695 2,435 2,2,4- Trimethylpentane 540841 456 23 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Department of Aibtio Henan & Environment Page 8 of 11 it are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 0.262 0.0131 CDPHE 71432 a nzw" e 0.007 0.00035 110543 n exane 0.022 0.0011 Note: The controlle : -missions factors for this point are based on the flare control efficiency of 95%. Point 010: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.11943 0.005971 AP -42 Chapter 5.2 Equation 1 110543 n -Hexane 0.00930 0.000465 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) = 4.45 psia M (vapor molecular weight) = 67 lb/lb-mot T (temperature of liquid loaded) = 512.12 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor and dividing by the VOC mass fraction. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 012: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source V0C 0.16850 0.00843 HYSYS simulation with site specific gas/liquid sample inputs and AP -42 71432 Benzene 0.00257 0.00013 108883 Toluene 0.00088 0.00004 100414 Ethylbenzene 0.00007 0.00000 1330207 Xylene 0.00013 0.00001 110543 n -Hexane 0.01312 0.00066 540841 2,2,4 Trimethylpentane 0.00050 0.00003 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. COLORADO Air Pollution Control Division irorovnt Page 9 of 11 CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source NOx 182.766 182.766 AP -42 Chapter 13.5 CO 833.199 833.199 VAC 1,073,290.2 5,366.45 HYSYS simulation with site specific gas/liquid sample 71432 enzene 315.7 15.785 108883. oluene 63.7 3.185 1330207 Xylene 17.1 0.855 110543 n- exane 2,318.8 115.94 54084121.7 2,2,4 -inputs Trimethylpentane 1.085 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This 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: VOC, HAP, NOx, CO PSD Synthetic Minor Source of: VOC 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 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 COLORADO Air Pollution Control Division pop.xrtmara of Pubt'w; Fitz:th a ErwiToftroont Page 10 of 11 .6 N^d 0-63 u+part ZZZZ - Subpart MMMMM bpart NNNNN - Subpart XXXXXX COLORADO Mr Pollution Control Division oartm r:t a€ M€M Hans h b Environment Page 11 of 11 Received 71?9slie 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-2O0) 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.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 / 9F6E / 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Noble Energy, Inc. Site Name: LC11-15 ECONODE T9N-R63W-S11 L01 Site Location: SWSE SEC11 T09 R59 Mailing Address: (Include Zip Code) 1625 Broadway, Suite 2200, Denver CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Shaun Higgins 720-587-2459 shaun.higgins@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 APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tankls) APEN - Revision 02/2017 ^,N! COLORADO 3oSZ? Permit Number: AIRS ID Number: 123 / 9F6E / 009 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 2 - Requested Action I] NEW permit OR newly -reported emission source El Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 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 name ❑ Change permit limit O Transfer of ownership3 ❑ Other (describe below) -OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source 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: Produced Water Storage For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: Storage tank(s) located at: 08/01/2017 24 hours/day 7 days/week 52 ❑� Exploration a Production (E&P) site weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes IS No Are Flash Emissions anticipated from these storage tanks? El Yes ■ No Are these storage tanks located at a commercial facility that accepts oil production• wastewater for processing? Yes No IN Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? 19 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 • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualal emissions ≥ 6 ton/yr (per storage tank)? Yes No I Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 Mt/ V COLORADO 2 I VVVV ...... o-_ ..-: . Permit Number: AIRS ID Number: 123 / 9F6E / 009 [Leave blank unless APED has already assigned a permit « and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Produced Water Throughput: From what year is the actual annual amount? Tank design: rj Fixed roof 950,000 N/A O Internal floating roof Requested Annual Permit Limit4 (bbl /year) ❑ 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) 2 4 2000 4/2017 8/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites On y) API Number Name of Well Newly Reported Well 05 - 123-4294' EARP FEDERAL LC23-735 O 05 - 123-4294'. EARP FEDERAL LC23-740 9 05 - 123- 4294( EARP FEDERAL LC23-745 O 05 - 123- 4294, JOHNNY FEDERAL LC11-715 9 05 - 123- 4294! JOHNNY FEDERAL LC11-725 MI 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EaP 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) 40.7609 / -103.9417 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 o Horizontal Downward o Other (describe): Indicate the stack opening and size: (check one) O Upward with obstructing raincap ❑ Circular Interior stack diameter (inches): o Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 02/2017 ��itr corcanoo Permit Number: AIRS ID Number: 123 / 9F6E / 009 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: Rating: MMBtu/hr Type: Enclosed Burner Make/Model: ZEECO HREC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 95 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: Q 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&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: Liquids from well to HP separator, then to LP separator, then produced water to the produced water storage tanks. Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 02/2017 COLORe DO 4 i Permit Number: AIRS ID Number: 123 / 9F6E / 009 [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 form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( or combined) control ernciency ix, reoucuuu/. Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95 NOx CO HAPs Other: Benzene, N -Hexane 95 From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions] (Tonslyear) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tonslyear) VOC 0.2620 lb/BBL CDPHE 124.45 ' 6.22 - NOx CO Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions' (Pounds/year) Benzene 71432 0.007 -- Ib/BBL CDPHE 6650 -' 332.50 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/BBL HYSYS/AP42 20900 ..- 1045 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 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 Tanklsi APEN - Revision 02/2017 5 AT COLD P.n00 Permit Number: AIRS ID Number: 123 / 9F6E / 009 [Leave blank unless APCD has already assigned a permit h 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. r'j Signature of Legally Authorized Person (not a vendor or consultant) Shaun Higgins 7/25/2018 Date Air Permitting Supervisor Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd 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 Form APCD-2O7 - Produced Water Storage Tank(s) APEN - Revision 02/2017 COLORADO 6 Ate. RaivJ 5111111 Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may;4e 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. 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: 17WE1151 assigned a p?rn = and AIID1 [Leave L`ianF ur'ii"S; APCD has a;.eady ass: -- RS Company equipment Identification: Truck Load Out IPro id • Facility Eq-npmcnt ID to identify ho•:, this equiprnnt is refor_nced yvithIn your or,?.nizationl AIRS ID Number: 123 /9F6E / 010 Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: LC11-15 ECONODET9N-R63W-S11 L01 Site Location: SWSE SEC11 T09 R59 Mailing Address: 1625 Broadway, Suite 2200 (Include Zip Code) Denver, CO 80202 E -Mail address': shaun.higgins@nblenergy.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Shaun Higgins Phone Number: 720-587-2459 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. MA-O_3,mA_ Form , P'CD•?CI3 Hydrocarb on Liquid l oadin? APEI`I - R 02/2017 1 1 �n coto,'DC Permit Number: 17WE1151 AIRS ID Number: 123 i9F6E /010 [Lea,,,aunlass APCD has alraaiy ass']i- cl a p2rns t = and AIRS ID] Section 2- Requested Action ❑.• NEW permit OR newly -reported emission source Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN Filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name O Change permit limit O Transfer of ownership' ❑ Other (describe below) - OR ▪ APEN submittal for update only (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: Only 2.5% of oil produced is to be loaded out. For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate truck loadout For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08/ 01 /2017 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? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? El El Yes Yes Yes Yes Yes Yes Yes El El ll El No No No No No No No onn APCD-203-Hydrocai bon Liquid Load'n AP1E1.1 P 3'02..1017 e� ccioae.oa 2 I Permit Number: 17WE 1151 AIRS ID Number: 123 /9F6E/ 010 [Lea,.e blank unless APCD has already a,se n -ad a permit = and MRS I0] Section 4 - Process Equipment Information Product Loaded: El Condensate ❑ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth 62,500 Eb /yr Actual Volume Loaded: Bbl/yr This product is loaded from tanks at this faclity into: (eg, "rail tank cars" or "tank trucks") tank trucks if site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: �� ° ^'t ° F True Vapor Pressure 2.82 Psia @ 60 °F Molecular weight of displaced vapors 69 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Bbl/yr Actual Volume Loaded5: Loaded: Bbl/yr a Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload COLORADO Form APCD-208 Hydrocarbon Liq;i:d Lom :n; APEll - Rev 02 '2017 3 I ❑ Upward 0 Horizontal Permit Number: 17WE 1151 AIRS ID Number: 123 / 9F6E/ 010 [Leave h!.-uik unless 4?':o has atread, assi,red a peraIt = and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.759228768 / -103.9441353 Operator Stack ID No. Discharge Height Temp. ( F) — Flow Rate (ACFM) - - - Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) o Downward o Other (describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter (inches): 0 Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information 0 Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: MMBtu/hr Type: Enclosed Burner Make/Model: Zeeco HREC 95 s� Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Constant Pilot Light: Ei Yes ❑ No Pilot burner Rating 95 Waste Gas Heat Content Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested Form APCD-202 Hydic;art;;n Lig 02/7017 4 I AY© COLORADO -.. Permit Number: 17WE1151 AIRS ID Number: 123 /9F6E/010 ,P ;,;r,_- di permit -r and AiP. iD; �rCDit.r r_i',laSSi� _ a 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? g Yes ❑ No If describe the control equipment Hrvu SLGIC uIC Vvcia•• L,„„�..,• �.,,�,—••_, N. - yes, Pollutant Control Equipment Description 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 ❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL 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: lse we aara repo,Leu ,,, JcuILA IJ -- U. - - -.. _..•-- --- - -- Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Actual Annual Emissions _ Requested Annual Permit Emission Limits) 5 Source (AP -42 , Mfg. etc) Uncontrolled (Tons/year) Controlled5 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NOX VOC 0.1193 lb/bbl AP -42 3.73 0.19 , CO Benzene Toluene Ethylbenzene Xylenes n -Hexane 0 3 ll6,l s Is l ) Vt On) 2,2,4- Trimethylpentane .DO° Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form , . CD -11Y2. I~�, it .a '_ � L�' _r, , Lciafo-i2 A.PEII Rev 02/ 2017 5 1 Ayc.oic�noo .,., Permit Number: 17WE1151 AIRS ID Number: 123/9F6E/010 tLea,,2 blank has permit .. 3:,= a!n5 !DI 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 the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Shaun Higgins Air Permitting Supervisor Name (print) Title Check the appropriate box to request a copy of the: I1 Draft permit prior to issuance E 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 $152.90 and the General Permit registration fee of $250 as 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 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 Luadl _ APDI R:=, 02_. ;1017 6I AY COLOR nGG lectiJ&4 sla li t Condensate Storage Tanks) 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 loadings, 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: 17WE1151 AIRS ID Number: 123 / 9F6E / 012 [L=ava blank unless APCD has already assigned a permit ? and AIDS ID] Section 1 - Administrative Information Company Hamel: Noble Energy, Inc. Site Name: LC11-15 ECONODE T9N-R63W-S11 L01 Site Location: SWSE SEC11 T09 R59 Mailing Address: 1625 Broadway, Suite 2200, Denver CO 80202 (Include Zip Code) Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Shaun Higgins Phone Number: 720-587-2459 E -Mail Address2: shaun.higgins@nblenergy.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt 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. /640—rif\mc SIO Fond APCD-207 - Condensate Storage Tank.lsl APEN - P.Revi3ion 0?/101- 1 A� COLORADO 1 Permit Number: 17WE 1151 AIRS ID Number: 123 / 9F6E/ 012 urless APCD Fc_ sIre_. . r ei a permit - and :IFS ID] Section 2 - Requested Action D NEW permit OR newly -reported emission source El Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit O Transfer of ownership3 O Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info a 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: Condensate Storage For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s)located at: hours/day 8/1/2017 7 CI Exploration & Production (E&P) site days/week 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes el No Are Flash Emissions anticipated from these storage tanks? IS Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? El Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.0002 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • D Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • p Form APCD-205 - Condensate Stara eTank(s) APEN - is'on 02/2217 AY CC1 hD0 Tank design: I] Fixed roof Permit Number: 17WE1151 AIRS ID Number: 123 i 9F6Ei 012 eaVe Man', +P_ a per AILS IDI, Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Condensate Throughput: From what year is the actual annual amount? Average API gravity of sales oil: 58.6 degrees ❑ Internal floating roof Requested Annual Permit Limit4 (bbl )year) 2,500,000 RVP of sales oil: 5.887 ❑ 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) 1 12 6000 5/2017 8/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EEP Sites Only) API Number Name of Well Newly Reported Well 05 -123-429 EARP FEDERAL LC23-735 El 05 - 123- 429 EARP FEDERAL LC23-740 0 05 -123-429 EARP FEDERAL LC23-745 0 05 -123-429 JOHNNY FEDERAL LC11-715 El 05 - 123- 429 JOHNNY FEDERAL LC11-725 0 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EFtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.759228768 / -103.9441353 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ftlsec) Indicate the direction of the stack outlet: (check one) © Upward ❑ Downward ❑ Horizontal O Other (describe): Indicate the stack opening and size: (check one) O Upward with obstructing raincap ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): F- m . PCD-2_O5 Cc n '' r, T F'I - ; i 0212717 ©cotta+ao 3 I Ay Permit Number: 17WE 1151 AIRS 1D Number: 123 / 9F6E / 012 [Leave black unless APCD i;,ii already assigned a permit =f ar.d 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. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: Rating: MMBtu/hr Type: ENCLOSED FLARE Make/Model:ZEECO HREC Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr 0 Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EaP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 4.0 Describe the separation process between the well and the storage tanks: psig Form APCD 205 - Coria _ns. StaraI:. Tank(s) APED - „ . ;sior 02!2017 V Coro-npd 41 Permit Number: 17WE 1151 AIRS ID Number: 123 / 9F6E/ 012 l'_= •, -. ni. `k un (_.,s APCD as;ideec s i_: rnit - ar. , G1 Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency ( o redaction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Burner 95 NOx CO HAPS Enclosed Burner 95 Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.1685 lb/bbl HYSYS/AP42 210.60 10.53 NOx 3.7e-3 Ib/Ib-VOC CDPHE 0.8113 0.8113 CO 9.4e-3 lb/lb-VOC CDPHE 2.0301 2.0301 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year) Benzene 71432 0.0026 lb/bbl HYSYS/AP42 6418.90 320.94 Toluene 108883 0.0009 lb/bbl HYSYS/AP42 2205.01 110.25 Ethylbenzene 100414 0.0001 Ib/bbl HYSYS/AP42 185.50 9.28 Xylene 1330207 0.0001 lb/bbl HYSYS/AP42 337.54 16.88 n -Hexane 110543 0.0131 lb/bbl HYSYS/AP42 32811.37 1640.57 2,2,4- Trimethylpentane 540841 0.0005 lb/bbl HYSYS/AP42 1250 62.5 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. norm A CD•7 - Con-i APEN �n U ;i=-201! I � 'G'J CO105 r. n0 Permit Number: 17WE1151 AIRS ID Number: 123 / 9F6E/ 012 APCD has 711 C -.d`! a_s"3f =d 3 p='r l'l.. 1DJ 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. Signature of Legally Authorized Person (not a vendor or consultant) Date Shaun Higgins Air Permitting Supervisor Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance I 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 $152.90 and the General Permit For more information or assistance -call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Small Business Assistance Program Environment (303) 692-3175 or (303) 692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 https://www.colorado.gov/cdphe/apcd Form APCD-2•)5 Ca deg ste St:orage Tank(s) APEN - 02/N)17 6 I caioanoo eV Rc.cLttkll lib g 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/cdohe/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: 17WE1151 AIRS ID Number: 123 / 9F6E/ 013 [Leave blar,-; unless APCD has alreac:y assigned a permit a and A!RS IDj Company equipment Identification: VRT/LP VOC Burners (Provide Facility Equipmer.l ID idarliiy how this equipmelt referenced within your . ri_alioi:] Section 1 - Administrative Information Company Name': Noble Energy, Inc. Site Name: LC11 Econode Site Location: T9N R63W S11 lu C Address: 1625 Broadway Suite 2200 (Include Zip Code) } Denver, CO 80202 E -Mail Address' shaun.higgins@nblenergy.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Shaun Higgins Phone Number: 720-587-2459 '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-21 I -- Natural. C r Venda rvPE'I - Re; 03/2017 1 �i corer aco liiiuuu--Yl'l1!! �" 'nom' Permit Number: 17WE 1151 AIRS ID Number: 123 /9F6E i 013 [Le see blank unless APCD has already ass'gred a permit _ and AIRS ID] Section 2- Requested Action El NEW permit OR newly -reported emission source - OR - 0 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 ❑ 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 a 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: Combustion of VRT or LP Gas when VRU is down For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 08 / 04 / 2017 / / 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: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year O Yes El No O Yes 0 No Form APCD-211 rlDtui o. Gls Venting APEN Rev 03;2017 AY toraRsoe 2 Permit Number: 17WE1151 AIRS ID Number: 123 /9F6E/ 013 [Leave blarl< unless A, CD has aireac�i a:.signed a pem c = and AIRS ID] Section 4 - Process Equipment Information r❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: O 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? I] Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: SCF/hr Vent Gas Heating Value: 2587 74 BTU/SCF Requested: 21 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/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 %) 74.15 VOC (Weight %) 85.32 Benzene (mole %) Q.15 Benzene (Weight %) 0.25 Toluene (mole %) 0.03 Toluene (Weight %) 0.05 Ethylbenzene (mole %) 0 Ethylbenzene (Weight %) 0 Xylene (mole %) 0.01 Xylene (Weight %) 0.01 n -Hexane (mole %) 1.02 n -Hexane (Weight %) 1.84 2,2,4-Trimethylpentane (mole %) 0 01 methylpentane 2,2,4-Trimethylpentane (Weight %) 02 Additional Required Information: O Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Form APCD-21I -Natural Gas Venting APEN Rev 113/2017 Ala" COLORADO 3 1�/'M+a B Upward ❑ Horizontal Permit Number: 17WE1151 AIRS ID Number: 123 / 9F6Ei 013 [Lea•;= ibLari' ur tess APCD has al-readyatready ass g ed ^ern t = and AIR: ID; Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.7309, -103.9417 Operator Stack ID No. -- Discharge Height Above Ground Level (Feet) Temp. ('F) Flow Rate (ACFM) Velocity (ftisec) Indicate the direction of the stack outlet: (check one) ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) El Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: Enclosed Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr 95 99+ % Waste Gas Heat Content Constant Pilot Light: O Yes ❑ No Pilot burner Rating Btu/scf MMBtu /hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-2'11-Natural Gas Venting,APFN - Re•ii O'2017 87 co 01,,00 Permit Number: 17WE1151 AIRS ID Number: 123 i 9F6Ei 013 (Leave btarAPCD i,ia IL?� 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? O Yes O No If yes, please describe the control equipment /*ID state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SO, NOx VOC Combustor 95 CO HAPs Combustor 95 Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Requested Annual Permit, Emission Limitis)s - Actual Annual l Emissions . Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOx NOx 0.068 lb/mmbtu AP42 1.94 - 1.94 VOC 107.33 Ib/mscf HYSYS 1126.96 - 56.35 - CO 0.310 Ib/mmbtu AP42 8.76 - 8.76 - Benzene 0.32 Ib/mscf HYSYS 3.31 0.17 Toluene 0.06 Ib/mscf HYSYS 0.67 -- 0.03 -- Ethylbenzene 0.01 Ib/mscf HYSYS 0.06 -' <0.01 Xylenes 0.02 Ib/mscf HYSYS 0.18. 0.01 n -Hexane 2.32 Ib/mscf HYSYS 24.35 - 1.22 2,2,4-0.02 Trimethyipylpentane lb/mscf HYSYS 0.23 - 0.01 - Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. AAnnual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 -rllturri G=, V.:'i_i i? APEN - t?._." 0-.1.'2017 5 �k o!.or eo Permit Number: 17WE1151 AIRS ID Number: 123 / 9F6E i 013 3:c hi;r ul'.ess APCD has air ad; a:;;i^;'.cd a p:rnvr :: and Ai3S ID} Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 5/3i/IV Signature of Legally Authorized Person (not a vendor or consultant) Date Shaun Higgins Air Permitting Supervisor Name (please print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance El 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-B1 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 Form APCD 211 enTiing . , Eil - . 03;2017 6IAy oC)R.0O Hello