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Home My WebLink About20151421.tiff * GDPHE COLORADO Co .. Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O PO Box 758 RECEIVED Greeley, CO 80632 May 12, 2015 MAY 1 8 2015 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On May 13, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Noble Energy, Inc. - Welts Ranch 21 Eco Node. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, I: / 1 Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure qu,.6.L.T\cw-t,,,, 5 - a 7- /5 a: r 14-1-5-118 2015-1421 "ii:ccr, 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303.692-2000 www.colorado.govlcdpne :�,`. '?'�°,_A. c` John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer '.,':•-: r .:. -x„+_876. CDPHE Air Pollution Control Division CO V Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Noble Energy, Inc. - Wells Ranch 21 Eco Node - Weld County Notice Period Begins: May 13, 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, Inc. Facility: Wells Ranch 21 Eco Node Exploration and production gas line compressor station NESE SEC 21 T6N R63W Weld County The proposed project or activity is as follows: Applicant proposes construction of a natural gas processing facility with enforceable limits on hazardous air pollution. 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 14WE1392 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 AV COLORADO 1 I STATE OF COLORADO LOR '• D T c F P =L C HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION ) TELEPHONE: (303) 692-3150 C /896 CONSTRUCTION PERMIT PERMIT NO: 14WE1392 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Wells Ranch 21 EcoNode, located in the NESE SEC 21 T6N R63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Flare 005 Separator controlled by a 40' flare stack. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 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/an/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 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 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 AIRS ID: 123/9D1D Page 1 of 8 olor. . Depa en • P di Health and Environment it Pollution Control Division II IP of eighteen (i = -. n- • -te c. - = ction 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. The following information 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 AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type x Flare 005 9.3 75.9 50.3 Point 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 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 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. Point 006: 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 AIRS ID: 123/9D1D Page 2 of 8 olor Depa en P li Health and Environment it Pollution Control Division • shall maintain of;-; ,e , w c•.ae ®_= count 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. 9. 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). 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 III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Flare 005 Flare VOC PROCESS LIMITATIONS AND RECORDS 11. 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. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Flare 005 Gas Vented from Separator 211 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/9D1 D Page 3 of 8 olor. Depa en • P .li Health' and Environment i •it Pollution Control Division 13 Visible emissi n. e- - - ty - - 0%) r - ty during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 301h 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 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. 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. 17. 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 AIRS ID: 123/9D1D Page 4 of 8 olor Depa en P li Health and Environment it Pollution Control Division e; virtue of a rel-.Etiic:n'rt a. r iti laxa at 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). 18. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID: 123/9D1 D Page 5 of 8 olor.i Depa en P .all Health and Environment II it Pollution Control Division 24. Section 25-7- a), ` - S. - -s =urce . ired to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. for a wellhead gas flare at a synthetic minor facility for VOC and CO2. AIRS ID: 123/9D1D Page 6 of 8 olor.' Depa it. en R .li Health and Environment ` 4Iiiit Pollution Control Division Notes to Permit Holder me o'" .e an 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 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 005 Benzene 71432 12400 Yes 620 005 n-Hexane 110543 37600 Yes 1880 005 Toluene 108883 12400 Yes 620 005 Ethylbenzene 100414 6400 Yes 320 005 Xylenes 1330207 6400 Yes 320 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled lb/MMscf lb/MMscf NOx @b/MMBTU) --- 0.088 0.088 AP-42 (Ib/ CO(Ib/MMBTU) --- 0.47 0.47 AP-42 VOC 46.18 14.4 0.72 Gas Analysis Benzene 0.10 0.059 0.003 Gas Analysis Toluene 0.08 0.059 0.003 Gas Analysis Ethylbenzene 0.01 0.030 0.002 Gas Analysis Xylenes 0.03 0.030 0.002 Gas Analysis n-hexane 0.63 0.178 0.009 Gas Analysis AIRS ID: 123/9D1D Page 7 of 8 D !, olor- Depa en P .li Health' and Environment it Pollution Control Division 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC; CO2; HAPS PSD or NANSR Synthetic Minor Source of: VOC; CO2 MACT HH Major Source Requirements: Not Applicable 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.q poaccess.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 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9D1D Page 8 of 8 Separator controlled by a 40'flare stack.Flare has a minimum combustion efficiency of 95%. The flare is 005 enclosed. 123 9010 Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator.Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10 4-3) Ex=Q`MW*Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas*MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm Throughput(Q) 211 MMsct/yr 24085.75799 scf/hr MW 2248 Ib/Ib-mol 0.578082192 MMscf/b mole% MW Ibx/Ibmol mass fraction Ib/hr lb/yr tpy Helium 000 4.0026 0.000 0000 000 0.00 0.00 002 2 45 44.01 1.076 0 048 68.39 599064.35 299.53 N2 048 28.013 0.135 0O06 8.58 75170.93 3]59 methane 7321 16.041 11.743 0.522 746.32 6537734.72 326887 ethane 13.54 30.063 4.070 0.181 258.66 2265844.34 1132.92 propane 6.53 44.092 2.877 0.128 182.87 1601954.27 800.98 isobutane 0.72 58.118 0.417 0.019 26.52 232315.59 116.16 n-butane 1.88 58.118 1.093 0.049 69.48 608615.07 304.31 isopentane 0.34 72.114 0.243 0.011 15.45 135298.42 67.65 n-pentane 0.42 72.114 0.305 0.014 19.39 169825.62 84.91 cyclopentane 0.00 70.13 0.000 0.000 0.00 0.00 0.00 n-Hexane 0.30 86.18 0.259 0.012 1643 143936.52 71.97 cyclohexane 0.00 84.16 0.000 0.000 0.00 0.00 0.00 Other hexanes 0.00 86.18 0.000 0.000 0.00 0.00 0.00, heptanes 0.00 100.21 0.000 0.000 0.00 0.00 0.00 methylcyclohexane 0.00 98.19 0.000 0.000 0.00 0.00 000 224-TMP 0.00 114.23 0.000 0 000 0 00 0.00 0.00 Benzene 0.10 78.12 0.078 0.003 4.96 43491.61 21.75 Toluene 0.10 92.15 0.092 0.004 5.86 51302.51 25.65 Ethylbenzene 0.05 106.17 0053 0.002 3.37 29553.92 14.78 Xylenes 005 106.17 0.053 0.002 3.37 29553.92 14.78 C8+Heavies 0 00 137 4837288 0.000 0.000 0.00 0.00 0.00 100.16 VOC mass frac: 0.243 Total VOC(Uncontrolled) 1522.92 Notes Mole%,MW,and mass fractions from Wells Ranch 21 gas analysis. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+based on the average MW on the analysis for the gas. Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1289 Btu/scf Throughput 271979 MMBtu/yr VRU Information Equipment Description Engine to recompress gas to sales line. Make Model Requested Control 100.00% Annual Bypass Tim 50.00% Backup Flare Lverall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 IIb NOX/MMBtu 0.37 I lb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 14435.30 lb/MMscf 721.76 Ib/MMsd 1522.92 tpy 76.15 tpy Gas Analysis Nox 0.07 Ib/MMBTU 0.07 Ib/MMBTU 9.25 tpy 9.25 tpy AP-42 CO 0.37 Ib/MMBTU 0.37 Ib/MMBTU 50.32 tpy 50.32 tpy AP-42 Benzene 206.12 lb/MMscf 10.31 lb/MMscf 43491.61 lb/yr 2174.58 lb/yr Gas Analysis n-Hexane 682.16 lb/MMscf. 34.11 lb/MMscf 143936.52 Ib/yr 7196.83 lb/yr Gas Analysis Toluene 243.14 lb/MMscf 12.16 lb/MMscf 51302.51 lb/yr 2565.13 lb/yr Gas Analysis Xylenes 140.07 lb/MMscf 7.00 lb/MMscf 29553.92 lb/yr 1477.70 lb/yr Gas Analysis Ethylbenzene 140.07 lb/MMscf 7.00 lb/MMscf 29553.92 lb/yr 1477.70 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." N O N 0; [z[] L O o 0 O E ° 'V ¢ G o z ti c m >; v =- = � a � c v ° ❑ 0 op E z �� r, r, r-, n C 0 O .G ,L'. \ l\ c q d ° C O O O G. Q C Q _ N ' Vi C H QFi C .0 _ C ` t. .' r' F. v 0°0 C. 4 0. X Q > P. .. ... 0- 0 v .5 T 3 c 3 _ .E y c " E .S °; W w ° -° U C O L C co O, p O W O N . N C \ L c co o A F 0 ..� 0 N y .. 0 •> L co n .y a 8'2. G p G G z GJ _ Y3 L G 'O on r'`` 7 0 `o c m y x O w = 0 o W 4 n no 6 CO. 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O m c0 g 0 a a La m 1. m Lm y v • ❑ V V : d " 6 cn p e 0> V 0 >1 ti Fc Gz. FL Lr. L- GL v v en c F. U1 v� °' :". .CuU y 0 ,E '� 0 W E c 2.Q I w V o 0 m C I '° _ 0 2 = I w . ur,c °6. O t7 p c o f m c m c c v c 0 c P 0 O ° . G C -•-• O a. .`N , C U U O C riE 3 U x O • K N = v c ea v q V oE A Z 0J V] K Q F ❑ o u — Oj ZZ U On aci c a -5; = o Q! a h ❑ L u C CO F z x O Q o O — ❑ W .� ❑ ❑ d c ❑ m ° 0 00 [Li U, C7 U1 V1 00 STATE OF COLORADO 7 y7 7y 77- COt COLORADO D RT T OF PUBLIC HEALTH AND ENVIRONMENT A AIR POLLUTION CONTROL DIVISION N F o TELEPHONE: (303) 692-3150 ", 1876 CONSTRUCTION PERMIT PERMIT NO: 14WE1392 Issuance 1 DATE ISSUED: ISSUED TO: Noble Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Wells Ranch 21 EcoNode, located in the NESE SEC 21 T6N R63W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Flare 005 Separator controlled by a 40' flare stack. Flare has a minimum combustion efficiency of 95%. The flare is enclosed. 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 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 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 AIRS ID: 123/9D1D Page 1 of 8 olor- Depa en P .li Health and Environment it Pollution Control Division of eighteen r u = z ," _ / (i - n- . : ..-te a - ction 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. The following information 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 AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type Flare 005 9.3 75.9 50.3 Point 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 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 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. Point 006: 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 AIRS ID: 123/9D1D Page 2 of 8 n,41.;:-+. *ice ELI4 h t olor- n Depar en21 of P' IiccHealth and Environment AEI ?ir Pollution Control Division shall maintain. '�.sa of 9. t.,5e4nJA c•ra y+ count y 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. 9. 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). 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 III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Flare 005 Flare VOC PROCESS LIMITATIONS AND RECORDS 11. 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. (Reference: Regulation 3, Part B, II A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Flare 005 Gas Vented from Separator 211 MMSCF Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/9D1 D Page 3 of 8 olor Depa en i Pi°i.Ii Health and Environment it Pollution Control Division 13. Visible emissia= n. e . - ty - 0%) • e. .Y•ty during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30`h whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. 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. 17. 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 AIRS ID: 123/9D1D Page 4 of 8 krEq % olor- Depa °men; f P ; IicaHealth and Environment e11jjj €fir Pollution Control Division t lid i I virtue of a relaxeitima a* r � iti• � at 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). 18. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation 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. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. AIRS ID. 123/9D1D Page 5 of 8 . olor Depa en P h `Health and Environment r it Pollution Control Division ip 3E 24. Section 25-7- : a), ` °4. S. ':-- es -urces . „ : fired to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. for a wellhead gas flare at a synthetic minor facility for VOC and CO2. AIRS ID: 123/9D1D Page 6 of 8 or Ai e olor. Depa ' enr f P'' lic-Health and Environment jsi NI PaAir Pollution Control Division LA l - " Notes to Permit Holder ref ' ime orthis pe ' a - 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 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) 005 Benzene 71432 12400 Yes 620 005 n-Hexane 110543 37600 Yes 1880 005 Toluene 108883 12400 Yes 620 005 Ethylbenzene 100414 6400 Yes 320 005 Xylenes 1330207 6400 Yes 320 5) The emission levels contained in this permit are based on the following emission factors: Point 005: Weight Emission Emission Fraction of Factors Factors Source Pollutant Gas (%) Uncontrolled Controlled lb/MMscf lb/MMscf NOx 0.088 0.088 AP 42 (Ib/MMBTU) CO 0.47 0.47 AP-42 (Ib/MMBTU) VOC 46.18 14.4 0.72 Gas Analysis Benzene 0.10 0.059 0.003 Gas Analysis Toluene 0.08 0.059 0.003 Gas Analysis Ethylbenzene 0.01 0.030 0.002 Gas Analysis Xylenes 0.03 0.030 0.002 Gas Analysis n-hexane 0.63 0.178 0.009 Gas Analysis AIRS ID: 123/9D1D Page 7 of 8 IIolor Depa en .+ P$.li '`Health and Environment II IL it Pollution Control Division 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC; 0O2; HAPS PSD or NANSR Synthetic Minor Source of: VOC; CO2 MACT HH Major Source Requirements: Not Applicable 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.qov/ 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 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9D1D Page 8 of 8 Separator controlled by a 40'flare stack. Flare has a minimum combustion efficiency of 95%. The flare is 005 enclosed. 123 9D1D Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator. Emissions from this source are routed to a flare. Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q'MW'Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas'MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/Ib-mol)at 60F and 1 atm Throughput(O) 211 MMscf/yr 24086.75799 scf/hr MW 22.48 Ib/Ib-mot 0.578082192 MMscf/d mole% MW Ibx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.00 4.0026 0.000 0.000 0.00 0.00 0.00 CO2 2.45 44.01 1.076 0.048 68.39 599064.35 299.53 N2 0.48 28.013 0.135 0.006 8.58 75170.93 37.59 methane 73.21 16.041 11.743 0.522 746.32 6537734.72 3268.87 ethane 13.54 30.063 4.070 0.181 258.66 2265844.34 1132.92 propane 6.53 44.092 2.877 0.128 182.87 1601954 27 800.98 isobutane 0.72 58.118 0.417 0.019 26.52 232315.59 116.16 n-butane 1.88 58.118 1.093 0.049 6948 608615.07 304.31 isopentane 0.34 72.114 0.243 0.011 15.45 135298.42 67.65 n-pentane 0.42 72.114 0.305 0.014 19.39 169825.62 84.91 cyclopentane 0.00 70.13 0.000 0.000 0.00 0.00 0.00 n-Hexane 0.30 86.18 0.259 0.012 1643 143936.52 71.97 cyclohexane 0.00 84.16 0.000 0.000 0.00 0.00 0.00 Other hexanes 0.00 86.18 0.000 0.000 0.00 0.00 0.00 heptanes 0.00 100.21 0.000 0.000 0.00 0.00 0.00 methylcyclohexane 0.00 98.19 0.000 0.000 0.00 0.00 0.00 224-TMP 0.00 114.23 0.000 0.000 0.00 0.00 0.00 Benzene 0.10 78.12 0.078 0.003 4.96 43491.61 21.75 Toluene 0.10 92.15 0.092 0.004 5.86 51302.51 25.65 Ethylbenzene 0.05 106.17 0.053 0.002 3.37 29553.92 14.78 Xylenes 0.05 106.17 0.053 0.002 3.37 29553.92 14.78 C8+Heavies 0.00 137.4837288 0.000 0.000 0.00 0.00 0.00 100.16 VOC mass frail 0.243 Total VOC(Uncontrolled) 1522.92 Notes Mole%,MW,and mass fractions from Wells Ranch 21 gas analysis. Emissions are based on 8760 hours of operation per year. I calculated the average MW of C8+based on the average MW on the analysis for the gas. Flaring Information Equipment Description Flare to combust produced gas until pipeline is available at this wellhead facility. Manufacturer TBD Model TBD Serial Number TBD Gas Heating Value 1289 Btu/scf Throughput 271979 MMBtu/yr VRU Information Equipment Description Engine to recompress gas to sales line. Make Model Requested Control 100.00% Annual Bypass Tim 50.00% Backup Flare (Overall Control I 95.00%I Combustion emission factor source: AP-42.Chapter 13.5 0.07 I lb NOX/MMBtu 0.37 IIb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 1443530 lb/MMscf 721.76 lb/MMscf 1522.92 tpy 76.15 tpy Gas Analysis Nox 0.07 lb/MMBTU 0.07 lb/MMBTU 9.25 tpy 9.25 tpy AP-42 CO 0.37 lb/MMBTU 0.37 lb/MMBTU 50.32 tpy 50.32 tpy AP-42 Benzene 206.12 lb/MMscf 10.31 lb/MMscf 43491.61 lb/yr 2174.58 lb/yr Gas Analysis n-Hexane 682.16 lb/MMscf 34.11 lb/MMscf 143936.52 lb/yr 7196.83 lb/yr Gas Analysis Toluene 243.14 lb/MMscf 12.16 lb/MMscf 51302.51 lb/yr 2565.13 lb/yr Gas Analysis Xylenes 140.07 lb/MMscf 7.00 lb/MMscf 29553.92 lb/yr 1477.70 lb/yr Gas Analysis Ethylbenzene 140.07 lb/MMscf 7.00 lb/MMscf 29553.92 lb/yr 1477.70 lb/yr Gas Analysis Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." Hello