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HomeMy WebLinkAbout20173189.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 September 7, 2017 Dear Sir or Madam: RECEIVED SEP 1 2 2017 WELD COUNTY COMMISSIONERS On September 14, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy Inc - SANDAU T4N-R66W-S25 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 a 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 i obi iG Rev i ec.J �l (l'all1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer CC t PLC mrrl -rP), HLC Jr), pwr£Rrc(-1/.Trinf ccc) pt/13/(7 2017-3189 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy Inc - SANDAU T4N-R66W-S25 L01 - Weld County Notice Period Begins: September 14, 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: SANDAU T4N-R66W-S25 L01 Well production facility NWSW SEC25 T4N R66W Weld County The proposed project or activity is as follows: Three Vapor Recovery Towers at individual locations 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 17WE0220 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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd®state.co.us LOR ADO Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Timothy Sharp 359043 3/6/2017 4/19/201.7 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? If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Noble Energy Inc 123 9dOf SAN DAU T4N-R66W-525 L01 NWSW quadrant of Section 25, Township 4n, Range 66wW, in Weld County, Colorado Exploration & Production Welt Pad Oil & Natural Gas Production. &. Processi Weld Quadrant Section Township Range articulate Matter (PM) NWSW 1�7zone (NOx & VOC) 25 AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 009 "SeparatorVenting VRT Ye,17WE022C- 1 t Permit Initial Issuan€e Section 03 - Description of Project Installation of VRT due to engine cancellation at syn-minor facility. pub -corn required := new syn minor limits; flow meter omission granted Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Penni 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 Colorado Air Permitting Project 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) Yei SO2 NOx ❑ ❑ ❑ ❑ CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ E ❑ ❑ ❑ ❑ Is this stationary source a major source? If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs. Prevention of Significant Deterioration (PSD) ❑ ❑ O O ❑ ❑ Title V Operating Permits (OP) ❑ O O ❑ O O O O Non -Attainment New Source Review (NANSR) ❑ ❑ Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Timothy Sharp 359047' 3/6/2017 4/19/2017': Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Noble Energy Inc 123 9CE8 Weld Quadrant Section Township Range HONEY BADGER TSN-R66W-S31601 SWSW quadrant of Section 31, Township 5n, Range 66W, in Weld County, Colorado Exploration & Production Well Pad Oil & Natural Gas Production & Processing. Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? [Carbon Monoxide (CO) Particulate Malta (PM) Section 02 - Emissions Units In Permit Application (]Ozone (NOx & VOC) 31 AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 007 Separator Venting: ..:, VRT Yes 17WE0221 1 Pio Permit Initial Issuance Section 03 - Description of Project Installation of VRT due to engine cancellation at syn-minor facility. ; pub-com required = new syn minor limits; flow meter omission granted Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Per Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Colorado Air Permitting Project 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) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ 0 0 0 ❑ ❑ 0 ❑ 2 0 ❑ ❑ ❑ 0 ❑ Is this stationary source a major source? des If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) 0 0 0 0 0 ❑ Title V Operating Permits (OP) ❑ 0 0 El ❑ ❑ ❑ ❑ Non -Attainment New Source Review (NANSR) 0 ❑ Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Timothy Sharp 359073: 3/7/2017 4/19/2017 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? If yes, for what pollutant? QCarbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Noble Energy Inc 123 9CE8 Weld Quadrant Section Township Range CECIL FARMS T6N-R66W-S6 102 NENE quadrant of Section 6, Township 6n, Range 66W, in Weld County, Colorado Exploration & Production Well Pad Off & Natural Gas Production & Processing.,,,;. Yes [particulate Matter (PM) [jJzone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 010 Separator Venting VRT Yes 17WE022? 1 No.. Permit Initial Issuance° Section 03 - Description of Project Installation of VRT due to engine cancellation at syn-minor facility. ; pub -corn required = new syn minor limits; flow meter omission granted Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Syntheti aor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Nu If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Colorado Air Permitting Project Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) ye SO2 NOx ❑ ❑ CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ O ❑ ❑ o ❑ ❑ ❑ ❑ SO2 NOx CO VOC PM2.5 PM10 TSP HAPs ❑ O O O O ❑ ❑ O ❑ ❑ ❑ ❑ ❑ O ❑ ❑ Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to an enclosed flare Natural gas venting from a well head separator. Emissions from this source are routed to an enclosed flare. Emission Calculation Method EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=0*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) MW 9 MMscf/yr 48.000 Ib/Ib-mol 1061.6 scf/hr 0.025 MMscf/d 0.79 MMscf/mo mole % MW Ibx/Ibmol mass fraction E lb/hr lb/yr tpy Helium 0 4.0026 0.000 0.000 Helium 0.0 0 0.00 CO2 0.73 44.01 0.321 0.007 CO2 0.9 7883 3.94 N2 0.24 28.013 0.067 0.001 N2 0.2 1650 0.82 methane 2.32 16.041 0.372 0,008 methane 1.0 9132 4.57 ethane 21.21 30.063 6.376 0.133 ethane 17.9 156465 78.23 propane 39.72 44.092 17.5133 0.365 propane 49.1 429747 214.87 isobutane 5.33 58.118 3.0977 0.065 isobutane 8.7 76012 38.01 n -butane 17.77 58.118 10.3276 0.215 n -butane 28.9 253421 126.71 isopentane 3.05 72.114 2.1995 0.046 isopentane 6.2 53971 26.99 n -pentane 4 72.114 2.8846 0.060 n -pentane 8.1 70782 35.39 cyclopentane 2.85 70.13 1.9987 0.042 cyclopentane 5.6 49045 24.52 n -Hexane 1.4700 86.18 1.2668 0.026 n -Hexane 3.5 31086 15.54 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 0.75 100.21 0.7516 0.016 heptanes 2.1 18442 9.22 methylcyclohexane 0 98.19 0.0000 0.000 methylcyclohexane 0.0 0 0.00 224-TMP 0.04 114.23 0.0457 0.001 224-TMP 0.1 1121 0.56 Benzene 0.27 78.12 0.2109 0.004 Benzene 0.6 5176 2.59 Toluene 0.09 92.15 0.0829 0.002 Toluene 0.2 2035 1.02 Ethylbenzene 0 106.17 0.0000 0.000 Ethylbenzene 0.0 0 0.00 Xylenes 0.02 106.17 0.0212 0.000 Xylenes 0.1 521 0.26 C8+ Heavies 0.13 116.000 0.1508 0.003 C8+ Heavies 0.4 3700 1.85 99.99 Notes VOC mass fraction: 47.688 0.8448 Total VOC Emissions (Uncontrolled) annual limit assuming 95% control monthly limit assuming 95% control (lb/mo.) 497.5 24.9 4225.6 Produced Natural Gas Venting/Flaring Preliminary Analysis Mole %, MW, and mass fractions from Cecil Farms PC106-67 68NH gas analysis collected 2/21/2017. Emissions are based on 8760 hours of operation per year. Colorado Department of Public Health and Environment Air Pollution Control Division Produced Natural Gas Venting/Flaring Preliminary Analysis Colorado Department of Public Health and Environment Air Pollution Control Division Flaring Information Equipment Description Flare to combust low-pressure separator gas during VRU downtime. Manufacturer Model Serial Number Gas Heating Value Throughput 2432 Btu/scf MMBtu/yr 22617.6 Combustion emission factor source: AP -42: Chapter 13.5 0.068 lb NOX/MMBtu tpy NOX 0.37 4.18 lb CO/MMBtu tpy CO 0.77 Emissions Summary 0.8 tpy NOX Uncontrolled/PTE 4.2 tpy CO 497.5 tpy VOC Controlled 24.9 tpy VOC Uncontrolled Total (Ib/yr) Scenario A Reportable? Controlled Total (lb/yr) Benzene 5176 Yes 259 Toluene 2035 Yes 102 Ethylbenzene 0 No 0 Xylenes 521 Yes 26 n -hexane 31086 Yes 1554 224-TMP 1121 Yes 56 2.588E+00 0.000E+00 #VALUE! 1.018E+00 0.000E+00 #VALUE! 1.294E-01 5.088E-02 0.000E+00 0.000E+00 #VALUE! 0.000E+00 2.605E-01 0.000E+00 #VALUE! 1.303E-02 1.554E+01 0.000E+00 #VALUE! 7.772E-01 5.606E-01 0.000E+00 #VALUE! 2.803E-02 Permit number: Date issued: DRAFT Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 17WE0220 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. SANDAU T4N-R66W-S25 L01 123/9D0F NWSW SEC25 T4N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT 009 Vapor Recovery Tower 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 Air Pollution Control Division Page 1 of 7 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT 009 --- --- 6.6 1.3 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VRT 009 Enclosed Flare VOC and HAP COLORADO s Air Pollution Control Division Page 2 of 7 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 VRT 009 Liquids Throughput 100,010 bbl/yr Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must use monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. 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.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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. 14. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS COLORADO Air Pollution Control Division Page 3 of 7 15. 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 16. 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 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS COLORADO [ Air Pollution Control Division Page 4 of 7 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. at a synthetic -minor facility. COLORADO Air Pollution Control Division • Page 5 of 7 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tPY) Controlled Emissions (tPY) VRT 009 Benzene 71432 6.184E-01 3.092E-02 Toluene 108883 6.200E-01 3.100E-02 Ethylbenzene 100414 0.000E+00 0.000E+00 Xylenes Y 1330207 1.681E-01 8.404E-03 n -Hexane 110543 4.195E+00 2.098E-01 2,2,4- Trimethylpentane 540841 5.425E-01 2.713E-02 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 009: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Source NOx 3.70E-03 lb/lb- VOC AP 42 CO 9.40E-03 lb/lb- VOC AP 42 VOC 2.6127 Source (Promax/HYSYS) 71432 Benzene 0.0126 Source (Promax/HYSYS) COLORADO Air Pollution Control Division Page 6 of 7 CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Source 108883 Toluene 0.0122 Source (Promax/HYSYS) 1330207 Xylene 0.0034 Source (Promax/ HYSYS) 110543 n -Hexane 0.0840 Source (Promax/HYSYS) 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: N/A 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 Page 7 of 7 Permit number: Date issued:DRAFT Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 17WE0221 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. HONEY BADGER T5N-R66W-S31 LO1 123/9CE8 SWSW SEC31 T5N R66W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VRT OO7 Vapor Recovery Tower 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 Air Pollution Control Division Page 1 of 8 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO VRT 007 --- 1.0 12.8 2.4 Point f Note: See "Notes to Permit Holder" for information on emission actors 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 007 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division Page 2 of 8 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 VRT 007 Liquids Throughput 100,010 bbl/yr Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must use monthly condensate/crude oil throughput records, calculation methods detailed in the OEtM Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. 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.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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. 14. 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. COLORADO Air Pollution Control Division Page 3 of 8 OPERATING Et MAINTENANCE REQUIREMENTS 15. 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 16. 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 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet COLORADO Air Pollution Control Division Page 4 of 8 commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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: Timothy Sharp Permit Engineer COLORADO Air Pollution Control Division Page 5 of 8 Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. at a synthetic -minor facility. COLORADO Air Pollution Control Division Page 6 of 8 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tPY) Controlled Emissions (tPY) VRT 007 Benzene 71432 1.45E+00 7.00E-02 Toluene 108883 9.10E-01 5.00E-02 Xylenes 1330207 3.20E-01 2.00E-02 n -Hexane 110543 9.18E+00 4.60E-01 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 007: CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) . Source N0x 3.70E-03 lb/lb- VOC AP 42 CO 9.40E-03 lb/lb- VOC AP 42 V0C 5.0954 Source (Promax/HYSYS) 71432 Benzene 0.0290 Source (Promax/HYSYS) 108883 Toluene 0.0183 Source (Promax/HYSYS) 1330207 Xylene 0.0064 Source (Promax/HYSYS) COLORADO Air Pollution Control Division Page 7 of 8 CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Source 110543 n -Hexane 0.1836 Source (Promax/HYSYS) 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: N/A 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 Page 8 of 8 Permit number: Date issued:DRAFT Issued to: COLORADO Air Pollution Control Division Department of Public Health b Environment CONSTRUCTION PERMIT 17WE0223 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Noble Energy, Inc. CECIL FARMS T6N-R66W-S6 L02 123/9D00 NENE SEC6 T6N R66W 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 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 Air Pollution Control Division Page 1 of 8 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO VRT 010 --- 1.9 25.2 4.8 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. 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 Enclosed Flare VOC and HAP COLORADO Air Pollution Control Division Page 2 of 8 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 VRT 010 Liquids Throughput 100,010 bbl/yr Cl ompiance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator must use monthly condensate/crude oil throughput records, calculation methods detailed in the O&M Plan, and the emission factors established in the Notes to Permit Holder to demonstrate compliance with the process and emissions limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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 TILE.) (State only enforceable) 11. 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.) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. 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. 14. 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 tine 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. COLORADO Air Pollution Control Division Page 3 of 8 OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. 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 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. 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 inemissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet `COLORADO Air Pollution Control Division Page 4 of 8 commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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: Timothy Sharp Permit Engineer COLORADO Air Pollution Control Division Page 5 of 8 isto Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. at a synthetic -minor facility. ;COLORADO Air Pollution Control Division Page 6 of 8 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tPY) Controlled Emissions (tPY) VRT 010 Benzene 71432 2.55E+00 1.30E-01 Toluene 108883 g.70E 01 5.00E-01 Xylenes 1330207 2.50E-01 1.00E-02 n -Hexane 110543 1.56E+01 7.80E-01 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) Source N0x 3.70E-03 lb/lb- V0C AP -42 CO 9.40E-03 lb/lb- V0C AP 42 V0C 10.0550 Source (Promax/HYSYS) 71432 Benzene 0.0509 Source (Promax/ HYSYS ) 108883 Toluene 0.0194 Source (Promax/HYSYS) 1330207 Xylene 0.0049 Source (Promax/HYSYS) COLORADO Air Pollution Control Division Page 7 of 8 CAS # Pollutant Uncontrolled Emission Factors (lb/bbl) Source 110543 n -Hexane 0.3112 Source (Promax/HYSYS) 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAPs PSD or NANSR Synthetic Minor Source of: N/A 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 Page 8 of 8 Section 02 — Requested Action (check applicable request boxes) [Leave C) U L C O C) d 0 G L O c 0 c. W 4. a C Cr C. dJ O O. O L C O' U r U V O O) C O d U cz. O CJ C O RMS T6N-R66W-S6 L02 O ❑ ❑ Change fuel or equipment Change permit limit ❑ ❑ A 6 T6N R66W U �i.. O O Request to limit HAPs with a Federally enforceable limit on PTE Permit Number: Facility Equipment ID: c? O it01—Adn U Car) z C) z a U Lz, U L-1 U Source Name: z :] z Source Location: n Mailing Address: O N O C2] 'O C U c N 303-228-4286 Fax Numbe C. G v e E-mail Address: Section 03 — General Infortfiation 4.1 rt C 0 U C) rt C) v C O 'C C) C v C r C) C C OO Vapor Recovery Tower C a C C d C O c'O U C c O q rn v j C.) C U. O oU c c L � F 'Ebel 0 U U7 G O L 1. O 4 N N C`1 M c cam._ p ro C7 C+1 U O O O O. �M.., r WI O\> O O C CI La tri`d Q f.4 u q a u ;� .O i) E u o °�5. o up .e;�' OG O > O 0 > U r.+ 4 M O ES C t) 0� +- 3 C ,m C C 0 V C y A ` L N a E 0.-,(-"g o U L CJ >> a) C) ca.) 4O Q C ,- O O .O .C � ti 5 C ^ U C — Qa ~�, p = O Q O > .0 G e`.� o G: o v O C F C,i deiC w dv) rn 'O C cn O O U AP EN forms:http:// C v P C) v L 'O O C C 0 O O C- Application statu O z ❑ T yj U CC .C po J) U E 'O 0 Y X MM set/event CJ C) Tower Gas Stream C 00 O G O Qcn ) C) 0] C > N C\ N F_ 0 o 7 0 Ti C O C O O O O > BIowdowns: S)) OOOOO 0 O U 0 2 Process Parameters: E o H.E. U h > 2 C) U O U C ^ O = 0 n C O. O O O O 0 O. 'O 0 C 0 c' U U C) C) c N O" 0 O Y, Y, o 0 CJ U U El El Vented Gas Properties: t _0 O E 00 00 O -0 U v. Venting-APEN (2) FORM APCD-211 y 0.4 CC z c.i iV a a▪ r O Wr � V z O U) U) Y�1 z O Ct] H 0 0 m M Emission Source AIRS ID: ►-1 4 Permit Number: Section 05 — Stack Information (Combustion stacks must be listed here) • • kl a) O O Other: Length (inches) = ❑ U U ❑ ❑ C O C • G E C� 4, i CO O y _ • v v A L O • C U C ccC C y C.0 Direction of stack outlet (chec z Estimation Method or Emission Factor Source y m ›. CDPHE II CDPHE h m >. H Cl) > Hysys II w H i, Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) ti ,� N r ao rt in r- 7 M '- O J!J O C ,--- o O 10.78 Uncontrolled (Tons/Year) co 0 If, 1.87 r if) N C\ O N O Vl .--, Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Y c .C .2 ..c U 0 ? 1..1' C U 0 r d A ^3 .G .a �' O .C O a C Uncontrolled Basis O Vl O M O d O r M M O c) O 7 o, O WI O O CT. rt O O '7 O O O ,-, ... cc'? O Control Efficiency (% Reduction) D Ce C C vl c1 95% o as C\ O Cn O, Overall Collection Efficiency O C. •� O w e1 O U Secondary Q a C O c....) T VOC Burner VOC Burner VOC Burner VOC Burner VOC Burner J Pollutant VOC. Z U Cn y y n U O H Ethylbenzcne Q) C >, X "C C Y ` C) C A C a' C C m C O C, F ,O c u G O G C C L C) Ca 9 O V u7 O r u o. C. r C) d 9 a C C 0 4 9 C "tl C C C) L. G Cl G C C u' C) C C 0 C 0 0 G C Gabriela Ye C) 0 M C) C 0 C) 0 CJ N 0 T a cu 0 0 C C C z VRT-Natural-Gas-Venting-APEN (2) N O N J C'ti Emission Source AIRS ID: [Leave blank unless APCD has already assigned a pemit I/ & AIRS ID] Permit Number: G N C •0 U C) C C. 0 C) .0 C C) E. U Lx. P Section 02 — Requested Action (check applicable request boxes) • 44( Request for NEW permit or newly reported emission source a a) CID. 0 C-) C.) Q U Z C 00 "D C) T5N R66W Facility Equipment ID: m O CV C!] Request to limit IIAPs with a Federally enforceable limit on PTE Request APEN update only (check the box below that applies) ❑ ❑ 00 > 303-228-4286 Fax Number: E O U C 0 C, p d C 0 cc cc U C) • 0--, O. C) t`) c 0 0 L a C C) V -0 c) —OO c a � :n Z C) J G. Cp y Q` Q 9 3 V > U 0 "> L t no 0 .O ^ C c Cn J c 3 v ? n �p c) . y 0 c 0 1.), c C.) •0 C) — y U C H �V E N l kr) *V 3s ss r y0 y U C r a how 3 � O 5 i L t•. C O Do to 'V' t� M Cn C4 N N w C., C0 C . .0 .0 p C 2 corn M C) 00O P. F °° ,C 0 _ C) G c. C < U Ca > p ,= C C. 0 c 0 v to 0 OL G .7,0 o U > U O Q c — 3 •y a n c G U - C) C N G .� F N r bn p-2 u OL _� P c. ;t" CZ < Application status:http://www.colorado.gov/cdphe/permitstatus cr. f nrnent arca? C C C/7 V Z c r ipment Information C 0 p. O Cl, U C) 0 -7t C) C)) MMscf/event Tower Gas Stream L-7 .0 Z C) z ccC p C CJ O Source Name: en en L C C Person To Contact CC N N O C) a 2 C) p a.) 1) X F3 0 C) O :) o c N c c V Cl, Normal Hours of Source Opera General description of equipme Section 04- Processing Eg Q❑❑❑❑❑ 131 CO .f Process Parameters: Vented Gas Properties: C) U • • O U G C c N a O O O 0 0. C C) C) 0 C w CS p - -O tL C 0 0 0 U C) U 3 0 G L L c 0 0 0 0 0 x C) U Venting-APEN (2) VRT-Natual N 4-. O C) CD p) FORM APCD-211 o O E Emission Source AIRS ID: Permit m a Other (Describe): f) V 61 V G C Width (inches) = ❑ N_ V? `•G O) 00 tan U O ntory Information & Emission Control Information L P L O c, Z 'O CJ a To V; C. O a L C O O C) y> C r U O 0 j O ti G Section 08 — Emissions Inv U U C C P J. C c Estimation Method or Emission Factor Source 0 CDPHE II w a y? y u3 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 12.74 If) O tV F-- O 0.05 tV O 0.46 Uncontrolled (Tons/Year) 00 in fV O 7 N in ,-; CR+ O 10.32 N CT Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units U O > - U 0 > - � n . . .0 Uncontrolled Basis 7 If) 0 If) to c, aJ r -M r, co CD Q\ o O o O cr) CO a O '' V:D© o O vo M 00 - O Control Efficiency (% Reduction) O I'1 !7 O V ., in O Ifi I If1 Overall Collection Efficiency vice Description Secondary Control D 'CC •G 0 VOC Burner VOC Burner[ VOC Burner VOC Burner VOC Burner C 75 0-, VOC O Z CO O VI 0 N N mH Q O„ V ° J L U U C X X O ,0 c O >, O U a) O v ▪ 00 Cr d U C.� WIH O V O U en 00 h O CO s, 00 c C U U Q Gabriela Veaa Name of Legally Authorized Person (Please pri VRT-Natural-Gas-Venting APEN (2) N O N on OO L'-.i FORM APCD-211 Permit Number: Section 02 — Requested Action (check applicable request boxes) Information Request for NEW permit or newly reported emission source Change fuel or equipment U Change permit limit Request to limit flAPs with a Federally enforceable limit on PTE Request APEN update only (check the box below that applies) El El OO '-4 O U U Q zo- T4N-R66W-S25 L01 U C II EC25 T4N R66W Facility Equipment ID Section 01 — Administrativ Company Name Source Name: Source Location: O in N ti -O 7 to C 7 N N w -C O U C, N C U- 303-228-4475 Phone Number: 303-228-4286 Fax Number: 1.4 4. Ce Section 03 — G the projected startup date For new or reconstructed sou N N rn T C C - N Vapor Recovery Tower V O C c o o_ r c On C rJ y O O 'U ', 'O O 00 VI 1- 'V °_ _ "4 / coo a a O V IT U a �� W P.- C �. i C C b5 G < U W U Q C U O G Q rn = L ' C N `� `--' tGn CS n L U r.. E r: O G C U l c :_ t U C.. O F. o >, G c u s C .. oo r o U v ,O C O c/aC. CO.. O 33 C O co L V O U U C .. ^ s. U .y O L oo C L� CG, > ` c 'o y c teO ❑rte E ,, ... a, o o t t, G. ❑ , C > U e, L s. N 0 Q �' p, C Q > _S.'E C' — U 0O0 (SUM r' . 'II .— O P O (' ❑.. O U a C C O C L E O O 'J G -' O EA „ U c7 - C O O U O V1 y C.)o c et 2GU te- a o_ z c� �. O �? O > 00 P. '7,W P. X•c 1 200, ac, )C , p P-. F U '�.+ z U -1 .1- A J.. Q (7, Q Q E p N - cn cn r? i C e 00 I N N N 'O m O t_+, c ., � +� V O C ." :_ 1 1•o 1O E • p rr cn m v c i g O z ❑ ment Information Section 04 — Processin U CJ C. CC U o C m .C, 0 G G Q) C) 1 1 o m 2 MMscf/event Tower Gas Stream N C') N Pi y U U C C a O G 0 17. F C r U c}S F• .'7 u C- W O O 0 0 U U U U O N a0 o O x 0 0 0C) U cn U U C O y 1O a J 7 O °y p C o J ° ec C C 7;0,1 C U`c c z "U C 0 W tl c- jz U VRT-Natural-Gas-Venting-APEN (2) N C.) 0- FORM APCD-211 Emission Source AIRS ID: (Combustion s U, U 0 O 0 N O 0 0 0 U] U] 0 0 0 U] 00 0 C) U, ,O z W C U, a 0 • C U C U a) r z U U Estimation Method or Emission 'Factor Source CA Vl CDPHE CDPHE II CA ;+a 1A n S cA T CA CA A H r w CA T CA T 'r Please use the APCD Non -Criteria Re ortable Mr Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions y M O 1 . c G J(6 r; rn CC a q 0 1.24 0.03 0.03 — 0 O ri 0 Uncontrolled (Tons/Year) In r) .--, 'T d N so O so O �--� O 4.20 Actual Calendar Year Emissions" Controlled Tons/Year Uncontrolled (Tons/Year) Emission Factor en U O > U O > Uncontrolled Basis N '0 N r1 O N0 r) M O C1 O. Oi C N ,--4 O N N - 0 O V r) 0 0 O co 7 C0 0 O Control Efficiency (% Reduction) O C, C a> C CC C CC Overall Collection Efficiency Vice Description T O La C) Control D T CJ F C—: VOC Burner VOC Burner VOC Burner 4) C = U O 4) C = U 0 i VOC `ON C-) V) a)C - m C cD E -El ,,p. N I.:, X c s O. U C. - O U C CC 4, 4-4 S. - a v C. O 0. 0 r U C] U) i.+ 0 y O a U, G 0 C C: C U, L. U, V C o (• J ry 1. Environmental Engineer Ill Gabriela Ve 4) H VRT-Natural-Gas-Venting-ADEN (2) N O N 00 Hello