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Home My WebLink About20140355.tiff 3 ° %;14 STATE OF COLORADO vv t D COUNTY Karin McGowanl6o r MFRS 9- CO Karin McGowan ��,° co,� Interim Executive Director re SK el Dedicated to protecting and improving the health and environment of the people of Colorado . 4300 Cherry Creek Dr,S. Laboratory Services Division i'*87Y6 i Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver.,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http.//www.cdphe.state co.us and Environment Weld County Clerk& Recorder 1402 N 17th Ave Greeley, CO 80631 January 27. 2014 Dear Sir or Madam: On January 30, 2014, the Air Pollution Control Division will publish a public notice for Noble Energy, Inc. — Wells Ranch EcoNode 6, in the 1 he (ireele) Fri hulk.. 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 date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health& Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, L / r Li/ Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure ? co r_ 2014-0355 ;,.•_• 10 • 2.01'-\ CC L t 1)L 174. :Brew. f✓ STATE OF COLORADO John W.Hickenlooper,Governor Karin McGowan 6 pt''Co .,ro Interim Executive Director c At o` Dedicated to protecting and improving the health and environment of the people of Colorado , ,� ** AZT 4300 Cherry Creek Dr.S. Laboratory Services Division ire Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment Website Title: Noble Energy, Inc. — Wells Ranch EcoNode 6—Weld County Released To: The Greeley Tribune On: January 27, 2014 Published: January 30, 2014 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT 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 EcoNode 6 Oil and gas wellhead site SESE Section 6, T6N, R62W Weld County The proposed project or activity is as follows: Oil and gas wellhead site that consists of condensate tanks, produced water tanks,truck loadout, wellhead gas flaring and other minor sources. 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.I.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 13WE1467 E1467 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 www.colorado.gov/cdphe/AirPublicNotices 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 Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us $4.,p I.C { y STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT s AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 `� •I876« CONSTRUCTION PERMIT PERMIT NO: 13WE1467 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 facility, known as the Well Ranch EcoNode 6, located in the SESE of Section 6, Township 6 North, Range 62 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Eighteen (18) fixed roof storage tanks with a total storage capacity TANKS 001 of 9684 barrels used to store condensate. Emissions from these tanks are controlled by an enclosed flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. 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, II.G.2). 2. 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; (U)discontinues construction fora 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.) 3. 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.) AIRS ID: 123/9B07 Page 1 of 8 Condensate Tank SM/M Version 2012-1 Depa a .f • bli "'Health and Environment it Pollution Control Division 4. The operator . • Dolor in e I on let.-.. ued 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 5. 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 Emission Type Equipment ID Point NO, VOC CO Tanks 001 --- 14.0 --- 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. 6. 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 'II.E.) Facility AIRS Pollutants Equipment Point Control Device • Controlled ID Tanks 001 Enclosed Flare VOC PROCESS LIMITATIONS AND RECORDS 7. 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 Tanks 001 Condensate throughput 1,000,000 BBL/yr AIRS ID: 123/9607 Page 2 of 8 . kw olor Depa f ery f blic Health and Environment it Pollution Control Division The owner or 4O hafiacitthontbapr s rat- ed on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. Visible emissions shall not exceed twenty percent (20%)opacity 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.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. 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. 12. 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. 13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 14. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII emission control requirements. These requirements include, but are not limited to: Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration and production operations, natural gas compressor stations, natural gas drip stations and natural gas processing plants. XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. AIRS ID: 123/9607 Page 3 of 8 olor.+ Depa e f bli Health and Environment iit Pollution Control Division XVII.C.3. g: r, o -• •r o— - • any nsate storage tank that is required to control volatile organic compound emissions pursuant to this section XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to ensure that it is operating at least as often as condensate is loaded out from the tank, unless a more frequent inspection or monitoring schedule is followed. In addition, if a flare or other combustion device is used,the owner or operator shall visually inspect the device for visible emissions at least as often as condensate is loaded out from the tank. XVII.C.4. Recordkeeping:The owner or operator of each condensate storage tank shall maintain the following records for a period of five years: XVII.C.4.a. Monthly condensate production from the tank. XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this section XVII.C., the date, time and duration of any period where the air pollution control equipment is not operating. The duration of a period of non-operation shall be from the time that the air pollution control equipment was last observed to be operating until the time the equipment recommences operation. XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date and time of any instances where visible emissions are observed from the device. 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The operator shall complete site specific sampling including a compositional analysis of the pre-flash pressurized condensate routed to these storage tanks and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site-specific emissions factor using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 17. The owner or operator shall demonstrate compliance with Condition 9, using EPA Method 22 to measure opacity from the flare. The observation period shall be a minimum of fifteen consecutive minutes. ADDITIONAL REQUIREMENTS 18. 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: AIRS ID: 123/9B07 Page 4 of 8 !1 olor. + Depa e f blic Health and Environment it Pollution Control Division i 4u For an, • 1( path 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. 19. 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). 20. 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 21. 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. 22. 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 AIRS ID: 123/9B07 Page 5 of 8 olor Depa e .4 • bli it PollutionHealth ControlandEnvironment Division to operate ar; -d ' e ' e Self- k- '4s for Final Authorization section of this permit. 23. 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. 24. 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. 25. 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. 26. 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. 27. 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 Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted condensate tanks at a synthetic minor wellhead site. AIRS ID: 12319B07 Page 6 of 8 Color a Depa men f bli Health and Environment it Pollution Control Division t Notes to Permit Holder attid'time of this per 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.cdphe.state.co.us/requl ations/a irregs/100102agcccom m on provisionsreg.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr) Benzene 71432 A 2000 YES 100 001 Hexane 110543 C 16000 YES 800 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors Emission Factors Uncontrolled Controlled CAS# Pollutant lb/BBL lb/BBL Source Condensate Condensate Throughput Throughput VOC 0.56 0.028 EPA Tanks(W+B) and WinSim (flash) 110543 n-Hexane 0.016 0.0008 EPA Tanks (W+B) and WinSim (flash) 71432 Benzene 0.002 0.0001 EPA Tanks(W+B) and WinSim (flash) Note: The controlled emissions factors for point 001 are based on the flare control efficiency of 95%. AIRS ID: 123/9B07 Page 7 of 8 olor• Depa e .f a bli 'Health and Environment •it Pollution Control Division 6) In accordance with -7- . ' P. ; .`..ission • y (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: NOx,VOC, CO, n-hexane and total HAPS PSD and NANSR Synthetic Minor Source of: NOx,VOC, CO 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: Fitt p:i!ccfit.epoaccess.vov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End SubpartA-SubpartKKKK 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 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) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilqaspermitting htm I AIRS ID: 123/9B07 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Noble Energy Inc. Permit Number: 13WE1467 Source Location: Wells Ranch Econode 6 SESE Section 6,T6N, R62W, Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9B07-001 Date: April 23, 2013, June 21, 2013 Review Engineer: Stephanie Chaousy, PE 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? February 22, 2013; Operator On what date was this application complete? changed process throughput and provided a revised APEN on 6/21/13 Section 4—Source Description AIRS Point Equipment Description Eighteen (18) above ground atmospheric condensate storage tanks with a total 001 storing capacity of 9,684 barrels. Emissions from these tanks are controlled by a flare. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 001 Source provided site-specific emission factors using gas sample and E&P Tanks. See Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 001 1,200,000 BBL per year(1,000,000 x 1.2) Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 1,000,000 BBL per year Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Granted 001 01 Flare 95 Section 6—Emission Summary (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 001 --- 280 --- 8.0 (Hexane) 9.0 - Uncontrolled point 001 --- 280 --- 8.0 (Hexane) 9.0 source emission rate: Controlled point 001 --- 14 --- 0.4 (Hexane) 0.45 source emission rate: Section 7—Non-Criteria/ Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (lb/yr) reportable? Rate(Ibtyr) Benzene 71432 A 2000 Yes 100 n-Hexane 110543 C 16000 Yes 800 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 Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method VOC, Liquids Analyses 001 01 HAPS PS Memo 05-01 according to PS Memo 05-01 Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Page 2 Classification relates to what programs? X Title V X 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 Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards(NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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, 001 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 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 001 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. Re•ulation 3-APENs Construction Permits, Operating Permits. PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 001 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) Part B—Construction Permit Exemptions 001 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section It O.2.a) Regulation 6- New Source Performance Standards Page 3 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; there are 18-538 bbl tanks onsite. Is this source subject to NSPS Kb? No WHY? It meets exemption §60.110b(b)(4): Vessels with a design capacity less than or equal to 1,589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer. 001 1 cubic meter= 264.172 052 36 gallon [US, liquid] 538 bbl 42 gal 1 cubic meter =85.54 cubic meters 1 bbl 264.172 gal I emailed the operator to confirm that they are prior to custody of transfer per the definition in the Regulation. Regulation 7—Volatile Organic Compound XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks 001 since it is located in a non-attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution 001 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 001 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (Y/N) Emission Factor Source (%o) 13.3484 EPA Tanks(W+B) and lb/1000 gal VOC No WinSim (Flash) 95 E&P Condensate 0.048 Benzene/ EPA Tanks(W+B) and 01 Storage Tanks lb/1000 gal 71432 N° WinSim (Flash) 95 001 0.3849 n-Hexane EPA Tanks(W+B)and lb/1000 gal / 110543 No WinSim (Flash) 95 SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY (permit threshold). Operator provided EPA Tanks(working and breathing) and WinSim (Flashing) in determining emission factors. I verified their calculations and they seemed to make sense; although there was some discrepancy between the calculations and the APEN. I emailed the operator for some clarification. They used a projected production limit of 600,000 bbl/yr even though they are requesting 540,685 bbl/yr. I am assuming they rounded up to calculate the emission factor, then used that to multiply with their requested value. Uncontrolled emission factors: VOC = (168.19*2000)/600000 = 0.56 lb/bbl * 1000/42 = 13.3484 lb/1000 gal Benzene= (0.602*2000)/600000 = 0.002 lb/bbl * 1000/42 = 0.048 lb/1000 gal n-hexane = (4.85*2000)/600000 = 0.016 lb/bbl * 1000/42 = 0.3849 lb/1000 gal I received a revised APEN on 6/21/13 requesting an increase in throughput. The emission factors would stay the same, but the emissions increased. I revised the PA and permit accordingly. Page 5 Ant .. r . 'Li 1n ,.,` , STATE OF COLORADO /pF Coz COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT /\ t AIR POLLUTION CONTROL DIVISION p TELEPHONE: (303) 692-3150 .� y .. CONSTRUCTION PERMIT PERMIT NO: 13WE1468 E 1468 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 facility, known as the Well Ranch EcoNode 6, located in the SESE of Section 6, Township 6 North, Range 62 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID TLO 002 Truck loadout of condensate. Emissions from the loadout are controlled by an enclosed flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. 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, II.G.2). 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, I I I.F.4.) AIRS ID: 123/9B07 Page 1 of 7 Condensate Loadout TM Version 2012-1 Col do op- e o Public Health and Environment Air Pollution Control Division 3. 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 4. 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 Point Emission Type ID VOC TLO 002 6.5 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. 5. 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 TLO 002 Enclosed flare VOC PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate 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 AIRS ID: 123/9607 Page 2 of 7 ,} uwr Col9"it do p rtme(,'[ or Public Health and Environment Air Pollution Control Division M .ter. AIRS Process Parameter Annual Limit Point 002 Condensate Loading 1,000,000 BBL The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 7. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 8. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 9. 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.) COMPLIANCE TESTING AND SAMPLING 10. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 11. 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 (NO.) 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 AIRS ID: 123/9807 Page 3 of 7 Col do p e o Public Health and Environment D Air Pollution Control Division 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. 12. 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: 13. 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. 14. 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. 15. 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. AIRS ID: 123/9607 Page 4 of 7 Col kado • p r₹mt of Public Health and Environment Air Pollution Control Division r— 4: 14 16. 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. 17. 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. 18. 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. 19. 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 Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted truck loadout at a synthetic minor wellhead site. AIRS ID: 123/9B07 Page 5 of 7 pCol do p e o Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (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.cdphe.state.co.us/req ulati on s/ai rreos/100102agcccom monprov isi onsreq.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr) Benzene 71432 A 2322 Yes 116 Toluene 108883 C 3354 Yes 168 002 Ethylbenzene 100414 C 258 No 13 Xylenes 1330207 C 1290 Yes 65 n-Hexane 110543 C 4128 Yes 206 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/1000 gal Source Lb/1000 gal Source loaded loaded VOC 6.15 AP-42 0.3075 AP-42 71432 Benzene 0.0553 Wt Frac 0.0028 Wt Frac 108883 Toluene 0.0799 Wt Frac 0.0040 Wt Frac 100414 Ethylbenzene 0.0061 Wt Frac 0.0003 Wt Frac 1330207 Xylenes 0.0307 Wt Frac 0.0015 Wt Frac 110543 n-Hexane 0.0983 Wt Frac 0.0049 Wt Frac The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S =0.6 (Submerged loading: dedicated normal service) AIRS ID: 123/9B07 Page 6 of 7 CoIjn do • p,rtme ° of Public Health and Environment 4y'1 4 Air Pollution Control Division ..G P (true vapor pressure) = 6.9 psia M (vapor molecular weight) = 62 lb/lb-mol T (temperature of liquid loaded) = 520 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the weight fraction of each NCRP in the vapors by the VOC emission factor using DOC# EPA-453/R-94-002a, Table 3-2 for normal gasoline. 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: I Applicable Status Requirement Operating Permit Synthetic Minor Source of: NOx, VOC, CO, n-hexane, total HAPS NANSR and PSD Synthetic Minor Source of: NOx, VOC, CO 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN —Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe.state.co.us/ap/oilqaspermating.html AIRS ID: 12319B07 Page 7 of 7 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Noble Energy, Inc. Permit Number: 13WE1468 Source Name: Wells Ranch EcoNode 6 Source Location: SESE Section 6,T6N, R62W, Weld County (non-attainment) Equipment Description: Truck loadout AIRS ID: 123-9607-002 Review Date: April 23, 2013 Review Engineer: Stephanie Chaousy Section 2 —Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval 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 please see Section 14 Information Request letter to the source? February 22, 2013; Operator On what date was this application complete? requested to increase throughput. Division received revised APEN 6/21/13 Section 4-Source Description AIRS Point Equipment Description 002 Truck condensate loadout. Emissions from the loadout are controlled by an enclosed flare. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source Mr) CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Is this source located at an oil and gas exploration site? X Yes No If yes, does this source load less than 10,000 gallons of crude oil per day on an annual average, splash fill less than 6750 bbl of condensate (hydrocarbons that have Yes X No an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) Yes X No emissions? Will this equipment be operated in any NAAQS X Yes No nonattainment area? Does this source load gasoline into transport vehicles? Yes X No Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42: Chapter 5.2, Equation 1 L= 12.46*S*P*M/T 002 L= loading losses in lb per 1000 gallons loaded S =Saturation Factor P =true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T=temperature of bulk liquid loaded [deg. R] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 002 1,000,000 BBL per year condensate loaded Basis for Actual Emissions Reported During this APEN Filina (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production 002 1,000,000 BBL per year condensate loaded Basis for Permitted Emissions(Permit Limits' AIRS Point Process Consumption/Throughput/Production 002 1,000,000 BBL per year condensate loaded Does this source use a control device? X Yes No AIRS Point Process Control Device Description %Reduction Granted 002 01 Enclosed flare 95 Section 6—Emission Summar, (tons per year) Point NO, VOC CO Single HAP HAP PTE: 002 --- 129.0 --- 2.0 (n-hexane) 5.0 Uncontrolled point 002 --- 129.0 --- 2.0 (n-hexane) 5.0 source emission rate: Controlled point 002 --- 6.5 --- 0.1 (n-hexane) 0.25 source emission rate: Page 2 Section 7—Non-Criteria/ Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS # BIN Emission Rate emissions reportable? Rate(lb/yr) pb/yr) Benzene 71432 A 2322 Yes 116 Toluene 108883 C 3354 Yes 168 Ethylbenzene 100414 C 258 No 13 Xylenes 1330207 C 1290 Yes 65 n-Hexane 110543 C 4128 Yes 206 Note: Regulation 3, Part A, Section ll.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 Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? Section 9—Source Classification Is this a new previously un-permitted source? X Yes No True Synthetic What is this facility classification? Minor X Minor Major Classification relates to what programs? X Title V X PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No Synthetic If"yes"what kind of modification? Minor Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards(NAAQS)? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate Smoke Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control 002 equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. &4.) Regulation 2—Odor 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 002 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. Page 3 Regulation 3-APENs, Construction Permits, Operating Permits, PSD 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) Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg.3, Part B, Section II.D.2.a) 002 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 tank battery from which loadout is occurring will be in service after the date above, this source is considered "new or modified." Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied. Regulation 6- New Source Performance Standards 002 No applicable subpart. This facility is not a bulk gasoline terminal. Regulation 7—Volatile Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 002 76,000 liters of gasoline(20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8—Hazardous Air Pollutants 002 MACT EEEE: Not subject because minor source of I-iAPs Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process throughput 9 Factor o Description Limit Factor CAS# (Y/N) Source (%) 6.15 VOC No AP-42 95 lb/1,000 gal Ib/01000 gal.0553 Mass Benzene No Balance 95 0.0799 Toluene No Mass 95 01 Truck Condensate 1000000 lb/1000 gal Balance 002 Loadout BBL/yr 0.0061 Mass lb/1000 gal Ethylbenzene No Balance 95 .0307 Mass lb/10000 gal Xylenes No Balance 95 0.0983 Mass lb/11000 gal n-hexane No Balance 95 SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14-Miscellaneous Application Notes AIRS Point 002 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service P 6.9 Psia Based on EPA TANKs run M 62 Lb/lb-mole Based on EPA TANKs run T 520 Deg R Based on source's knowledge of bulk liquid temperature L 6.15 Lb/10^3 gal This value is used to calculate annual emissions 2.58E-01 Lb/bbl AP-42: Chapter 5.2 Equation 1 L= 12.46*S*P*M/T L= loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T= temperature of bulk liquid loaded [deg. R] L 6.151b/10^3 gal 2.58E-011b/bbl Annual requested Throughput 42000000ga1/yr Annual requested VOC emissions 2583191b/yr 129.2tpy HAPS are calculated by taking the total VOC and multiplying it by the vapor fraction from EPA DOC# EPA-453/R-94-002a, Table 3-2, for normal gasoline (attached to this PA). Benzene = (129*2000*0.009) = 2322 lb/yr(operator said 2000 Ib/yr)- 116.1 lb/yr controlled Toluene= (129*2000*0.013) = 3354 lb/yr (operator said 3000 Ib/yr) - 167.7 lb/yr controlled Ethylbenzene= (129*2000*.001) = 258 lb/yr(operator said 0 Ib/yr) - 12.9 Ib/yr controlled Xylenes= (129*2000*0.005) = 1290 lb/yr(operator said 1000 Ib/yr) - 64.5 lb/yr controlled n-hexane = (129*2000*0.016) = 4128 lb/yr(operator said 4000 Ib/yr) - 206.4 lb/yr controlled HAP emission factors: Benzene= (2322 lb/year)/1000000 bbl/yr= 0.0023 lb/bbl (matches APEN)*1000/42 = 0.0553 lb/1000 gal Toluene= (3354 lb/year)/1000000 bbl/yr= 0.0034 lb/bbl (matches APEN)*1000/42 = 0.0799 lb/1000 gal Ethylbenzene=(258 lb/year)/1000000 bbl/yr-0.0003 lb/bbl (matches APEN)*1000/42 = 0.0061 lb/1000 gal Xylenes = (1290 lb/year)/1000000 bbl/yr= 0.0013 lb/bbl (matches APEN)*1000/42 = 0.0307 lb/1000 gal n-hexane = (4128 lb/year)/1000000 bbl/yr= 0.0041 lb/bbl (matches APEN)*1000/42 = 0.0983 lb/1000 gal Page 5 r R t2 STATE OF COLORADO .,a.v 00F COQ\ COLO RADO DEPARTMENT OF PUBLIC IIEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION *p n* TELEPHONE: (303)692-3150 '' �r`6 CONSTRUCTION PERMIT PERMIT NO: 13WE1469 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 facility, known as the Wells Ranch EcoNode 6, located in the SESE of Section 6, Township 6 North, Range 62 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Seven (7) fixed roof storage tanks with a total storage capacity of PW 003 2,890 barrels used to store produced water. Emissions from these tanks are controlled by an enclosed flare. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. 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). 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 3 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. AIRS ID: 123/9B07 Page 1 of 8 Produced Water Tank SM/M Version 20124 olor a Depa e .f bli Health and Environment •it Pollution Control Division EMISSION LIMITA €° �,'_`•NP r. • - _.. 4. 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 PW 003 --- 3.0 --- 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. 5. 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.) FacilityAIRS Pollutants Equipment Point Control Device Controlled ID PW 003 Enclosed flare VOC PROCESS LIMITATIONS AND RECORDS 6. This source shall be limited to the following processing rate as listed below. Monthly records of the actual processing rate 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 Equipment Point Process Parameter Annual Limit PID PW 003 Produced water throughput 450,000 BBL/yr The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. AIRS ID: 123/9B07 Page 2 of 8 4a 9 t.r Color?, Depa " e�n of 'Health and Environment " " it Pollution Control Division 7. Records shall sake in r = = a' troy 'I hard y,provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. Visible emissions shall not exceed twenty percent (20%) opacity 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.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance. This source shall meet the requirements to apply RACT and reduce emissions by installing and operating an enclosed flare (Reference: Regulation No. 3, Part B, III.D.2.a). OPERATING & MAINTENANCE REQUIREMENTS 12. Flares 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 flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 13. If a control device is used to comply with the emission limits of this permit, the following conditions must be met: a. Leakage of VOCs to the atmosphere must be minimized as follows: (I) Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. (ii) Pressure relief valves (PRV) shall be inspected for proper operation annually and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. (iii) Annual inspections of thief hatches and PRV shall be documented with an indication of status, a description of any problems found, and their corrective action. 14. Control devices shall be adequately designed, and operated and maintained according to manufacturer specifications to achieve a control efficiency of at least 95%, and to handle reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. 15. The owner or operator shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper AIRS ID: 123/9607 Page 3 of 8 olor Depa e 1 • bli r ` Health and Environment A it Pollution Control Division operation for . - ,-, ctu u t I • abse . •f pilot light, malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation. Improper operation of a control device shall be further documented with a description of the problem and its corrective action, the date range the control was inoperable, and the produced water production through the battery during the downtime. If the owner or operator cannot document the date that the control equipment became inoperable then downtime shall be assumed to have started directly after the last documented monitoring event. During control device downtime, emissions shall be considered to be uncontrolled. COMPLIANCE TESTING AND SAMPLING 16. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 17. 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 (NO„) in ozone nonattainment areas emitting less than one hundred 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. 18. 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 AIRS ID: 123/9807 Page 4 of 8 Color Depao,menz of -bile/Health and Environment _w�. -,z~' it Pollution Control Division 3tre 19. This an permit ,- 5>„,5yattachrrtept .tw7, ,,be riFgcnd ma ailable 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer AIRS ID: 12319B07 Page 5 of 8 olor. Depa a .f bli 'Health and Environment A A it Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted produced water tanks at a synthetic minor facility. Federally enforceable permit limits to opt out of NSPS OOOO. AIRS ID: 12319B07 Page 6 of 8 w • Color 51 Depa en Jf PS bliciHealth and Environment Air Pollution Control Division is x`' Notes to Permit Holder at'tti& e of th permitl5suanc . 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.cdphe.state co.us/regulations/airregs/100102agcccommonprovisionsreq.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 3150 Yes 158 003 n-Hexane 110543 C 9900 Yes 495 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Produced lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 Source 110543 n-Hexane 0.022 0.0011 Source 71432 Benzene 0.007 0.0004 Source Note: The controlled emissions factors for point 003 are based on the enclosed flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: AIRS ID: 123/9607 Page 7 of 8 olor. Depa a +f biz Health and Environment it Pollution Control Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, CO, VOC, n-hexane and total HAPS PSD and NANSR Synthetic Minor Source of: NOx, CO and VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.epoaccess.aov/ 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) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.colorado.gov/cdphe/oilgaspermits AIRS ID: 123/9807 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Noble Energy, Inc. Permit Number: 13WE1469 Source Location: Wells Ranch EcoNode 6 SESE Section 6,T6N, R62W, Weld County (non-attainment) Equipment Description: Produced water tanks AIRS ID: 123-9B07-003 Date: April 23, 2013, June 21, 2013 Review Engineer: Stephanie Chaousy, PE Control Engineer: Chris Laplante Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt " If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first being issued an Initial Approval permit 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? February 22, 2013; Operator On what date was this application complete? requested to modify application. Division received revised APEN application on June 21, 2013 Section 4—Source Description AIRS Point Equipment Description Seven (7) above ground atmospheric produced water storage tanks with a total 003 storage capacity of 2890 barrels. Emissions from these tanks are controlled by an enclosed flare. • Are"flash" emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PMio CO X Ozone Page 1 Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PMI( CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less X Yes No than 1% by volume crude oil on an average annual basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 Yes X No Rule? If so, submit Form APCD-105 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 003 CDPHE Condensate Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PIE) AIRS Point Process Consumption/Throughput/Production 003 540,000 BBL per year(450,000 x 1.2)wastewater Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 003 450,000 BBL per year wastewater 2012 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 003 450,000 BBL per year wastewater Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Granted 003 of Enclosed flare 95 Section 6—Emission Summary (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 003 --- 70.7 --- 5.9 7.8 (Hexane) Uncontrolled point 003 --- 59.0 --- 5'0 6.5 source emission rate: (Hexane) Controlled point 0.25 source emission rate: 003 3.0 (Hexane) 0.33 Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS # BIN Emission Rate emissions Ibl r (Ib/yr) reportable? Rate( Y ) Benzene 71432 A 3150 Yes 158 n-Hexane 110543 C 9900 Yes 495 Page 2 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X 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 Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If'yes", for which pollutants?Why? For Reg. 3, Part B, III.C.1.a(emissions increase > 25/50 tpy)? Yes X No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 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, 003 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 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 003 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. Page 3 Regulation 3-APENs. Construction Permits. Operating Permits. PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 003 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) Part B—Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this 003 facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section Il.D.2.a) OR Applicant is required to obtain a permit since they are wanting federally enforceable permit limits under 6 TPY to opt out of NSPS OOOO. Regulation 6- New Source Performance Standards 003 None Regulation 7—Volatile Organic Compounds 003 None Rice ulation 8—Hazardous Air Pollutants 003 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 6.2381 VOC No CDPHE PS 95 lb/1000 gal Memo 09-02 01 Produced Water Storage 0.1667 Benzene No CDPHE PS 95 003 Tanks lb/1000 gal Memo 09-02 0.5238 n-Hexane No CDPHE PS 95 lb/1000 gal Memo 09-02 SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 003 Produced Water Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(APEN threshold) and they are requesting federally enforceable emissions under 6 TPY to opt out of NSPS OOOO. State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors (lb/1000 gal) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 6.2381 0.1667 0.5238 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 Page 4 a K 'k kr . r= v� xn. STATE OF COLORADO aFcoto COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fie ,�o, AIR POLLUTION CONTROL DIVISION . J TELEPHONE: (303)692-31501816 'w CONSTRUCTION PERMIT PERMIT NO: 1 3W E 1 946 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 facility, known as the Wells Ranch EcoNode 6, located in the SESE of Section 6, Township 6 North, Range 62 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Flare 009 Wellhead gas flare that has a minimum combustion efficiency of 95%. The flare is not 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. 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). 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i)does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 3. 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.) AIRS ID: 123/9607 Page 1 of 8 Wellhead Version 2012-1 Col D men f Public Health and Environment Air Pollution Control Division 4. 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 5. 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 009 3.9 41.4 21.2 Point See "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 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. 6. 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 Equipment Control Device Pollutants ID Point Controlled Flare 009 Flare VOC PROCESS LIMITATIONS AND RECORDS 7. 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 AIRS Process Parameter Annual Limit Equipment ID Point Flare 009 Natural gas flaring 84 MMSCF/yr The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9B07 Page 2 of 8 atr'en, -ant Colca ,io D mentf Public Health and Environment sq 4 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 a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent(20%) opacity 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. (Reference: Regulation No. 1, Section II.A.1. & 4.) 10. 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. (Reference: Regulation No. 1, Section II.A.5.) 11. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 12. 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 Requirements 13. The operator shall complete an initial site specific extended gas analysis of the natural gas produced at this site in order to verify the VOC, benzene,toluene, ethylbenzene, xylenes, n- hexane,and 2,2,4-trimethylpentane 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. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 14. The owner or operator shall demonstrate compliance with Condition 10 using EPA Method 9 to measure opacity from the flare. (Reference: Regulation No. 1, Section II.A.5). Periodic Testing Requirements 15. 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. AIRS ID: 123/9B07 Page 3 of 8 Col., j ,• D men •f Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually 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 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 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 18. 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. 19. 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. 20. 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. AIRS ID: 123/9B07 Page 4 of 8 � 0e Col 4.a . D men , f Public Health and Environment Air Pollution Control Division 21. 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. 22. 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. 23. 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. 24. 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 Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Noble Energy, Inc. Newly permitted flare at a synthetic minor wellhead site. AIRS ID: 123/9607 Page 5 of 8 DCol.E • D- men' .f Public Health and Environment DAir Pollution Control Division Notes to Permit Holder: 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 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: http://www.cdphe.state.co.us/requlations/airreqsil 001 02aqcccom m onprovisionsreq.pdf. 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 Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Iblyr) Benzene 71432 A 10951 Yes 548 Toluene 108883 C 8269 Yes 413 009 Ethyl benzene 100414 C 1390 Yes 70 Xylenes 1130207 C 3435 Yes 172 n-Hexane 110543 C 67135 Yes 3357 5) The emission levels contained in this permit are based on the following emission factors: Point 009: Weight Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas(%) Uncontrolled Controlled NOx 0.068 0.068 AP-42, Table 13.5-1 Ib/MMBtu Ib/MMBtu CO 0.37 AP-42,Table 13.5-1 0.37 lb/MMBtu Ib/MMBtu VOC 31.23 19.7 Ib/mscf 0.985Ib/mscf Engineering Calculation 71432 Benzene 0.10 0.063Ib/mscf 0.0032 Engineering Ib/mscf Calculation 108883 Toluene 0.10 0.0631b/mscf 0.0032 Engineering Ib/mscf Calculation 100414 Ethylbenzene 0.05 0.032 lb/mscf 0.0016 Engineering Ib/mscf Calculation AIRS ID: 123/9B07 Page 6 of 8 -',7E-4->,z, i` SS 0 :;;4* t % Colc> a o D- Omen f Public Health and Environment Air Pollution Control Division Weight Emission Emission CAS# Pollutant Fraction of Factors Factors Source Gas (%) Uncontrolled Controlled 1330207 Xylenes 0.05 0.032 lb/mscf 0.0016 Engineering lb/mscf Calculation 110543 n-hexane 0.30 0.19 lb/mscf 0.0095 Engineering lb/mscf Calculation Note: The uncontrolled VOC and HAP emissions for this point were calculated using an average of the WR AE 6-62-1 H N,WR AE 6-63-1 H N,WR AE 6-63-1 H N,WR AE 6-86-1 HN and WR AE 6- 69-1 HN well sites with March 14,2013 analysis of a gas sample collected from each well. The controlled VOC and HAP emissions factors for point 009 are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit.For any questions regarding a specific expiration date call the Division at(303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: NOx, CO,VOC, n-hexane and total HAPS PSD and NANSR Synthetic Minor Source of: NOx, CO, VOC 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.epoaccess.eov' Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End SubpartA—SubpartKKKK 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 AIRS ID: 123/9807 Page 7 of 8 Col D- men f Public Health and Environment Air Pollution Control Division 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.col orado.gov/cdphe/oil gaspe rm its AIRS ID: 123/9607 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Noble Energy, Inc. Permit Number: 13WE1946 Wells Ranch EcoNode 6 Source Location: SESE Section 6,T6N, R62W,Weld County (non-attainment) Equipment Description: Wellhead gas flare with a minimum combustion efficiency of 95%. AIRS ID: 123-9B07-009 Date: August 14, 2013 Review Engineer: Stephanie Chaousy, PE 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 See Section 14 Information Request letter to the source? On what date was this application complete? June 21, 2013 Section 4—Source Description AIRS Point Equipment Description 009 Wellhead gas flare with a minimum combustion efficiency of 95%. The flare is not enclosed. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region? (Note: If"yes" the provisions of Yes X No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 009 AP-42, Table 13.5-1 for NOx and CO Gas analysis and engineering calculation for VOC. See Section 14 for calculation. Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 009 84 mmscf/yr Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 009 84 mmscf/yr Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 009 84 mmscf/yr Does this facility use control devices? X Yes No AIRS Point Process Control Device Description % Reduction Granted 009 01 Flare 95 Section 6—Emission Summar/ (tons per year) Point NO, VOC CO SOx PM10 Single Total HAP HAP 8.0 PTE: 009 3.9 827.7 21.2 --- --- (n-hexane) 17.3 Uncontrolled point 009 3.9 827.7 21.2 --- --- 8.0 17.3 source emission rate: (n-hexane) Controlled point 009 3.9 41.4 21.2 --- --- 0.4 (n- 0.9 source emission rate: hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Ibtyr) reportable? Rate(Ibtyr( Benzene 71432 A 5294 Yes 265 Toluene 108883 C 5294 Yes 265 Ethylbenzene 100414 C 2689 Yes 134 Xylenes 1130207 C 2689 Yes 134 n-Hexane 110543 C 15966 Yes 798 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 Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Page 2 009 01 VOC, State only requirement Site-specific gas HAPS analysis Section 9—Source Classification What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V X 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 Major Minor 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)? Yes X No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? 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 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 009 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. Re•ulation 2—Odor 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 009 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. Regulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 009 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) Part B—Construction Permit Exemptions 009 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section Il.D.2.a) Regulation 6- New Source Performance Standards 009 None Page 3 Regulation 7—Volatile Organic Compounds 009 None Regulation 8—Hazardous Air Pollutants 009 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 19.7 lb/Mscf VOC No Engineering 95 Calculation 0.066 NOx No AP-42, NA Ib/MMBtu Table 13.5-1 0.37 CO No AP-42' NA lb/MMBtu Table 13.5-1 0.063 Ib/Mscf Benzene No Engineering 95 Calculation 01 Flare 009 0.063 lb/Mscf Toluene No Engineering 95 Calculation 0.032 lb/Mscf Ethlybenzene No Engineering 95 Calculation 0.032 lb/Mscf Xylenes No Engineering 95 Calculation 0.19 lb/Mscf n-hexane No Engineering 95 Calculation SCC 31000205-Flares Section 14—Miscellaneous Application Notes AIRS Point 009 Flare NOx and CO was calculated using AP-42, Table 13.5-1 emission factors of 0.068 lb/mmbtu (NOx) and 0.37 lb/mmbtu(CO). Emission factor for VOC is: VOC = (827.7*2000)/84000 mscf/yr= 19.707 lb/mscf(matches APEN) Emission factors for HAPS are: Benzene= (5294 Ib/yr)/84000 mscf/yr= 0.063 lb/mscf(matches APEN) Toluene= (5294 Ib/yr)/84000 mscf/yr= 0.063 lb/mscf(matches APEN) Ethylbenzene= (2689 Ib/yr)/84000 mscf/yr= 0.032 lb/mscf(matches APEN) Xylenes= (2689 Ib/yr)/84000 mscf/yr= 0.032 lb/mscf(matches APEN) n-hexane= (15966 Ib/yr)/84000 mscf/yr= 0.190 lb/mscf(matches APEN) Emissions were calculated using Gas MW and wt%of VOC and HAPS (provided by the operator). An average gas analyis was provided in the application using 5 nearby wellsites. It appears that all these samples were done on March 14 (date not listed). An updated extended gas analysis will be required because this source is a new source and an actual sample was not available for emission calculations. A test performed at the source once constructed will provide an accurate emissions sampling. 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O E T T O :n Y } Y = -. _e G C c 0. G Y y , 0. z m _ F I.- O Y z . OIl- Q > _ 'Z [= .o E E_ co O 2 o c y z _ t o a 0C > o o c ^ _ G C 9 ✓: F11 H � m e = 3 Q E V F I.c v = ac�—� n a.GJ o ac) Ci V] 2 ^ 4. E G o4. P., =-1-s v. a sz° CY ♦ ♦ e ♦ UFz ♦ ate ♦ tea • .= 2 6 - r - i J % U - u• C i L•I •= i i ... C {� 1, ! 1:3 8 c - c:3 1r,13 6 QO A !j1 I1i -ter o c o - _r MI C r - - G •= u = .I = ii c — v 'N u r _ O ! 1 C •F- 1 �.i :aJ _ j j r. cir (7... 1 =c ' ❑ ..:_.• ` ` r - iIEI _ -rte _ - = = �. ' rI �- = c o C x - V N U CJ J -x c r 1i1U 71 f - , J •� - - 4 •41 c.i=C - C O L __ I J E _ ..J L ... o i G _2. -C IL @ 3 L C C { - - !--.; :. J; :n-I y `! v :i •c ice.. •z ') !, ii- -cc E F I u -z I. - J. J. ..-_T.._ --.... '!. '^--'•!--.^ 'l. jam} - Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY c` _... Current Status(Check all that apply) Reason for APEN Submittal(Check all that apply) II/42/20j I/4 2/20j / • AIRS ID#1: 123-9B07-001 ❑ APEN update only] ® New or previously unreported battery ❑ Modification to existing source' ❑ Previously grandfathered battery2 ❑ Registration for coverage under general permit no. GPOI'arid—: ® Synthetic minor facility cancellation request for individual permit: ® Located in the 8-hr Ozone Control Area3 ® Application for or Modification of an individual permit ❑ Registered under general permit no.GPOI ff ❑ Administrative permit amendment ❑ Permitted under individual permit: I =C )'4['I ❑ Other: For individual permit applications,check if you wants: ❑ A copy of the preliminary analysis conducted by the Division ❑ To review a draft of the permit prior to issuance Company Name]: Noble Energy,Inc OGCC Operator k: 100322 Mailing Address10: 1625 Broadway Suite 2200 City: Denver State: CO Zip: 80202 E-mail: tplon"mllps©oobleenergyinc Contact Name: Taryn Phillips Phone: (303)2284362 Fax: (303)228-4286 Tank Battery Name": WELLS RANCH ECONODE 6 Number of tanks: 18 Location'2(QQ Sec. Twp.Range.): SESE SEC6 T6N R62W County: Weld Total tank capacity[bbl]: 9684 Calendar year for which"Actual" data applied': 2012 Year(s)tank(s)were placed in service": 2012 Control Description'': FLARE Control Efficiency16: 95% Condensate Throughput12[bbl/year] Requested's: 1,000,000 Maximum for PTE calculation19: 1,000;806 Cne. Actual'°: While Controls Operational" Other equipment at facility22: Twt _.4a. t�a;u sA-m".-‘...4 aE,,r "1‘112\-21Comments: Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit El Check if the Division is to calculate emissions. 0 Check if site-specific emission factors provided to calculate emissions'. Emission Factor Battery Requested Emissions's Actual Emissions2° Pollutant2° [Ib/bbl] PTE`I Uncontrolled26 � Controlled2' Uncontrolled26 Controlled22 VOC[tons/year] 0.56 ✓ L-5W, 2801E 280.0 I14.0 NOx[tons/year] CO[tons/year] Benzene[Ibs/year] 0.002✓ OK 27400 2,000 i 100 n-Hexane[lbs/year] 0.016 ✓ W 16,400,„ 16,000 800 Wells serviced by this tank or tank battery's API#: Name: See attached sheet ❑ Newly Reported Well API#: Name: ❑ Newly Reported Well API#: Name: ❑ Newly Reported Well API#: Name: ❑Newly Reported Well API y: Name ❑Newly Reported Well API#: Name: El Newly Reported Well II API #: Name: ❑Newly Reported Well API#: Name: El Newly Reported Well 1 i The signature below indicates that I have knowledge of the facts herein set forth and that the same are true, accurate,and complete to the best of my knowledge and belief If this is a registration for coverage under general permit GPI,I further certify that this source is and will be operated in full compliance with each condition of general permit GPI. _ �(/jovi ,, June 19,2013 Signature of Leg Authorized Person(not a vendor or consultant) Date Taryn Phillips Environmental Engineer Type or Print Name of Person Signing Above Official Title Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call: 'I filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-BI 2 9 3 7 2 4303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South registration to: Denver,CO 80246-1530 FORM APCD-205 Page 1 of 3 415829207 WELLS RANCH AE06 ECONODE Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY Wells serviced by this tank or tank battery API#; 05-123-35569 Name: WELLS RANCH AE06-62-1HN ❑Newly Reported Well API#: 05-123-35572 Name: WELLS RANCH AE06-63-1 HN ❑Newly Reported Well API 4; 05-123-35570 Name: WELLS'RANCH AE06-64-1HN ❑Newly Reported Well API#: 05-123-35573 Name; WELLS RANCH AE06-65-1 HN ❑Newly Reported Well API#: 05-123-35558 Name WELLS RANCH AE06-66-I HN ❑Newly Reported Well API#: 05-123-35567 Name: WELLS RANCH AE06-67-1HN ❑ Newly Reported Well API 4: 05-123-35564 Name: WELLS RANCH AE06-68-1HN ❑ Newly Reported Well API 4: 05-123-35559 Name: WELLS RANCH AE06-69-1HN ❑ Newly Reported Well API 4: 05-123-36772 Name: WELLS RANCH AE05-62-1HN Z Newly Reported Well API#: 05-123-36768 Name: WELLS RANCH AE05-63-1HN ® Newly Reported Well API 4: 05-123-36770 Name: WELLS RANCH AEOS-63HN ®Newly Reported Well API 4: 05-123-36771 Name WELLS RANCH AE05-64-1HN ®Newly Reported Well API 4: 05-123-36673 Name: WELLS RANCH AEOS-65-IHN Z Newly Reported Well API 4: 05-123-36672 Name: WELLS RANCH AE05-65HN ®Newly Reported Well API 4: 05-123-36674 Name: WELLS RANCH AE05-66-1HN ®Newly Reported Well API 4: 05-123-36670 Name: WELLS RANCH AE05-66HN ®Newly Reported Well API 4; 05-123-36978 Name: WELLS RANCH AE05-67-IHN ®Newly Reported Well API 4: _ 05-123-36977 Name: WELLS RANCH AE05-67HN Z Newly Reported Well API 4: 05-123-36979 Name; WELLS RANCH AEOS-68-1HN Z Newly Reported Well API 4: 05-123-36981 Name: WELLS RANCH AE05-68HN ®Newly Reported Well API 4: 05-123-36980 Name: WELLS RANCH AEOS-69-IHN Z Newly Reported Well Page 2 of 3 415829207 WELLS RANCH AE06 ECONODE v C j m .,. a. z aa \ 'O E - 2 a° a >, Ca a s 72; r y O v R ❑ E .Z' N U �� M til M2. 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