The URL can be used to link to this page

Browse Search

Home My WebLink About20171725COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Gabriela Vega Gabriela.vega@nblenergy.com June 1, 2017 Ref: Permit No: 17WE0151 SUBJECT: Draft Permit and Related Public Notice Dear Gabriela Vega: RECEIVED JUN 022017 WELD COUNTY COMMISSIONERS The Air Pollution Control Division has prepared a public comment package for the Noble Energy, Inc. - No Worries T4N-R65W-S14 L01. The thirty (30) day public notice period will begin on June 8, 2017. This public notice period is being provided in accordance with the Colorado Air Pollution Prevention and Control Act and Regulation No. 3, Part B, Section III.C. For thirty (30) days from the beginning of the notice period, copies will be available for public inspection at the respective county clerk's office(s). During the thirty -day period, please review your permit and call your permit engineer with any questions or concerns you may have. This application is complete and in proper form. It meets the requirements of the Colorado Air Quality Control Commission's Regulation No. 3, Part B, Section III.B. I. B. Sincerely, Betsy Gillard Stationary Sources Air Pollution Control Division Enclosures 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pvipl IC Re Vt Cela/1-1 cc pLCMCM TP), tALC 96), PWCER/C H/ J'M /CIA) COICOI t7 2017-1725 COLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150OSt PO Box 758 Greeley, CO 80632 June 1,2017 Dear Sir or Madam: On June 8, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy, Inc. - No Worries T4N-R65W-S14 L01. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - No Worries T4N-R65W-S14 L01 - Weld County Notice Period Begins: June 8, 2017 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: No Worries T4N-R65W-S14 L01 Exploration and Production SWSW Sec 14 T4N R65W Weld County The proposed project or activity is as follows: Existing EEtP facility. Emissions from the vapor recovery tower (VRT), which are currently compressed by the ERS COMP1 engine (Point 008), will be routed to a VOC burner and the engine will be removed. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • 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 17WE0151 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Betsy Gillard Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us �,° COLO ADO 1I `7'M> Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? Yes'' If yes, for what pollutant? ❑Carbon Monoxide (CO) ❑Particulate Matter (PM) Betsy Gillard 8420 2/15/2017 4/26/2017 Noble Energy, Inc. 123 9CF1 No Worries T4N-R65W-S14 LO1 SWSW quadrant of Section 14, Township 4N, Range 65W, in Weld County, Colorado Explora.& Production Well Pa Oil & NaturaGas. Production & Prod Weld Quadrant Section Township Range Section 02 - Emissions Units In Permit Application I°Ozone (NOx & VOC) 4= 4N AIRS Point4t Emissions Source Type Equipment Name Emissions Control? Permit If Issuance if Self Cert Required? Action Engineering Remarks 010 Vapor Recovery Tower ( 1RT) VRT Yes; 17 W E015 ] I des Pe it•ial Is ance Section 03 - Description of Project Existing E&P facility. Emissions from the vapor recovery tower (VRT), which are currently compressed by the ERS COMP1 engine (Point 008), will be routed to a VOC burner and the engine will be removed Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ng Synthetic Minor Pei Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ El ❑ ❑ ❑ ❑ ❑ O ❑ ❑ ❑ CI ❑ 2 010 One (1) VRT controlled by one (1) enclosed flare. Flare has a minimum control efficiency of 95%. Equipment Description This source vents natural gas from: Emissions from this source are: a vapor recovery tower routed to a flare Natural gas venting from a vapor recovery tower. Emissions from this source are routed to a flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of pollutant x Q = Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm Throughput (Q) 3.7 MMscf/yr 425.8 scf/hr 0.32 MMscf/mo MW 43.220 Ib/Ib-mol 0.010 MMscf/d mole % MW Ibxllbmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 1.9 44.01 0.836 0.019 CO2 0.9 8230 4.11 N2 0 28.013 0.000 0.000 N2 0.0 0 0.00 methane 12.02 16.041 1.928 0.045 methane 2.2 18976 9.49 ethane 26.95 30.063 8.102 0.187 ethane 9.1 79737 39.87 propane 29.56 44.092 13.0336 0.302 propane 14.6 128273 64.14 isobutane 6.07 58.118 3.5278 0.082 isobutane 4.0 34719 17.36 n -butane 13.22 58.118 7.6832 0.178 n -butane 8.6 75616 37.81 isopentane 3.23 72.114 2.3293 0.054 isopentane 2.6 22924 11.46 n -pentane 3.81 72.114 2.7475 0.064 n -pentane 3.1 27040 13.52 cyclopentane 0.9 70.13 0.6312 0.015 cyclopentane 0.7 6212 3.11 n -Hexane 0.9500 86.18 0.8187 0.019 n -Hexane ' 0.9 8057 4.03 cyclohexane 0.0000 84.16 0.0000 0.000 cyclohexane 0.0 0 0.00 Other hexanes 0 86.18 0.0000 0.000 Other hexanes 0.0 0 0.00 heptanes 0.66 100.21 0.6614 0.015 heptanes 0.7 6509 3.25 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.13 114.23 0.1485 0.003 224-TMP 0.2 1461 0.73 Benzene 0.15 78.12 0.1172 0.003 Benzene 0.1 1153 0.58 Toluene 0.14 92.15 0.1290 0.003 Toluene 0.1 1270 0.63 Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00 Xylenes 0.05 106.17 0.0531 0.001 Xylenes 0.1 522 0.26 C8+ Heavies 0.28 169.029 0.4733 0.011 C8+ Heavies 0.5 4658 2.33 VOC mass fraction: 43.220 Notes Mole %, MW, and mass fractions from No Worries G14-65-1HN HP gas analysis collect Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+ based on the average MW on the analysis for the gas. enough and therefore considered acceptable. The permit reflects operator calculations. The PFD provided with this permit application indicates that there is also an LP separator at the facility, with vapors being routed to a flare. I asked Gabriela Vega about this in an email 4/26/17, and she explained that the stream was mis-labeled and the vapors from the LP separators are routed to a VRU and therefore do not require a permit. 8.0 159.4 8.0 0.7486 Total VOC Emissions (Uncontrolled) Total VOC Emissions (Controlled) Uncontrolled VOCs (operator calcs) ed 1/11/2017. Controlled VOC (operator calcs) 17WE0151.CP1.xlsm 010 One (1) VRT controlled by one (1) enclosed flare. Flare has a minimum control efficiency of 95%. Flaring Information Equipment Description Flare to combust VRT gas Manufacturer Model VOC Burner Serial Number Gas Heating Value 2225 Btu/scf Throughput 8299.25 MMBtu/yr Combustion emission factor source: AP -42: Chapter 13.5 0.07 0.3 lb NOX/MMBtu 0.31 lb CO/MMBtu Overall Control 95.00% Emissions Summary tpy NOX 1.3 tpy CO Operator calcs Uncontrolled/PTE 0.3 tpy NOX 0.6 1.3 tpy CO 1.51 159.2 tpy VOC 159.4 Controlled 8.0 tpy VOC 8.0 Uncontrolled Total (Ib/yr) Reportable? Controlled Total (Ib/yr) Operator Calcs (Ib/yr) Benzene 1153 Yes 58 1119 56 Toluene 1270 Yes 63 1229 61 Ethylbenzene 0 No 0 11 1 Xylenes 522 Yes 26 445 22 n -hexane 8057 Yes 403 8102 405 224-TMP 1461 Yes 73 1417 71 Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity.' AQCC Regulation 2 Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air." AQCC Regulation 3 Is public comment Public Comment Required required? AQCC Regulation 7 Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? no This separator is not subject to Reg 7 Section XVII.G Emission Factors for Permit VRT emissions will be monitored as a function of condensate throughput Annual throughput: 120085 bbl Uncontrolled Engineer calcs Operator calcs Controlled Engineer calcs Operator calcs NOX 0.005 0.010 lb/bbl NOX 0.005 0.010 lb/bbl CO 0.021 0.025 lb/bbl CO 0.021 0.025 lb/bbl VOC 2.652 2.655 lb/bbl VOC 0.1326 0.1327 lb/bbl Benzene 0.0096 0.009 lb/bbl Benzene 0.0005 0.0005 lb/bbl Toluene 0.0106 0.010 lb/bbl Toluene 0.0005 0.0005 lb/bbl Ethylbenzene 0.0000 0.000 lb/bbl Ethylbenzene 0.0000 0.0000 lb/bbl Xylenes 0.0044 0.004 lb/bbl Xylenes 0.0002 0.0002 lb/bbl n -Hexane 0.0671 0.067 lb/bbl n -Hexane 0.0034 0.0034 lb/bbl 224-TMP 0.0122 0.012 lb/bbl 224-TMP 0.0006 0.0006 lb/bbl 17WE0151.CP1.xlsm Permit number: Date issued: Issued to: CO Air Po Depart CONSTRUCTION PERMIT 17WE0151 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. No Worries T4N-R65W-S14 L01 123/9CF1 SWSW SEC 14 T4N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 010 Vapor Recovery Tower controlled by VOC burner Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 'COLORADO Aix Pollution Control Division ^r.f of F of f; Iffaith a Efmfo -r ie^t[ Page 1 of 8 3. This permit shall expire or which this permit was issued: (i) does not commence cratio of this source within 18 months after either, the date - dan co n p t or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III. F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO VRT 010 -- -- 8.0 1.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methoos use limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT 010 Emissions from the VRT are routed to an 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.) COLOR ADO Air Pollution Control Division c.-omm€,,:t S Ptid'z Health 7 •M 3•vethar`eee Page 2 of 8 Process Limits Facility Equipment ID AIL-, Point —I—Agg5s Pa nler Annual Limit VRT 010 Condensate Throughput 120,085 bbl Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 13. 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 O&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 14. The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- 1COLORADO Air Pollution Control Division DepFinme:t of Pco tc fleffith .y too oontr onf Page 3 of 8 trimethylpentane conten (we t r, ion) this ssion stream. Results of the Analysis shall be used to calculat site .p: i em . fa• •r for e pollutants referenced in this permit (in units of lb/ ga -n - si +' on ved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal 'COLORADO Air Pollution Control Division arc? r'ne,-.r of R.i t ; hk e,h ivimr,mt-^r Page 4 of 8 program threshold will r: uire f 1. iew the u e as hough construction had not yet commenced on the sourc Th s• r sha . exc e the deral program threshold until a permit is granted. (Regu - 1 u - - is GENERAL TERMS AND CONDITIONS 19. 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. 20. 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 alt 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. 21. 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. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Betsy Gillard Permit Engineer COLORADO Air Pollution Control Division DepaamerO of Public kliteh u Ef1v;rc eflont Page 5 of 8 DRAFT Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. COLORADO Air Pollution Control Division Depwernent of Fci^.flr.. H.;nith Page 6 of 8 Notes to Permit Holder at the tim 1) The permit holder is requir__'''' " ay - s - e - -__'ng ti rxi -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 wilt result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) 'This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tPY) Controlled Emissions (tPY) VRT 010 Benzene 71432 0.560 0.028 Toluene 108883 0.615 0.031 Xylenes 1330207 0.223 0.011 n -Hexane 110543 4.051 0.203 2,2,4- Trimethylpentane 540841 0.709 0.035 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons per year (tpy) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 010: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Controlled Emission Factors (lb/bbl) Source CO 0.025 0.025 CDPHE V0C 2.655 0.133 HYSYS simulation based on site -specific HP gas sample 71432 Benzene 0.009 0.0005 108883 Toluene 0.010 0.0005 1330207 Xylene 0.004 0.0002 110543 n -Hexane 0.067 0.0034 540841 2'2'4 Trimethylpentane 0.012 0.0006 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. The emission factors listed above are based on modeled separator temperature of 70°F and separator pressure of 4.0 psig. COLORADO .Air Pollution Control Division I Dept- arnen; if Peel. l : Health la _^,virrnrr;;ni Page 7 of 8 6) In accordance with C.R.S. 25- 114 , : c it P. l ant sion otice (APEN) associated with this permit is valid for a term •f fiv y: r om ate as r eived by the Division. A revised APEN shall be submitted no - an • • - -for - e -ye rm expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, total HAPs, n -Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Depv rteri Envt,rn..rr Page 8 of 8 fkc..ocd U- 0 C)I M cn T Ct C7 it z E y U I- () O U O c.e c..> rs, z ("2 H 0 z 0 cip Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 02 — Requested Action (check applicable request boxes) Section 01 — Administrative Information Request for NEW permit or newly reported emission source w U O O 0. a, W °am o F > y c y G H .0 T N C U- .- E .o Ga 3 0 C 0 b C O C CCP .) a a > R ❑ N C O O -8 U z� 0 CD C U SWSW S -E- 4 T4N R65W Source Loc LL O O W S �❑❑cam❑❑ 1625 Broadway, Suite 2200 O N CO 00 U 0- N O U 6! C A CD o � H C o C! 4 z 303-228-4286 Fax Number: E-mail Address: Section 03 — General Information For new or reconstructed sources, the projected startup date is: C c C m C .0 C U ("1 U O v` O � G c ° E 0 L). 7_ Vapor Recovery Tower General description of equipment and purpose: E C O o0 WG c d e o 0 = Vl 7.6 d � a e 0, O o U C C d y E t N L A c L O U CC) 0 C ^ O DP V) C ; vt 7 ^ v; Z U U M en M i CCA 'uU N N N Y m., Q m a) aC) ,o O so v -o u E n en rn aC) C.) .- 5 C O O O C. d' C O O ��cn v C 'U C ; .. an L r ,E a C W .C .� W ` -0 �C .r`U U o 0- o G m � 69 s 0- a ' to v) C U L+ Q O 0 ,° o v c5 C .. .1-,'.C .- M O >' O G. v a CA m O Go^ c ° -01. c ° > a E •v2- 0 3 > 3 sw : G •>' u 3 W I. O O V _ U 'D .c C .Y O 0 O E CUi 7 O &`-f, ii, I U R 1. L N O Q .9.-: 0 0 `'_ "P E o. - L o U n c c. "P w c`5' i O U O C v I V o ,c1:•':"— '7 L L `° .7 0 0 O G c s s`� C� U a '3 ..,=. m • n v,,0. V OU CO C SA L �O lZ P. EL- ai z U a a a LOL. Q cn Q< Section 04 — Processing Eouinment Information F 0 > e) 11 0 0 m m 2 Blowdowns: 00 00 O 0 N V > E 2 U N a O 7-, -6 X co 4 �- V E O� Molecular Wt. V) N V1 Vented Gas Prope ti U C C U O L G 2. G C P. o a a. a' O C O. O n a C) 0 0 0 Y Y 0 L U V Venting-APEN (2) 0 O m cot O 2 (0 U � U � t o7, aE i c'= o C. X 7 av X '= F ° , o PIE °z r o CZ. ❑ 0 - m < ^ - 7.• o Cl U = V f p � T u r C 2 R U 2 L j CL Y • 9 j Cr0 z� FORM APCD-211 Permit Number: Section 06 -Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) 14, E 0 U e N V V Other (Describe): O Width (inches) = ❑ Horizontal ❑ Dow ❑ Other: Length (inches) = structing raincap nner Diameter (inches) = > ❑ tlet (check one): C U O C Exhaust Opening Shape & Size (check on Section 07 — Control Device Information Section 08 — Emissions .Inventory Information & Emission Control Information z t-- 0 .0 .0 F C C 0 0 C O C >. 'C L z� c_▪ . O C C '5 if, C 0 v 0 U C o V u C C. o -5-,)3 a • o C V • G U C • u Estimation Method or Emission Factor Source V, h ? 2 CDPHE CDPHE Hysys WI h J. S US in h S t i T Please use the APCD Non -Criteria Re .ortable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) a N .c o vi .- 0.03 o O 0 0 0.2 Uncontrolled (Tons/Year) 7 in .+ 'c O .y V) .-- vi O 'o O 0.22 14.05 Actual Calendar Year Emissions' Controlled (Tons/Year) -o '•, _11 11 V C E'-' Emission Factor Units 0 O z y F U C:) F J 2.6549 1 M .C O en t7 et C C' O O O O O M O O N O O Control Efficiency 1% Reduction) c If) 0', C\ .I) ON U1 01 I C' Overall Collection Efficiency Control Device Description Secondary CC Gcc 'C .-. VOC Burner VOC Burner L. Ca L _ U 0 VOC Burner VOC Burner Pollutant VOC xON CO K O II Benzene C v C C u , cJ U C u N U C C x z C ++ c CC C '41 U L • ¢ a CC O C Gabriela Ve CC O. o. VRT-Natural-Gas-Venting-APEN (2) FORM APCD-211 a O N O N O co a) O O n. N SWSW SEC4 T4N R65W Plant Location: Phone Number: 303-228-4475 gabriela.vega@nblenergy.com E-mail Address: Controlled Actual Emissions Ibs/ ear O O Uncontrolled Actual Emissions Ibs/ ear 1417 Emission Factor Source Hysys Emission Factor (Include Units) cD m 0 0 a Control Equipment / Reduction (%) 0 LO O Chemical Name 2,2,4-Trimethylpentane Chemical Abstract Service (CAS) Number Cr CO O 'i in w F- a_ a) a) Q a_ a) a) a a) U L ndar Year for wh a) a) a ed to Supply Data Environmental Engineer III Gabriela Vega Title of Person Legally Authorized to Supply Data Name of Person Legally Authorized to Supply Data (Please print) Form Revision Date: A Hello