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HomeMy WebLinkAbout20130342.tiffSTATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us January 25, 2013 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment 'The Air Pollution Control Division will publish a public notice for Encana Oil & Gas (USA) Inc. This public notice will be published in the Greeley Tribune on January 30, 2013. Thank you for assisting the Division by making the enclosed package (includes public notice, preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review and comment. It must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please forward any comment regarding this public notice to the address below. Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division ( ti �eoteeiCJ Cc. Pt , - oli0 2013-0342 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbino, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Website Title: Encana Oil & Gas (USA), Inc. — Gratton 1 20 — Weld County Released to: The Greeley Tribune on January 25, 2013, published January 30, 2013 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Colorado Department of Public Health and Environment The Colorado Air Pollution Control Division declares the following proposed construction activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment hereby gives NOTICE pursuant to Section 25-7- 114.5(5), C.R.S. of the Colorado Air Quality Control Act that the Division received an application for an air pollution emission permit on the following proposed project and activity: Encana Oil & Gas (USA), Inc. proposes to operate a wellhead site with condensate tanks and truck loadout located at the SESE of Section 30, Township 2 North, Range 64 West in Weld County. The company has submitted an application requesting issuance of a federally enforceable synthetic minor source permit limiting the potential to emit. As a synthetic minor source the permit is subject to public comment per Regulation 3, Part B, Section III.C.1. The Division hereby solicits and requests submission of public comment from any interested person concerning the aforesaid proposed project and activities to comply with the applicable standards and regulations of the Commission for a period of thirty (30) days from the date of this publication. Any such comment must be submitted in writing to the following addressee: Stephanie Chaousy, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B l Denver, Colorado 80246-1530 Within thirty (30) days following the said thirty (30) -day period for public comment, the Division shall consider comments and, pursuant to Section 25-7-114.5(7)(a), either grant, deny, or grant with conditions, the emission permits. Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the subject project and activity by affected persons. A copy of the applications for the emission permits, the preliminary analysis of said applications, and accompanying data concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld County during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of Public Health and Environment, 4300 Cherry Creek Drive South, Denver, Colorado. A copy of the draft permit and preliminary analysis are available on the Air Pollution Control Division's website at: http://www.colorado.gov/cs/Satellite/C DPHE-AP/CBON/ 1251596498449 sir Construction Permit Application Preliminary Analysis Summary Section 1 — Applicant Information Company Name: Encana Oil & Gas (USA) Inc. Permit Number: 12WE2463 Source Location: SESE Section 30, T2N, R64W, Weld County (non -attainment) Equipment Description: Point 001: Eleven condensate storagedanks Point 003: truck loadout AIRS ID: 123-99E9 Date: December 18, 2012 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? I sent Encana a question regarding the number of tanks onsite. Please refer to Section 14 On what date was this application complete? August 3, 2012 Section 4 — Source Description AIRS Point Equipment Description 001 One (1) 100 BBL and ten (10) 330 BBL above ground atmospheric condensate storage tanks. Emissions from these tanks are controlled by a combustor. 003 Truck condensate loadout. Is this a portable source? Yes X No Is this location in a non -attainment area for any criteria pollutant? X Yes No If "yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for any criteria pollutant? Yes X No If "yes", for what pollutant? (Note: These pollutants are subject to minor source RACT per Regulation 3, Part B, Section III.D.2) PM10 CO Ozone Page 1 Alb Is this source located in the 8 -hour ozone non - attainment region? (Note: If "yes" the provisions of Regulation 7, Sections XII and XVII.C may apply) X Yes X No Point 003: Is this source located at an oil and gas exploration site? X Yes No Point 003: 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 an API gravity of 40 degrees or greater) per year or submerged fill less than 16,308 bbl of condensate per year? Yes X No Point 003: Is this source located at a facility that is considered a major source of hazardous air pollutant (HAP) emissions? Yes X No Point 003: Will this equipment be operated in any NAAQS nonattainment area? X Yes No Point 003: Does this source load gasoline into transport vehicles? Yes X No Section 5 — Emission Estimate Information AIRS Point Emission Factor Source 001 Operator provided site -specific emission factors using E&P Tanks. Refer to Section 14 for calculations. 003 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] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit (PTEI AIRS Point Process Consumption/Throughput/Production 001 91,781 BBL per year (76484 * 1.2) 003 91,781 BBL per year Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 001 76,484.2 BBL per year 2012 003 91,781 BBL per year 2012 Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 91,781 BBL per year 003 91,781 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 001 01 Combustor 95 Page 2 Section 6 — Emission Summa (tons per year) Point NO, VOC CO Single HAP Total HAP PTE: 001 2.0 1056.7 11.0 15.8 (Hexane) 21.1 (�U2) --- 8.8 --- 0.7 (n -hexane) 1.0 003 --- 15.3 0.4 (n -hexane) 0.9 Uncontrolled point source emission rate: 001 2.0 1056.7 11.0 15.8 (Hexane) 21.1 GP5 (002) __ 8.8 --- 0.7 (n -hexane) 1.0 003 --- 15.3 --- 0.4 (n -hexane) 0.9 TOTAL (TPY) 2.0 1080.8 11.0 16.9 (n -hexane) 23.0 Controlled point source emission rate: 001 2.0 52.8 11.0 0.8 (Hexane) 1.1 GP5 (002) _ 10.0 --- 0.7 (n -hexane) 1.0 003 --- 15.3 0.4 (n -hexane) 0.9 TOTAL (TPY) 2.0 78.1 11.0 1.9 (n -hexane) 3.0 Section 7 — Non -Criteria / Hazardous Air Pollutants Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the etabe reportable? Controlled Emission r RateIb/ ( y ) Point 001 Benzene 71432 A 5232 Yes 262 Toluene 108883 C 3671 Yes 184 Ethylbenzene 100414 C 367 No 18 Xylenes 1330207 C 1193 Yes 60 n -Hexane 110543 C 31664 Yes 1583 Point 003 Benzene 71432 A 287 Yes 287 Toluene 108883 C 506 No 506 Ethylbenzene 100414 C 21 No 21 Xylenes 1330207 C 223 No 223 n -Hexane 110543 C 711 Yes 711 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 standard? X Yes No If "yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 001 01 VOC/HAPs State only requirement peci Site-specificp sampling Page 3 Section 9 — Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True Minor X Synthetic Minor Major Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If "yes" what kind of modification? Minor Synthetic Minor Major Section 10 — Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If "yes", for which pollutants? Why? For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes X No 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 Air Quality Standards (NAAQS)? If "yes", for which pollutants? Why? Yes X No AIRS Point Section 12 — Regulatory Review Requlation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide 001, 003 Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Requlation 2 — Odor 001, 003 Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Re.ulation 3 - APENs, Construction Permits, O.eratinq Permits, PSD 001, 003 Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is nonattainment. (Applicant is required to file an APEN since emissions from condensate production are greater than 1 ton per year VOC) 001, 003 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 ll.D.2.a) Re.ulation 6 - New Source Performance Standards Page 4 001 NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? No Is this source subject to NSPS Kb? No WHY? Tanks at this facility are all less than the 471 BBL threshold. Therefore, not subject to NSPS Kb. 003 No applicable subpart. This facility is not a bulk •asoline terminal. Regulation 7 — Volatile Or. anic Compounds 001 XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks 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.) 003 No sections apply. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8 — Hazardous Air Pollutants 001, 003 MACT EEEE: Organic Liquids Distribution 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 Point Process Process Description Emission Factor Pollutant/ CAS # Fugitive (YIN) Emission Factor Source Control (%) 001 01 E&P Condensate Storage Tanks 548.268 lb/1000 gal VOC No Engineering Calculation 95 1.361 lb/1000 gal Benzene No Engineering Calculation 95 0.964 lb/1000 gal Toluene No Engineering Calculation 95 0.086 lb/1000 gal Ethylbenzene No Engineering Calculation 95 0.309 lb/1000 gal X lenes y No Engineering Calculation 95 8.225 lb/1000 gal n -hexane No Engineering Calculation 95 SCC 40400311 — Fixed Roof Tank, Condensate, working+breathing+flashing losses 003 01 Truck Condensate Loadout 91,781 BBLJyr 7.911b/1,000 gal VOC No AP -42 0 0.0744 lb/1,000 gal Benzene No Engineering Calculation 0 0.1313 lb/1,000 gal Toluene No Engineering Calculation 0 0.0055 lb/1,000 gal enylbenzene No Engineering Calculation 0 0.0577 lb/1,000 gal Xylenes No Engineering Calculation 0 0.1843 lb/1,000 gal n -hexane No Engineering Calculation 0 SCC 40600132: Crude Oil: Submerged Loading (Normal Service Page 5 Section 14 —Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks I emailed Encana on 12/18/12: The APEN does not list the total tank capacity (bbl). I was hoping you can help me with this piece of information. Paul Buck with Encana called back on 12/19/12 providing information on the total tank capacity. He said that there was one 100 -BBL and ten 330 -BBL tanks onsite. I quickly emailed him asking him to confirm the year the tanks were in place. These sources are emitting a lot of emissions and I want to make sure before I grant them GF status, that they meet it. APEN says that the source was in place in 2000, which is prior to December 30, 2002. He wrote back on 12/19/12: No, the 2000 is incorrect- the 10 330s were associated with the new wells were put in service in 2012. The one tank associated with the 100 bbl tank is associated has been in service since 1985. Therefore, this source has been modified and lost its grandfather status, therefore, will require a permit. Operator provided site -specific emission factors using an extended gas analysis dated 7/11/12 and E&P tanks. The emission factors are: VOC = (1056.732 *2000)/91781 = 23.027 lb/bbl* 1000/42 = 548.268 lb/1000 gal Benzene = (2.623*2000)/91781 = 0.057 lb/bbl * 1000/42 = 1.361 lb/1000 gal Toluene = (1.858*2000)/91781 = 0.040 lb/bbl * 1000/42 = 0.964 lb/1000 gal Ethylbenzene = (0.165*2000)/91781 = 0.004 lb/bbl * 1000/42 = 0.086 lb/1000 gal Xylenes = (0.595*2000)/91781 = 0.013 lb/bbl * 1000/42 = 0.309 lb/1000 gal n -hexane = (15.853*2000)/91781 = 0.345 lb/bbl * 1000/42 = 8.225 lb/1000 gal 12/19/12: I had a few questions for the operator regarding the O&M plan: 1. Section 2: Both boxes have been checked. I typically see only one box checked. Is this correct? If not, which one should it be? Paul Buck called on 12/19/12 and said that the second box should be checked, not the first. I redlined the O&M and made sure the correct information was added in CACTIS. 2. Section 4: Backup method was checked for "Other" however there were no attachments to the O&M plan. Should backup just be the tank level measurements? Paul Buck called on 12/19/12 and said to remove the "other." I redlined the O&M and made sure the correct information was added in CACTIS. Page 6 AIRS Point 003 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service Pw 8.5 Psia Based on extended natural gas sample M 109.18 Lb/lb-mole Based on E&P TANKs run T 530 Deg R Based on source's knowledge of bulk liquid temperature L 7.91 Lb/10^3 gal This value is used to calculate annual emissions 0.332 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. RI L 7.911b/10^3 gal 3.32E-01lb/bbl Annual requested Throughput 3854802ga1/yr Annual requested VOC emissions 305041b/yr 15.25tpy 12/19/12: I emailed the operator how the wt% of VOC was calculated for the HAPS. I tried several times, and did not get what they calculated. Paul Buck called on 12/19/12 saying that those numbers are assumed numbers that Encana has seen over several applications. However, he noticed that the molecular weight should not be 109 Ib/Ib-mol (that is for the oil) and it should be 66 lb/lb-mol (for the vapors). He provided me supporting documentation via email on 12/19/12. I reviewed it and made the changes to the APEN, PA and permit. Emission factors are calculated as multiplying the VOC emission factor (generated from AP -42) with the wt % of VOC (which is an assumed engineering calculation done by Encana): VOC E.F. = 7.91 lb/1000 gal Benzene = (7.91 lb/1000 gal) * .0094 = 0.0744 lb/1000 gal Toluene = (7.91 lb/1000 gal) * .0166 = 0.1313 lb/1000 gal Ethylbenzene = (7.91 lb/1000 gal) * .0007 = 0.0055 lb/1000 gal Xylenes = (7.91 lb/1000 gal) * .0073 = 0.0577 lb/1000 gal n -hexane = (7.91 lb/1000 gal) * .0094 = 0.1843 lb/1000 gal Page 7 123-99E9-001-APEN-2012-08-03-01 Pollutant'° VOC [tons/year] NOx [tons/year] CO [tons/year] Benzene [lbs/year] n -Hexane [lbs/year] Air Pollutant Emission Notice (APEN) — and — Application for Construction Permit OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY Current Status (Check all that apply) [ 23RgEq I0D AIRS ID #1: ® New or previously unreported battery , ❑ Previously grandfathered battery' ❑ Synthetic minor facility ® Located in the 8 -hr Ozone Control Area3 I' ❑ Registered under general permit no. GPOI 12WEZy6 2 J ❑ Permitted under individual permit: Reason for APEN Submittal (Check all that apply) _ ❑ APEN update only° 4< / 1 / ❑ Modification to existing source' \ ❑ Registration for coverage under general permit no. GP01\ ; , & cancellation request for individual permits: N ® Application for or Modification of an individual permit ❑ Administrative permit amendment? ❑ 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 Name9: Mailing Address 1e City: Contact Name: Adam Berig Encana Oil & Gas (USA) Inc. Republic Plaza 370 17th St. Suite 1700 Denver Tank Battery Name 11: GRATTAN 1 20 Location" (QQ Sec. Twp. Range.): SESE Sec 30 T2N R64W Calendar year for which "Actual" data applies13: Projected Control Description": Combustor Condensate Throughput1° [bbl/year] Requestedis: Other equipment at facility": Comments: a1 X81 OGCC Operator #: 100185 State: CO Zip: 80202 E-mail: adamberig@encana Dom Phone: 720-876-3884 Fax: 720-876-4884 Number of tanks: 1" I 1 County: Weld Total tank capacity [bbl]: t51,;,.; - Year(s) tank(s) were placed in service14: 2000' 20 t 2 - Control Efficiencyl6: 6: 95 Maximum for PTE calculation19: 91781 While Controls Operational" C5t— Actual20: 7r(•i `j`S`l, Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit ❑ Check if site -specific emission factors provided to calculate emissions'. ❑ Check if the Division is to calculate emissions. Emission Factor [Ib/bbl] 23.027 Battery PTE"s 52.84 Requested Emissions Uncontrolled's Controlled" Uncontrolled Controlled 1056.72 Actual Emissions 52.84 880.60 44.03 0.068 lb/MMbtu 2.03 1.69 0.37 lb/MMbtu 11.03 9.19 0.057 0.096 5231.52 261.58 4359.60 217.98 0.3540.3-] 11i - 0.84 31664.46 1583.22 26387.05 1319.35 API#: API#: API 4: API #: API 4: API#: API 0: 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 GPOI, I further certify that this source is and will be operated in full compliance with each condition of general permit GPOI. 0512312696 0512334369 0512334362 Name: Name: Name: Name: Name Name: Name: Wells serviced by this tank or tank battery's 0512312696 GRATTON I 0512334369 GRATTAN 4A -30H 0512334362 GRATTAN 4B -30H ❑ Newly Reported Well Z Newly Reported Well ® Newly Reported Well ❑ Newly Reported Well ❑ Newly Reported Well ❑ Newly Reported Well ❑ Newly Resorted Well Signature of Legally Authorized Person (not a vendor or consultant) Adam Berl: Type or Print Name of Person Signing Above 8/2/2012 Date Air Quality Lead Official Title Submit this form, along with $152.90 for each filing of up to 5 tank battery APENS. Include $250 General Permit fee for each new GP registration to: FORM APCD-205 Colorado Department of Public Health and Environment Air Pollution Control Division, APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 277080 For information call: (303) 692-3150 Page 1 of 2 02_APEN - EP Condensate Storage Tank eatery 2012-01-02 11-21-Ot.doc N 'O O at drocarbon L nested Action (Check applicable request boxes) Section 02 — Re 0 R a C L E ^J 0 0 U Ce or newly reported emission source Ch a O T 4 G 7.1 C O U U 0 c Q a a ❑ ❑ a Encana Oil & Gas (USA) Inc. GRATTAN 1 20 E 5 E F z m c i° 0 0 O 0 7, 3 at U CD a O at SE1/4 SE 1/4 Sec. 30 Twp. 2N Range 64W N O co 0 a. N Republic Plaza 370 17th St. Suite 1700 a C .p O •— R .0 _ • E y v a 0 9 3 O O O O W x y 0 iN . 3 ,.=N c C V N o z 0 W • Ti - O .d Q O U a -o a a a 0 > c ❑ 'v Z o 2 O) 4 al • .5 -c Ef a d c cc C ❑ Person To Contact: O az For new or reconstructed sources, the projected startup date is: Don't know Don't know ❑ ❑ ❑ ❑ ❑ z 0 z z z ❑ ®❑® C at V vi T>' >8 >-a >' Z ❑ ❑ ® ❑ O 0 P. z 0 W 00 •y O o 00 Va) -_ ,n CT I c_ °' V2 vo Cr) p U C O O O i° a o > 9D vi v O O 9 ry an c cult G U v C) 3 N >` Lo a F • c • V > ca C O O C G COy c' m E V_ F m o 3 0 crtii 0 a E T • d 2 °^ ° 5 o U E„ g s E n a c ' oo o 0 O _450' ` = q \ U ws �x m m� 0 s' y AEx ...a .c w 3 i° vF n p� r o� v 0._ N c C v 6 'O pp - O w a C o y 4'' G. n ..9h 0 N700 Q 0 0� u .. 3o Ed. 00 'S o •g'- ° . T 6 O a U 0 at C ''J`0 E N P. 0 c C ei n m R C • C> O p n �. m p 'N O Y d Z p y toe, a at CO L O U O N s-; .. 3 m a s co, -,y, ay W a _d a ^� T t00 T c '� .p .O ,pnOa W -,5:,•• . • y .0. 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Z i. .. • E 0 o a v o ‘4", 'y `h m W vW70 a IY a .N .a a 0 at> O O' a c_ m— — o o o. 1 2 m m> :+ ▪ C. n x 0 ri y E c- r' 0 O F a E 8. v 0 0 4 a) 2 'o w y 0 o w 7 CO 5 c CO c o m = m C o 0 =.6 E o 0 aN m h s N 4 N E y 4 C C i y - -o v 0 Cr) CO 0 O CO 921 a Cr) 01 C1 M 0.1 ry 0 0 vCO w FORM APCD-208 drocarbon Li Permit Number: Section 06 Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) 0 0 0 N o ara 4.2 v E0 P b 0 Z " o gab. H a In or, 00 an en 2\ J o [i F h vd v ti cr V Y O Az a w C O- Vertical ❑ Vertical with obstructing raincap ❑ Circular: Inner Diameter (inches) _ a AC; L R O U •N • o • Co S O ct CO - C N _ C O U 4 O O O O y U ry L u Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information a) d 0.a 0 co ti 0 o. CO CO 0 0 0 a 0 E CO 0) CO C CO V CO V CO CO Emission Factor Documentation attached Estimation Method or Emission Factor Source AP42 AP42 Fr S G T AP42 Please use the APCD Non -Criteria Rportable Air iRollutant Addenduhi form to report pollutants not listed above. Requested Permitted Emissions 5 Controlled (Tons/Year) 'in Uncontrolled (Tons/Year) i , m IN N ka N 0" 4 N 01 N.2 o — =O li c x N O` Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units = a 8 -. 0 Uncontrolled Basis e O :Q n o a= cr i J O T c O Control Efficiency (% Reduction) Identify in Section 07 Control Device Description Secondary Primary Pollutant O O > O Benzene Toluene Ethylbenzene Xylene U F c complete, true and correct. C CO E L u c P et CO R7 C L L d C O CO O u C Y N R ~ E N CO C R L v L v CO CO v 72. C.) F- CO 00 a) 0 E z 220 CO Signature of Person Legally Authorized to Supply Data I c N CC STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 12WE2463 Issuance 1 DATE ISSUED: ISSUED TO: Encana Oil & Gas (USA), Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as Grattan 1 20, located in the SESE of Section 30, Township 2 North, Range 64 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Point Description 001 One (1) 100 BBL and ten (10) 330 BBL above ground atmospheric condensate storage tanks. Emissions from these tanks are controlled by a combustor. 003 Truck condensate loadout. Emissions from the loadout are not controlled. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit AIRS ID: 123/99E9 Page 1 of 10 Condensate Tank SM/M Version 2012-1 lic'Health and Environment r Air Pollution Control Division application assp jte•' ithh to pa+_a Qi) di- e , :q ; s constZ.:,lction 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.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: AIRS Point Tons per Year Emission Type NO. VOC CO 001 2.0 52.9 11.0 Point 003 --- 15.3 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. 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.) AIRS Point Control Device Pollutants Controlled 001 Combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator AIRS ID: 123199E9 Page 2 of 10 and made aval -.te`"he Is Part B, II A.4) Process/Consumption Limits AIRS Point Process Parameter Annual Limit 001 Condensate throughput 91,781 BBL/yr 003 Condensate Loading 91,781 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. Health and Environment it Pollution Control Division n req - (Reference: Regulation 3, STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. 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 XVI1.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. Point 001: 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. 13. Point 001: 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. 14. Point 001: 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. AIRS ID: 123/99E9 Page 3 of 10 Iic'Health and Environment it Pollution Control Division 15. Point 001: T e"(isa fora ks e _er.t'4 oy this la it 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. XVII.C.3. Monitoring: The owner or operator of any condensate 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. 16. Point 003: 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) OPERATING & MAINTENANCE REQUIREMENTS 17. Point 001: 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 AIRS ID: 123199E9 Page 4 of 10 li Health and Environment kir Pollution Control Division 18. Point 001: Th. m=' or at -at-a de roc como ?r ewith Condition 10, using EPA Method 22 to measure opacity from the flare. The observation period shall be a minimum of fifteen consecutive minutes. ADDITIONAL REQUIREMENTS 19. 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. 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 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 AIRS ID: 123199E9 Page 5 of 10 Health and Environment it Pollution Control Division 25-7-114.5(12 '".S.,;=as •'a:.,:.Re• gt!.?,,,.No. 3 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. 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 or 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, P.E. Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA), Inc. AIRS ID: 123199E9 Page 6 of 10 Health and Environment it Pollution Control Division Nett(=: '`'tted w= "` =d site. Condensate tanks and loadout at synthetic minor facility. AIRS ID: 123199E9 Page 7 of 10 olor % Depa , en .f .li Health and Environment a � Air Pollution Control Division Notes to Permit Holder a '` "me o"` '.ef17 an 1) 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. 2) 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.cdph e. state. co. us/req ulations/ai rregs/ 100102aq cccom mon provisionsreq. pdf. 3) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN ' Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 001 Benzene 71432 A 5232 Yes 262 Toluene 108883 C 3671 Yes 184 Ethylbenzene 100414 C 367 No 18 Xylenes 1330207 C 1193 Yes 60 n -Hexane 110543 C 31664 Yes 1583 002 Benzene 71432 A 287 Yes 287 Toluene 108883 C 506 No 506 Ethylbenzene 100414 C 21 No 21 Xylenes 1330207 C 223 No 223 n -Hexane 110543 C 711 Yes 711 4) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Emission Factors Uncontrolled Ib/BBL Condensate Throughput Emission Factors Controlled lb/BBL Condensate Throughput Source NOx 0.068 Ib/MMBtu --- AP -42, Table 13.5-1 CO 0.37 lb/MMBtu --- AP -42, Table 13.5-1 VOC 23.027 1.151 E&P Tanks 110543 n -Hexane 0.345 0.017 E&P Tanks 71432 Benzene 0.057 0.003 E&P Tanks 108883 Toluene 0.040 0.002 E&P Tanks AIRS ID: 123199E9 Page 8 of 10 Health and Environment Air Pollution Control Division CAS # Pollutant ni actq s Uncontrolled lb/BBL Condensate Throughput issio gtors Controlled lb/BBL Condensate Throughput Source 100414 Ethylbenzene 0.004 0.0002 E&P Tanks 1330207 Xylene 0.013 0.001 E&P Tanks Note: The controlled emissions factors for point 001 are based on the combustor control efficiency of 95%. Point 003: CAS Pollutant Emission Factors lb/1000 gal loaded - Uncontrolled Source VOC 7.91 AP -42 71432 Benzene 0.0744 AP -42 108883 Toluene 0.1313 AP -42 100414 Ethylbenzene 0.0055 AP -42 1330207 Xylene 0.0577 AP -42 110543 n -Hexane 0.1843 AP -42 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) P (true vapor pressure) = 8.5 psia M (vapor molecular weight) = 66 lb/lb-mol T (temperature of liquid loaded) = 530 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. 5) 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. 6) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -hexane NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: AIRS ID: 123/99E9 Page 9 of 10 Health and Environment it Pollution Control Division 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 WW MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 8) 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/oiloaspermittinghtml AIRS ID: 123199E9 Page 10 of 10 Hello