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Home My WebLink About20160030.tiffCOLORADO Department of Public Health £r Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 December 17, 2015 Dear Sir or Madam: RECEIVED DEC 2 2 2015 WELD COMMISSIONERS On December 23, 2015, the Air Pollution Control Division will begin a 30 -day public notice period for Noble Energy - Wells Ranch Processing Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure CC : PI,?w; )/A8 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer 2016-0030 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy - Wells Ranch Processing Facility - Weld County Notice Period Begins: December 23, 2015 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 Facility: Wells Ranch Processing Facility Oil and gas exploration and production facility NW Section 22, T6N, R63W Weld County The proposed project or activity is as follows: Oil and gas exploration and production facility including condensate storage tanks, natural gas flare venting and associated facility fugitive emissions. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 13WE2908 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: Stephanie Spector Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO 1 I A D.p.rarrmra "mute iiiiiIaiW+A aYuwmWn.m STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 13WE2908 Noble Midstream LLC Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Wells Ranch Processing Facility, located in the NW Sec of Section 22, Township 6N, Range 63W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Flare 001 Separator controlled by a flare stack. Flare has a minimum combustion efficiency of 98%. The flare is not the primary control device for the flare will only be during VRU downtime. The flare is not enclosed. TK CND 002 Sixteen (16) above ground 8000 bbl atmospheric condensate storage tanks. Emissions from these tanks are captured by VRU compression with 100% reduction under normal operation. When the VRU has downtime (i.e. purging oxygen out of the tank system), the emissions are routed to a flare with a destruction efficiency of 98%. This flare is not enclosed because it is a backup flare for upset conditions only. FUG 004 Equipment leaks (fugitive VOCs) from a natural gas processing facility. 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 THOSE 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 after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or AIRS ID: 123/9BFD Page 1 of 16 Wellhead Version 2012-1 D Public Health and Environment Air Pollution Control Division operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this sourcewithin 18 months after eithet;ahe 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5 Point 001: The following information for all permitted equipment except fugitive emissions from equipment leaks shall be provided to the Division within fifteen (15) days after issuance of permit. - • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO„ VOC CO Flare 001 4.7 43.0 25.3 Point TK CND 002 4.3 53.0 22.9 Point FUG 004 — 3.0 — Fugitive e `Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from AIRS ID: 123/9BFD Page 2 of 16 f Public Health and Environment Air Pollution Control Division each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as seen below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). Total emissions from the facility, including permitted emissions and insignificant activities, shall not exceed: • 100 tons per year of any criteria pollutant and/or • 10 tons per year of a single hazardous air pollutant and/or • 25 tons per year of total hazardous air pollutants (HAP). 9. Point 004: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. 10. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section I I.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Flare 001 VRU and a flare for backup VOC and HAPs TK CND 002 VRU and a flare for backup VOC and HAPs FUG 004 LDAR Program VOC and HAPs PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Flare 001 Natural gas venting to atmosphere 65 MMSCF/yr TK CND 002 Natural gas venting to atmosphere 45 MMSCF/yr The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9BFD Page 3 of 16 D en f Public Health and Environment Air Pollution Control Division 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 mcal fieldoffice with site responsibility, for Division review. STATE AND FEDERA (ULATORY R UII EMENTS 12. The permit numberfid AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Num3, Part B, III.E.) (State only enforceable) 13. Visible emissions stall not exceed twenty percent (20%) opacity during normal operation of the source. During ,periods of startup, ';process modification, or adjustment of equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section I I.A.1 & 4:) 14. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow afcause emissions into the atmosphere of any air pollutant which is in excess of 30% opaoty for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 15. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 16. The Division has determined this flare shall comply with the New Source Performance Standards requirennts''of Subpart A Section §60.18, General Control Device and Wotk Practice Requirements, including, but not limited to, the following: a. §60.18(b) Flares. Paragraphs (c) through (f) apply to flares. b. §60.18(cx1) Flares shall be designed for and operated with no visible emissions as determined by the methods specified in paragraph (f), except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. c. §60.18(cX2) Flares shall be operated with a flame present at all times, as determined by the methods specified in paragraph (f). d. §60.18(c)(3) An owner/operator has the choice of adhering to either the heat content specifications in paragraph (c)(3)(ii) of this section and the maximum tip velocity specifications in paragraph (c)(4) of this section, or adhering to the requirements in paragraph (c)(3)(i) of this section. (i) §60.18(cX3)(lXA) Flares shall be used that have a diameter of 3 inches or greater, are nonassisted, have a hydrogen content of 8.0 percent (by volume), or greater, and are designed for and operated with an exit velocity less than 37.2 m/sec (122 ft/sec) and less than the velocity, Vmak, as determined by the following equation: max = (42-Ki)" K2 Where: Vm = Maximum permitted velocity, m/sec. K, = Constant, 6.0 volume -percent hydrogen. AIRS ID: 123/9BFD Page 4 of 16 f Public Health and Environment Air Pollution Control Division K2 = Constant, 3.9(m/sec)/volume-percent hydrogen. XH2 = The volume -percent of hydrogen, on a wet basis, as calculated by using the American Society for Testing and Materials (ASTM) Method D1946-77. (Incorporated by reference as specified in §60.17). (ii) §60.18(c)(3)(i)(B) The actual exit velocity of a flare shall be determined by the method specified in paragraph (f)(4) of this section. (iii) §60.18(c)(3)(ii) Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam -assisted or air -assisted; or with the net heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare is nonassisted. The net heating value of the gas being combusted shall be determined by the methods specified in paragraph (f)(3) of this section. e. §60.18(c)(5) Air -assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by the method specified in paragraph (f)(6). f. §60.18(c)(6) Flares used to comply with this section shall be steam -assisted, air - assisted, or nonassisted. g. §60.18(d) Owners or operators of flares used to comply with the provisions of this subpart shall monitor these control devices to ensure that they are operated and maintained in conformance with their designs. Applicable subparts will provide provisions stating how owners or operators of flares shall monitor these control devices. h. §60.18(e) Flares used to comply with provisions of this subpart shall be operated at all times when emissions may be vented to them. i. §60.18(f)(1) Method 22 of appendix A to this part shall be used to determine the compliance of flares with the visible emission provisions of this subpart. The observation period is 2 hours and shall be used according to Method 22. §60.18(f)(2) The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. k. §60.18(f)(3) The net heating value of the gas being combusted in a flare shall be calculated using the following equation: MT ■ K Y Ciiii 1.1 Where: HT = Net heating value of the sample, MJ/scm; where the net enthalpy per mole of offgas is based on combustion at 25 °C and 760 mm Hg, but the standard temperature for determining the volume corresponding to one mole is 20 °C; AIRS ID: 123/9BFD Page 5 of 16 fen f Public Health and Environment Air Pollution Control Division .740 x 0 r t� „ `c e) c rt the =standard tture for (_--_? 3434 C;. = Concentration of sample component i in ppm on a wet basis, as measured for organics by Reference Method 18 and measured for hydrogen and carbon monoxide by ASTM D194677 or 90 (Reapproved 1994) (Incorporated by reference as specified in §60.17); and H, = Net heat of combustion of sample component i, kcal/g mole at 25 °C and 760 mm Hg. The heats of combustion may be determined using ASTM D2382-76 or 88 or D4809-95 (incorporated by reference as specified in §60.17) if published values are not available or cannot be calculated. §60.18(f)(4) The actual exit velocity of a flare shall be determined by dividing the volumetric flowrate (in units of standard temperature and pressure), as determined by Reference Methods 2, 2A, 2C, or 2D as appropriate; by the unobstructed (free) cross sepfional area of the flare tip. m. §60.18(f)(5) The maximum permitted velocity, Vmax, for flares complying with paragraph (c)(4)(iii) shall be determined by the following equation. I-og10 Nmax)=(HT+28.8)/31.7 Vm,, = Maximum permitted velocity, M/sec 28.8=Constant 31.7=Constant HT = The net heating value as determined in paragraph (f)(3). n. §60.18(f)(6) The maximum permitted velocity, Vma,„ for air -assisted flares shall be determined by the following equation. Vmax = 8.706+0.7084 (HT) Vm = Maximum permitted velocity, m/sec 8.706=Constant 0.7084=Constant HT = The net heating value as determined in paragraph (f)(3). 17. Point 002: The flare covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XII. 18. Point 002: This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. AIRS ID: 123/9BFD Page 6 of 16 Public Health and Environment Air Pollution Control Division 19. Point 002: The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.2.e Alternative emissions control equipment shall qualify as air pollution control equipment, and may be used in lieu of, or in combination with, combustion devices and vapor recovery units to achieve the emission reductions required by this Section XVII., if the Division approves the equipment, device or process As part of the approval process the Division, at its discretion, may specify a different control efficiency than the control efficiencies required by this Section XVII. XVII.B.2.d.(ii) 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. 20. Point 002: The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto -igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment AIRS ID: 123/9BFD Page 7 of 16 en f Public Health and Environment Air Pollution Control Division must -be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If stonqie tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control' equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Ownersoperators of storage tanks must route all hydrocarbon emissions to air pollution ccarol equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during no*l operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners, or operators of storage tanks subject to the control requirements of Sections V .2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, ,and employ appropriate control technologies, monitoring practices, operational ct"i es, and/or other strategies designed to meet the requirements set forth in Sebton XVII.C.2.a. Owners or operators must update the STEM plan as necessary tbachieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C:2.b.(I) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applteable schedule in Section XVILC.2.b.(ii) and Inspection Frequency in. Table 1. XVII.C.2.b.(II) ; Owners or operators must achieve the requirements of Sections XV l:C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(li)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase -In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b:(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections AIRS ID: 123/9BFD Page 8 of 16 f Public Health and Environment Air Pollution Control Division Threshold: Storage Tank Uncontrolled Actual VOC Emissions (tpy) Approved Instrument Monitoring Method Inspection Frequency Phase -In Schedule > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 21. Point 004: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. AIRS ID: 123/9BFD Page 9 of 16 D en f Public Health and Environment Air Pollution Control Division Point 004: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repo(LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring,, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. OPERATING & MAINT ',NANCE REQUIREMENTS 23. Upon startup of these points, the applicant shall follow the 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Reauirements 24. Point 001: The owner or operator shall demonstrate compliance with Condition 14 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section I.A.5). 25. Point 004: Within one hundred and eighty days (180) after issuance of permit, the operator shall complete a hard count of components` at the source and establish the number of components that are operated in "heavy liquid service°, "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Periodic Testing Requirements 26. Point 001: On an annual basis, the operator shall complete a site specific extended gas analysis of the natural gas produced at this site that is routed to the flare in order to verify the VOC content (weight fraction) of this emission stream used in the permit application. Results of testing shall be used to determine site -specific emission factors using Division approved methods. 27. Point 004: On an annual basis, the owner or operator shall complete an extended gas analysis of gas saples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 28. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 AIRS ID: 123/9BFD Page 10 of 16 f Public Health and Environment Air Pollution Control Division 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 29. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) 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 No. 3 Part D). GENERAL TERMS AND CONDITIONS 30. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 31. 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 No. 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. 32. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 33. 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. AIRS ID: 123/9BFD Page 11 of 16 Col men Public Health Pollution andControl Environmennt Air Divisio 34. 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 applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 35. 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. 36. 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: Stephanie Spector, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Midstream LLC. Newly permitted condensate tanks, venting, flare and associated fugitives at a synthetic minor facility. AIRS ID: 123/9BFD Page 12 of 16 Notes to Permit Holder: f Public Health and Environment Air Pollution Control Division 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 (Reference: Regulation No. 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 maybe revised upon request of the permittee 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 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 permittee 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: htto://www.colorado.00v/cs/Satellite?c=Document C&childi aoename=CDPHE- Main%2FDocument C%2FCBONAddLin kView&cid=1251599389641 &Daaename=CBONWraDDer 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Benzene 71432 A 97760 Yes 1955 Toluene 108883 C 32565 Yes 651 Ethylbenzene 100414 C 6500 Yes 130 Xylenes 1130207 C 6500 Yes 130 n -Hexane 110543 C 260715 Yes 5214 2,2,4- Trimethyl pentane 540841 C 6500 Yes 130 002 Benzene 71432 A 459900 Yes 210 Toluene 108883 C 744600 Yes 340 Ethylbenzene 100414 C 43800 Yes 20 Xylenes 1130207 C 262800 Yes 120 n -Hexane 110543 C 3438300 Yes 1570 2,2,4-TMP 540841 C 131400 Yes 60 004 Benzene 71432 A 53 No 53 Toluene 108883 C 59 No 59 Ethylbenzene 100414 C 6 No 6 Xylenes 1130207 C 65 No 65 n -Hexane 110543 C 162 No 162 AIRS ID: 123/9BFD Page 13 of 16 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42 CO 0.37 lb/MMBtu 0.37 lb/MMBtu AP -42 VOC 65.0 65200 Ib/mmscf 1304 lb/mmscf Engineering Calculation 71432 Benzene 0.10 1504 ib/MMscf 30.08 Ib/mmscf Engineering Calculation 108883 Toluene 0.08 100 lb/MMscf 2.0 lb/mmscf Engineering Calculation 100414 Ethylbenzene 0.01 100 lb/MMscf 2.0 lb/mmscf CalcEngineeringulation 1330207 Xylenes 0.03 4011 IbIMMscf 80.22 Ib/mmscf Engineering Calculation 110543 n -hexane 0.63 100 lb/MMscf 2.0 lb/mmscf Engineering Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using the November 25, 2014 analysis of a gas sample collected from the Wells Ranch CPF V-2110 well. The controlled VOC and HAP emissions factors for point 001 are based on the flare control efficiency of 98%. Point 002: CAS # Pollutant Emission Factors Uncontrolled Emission Factors Controlled Source NOx 0.068 Ib/M MBtu 0.068 lb/MMBtu AP -42, Table 13.5-1 CO 0.37 lb/MMBtu 0.37 'lb/MMBtu AP -42, Table 13.5-1 VOC 231.11 lb/mmscf 4.6222 lblmmscf Engineering Calculation 71432 Benzene 4.67 lb/mmscf 0.0934 lb/mmscf Engineering Calculation 108883 Toluene 7.56 lb/mmscf 0.1512 lb/mmscf Engineering Calculation 100414 Ethylbenzene 0.44Ib/mmscf 0.0088 lb/mmscf . Engineering Calculation 1330207 Xylenes 2.67 lb/mmscf 0.0534lb/mmscf Engineering Calculation 110543 n -hexane 34.89 Ib/mmscf 0.6978 Ib/mmscf Engineering Calculation 540841 2,2,4-TMP 4-TMP ' ' 1.33 Iblmmscf 0.0266 Ib/mmscf , Engineering Calculation Note: The controlled emissions are based on the flare control efficiency of 98%. AIRS ID: 123/9BFD Page 14 of 16 D Point 004: f Public Health and Environment Air Pollution Control Division Component Gas Service Heavy Oil Light Oil SOil ervi Service Connectors 3840 --- 6640 750 Flanges 2380 --- 2940 380 Open -Ended Lines 10 --- 10 10 Pump Seals --- --- 30 10 Valves 2180 --- 3010 560 Other 190 --- 20 10 VOC Content (wt%) 90% 100% 100% 100% Benzene Content (wt%) 1.5% --- 0.5% 0.5% Toluene Content (wt%) 0.5% --- 1.5% 1.5% Ethylbenzene (wt %) 0.1% --- 0.1% 0.1% Xylenes Content (wt%) 0.1% --- 2.0% 2.0% n -hexane Content (wt%) 4.0% --- 2.0% 2.0% *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 , 1.4E-05 3.5E-06 Pump Seals 3.5E-04 NA 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA -453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 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, BTEX, n -hexane, 2,2,4-TMP, total HAPS NANSR Synthetic Minor Source of: VOC AIRS ID: 123/9BFD Page 15 of 16 D f Public Health and Environment Air -Pollution Control Division MACT HH Area Source Requirements: Not Applicable 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, Appendoaes 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 M — 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 9) A self certification form and guidance on how to self -certify compliance as required by thi§ permit may be obtained online at: htto://www.colorado.aovloacific/cdohe/air-permit-self-certification AIRS ID: 123/9BFD Page 16 of 16 Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Noble Energy, Inc. Permit Number: 13WE2908 Source Location: Wells Ranch Processing Facility NW 22 T5N R63W, Weld County (non -attainment) Equipment Description: Point 001: Plant flare with a minimum combustion efficiency of 95%. Point 002: Twelve (12) 8,000 BBL above ground atmospheric crude oil storage tanks Point 003: Four (4) 8,000 BBL above ground atmospheric produced water storage tank. POINT CANCELLED ON 2/19/2015. Point 004: Fugitive emissions AIRS ID: 123-9BFD Date: 12/24/2013 (L. Strohkirch); 3/17/14 (S. Chaousy). Project was put on - hold. Received revised APENS and calculations via email 2/19/15. Operator requested permit to be on hold. Began working on permit 10/22/15. Review Engineer: Stephanie Spector Control Engineer: Chris Laplante Section 2 — Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt Section 3 — Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no" to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? October 28, 2013; received revised APENS and calculations via email 2/19/15. Picked up permit again on 10/22/15 after putting it on -hold. Section 4 — Source Description AIRS Point Equipment Description 001 Separator controlled by a flare stack. Flare has a minimum combustion efficiency of 98%. The flare is not the primary control device for the flare will only be during VRU downtime. The flare is not enclosed. 002 Sixteen (16) above ground 8000 bbl atmospheric condensate storage tanks. Emissions from these tanks are captured by VRU compression with 100% destruction under normal operation. When the VRU has downtime (i.e. purging oxygen out of the tank system), the emissions are routed to a flare with a destruction efficiency of 98%. Page 1 004 Fugitive emission leaks. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM,o CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants, are subject to minor source RACT per Regulation*, part B, Section III.D.2) PM10 CO Ozone Is this source located into 8 -hour ozone non - attainment region? (Nat►: If "yes" the provisions of Regulation 7, Sections Ail and XVII.C may apply) X Yes No Section 5 — Emission Eli Situate Information AIRS Point Emission Factor Source 001 Site -specific using VOC weight fraction (Refer to Section 14 for calculations) 002 Site -specific using HYSYS/EPA Tanks (Refer to Section 14 for calculations) 004 EPA -4531R-95-017, Table 2-8 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit (PTE) AIRS Point Process ConsumptionlThroughput/Production 001 65 MMscf per year 002 45 MMscf per year 004 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 3840 - 6640 750 Flanges 2380 - 2940 380 Open -Ended Lines 10 - 10 10 Pump Seals — — 30 10 Valves 2180 -- 3010 560 Other 190 - 20 • 10 Basis for Actual Efnissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 001 65 MMscf per year 2013 002 45 MMscf per year 2013 004 Equipment Type Gas Heavy Oil ' (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil 2013 Connectors 3840 - 6640 750 Flanges 2380 - 2940 380 J Open -Ended Lines 10 - 10 10 Pump Seals — — 30 10 Valves 2180 - 3010 560 Other 190 - 20 10 Basis for P (Permit Limits) AIRS Point Process ConsumptionnbroUghputAbilucdon Page 2 001 65 MMscf per year 002 45 MMscf per year 004 Equipment Type Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Connectors 3840 --- 6640 750 Flanges 2380 --- 2940 380 Open -Ended Lines 10 -- 10 10 Pump Seals --- --- 30 10 Valves 2180 --- 3010 560 Other 190 --- 20 10 Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 001 01 Flare 98 002 01 Vapor Recovery Unit (100% recycled) 100 02 Thermal oxidizer (when VRU is not operational) 98 004 01 LDAR program Based on components Section 6 — Emission Summary (tons per year) Point NOx VOC CO SOx PM10 Single HAP Total HAP PTE: 001 4.7 2119 25.3 --- --- 130.4 (n -hexane) 205.3 002 4.3 113880 22.9 --- --- 1719 (n -hexane) 2540 004 -- 3.0 --- --_ _ 0.08 (n- hexane) 0.17 Uncontrolled point source emission rate: 001 4.7 2119 25.3 --- ___ 130.4 (n -hexane) 205.3 002 4.3 113880 22.9 --- --- 1719 (n -hexane) 2540 004 --- 3.0 --- -__ -__ 0.08 (n- hexane) 0.17 TOTAL (TPY) 9.0 116002 48.2 --- ___ 1849.5 (n- hexane) 2745.5 Controlled point source emission rate: 001 4.7 43.0 25.3 --- --- 2.6 (n -hexane) 4.1 002 4.3 53.0 22.9 --- --- 0.8 (n -hexane) 1.2 004 -- 3.0 --- -_ ___ 0.08 (n- hexane) 0.17 INSIGNIFICANTS (TPY) 16.1 0.9 13.5 --- --- --- --- TOTAL PERMITTED (TPY) 5.0 99.0 48.2 0.03 1.3 3.5 (n- hexane) 5.5 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate Ir ( Y ) Point 001 Benzene 71432 A 97760 Yes 1955 Toluene 108883 C 32565 Yes 651 Page 3 Ethylbenzene 100414 C 6500 Yes 130 Xylenes 1130207 C 6500 Yes 130 n -Hexane 110543 C 260715 Yes 5214 2,2,4-Trimethylpentane 540841 C 6500 Yes 130 Point 002 Benzene 71432 A 459900 Yes 210 Toluene 108883 C 744600 Yes 340 Ethylbenzene 100414 C 43800 Yes ' 20 Xylenes 1130207 C 262800 , Yes 120 n -Hexane 110543 C 3438300 Yes 1570 2,2,4-Trimethylpentane 540841 C 131400 Yes 60 Point 004 Benzene 71432 A 53 No 53 Toluene 108883 C 59 No 59 Ethylbenzene 100414 C 6 No 6 Xylenes 1130207 C 65 No 65 n -Hexane 110543 C 162 No 162 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non -criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8 Testing Requirements wA testing be required to show compliance with any emission rate or regulatory standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 001 of VOC Regulation No.1, Section ll.A.5 Method 9 004 oa VOC, HAPS State only requirement Hard component count Section 9 — Source Classification is this facility dassification? TrueWhat Mina X Synthetic Major Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? VOC For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes , No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No r Page 4 For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 — Modelin Is modeling required to demonstrate compliance with National Ambient Air Quality Standards (NAAQS)? Yes X No If "yes", for which pollutants? Why? NOx emissions are less than 40 TPY. AIRS Point Section 12 — Regulatory Review Regulation 1- Particulate; Smoke. Carbon Monoxide and: Sulfur Dioxide 001-002, 004 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases 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 2 —Odor 001-002, 004 Section I.A - 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. • I-tion 3 -AP N ! •n Ki•n Perrrr`__ -ti.. P -irn' - PSD 001-002, 004 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) 001-002, 004 Part B - Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold (Reg. 3, Part B, Section II.D.3.a) 004 Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the fugitives have been in service after the date above, this source is considered "new or modified." Operator has a LDAR program at the facility. Regulation 6 - New Source Performance Standards 001 None 002 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? Yes Is this source subject to NSPS Kb? No WHY? Tanks are located prior to custody of transfer; therefore not subject to this subpart. 002 NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. Are uncontrolled VOC emissions greater than 6 TPY? Yes Are controlled emissions greater than 6 TPY? Yes • Is the operator requesting a permitted limit less than 6 TPY? No • Source is subject to NSPS OOOO requirements. Page 5 004 002 NSPS OOOO: Standards of Performance for Crude Oji and Natural Gas Production, Transmission and Distribution. For fugitive emissions at natural gas processing plants subject to NSPS OOOO. This subpart establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide°(SO2) emissions from affected facilities that commence construction, modification or reconstruction after August 23, 2011.: Is this sob= °at a "natural gas processing plant?" No Is this source subject to NSPS OOOO? No WHY? F does not meet the definition of a "natural •.:- • • . �: .. - t." XII. VOLA 'U -''s - GANIC COMPOUND ISSIONS FROM • IL AND GAS __ OPERATIONS (Applicant Is subject to the emission control requirements for condensate tanks since it ld'ited in a non -attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant' iscurrently subject to this since actual uncontrolled emissions are greater 6"tpDy of VOC.) Section ( If facility is a not natural gas processing plant located in non - 004 attatnm araati therefore, not subject to Section XILG. It is not a natural gas • rocessi ' therefore, not su •'ect to this su • • . rt. 001-005 None MACT HH If facility is MAJOR source for HAP at a natural gas processing plant ONLY (summation of HAPS of dehydrators and fugitives), then fugitive emissions are subject to MACT HH. 002, 004 Is this facility considered MAJOR for HAPS? No Is this source subject to MACT HH? No WHY? Facility is considered area source for MACT HH, therefore it is not subject to MACT HH. Only TEG dehydrators at the facility are subject (if there are any). Section 13 — Aerometric Information Retrieval System Coding Information Point Process Process Description Emission , Factor Pollutant / CAS # Fugitive (YIN) Emission Factor Source Control (%) 001 01 65200 Ib/MMscf VOC No Engineering Calculation 98 0.068 lb/MMBtu NOx No AP -42, Table 13.5-1 NA 0.37 lb/MMBtu CO No AP -42, Table 13.5-1 NA Flare 1504 lb/MMscf Benzene/ 71432 No Engineering Calculation 98 100Ib/MMscf 101uene/ 08883 No Engineering Calculation 98 100 lb/MMscf Ethlybenzene/ 100414 No Engineering Calculation 98 4011 Ib/MMscf Xylenes/ 1130207 No Engineering Calculation 98 100 Ib/MMscf n -hexane! 110543 No Engineering Calculationse SCC 31000205 -Flares 002 02 Condensate tanks 231.11 Ib/mmscf VOC No Engineering Calculation 98 0.068 Ib/MMBtu NOx No AP -42, Table 13.5-1 NA 0.37 lb/MMBtu CO No AP -42, Table 13.5-1 NA 4.67 Ib/mmscf Benzene/ , 71432 No Engineering Calculation 98 7.56 Ib/mmscf Toluene/ - 108883 No Engineering Calculation 98 Page 6 0.44 lb/mmscf Ethlybenzene/ 100414 No Engineering Calculation 98 2.67 Ib/mmscf Xylenes/ 1130207 No Engineering Calculation 98 34.89 lb/mmscf n -hexane/ 110543 No Engineering Calculation 98 1.33 lb/mmscf 2,2,4-TMP/ 540841 No Engineering Calculation 98 SCC 40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses 004 01 Fugitive VOC Leak Emissions VOC Yes EPA -453/R-95- 017, Table 2-4 NA SCC 31000220: All Equip. Leak Fugitives (Valves, flanges, connections, seals, drains) Section 14 - Miscellaneous Application Notes AIRS Point 001 Venting flare Please see K:\PA\2013\13WE2908-001.CP1.xlsm for calculations. Operator calculated 2119 TPY uncontrolled VOC (43.0 TPY controlled). They calculated emissions using a mass balance and conservative wt% from similar facilities because they didn't have a gas analysis done at the time of application submittal. When I was able to review it again (originally Laura's application; I picked it up again February 2015) I was able to get a gas analysis sampled on 11/25/2014. From this, I generated calculations using the displacement equation, which were less than what the operator calculated. Since the operator calculations are greater than what I calculated, I feel comfortable permitting the flare with the operator emissions. Controlled VOC is not significantly greater than what I calculated. Component Uncontrolled Total (lb/yr) Operator emissions (lb/yr) Scenario A Reportable? Controlled Total (lb/yr) Operator emissions (lb/yr) VOC 2072.2 TPY 2119 TPY --- 41.4 TPY 43.0 TPY Benzene 68718 97760 Yes 1374 1995 Toluene 28289 32565 Yes 566 651 Ethylbenzene 109 6500 Yes 2 130 Xylenes 273 6500 Yes 5 130 n -hexane 242425 260715 Yes 4849 5214 224-TMP 137 6500 Yes 3 130 NOx = 0.068 lb 65 mmscf 2100 btu 1 T = 4.64 TPY NOx mmbtu yr scf 2000 lb CO = 0.37 lb 65 mmscf 2100 btu 1 T 25.25 TPY CO mmbtu I yr scf 2000 lb Emission factor for VOC based on operator's calculated emission is: VOC = (2119*2000) / 65 mmscf/yr = 65200 lb/mmscf Emission factors for HAPS based operator's calculated emissions are: Benzene = (97760 lb/yr) / 65 mmscf/yr = 1504 lb/mmscf Toluene = (32565 lb/yr) / 65 mmscf/yr = 501 lb/mmscf Ethylbenzene = (6500 lb/yr) / 65 mmscf/yr = 100 lb/mmscf Xylenes= (6500 lb/yr) / 65 mmscf/yr = 100 lb/mmscf n -hexane = (260715 lb/yr) / 65 mmscf/yr = 4011 lb/mmscf 2,2,4-TMP = (6500 lb/yr) / 65 mmscf/yr = 100 lb/mmscf An extended gas analysis was provided in the during my review sample dated 11/25/2014. The gas analysis was performed within a year of review. An updated extended gas analysis will not be required because an extended gas analysis was performed within a year of this review and included with this package. Page 7 AIRS Point 002 Condensate tanks Emissions were calculated using HYSYS model (Flash) and EPA Tanks (working + breathing). • Tanks are controlled by a vapor recovery unit (VRU) and a backup flare. It is assumed the VRU will control at 100% and during downtime the flare MI control at a requested 98%. Because the request is greater than 95%, the operator will have to follow the provisions of 60.18 for the flare. Emissions were divided out because of the 100% dosed loop. It is assured that 21,400,000 bbl/yr will go through the VRU when it is operational and 500,000 bbl/yr will go through the flare during VRU downtime. Component Flash EF (lb/bbl) 1AB EF (lb/bbl) Total EF (lb/bbl) Total EF (lb/1000 gal) Uncontrolle d (lb/yr) Uncantroll ed (TPY) ' Uncontrolled to Flare (rest is 100% racy led) (b/yr) Controlled (lb/yr) Controlled (TPY) VOC 10.2 0.2 10.4 247.6190 227760000 113880 2600 10400 53 Benzene 0.021 0 0.021 0.5 459900 230 525 210 011 Toluene 0.033 0.001 0.034 0.8095 744600 372 8.5 340 0.17 E -Benzene 0.002 0 0.002 0.0478 43800 22 0.5 20 0.01 Xylenes 0.012 0 0.012 0.2857 262800 131 3.0 120 0.06 n -hexane 0.154 0.003 0.157 3.7381 3438300 1719 39.25 1570 0.79 224-TMP 0.006 0 0.006 0.1429 131400 66 1.5 60 0.03 NOx = 0.068 lb 123750 MM btu 1 T 4.21 TPY NOx I am 60.18 002 is or 45 the a with As that it with second - the calcs we would to Let me yr lb mmbtu I I2000 CO = 0.37 lb 123750 MM btu 1 T I 22.89 TPY CO I mmbtu I emailed the operator on 2/26/15: Is the backup control device for hesitant to give a regular flare 98% Since I wrote that email to the operator, requirements. I will include this The operator provided this comment correctly listed as natural gas venting MMSCF/yr I responded to him on 11/13/2015 APEN is showing 500,000 bbl/yr. condensate throughput limit..? condensate; however, lam not such, I was thinking/hoping that would make the most sense to the 500,000 bbl/yr throughput during I think the best option would be process limit would be: VOC =113880'2000/45 = 5061333.333 Benzene = 230'2000145 =10222.2222 Toluene = 372'2000/45 =16533.3-'x-43 Ethylbenzene = 22'2000/45 = Xylenes= 131'2000/45 =5822.222 n -hexane= 1719 *2000/45 = 76400 224-TMP = 66'2000/45 = 2933.3333 I received an email on 12/9/15 from below, which I previously said looked would blow our tpy limits enormously. assume the flare was running 8760, demonstrate compliance should know if you'd like me to elaborate VOC =10400/45 = 231.1111 lb/mmsd Benzene = 210/45 = 4.6667 lb/mmscf Toluene = 340/45 =7.5556 lb/mmscf Ethylbenzene = 20/45 = 0.4444 Xylenes= 120/45 =2666.6667 lb/mmsd n -hexane= 1570/45 = 34.8889 lb/mmscf 224-TMP = 60/45 = 1.3333 lb/mmscf I the tanks control the condition on the to and his I think You're not sure it would since the track compliance VRU to have 2 lb/mmscf yr I2000lbI a thermal oxidizer (as was in the (and typically the division has given Division has granted 98% for flares in the permit. draft permit In condition 11, the atmosphere; however, the annual response is in italics; Hrnmmrn...are I got Points 001 and002 confused wrong that theemleefions associated really be passb)e fo;estimate actual emissbrl,sfisbirt Js going to by stayg under the volume downtime. Hopei* that makes process limits for this point source. lb/mmscf lb/mmsd In the notes to permit holder. to me. It just occurred to meiiwe factors you calculated were basl.on more than 45 MMSCF. These on the controlled lb/yr numbers being original application) or a flare? 95% for flares). with the operator following process parameter for point limit should be 45,000 mscf/yr you sure? It is for tanks and in the table, and it should be with Point 002 are associated throughput while the VRU is down. the flare and would be metered of gas, 45MMSCF/yr associated sense? The emission factor for the 5.) table for Point 002... or actually flared 45 MMSCF total uncontrolled lb/yr which factors, if they are to be used divided by 45 MMSCFD. Ib/mmsd 977.7778 lb/mmscf lb/mmscf lb/mmscf the operator: good The or much be based on this. lb/mmscf Page 8 AIRS Point 002 Condensate tanks continued I emailed this about being able cannot be exactly that with high flare from the throughput than have VOC/bb/ 100% VRU capture too onerous to demonstrate reference/Reg with me here! I decided to just the 500,000 Operator commented condition 19 impossible to I responded: because it's really need A LOT dig into this deeper like this can be another one to the operator. He wrote back: This calcs below look good to me, I'm still a bit concerned to demonstrate compliance with the 500,000 bbl/yr limitation, since the throughput correlated with VRU up/down time, we just don't have the granularity in the data to do confidence; however, we do have the ability to measure the gas volume that goes to the tank system. I would feel a lot more confident demonstrating compliance with the gas the liquid throughput while the VRU is down. From my perspective the only reason to emission factors is for Reg 7 purposes and our Reg 7 reporting doesn't take credit for the -98% of the time but assume everything is combusted b/c it was determined to be figure out how to match production to VRU uptime. Any chance we could just compliance vs. the gas volume limitation and have the liquid factors in there for 7 purposes only? I know this is a weird one, thanks for being willing to go back and forth remove any reference to the 500,000 bbl/yr throughput. The 45 MMscf/yr correlates to bbl/yr and it is easier for Noble to comply with the 45 MMscf/yr throughput limit. on a few other conditions in the draft permit via an email 12/9/15: Starting with there are lots of references to enclosed flares, these aren't enclosed flares, so it will be comply, but I'd say that a few references to Reg 7 XVII b.2.e could probably help that? Can you refresh my memory why these aren't enclosed? The tank flare isn't enclosed a backup control device for upset conditions only...for production of this scale you'd of enclosed flares, I'd also assume that the simplicity makes operation safer this way. I can if you need me to, I apologize if this wasn't clear from the beginning...I know things awkward when you start out working with one air quality engineer (Cat) and then switch to me) part way through. AIRS Point 004 Fugitive emissions A permit will be issued because the uncontrolled VOC emissions are greater than 1 TPY (APEN threshold) and TOTAL FACILITY is greater than 2 TPY (permit threshold). An extended gas analysis was provided in the application dated 11/25/2014 (gas) and 12/3/2014 (liquids). The gas analysis was perfomed less than a year of revised submittal. An updated extended gas analysis will not be required because an extended gas analysis was performed within a year of this submittal and included with this package Operator will have a LDAR program in place at this facility. Therefore, they are able to use EPA Table 2.8 (screening factors) for fugitives. This significantly decreases the fugitive emissions, but still requires a permit. I emailed the operator on 02/25/2015. She responded on 02/25/2015 (in italics): 1. It looks like there was a lot of rounding up when calculating the emissions. Looks like the wt% were rounded up: For gas: VOC from 88 to 90; benzene from 1.091 to 1.5; toluene from 0.449 to 0.5; ethylbenzene from 0.002 to 0.1; xylenes from 0.004 to 0.1 and n -hexane from 3.849 to 4.0. Is this correct? Noble just wanted to have a safety cushion in the emission calculations? Same rounding with the light oil (benzene from 0.228 to 0.5; toluene from 1.141 to 1.5; ethylbenzene from 0.011 to 0.1; xylenes from 1.787 to 2.0 and n -hexane from 1.719 to 2.0). Yes, we were just rounding to account for potential variations in composition. I believe / was also trying to look at the various gas compositions throughout the facility and pick the most conservative. Page 9 51 r Cd czt z C o � o � o � O •� v .' s 2 •R W P. 7 pU� y U 1'0U' Z z O A VI u fj OJ cd p, w 171 0 Section 01— Administrative Information Request for NEW permit or newly reported emission source y ',:o O R. el O Da O G' ToP. 0 00 UG 61 N a) rn d H T) Z P U A O t 7 C4 ❑ ❑ ® ❑ -C 0 0 0U zc Noble Energy, Inc. Change fuel or equipment b NW Sec 22 T6N R63W Wells Ranch Processing Facility Change permit limit 4) r v with a Federally enforceable limit on PTE Request to limit ® ❑ N 0 G) •0 O U O a) a) 303.228.4280 5 z .p c) cip d For new or reconstructed sources, the projected startup date is: N v1 N I N Separator gas fl 4) ow F.' G o 0. 0 'o a o� 8 U 6 U oP 0 0 O 8 Po •0 y 1Fq b( O o •Ax•0 Iii O co N NNN 0000 000PN 111 < U c 0 7/3 G 4r 0 o ° 4( • = C'J .colorado.gov/cdphe/permitstatus Section 04 — Processin ii C) 0 04 0 O ,. a a" o w°' A C7:ID O 0yo a 6) 4 0 P4 •6uwu as A❑®❑❑❑ O v 0. N r O N ti e O P Process Parameters: a OG e O X O gR O o� H N 0 8 v) U 0 0C A G 00 .I •ELG 0 0 pT O a 2 o o .4O .0 6 O El U U 7 m O �• a e g tl 0 O Ob X4.4 .e A o > 4 z U d O. N 'o 3�y lC A 00 M FormAPCD-211-Natural Gas Venting APEN - Ver.l0-14-2014.doc N 0 0 ti bA Q•t FORM APCD-211 r I I Z-QDd tV IARIO3 d O Pop'fil ti W 0 I 0 I O b�{ P., O O 2 1NL cr as o tr 6 O O rt • a itt so 0 k°i p ie 17 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. t..)' x N c ° td O r X0N -o n Pollutant h Control Device Description vo 41. trl O • 00 Control Efficiency (% Reduction) O j.r A N O N O j.+` O t►/+� O J O 0000 u N Emission Uncontrolled Basis lb/mcf ItEUarr 1 aa Ut I 13036 3.25 N oho o°Do N b Actual Cali Emiss Uncontrolled ons/Year 0.07. 2.61 0.07 O J O W.' O 0O0 U Go 4.7 N A q n O O R Uncontrolled (Tons/Year) Requested Permitted Emissions .__p r a m o w 00 o N A .P Ap oO & _W Calculation I dd ag 00 Estimation Method or Emission Factor Source O • E d r a o• I p a e� I S 2 9 8' rriq g tlw g' a Imo• to a8 uogsut iojtg 0 O 0 O 0 2.. co �t O w c • o . G c R° e En N • O or p v. " ❑ • C C1 • g. • g n ❑ q • a a ors R.# 4 to o a I R R5 W I - a R b C) O 0Q I ( 0 0 1-3 CD • 1.4IV Io • g p a p g 2 0 ►rt! O 0 O p 0 0 Vs it n N d 0 iJ H ra co (KM ao 2uo 8Z aarmo [Leave blank unless APCD has already assigned a permit # & a Permit Number: 0 Z U Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 —Re Section 01— Administrative Information o b UU U zCC Source Location: NW Sec 22 T6N R63W Change process or equipment Transfer of ownership Change permit limit 1625 Broadway, Suite 2200 Mailing Addr APEN Submittal for Permit Exempt/Grandfathered source 0 0 a) N Phone Number. 303.228.4150 Person To Contact Catherine Flanders WNIe VRU b operatonet, emissions are zero_ The requested perrnit rime is the allowed throughput while secondary controls e Fax Number- 303.228.4280 O U m N C N a C �) a) C a) a) C •C a) -C to U 4 N "0 k] Section 03 — General Information C'.) 0 N Cr) 3 z z z 0 a 0 04) 0 O C O 4) 0 a z 0 C') oc2 v, /4I W .4 b o a, y E'H ❑O❑�� 0 N N y0 O 2 0 O "g3 ❑ ,c3 y A N N O a) A 0 ° ctl a ro co L o' ° y vi _ U cy w b U N 0 ei p",k3 H ,O' p� O w8>� • 5� o C. ° 0 Al E-oo,a a › c ° a) G' ° u a) 44! g 7 y . O O O �>0 a U °I - a) a 0 d) O V J 5'2ab 0 Di) OD 0 O cn ❑O 0 •o 0 , 4 4-. a) & Production td > 0 00, o ` $C'. a a) o co 4, t Z7 °'two w a a 0O,VD aI. az a 0> o P. �a bow E o 1°00 a`�^eV � � omv2 G1 O O a w O A. m w W ,o c0 A °') L 5?, W 0 Fppyyy ) i., O 7.. 769 'd y 'k .§ an q 1-4 y o 0 -)0C4)6)4)4) .C o id api, u `' i. " A 7 ma 7 .^ -C. y- O O 7 7 0 0) .O, 2 O P-, b i., Li 6, w 6, Q O U oq H 0 �4p., o ..o o > po „.9y LE q �.' �"' In Q td c. b co a' a Cd L ila b 0 ° 'N O y b. 4' 84. yN . 0Q E C", C. 0 z G ° G „y U 000 o U rn a o a y u 0 b c. g a °' pa 'L a) a o is o g o 6, ... 1Cri i A C? ct) rti U 6) '0 dS2. a; 41 t c. U vA w Qcn APEN forms: h colorado.eov/cd Application status: h a 0 Ca 0 o au 0 0 0 P4 U ❑ 04 bo w Internal Floating Roof: Fixed Roof: ib c 6)0 v W y w C Tim ".(g.' O 41 O bit Q 47 H N N 0 0 CO Ca to Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) I Newly Reported Well ❑ ❑ • Name of Well New wells are tied into this location on a routine basis API Number 1 1 1 1 1 1 , , , , Form APCD-205-CondensateTank APEN-Ver.12-22-2014.doc Permit Number: 1. 0 G a u 0 00 6.1 .14 rA a p o w a O :G O 0 A o V 1§ .�, m • i o y cV Up rya O. o •y A 0 QS 1«, O t E F O 0' C 0 E 0 C 8 3 e e a es c e O. e 0 0 r Z o q1` a — E GO O GS I a Y �+ a o Q 5 O 0 O O a O. in 0 Qj j Y U w a g O +0 b O • uga tion & Emission Control Information issions Inventor Emission Factor Data Source AP -42 13.5-1 I HYSYS / EPA TANKS ri N I Q HYSYS / EPA TANKS I HYSYS /EPA TANKS I HYSYS / EPA TANKS 1 HYSYS I EPA TANKS a zY r a w y 0y [ HYSYS / EPA TANKS I • port pollutants not listed above. • Requested Permitted Emissions Controlled (Tons/Year) o of ` w v , .c Uncontrolled (Tons/Year) Actual Calendar Year Emission Controlled (Tons/Year) o 1In 1-1oo�o o o 0 O O 0 Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to re Uncontrolled (Tons/Year) O N N �. �. Emission Factor a 0 Uncontrolled Basis •I 03 m 0 a O_ •,- 10.37 0 .0 O: Y0 0 01:i 0 O CCD G 0 4g. O. PLI Xox O U o E" Ioa.a t,C W I Xylenes E o8i. . 0 v N N 1 W C 0 0 4 a uY Cw 0 p u O. O. Eo 110 S9 G e IZ e a g a U 'd ° o E 'a u0 w to E s� Y 0 0 a Y Ara Y ,3 fl Y a o 0 0 o u o ae o L.'s* 11a a q �y' •a a u It Y 0 C C C1 W E C 2 C tiJ Catherine Flanders •+ b 8 a O .R 0 a 8 S EE I S B 4 I I N.0 0 a b FORM APCD-205 onent Leak Emissions] AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Fu 2 Emission Source A [Leave blank unless APCD has already assigned a permit # & Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] U- LL Facility Equipment ID: nested Action (Check applicable request boxes) Section 02 — Re Section 01— Administrative Information Request for NEW permit or newly reported emission source u id C o a 0 d 0 uc) 0 ❑ ❑ 4) 0 Change process or equipment 4.3 43 Transfer of ownership Change permit limit O O N- s with a Federally enforceable limit on PTE B C CO O N O v y' 0 v U 0 U U o'. zv, w N Noble Energy, Inc. 0 z 0 Mailing Address: 1625 Broadway, Suite 2200 for update only (Please note blank APENs will not be accepted) APEN Submitt O U c N O Phone Number: 303.228.4150 Person To Contact: Catherine Flanders Fax Number: 303.228.4280 Section 03 — General Information CO 0 N M O N 0 CO rn N If) I N - v O .C N Other (Describe): ❑ Natural Gas Processing Plant C 0 0 o C O 4) 0 8 0 0 Normal Hours of Source Operation: z ❑ O C A no PI � G izq o U 0 .+ p C'O s Cl. a d F. A Q 0 4 O 0 U ob .. 44 o N N U e m.5. •N 04 g V) N 4 3 5 > 0 a • O" N N 0 • 11 w e c 0 13, C R' o g 0 Oo0 crl In' M r1 f^ A T C) p Co Co CD O O © W _ ��£^W o y U -111. U ) j 2 0 0 H o 0 o .r A• U O .9 CAC ate, • G 0 APEN forms: htto:/ /www.colorado Application status: h o ^CO 0 0 AA A A ❑❑❑ ❑ z z z z ❑000 0 td N ' .9. a 4 o 3 v ; 3w gb a a' 0 ° oI a o a w 0 '43 o H " 5 W � � Information 0 :d Section 04 — Re CC N 14 H ❑� ❑ ❑ ❑ Is this equipment subject to Regulation 7, Section XVII.F? pxC o O a a CC y G co" so so o cip z z 0 0 4) a 4) a. as C 43 4) H M 40 CFR Part 63, Subpart HH? Is this equipment subject to NES Section 05 - Stream Constituents n -Hexane (wt. %) N N Xylene (wt. %) T O N N o C o 4 44 r r r W O 0 O lee H .� I(. o ICS 1.0. 'Benzene wt. I() If) It? T- 0 0 C.) .e' O .4 0 0 c""- 0 5 cli c7 IHeavy Oil (or Heavy Liquid) I Light Oil (or Light Liquid) Water/Oil Check box to request copy of draft permit prior to public notice or issuance. N 4-+ 0 FORM APCD-203 4 Emission Source Permit Number: Se it.scg 0. u ..^ t 0 ❑ ' 0 O 1 o S bb ed s a th , go I Z w P o f e a<x .,,a w p w ,,i9zA d ❑D ❑❑ w F C 8 CD M M 0 Z 44 3� 999T��y kg/hr/count I C I kg/hr/count kg/hr/count kg/hr/count C 7 8 Y r W o - 1 r4 tr) v N CO r C) rn 1. g U N. co O o CO `•O -f b ••••• kg/hr/count kg/hr/count kg/hr/count kg/hr/count kg/hr/count v Light Oil (or Light Liqui 9 i.t.1 W%111 I co CV •- t0 r 6640 2940 0 't' d U co Cr) N .O CA to assume all light oil 0 g Illy o o la kg/hr/count kg/hr/count kg/hr/count kg/hr/count kg/hr/count I t Y 0w W 0 f4) tp tp tcO. b 1 r LI) r- C) N .- U c.) 2380 •-° O co N o Equipment Type 8 v b' w Open -Ended Lines I I Pump Seals > o Estimation Method g 03 a .s o EPA Leak Protocol 00 CV 0 a - 1 a. a. 0 V Screening Factors = Data year for actual calendar year emissions. below (e.g. 2007): Actual Calendar Year Emissions' o F*miicion Factor Uncontrolled Basis 8 a w t m cV 8 ,) H .A I O M a z o w° 0 eg W z N en O N 0 U • Hello