HomeMy WebLinkAbout20180433.tiff1COLOR ADO
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
February 5, 2018
Dear Sir or Madam:
RECEIVED
FEB 0 8 2018
WELD COUNTY
COMMISSIONERS
On February 8, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Encana Oil 8. Gas (USA) Inc. - Zisch 6H -M368 Battery. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
eC :cfrim
jP /ic Review/ W e if%TMCK)C7T),
v2-12-18 P oz-iz-/8
2018-0433
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Encana Oil Ft Gas (USA) Inc. - Zisch 6H -M368 Battery - Weld County
Notice Period Begins:- February 8, 2018
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: Encana Oil Et Gas (USA) Inc.
Facility: Zisch 6H -M368 Battery
Oil and gas exploration and production site
SWSW Sec 6 T3N R68W
Weld County
The proposed project or activity is as follows: Oil and gas exploration do production facility including tank
battery and loading of condensate into tanker trucks. Requested annual condensate production of 212,423
BBL.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0120 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Christian Lesniak
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
0 A l>0
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Colorado Air Permitting Project
Review Engineer:
Package #:
Received Date:
Review Start. Date:
Section01- Facility Information ._
Company Name:
County AIRS ID:
Plant AIRS ID:.
Facility Name:
Physical Address/Locatio SWSW quadrant of Section 6, Township 3N, Range 68W, in Weld County, Colorado
Type of Facility: ExplQ a.,..- _-_
` YP - ration &.,Prxxtiuctlan Well Pad -
-. What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in. a NAAQS non -attainment area? - Yes
If yes,.for what pollutant? Hon Mono aae (CO) PDa iculate Matter (PM) Eine (NOx a VOC)
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
3N
68
AIRS Point #' r
Emissions Source : Type
l
Equipment Name
Emissions
Control?
- Permit #
-
Issuance .#
_'- Self Cert
Required?
Action
Engineering
" Remarks
003
Condensate -Tank
Condensate Tank -
Yes
17 0120
iau1
Yes
Permit initial
Issuance
,?.
(}+1. '"'
; -
- Hydrocarhca.Lur.;id e:acdirig
Condensate La clout
2 Yes
17WE0121
1
Yes
tial
Issuance.
z
�
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? - Requesting Sycsthetic
Section 05 - Ambient Air Impact Analysis Requirement:
Was a quantitative modeling, analysis required?'
If yes, for what. pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (POD)
Title V Operating Permits'(OP)
- Non -Attainment New Source Review (MANOR)
Is this stationary source a major source? If yes, explain what programs and which pollutants hers SO2
Prevention of Significant Deterioration (POD)
Title V Operating Permits (OP) Non -Attainment NewSourceReview (NANSR)
CO VOC PM2.5 PM10 TSP HAPs
El
Condensate Storage Tank(s.) Emissions Inventory
Section 01'- Administrative. Information
'Facility AIRS ID:
County Plan
Poin
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency%:
Section:03 - Processing Rate Information for Emissions Estimates
Primary Emissions- StorageTenk(s)
Actual Condensate Throughput
Requested Permit LimitThroaghput=
Potential to Emit (PTE) Condensate Througpp
Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating =
Barrels (bbl( per year
Barrels (bbl) per year Nysys throughput
Secondary Emissions -Combustion Device(s)
Heat content of waste gas= M:716 ' Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= ;Iale7;iai?n3scf/bbl -
Actual heat content of waste gas routed to combustion device ---
Requested heat'content of waste gas routed to combustion device =
35,311 MMBTU per year
42,373 MMBTU per year
Potential to. Emit (PTE) heat content of waste gas routed to combustion device= 42,373 MMBTU peryear
Section 04 - Emissions Fectois & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(Ib/bbl) (16/661)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
1152'
0.001
0.003
0.000
0.001
0.016
0.001
Benzene
Toluene
11.070.
Ethylbenzene
Xylege
n -Hexane
224 TMP
Pollutant
Control Device -
Emission Factor Source
Uncontrolled- Uncontrolled
(Ib/MMBtu) (I6/bbl)
(waste heat'
combusted)
(Condensate
Throughput)
Emission Factor Source
PM10
PM2.5
NOB
CO'
0.0015
0.0015
0.0136
0.0738
Section 05- Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled-
(tons/year)
Actual Emissions
Uncontrolled Controlled '
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
VOC
1101.9
918.2
45.9
1101.9
55.1
PM10
0.2
0.1
0.1
0.2
0.2
PM2.5
0.2
0.1
0.1
0.2
0.2
NOB
L4
1.2
1.2
1.4
1.4
CO
7.8
6.5
6.5
7.8
7.8
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(Ins/year) (lbs/year)
(lbs/year) (lbs/year)
Benzene
5141
4284
214
5141
257
Toluene
14785
12321
616
14785.
739
Ethylbenzene
510
425
21
510
25
Xylene
3717
3098
155
3717
186
n -Hexane
69590
- 57991
2900
69590
3479
224 TMP
2698
2248
112
2698
135
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7,Section XII.C, D, E, F
Regulation 7, Section XII.G, C
Regulation 7, Section XVILB, Cl,.. C.3
Regulation 7, Section XVI I.C.2
Regulation 6, Part A, NSPS Subpart Kb
Regulation 6, PartA, NSPS Subpart 0000
Regulation 8, Part E, MACT Subpart HO
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Storage tank is subject to Regulation 7,Section XR.C-F
Storage Tank is not subjectto Regulation 7, Section X1I.G
Storage tank is subject to Regulation 7, Section XVII, 8, C.1 &C.3
Storage tank issubject to Regulation 7, Section XVtl.C.2
Storage Tank is not subjectto NSPS, Kb
Storage Tank is not subject to N5PS 0000
Storage Tank is not subject to MACT HH
582 bbl/day
24.25 bbl/hr
Barrels (bbl) per year '
Hysys Gas released
53,61384 mscf/day 0.09212
2.23391 mscf/hr
212430 bbl/yr 0.019569052 mmscf/yr
3 of 9 - ' K:\PA\2017\ 17WE0120,17WE0121.CPLxlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or sequested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means sits -specific and
collected within one year of the application received date. However, if the facility has not been modfiled (e.g., no
new wells brought on-line}, then it may be appropriate to use an older site -specific sample
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% fora flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based an inlet and outlet concentration sampling
Section 08 -Technical Analysis Notes
iiysyc model ngrun. Sdbm ttal dacumep0v
AIRS Point #
003
Section 09 - Inventory SCC Coding and Emissions Factors
Process # SCC Code
01
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.04 0 lb/1,000 gallons condensate throughput.
PM2.5 0.04 0 lb/1,000 gallons condensate throughput
NOx 0.32 0 ib/1,000 gallons condensate throughput
VOC 247.0 95 lb/1,000 gallons condensate throughput
CO 1.76 0 lb/1,000 gallons condensate throughput
Benzene 0.58 95 lb/1,000 gallons condensate throughput
Toluene 1.66 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.06 95 lb/1,000 gallons condensate throughput
Xylene 0.42 95 lb/1,000 gallonscondensate throughput
n -Hexane 7.80 95 lb/1,000 gallons condensate throughput
224TMP 0.30 95 lb/1,000 gallons condensate throughput
4 of 9 K:\PA\2017\ 17WE0120,17WE0121.CP1.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APES and Permit Requirements
'Source lain the Non•Attainmant Area
ATTAINMENT
1, Are uncontrolled actual emissions front any criteria pollutants front this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1,14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total Will uncontrolled VOC emissions treater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
Yon have indicated that courcn is in the Ncn.Atteinment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants front this individual source greater than 1 TPY (Regulation 3, Part A, Section ii.D.1.a)?
2. Is the construction data (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1,12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NM greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)?
Source requires a permit
Colorado Regulation 7, Section XII.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? •
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
`Storage tank is subject to Regulation 7, Section XR.C-f
Section XII.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Section XII.C.2 — Emission Estimation Procedures
Section 111.0 —Emissions Control Requirements
Section Xing —Monitoring
Section XII.F—Recordkeeping and Reporting
Colorado Regulation 7, Section 011.0
1. Is this storage tank located In the B -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located ate natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
I5torage Tank Is not subject to Regulation 7, Section 511.0
Section XII.G.2 - Emissions Control Requirements
Section XILC.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1.. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this storage tank equal to or greater than 6 tons per year VOC?
Stnrxg4 tank in strkjeot to Regulntion 7, Snctinn Still, B, C..t & C,3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII,C.1 - Emissions Control and Monitoring Provisions
Section XVII.C,3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
IStorago tank is subject to Regulation 7, Section KV0-C.2
Section XVII,C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cuklf meters (ma) ("472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a, Does the vessel has a design capacity less than or equal to 1,589,874 ma ['"10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' es defined in 00.1116?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"' In 60.1116?
5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.1116?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (^29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 ma (-950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110h(b))?; or
c. The design capacity is greater than or equal to 75 Mc ("472 BBL] but less than 151 ma [^'950 BBL] and stores a liquid with a maximum true vapor pressures less than 15,0 kPe(60.110b(b))?
Storage Tatar is not suhjeot to NSPS Kb
Subpart A, General Provisions
§60.1126- Emissions Control Standards for VOC
§60.1136 -Testing and Procedures
§60.1156 - Reporting and Recordkeeping Requirements
§60.1166 - Monitoring of Operations
Ten
Yes
No
No
Ycs
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Source Req
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40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Ges Production, Transmission and Distribution
1. Is this condensate storage vessel located ata facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 20157
3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.54307
5. Is the storage vessel subject to and controlled In accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH7
•Intora0e Yank is not subject to eISP60000 •
Subpart A, General Provisions per §60.5425 Table 3
460.5395 - Emissions Control Standards for VOC
060.5413 -Testing and Procedures
460.5395(g) - Notification, Reporting and Recordkeeping Requirements
060.5416(c) - Cover and Closed Vent System Monitoring Requirements
460.5417 - Control Device Monitoring Requirements
)Note; If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.53651e)(2) even if
potential VOC emissions drop below 6 tons per pearl
40 CFR, Part 63, Subpart MACE HH, Oland Gas Production Facilities
• 1. Is the storage tank located at en oil and naturafgas production facility that meets either of the following criteria;
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
h. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))7
2. Is the tank located at a facility that Is Major' for HAPs?
3. Does the tank meet the definition of"storage vessel"' in 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.7617
5. lotion tank subject to control requirements under 40 CFR Part 60, Sub art Kb or Subpart 00007
manage Took is nut sublect to MACE rill
SubpartA, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
463.773.- Monitoring
§63.774-Recordkeeping
§63.775 - Reporting
RACT Review
RACT review Is required If Regulation 7 does not apply AND if the tank is In the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists,operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation; or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing'
regulations, end Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is
intended to describe APQD Interpretations and recommendations. Mandatory terminology such es "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act
end Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of Itself
Yes
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Hydrocarbon Loadout Emissions Inventory
Section 01- Administrative information
'Facility AIRs ID:
BsgagiliTSMANZ—
County
FigNiiiEngrEC= tea
Plant Poin
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:.
Control Efficiency:
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03 - Processing Ratelnformation for Emissions Estimates
Primary Emissions- Hydromrbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput=
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions- Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of wastegas routed to combustion device =
Requested heatcontent of waste gas routed to combustion device =
Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Btu/scf
439317 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section.04- Emissions Factors.& Methodologies.
Does the company use the state default emissions
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L= 12.46*5*P•M/T
Actual Volume Loaded While Emissions Controls Operating= ,,7;pld Barrels (bbl) per year
793 MMBTU per year
951 MMBTU neryear
951 MMBTU per year
The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
P
True Vapor Pressure
&$ .:pia
aL1a4-
.,`I;t333')ai
M
Molecular Weight of Vapors
I'-, .TSB,- . ,,.
Ib/Ib-mol
= >f
"f fib t7 .
h.' 1i 1,,,
a cv
T
Liquid Temperature
illTgl132.12 ;t'
Rankine
«_
..-
r,.z-
arlb:
e$
L
Loading Losses
8.83479497
lb/1000 gallons
'-
'
:.::
. ',,,,
., ?
,,,,i...irl
0.371061389 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
f#°0094i.. -I t ,-r
0.003187977
lb/bbl
`:
-:::
.. �-, �.. ��. ifattRid EilAPs dzci5f gps YE.3 iie3;
Toluene
...... .... ... ..
�irH�i�rua�i''i9.'.gMO : =
0.006159619
lb/bbl
'f a«-.,
.. f-hOlliltanfilik40A ii�c9Lit. r3at� t .3: ... _...
Ethylbenzene
3v? Pc)i Qi3f}L
0.000259743
lb/bbl
o sl R'4�fLk�1?s3na7Fund�nsater
Xylene
V �a,'-.._„g 0073 ,3" - _
0.002708748
lb/bbl
( j,dy. ..
;.
.° Ciur1dlf 4\Asais
n-H
a,' ,., ;0,0233 =
0.00864573
lb/bbl
fAfr#i)k"eoftdnte3uYas
224TMP
"' ,0!00001 - ,S
3.71061E-06
lb/bbl
3,.)f6ttry,,..,3 s:m onderreat�.�.,.._,:
Emission Factors
Hydrocarbon Loadout
Pollutant
Benzene
Toluene
Ethylbenzene
Xylene
Uncontrolled Controlled
(lb/bbl)
(Volume Loaded)
2.71E-03
8,55E-03
n -Hexane
224 TMP
.71E-05.
Pollutant
(lb/bbl)
(Volume
Loaded)
1.86E-02
1.74E-04
3.08E-04
1.30E-05
1.35E-04
Emission Factor Source
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(Volume
(waste heat combusted) Loaded)
Emission Factor Source
PM10
PM2.5
0.0075
0.0075
0.0006.
SOx
NOx
CO
7 of
K:\PA\2017\17 W E0120,17 W E0121. CP1.xls m
Hydrocarbon Loadout Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
500
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0-00
0.00
0.00
0.00
0.03
0.03
0.03
0.03
0.03
39.41
32.84
L64
39.41
1.97
0.15
0.12
0.12
0.15
0.15
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
{Iles/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year). (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylhenzene
Xylene
n -Hexane
224 TMP
741
617
31
741
37
1308
1090
55
1308
65
55
46
2
55
3
575
480
24
575
29
1837
1530
77
1837
92
1
1
0
1
0
Section 06 -Regulatory Summary Ana, Ivsis
Regulation 3, Parts A, 0
Source requires a permit
The loadout must operate with submerged fill and loadout
emissions must be routed to flare to satisfy RAC'.
RACT- Regulation 3, Part e, Section 111.D.2.a
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point it
004
Process tt SCC Code
01 '4-06-001-32 Crude Oii: Submerged Loading Normal Service (1=0,6)
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 - 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
50x 0.00 0 lb/1,000 gallons transferred
NOx 0.01 0 lb/1,000 gallons transferred
VOC 8.8 95 lb/1,000 gallons transferred
CO 0.03 0 lb/1,000 gallons transferred
Benzene 0.08 95 lb/1,000 gallons transferred
Toluene 0.15 95 lb/1,000 gallons transferred
Ethylbenzene 0.01 95 lb/1,000 gallons transferred
Xylene 0.06 95 lb/1,000 gallons transferred
n -Hexane 0.21 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
8 of 9 K:\PA\2017\17WE0120,17WE0121.CP1.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is hi the Nun -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 8, Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)?
3: Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)?
' ISo
7. RACT- Are uncontrolled VOC emissions f
it
om the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
Go to next,
Go to then
Go to next ,
Go to next
Go to next ,
The loadou
, The loadou'
IT he loadout mast rsperate with submerged 311 and loadout emissions tatust be routed to fiats to sa₹isfy RAC@".
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a
rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulatior, or
any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations,
and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended tot
describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Qualify Control Commission regulations, but this document does not establish legally binding requirements In and of itself.
Permit_ number:
Date issued:
Issued to:
?
ontrol Division
Department of Public Health Er Environment
STRUCTION PERMIT
Issuance: I
Encana Oil Et Gas (USA) Inc.
Facility Name: Zisch 6H -M368 Battery
Plant AIRS ID: 123/9F0D
Physical Location: SWSW quadrant of Section 6, Township 3N, Range 68W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:.
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
Condensate
Tank
003
Twelve (12) 500 bbl fixed -roof storage
vessels used to store of condensate.
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 the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup,
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
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
=COLORADO
Air Pollution Control. Division
Depati xrc o PubkHeaW,& Eiwrnfrn ner t
Page 1 of 7
died to commence as set forth in the permit application
ted t his .`fermi` ii iscontinues construction for a period of eighteen months or
more; (iii ices no comple e construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
IIi.F.4.)
4 The operator shall complete all initial compliance testing and sampling as required in this permit
and submit `- i s to the Division as part of the self -certification process. (Regulation
Number 3, Part B F.Aection III.E.)
5. The operator sh z retain the permit final authorization letter issued by the Division, after
completion of s- ; certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Condensate
Tank
003
-
1.4
55.1
6.6
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for criteria pollutants shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on the
previous twelve months' data. The permit holder shall calculate actual emissions each month
and keep a compliance record on site or at a local field office with site responsibility for Division
review.
The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled.
Condensate
Tank
003
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
COLORADO
Air Pollution Control Division
°�Crr".3'Y^'.i •;if PbaC_ HjcYu'Cn s Eyirranee;C
Page 2 of 7
Faoiaty,
Equipment ID
S
Point
Process Parameter
Annual Limit
Condensate
Tank
003
Condensate throughput
"212,423 barrels
Compliance with ' e annual throughput limits shall be determined on a rolling twelve (12) month
total. By the enf each month a new twelve-month total is calculated based on the previous
twelve months' 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
9. The permit number and ten digit AIRS ID number assigned by -the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control requirements
for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank 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. (Regulation
Number 7, Section XII.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. if
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1..d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be,met within 90 days of the date that
the storage tank commences operation.
COLORADO
Air Pollution Cortina Division
:AAs�Klent o1 Putgo. weenn envonntene
14. - a t- s cove""""' jy th pmit are subject to the venting and Storage Tank. Emission
irements of Regulation Number 7, Section XVII.C.2.
OPERATING £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follpw the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate ,.-, - =,-e on an ongoing basis with the requirements of this permit. Revisions to
the O&M pia ar "°.u•"'ect to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III ' .7. )
COMPLIANCE TESTING A ..,,� SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
Annually by April. 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t 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 charge in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
COLORADO
Mr Pollution Control Division
Page 4 of 7
19. m a any 1 """: men ust be retained and made available for inspection upon
ay b _- eiss '-d to a new owner by the APCD as provided iiMQCC Regulation
umber , art :, ec ion .:. 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 "fina ... . ; y for this activity or operation of this source. Final authorization of the
permit must •e ;:curedfrom the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.and AQCC Regulation Number 3, Part, B, Section iII.G. Final authorization
cannot be grante until the operation or activity commences and has been verified by the APCD
as conforming 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:
Christian Lesniak
Permit Engineer
Permit History
issuance
Date
Description
Issuance 1
This Issuance
Issued to Encana Oil a Gas (USA) Inc.
COLORADO
Air Pollution Control Division
6t�;_ diea>t,16 EtAw.mer t
Notes Per .";H• • "Nr:�t the' •f th ;,p= mit issuance:
1) T "it hisfor the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in - revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production
based on the consum
upon request of the
control regulation or
and complete appli
terial processing limits and emission limits contained in this permit are
ion rates requested in the permit application. These limits may be revised
ner or operator providing there is no exceedance of any specific emission
y ambient air quality standard. A revised air pollution emission notice (APEN)
form must be submitted with a request for a permit revision.
3) This source is subject to the Common -Provisions Regulation Part Ii, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to.
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
5141
257
Toluene
108883
14785
739
Ethylbenzene
- 100414
510
25
Xylenes
1330207
3717
186
n -Hexane
110543
69590
3479
2,2,4-
Trimethylpentane
540841
2698
135
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission
Factors lb/bbl.
Source
N0x
0.0136
0.0136
AP -42 Ch. 13.5
CO
0.0618
0.0618
AP -42 Ch. 13.5
V0C
10.37
0.52
Site Specific - Hysys
71432
Benzene
0.024
0.001
Site Specific - Hysys
108883
Toluene
0.070
0.003
Site Specific - Hysys
100414
Ethylbenzene
0.002
0.000
Site Specific - Hysys.
1330207
Xylene
0.018
0.001
Site Specific - Hysys
110543
n -Hexane
0.328
0.016
Site Specific - Hysys
540841
2,2,4-Trimethylpentane
0.013
0.001
Site Specific - Hysys
COLORADO
Air Pollution Control Division
r PubtiL Her: th n En•Ar Onrner:t
Page 6 of 7
this point are based on the flare control efficiency of 95%.
6) I 5- .chAir 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)-692-315
7) This permit fulfills th„requirement to hold a valid permit reflecting the storage tank and associated
control device per _ e Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is class.' e• as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
PSD or NANSR
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Mr Pollution Control Division
envv6rrrx
Page 7 of 7
DO
ontrol Division
Department of Public Health Et Environment
Permit number:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
STRUCTION PERMIT
Issuance: 1
Encana Oil Et Gas (USA) Inc.
Zisch 6H -M368 Battery
123/9F0D
SWSW quadrant of Section 6, Township 3N, Range 68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
Condensate
Loadout
004
Truck loadout of condensate
Enclosed. Flare
This permit is granted subject to alt 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 the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe%other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1 and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall: be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3 This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) doesnot commence construction/modification or operationof this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
COLORADO
Air Pc a Lion Control Division
I prrtxr sits+,t of. PO*: eu;snG E'mirvrr:tet:t
Page 1 of 7
dl. ed to commence as set forth in the permit application
ted£ it is;.ermi ; ii iscontinues construction for a period of eighteen months or
more; (iii .oes not comple e construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4 The operator shall complete all initial compliance testing and sampling as required in this permit
and submit 3 `- r'=s to the Division as part of the self -certification process. (Regulation
Number 3, Part B ection III.E.)
5. The operator sh retain the permit final authorization letter issued by the Division, after
completion of s =` certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. • Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO),
VOC
CO
Condensate
Loadout
004
-
-
2.0
-
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for criteria pollutants shall be determined on a rolling twelve
(12) month total. By the end of each month -a new twelve month total is calculated based on the
previous twelve months' data. The permit holder shall calculate actual emissions each month
and keep a compliance record on site or at a local field office with site responsibility for Division
review.
The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
Condensate
Loadout
004
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
COLORADO
Air Pollution Control Division
- ,•& rtt&A t Pubtic HC t°* & Cnvcrrner,k
Page 2 of 7
Condensate
Loadout
Process Parameter
Condensate loaded
212,423 barrels
Compliance with e annual throughput limits shall be determined on a rolling twelve (12) month
total. By the en..f each month a new twelve-month total is calculated based on the previous
twelve months' ,.,,r.. The permit holder shalt calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
9. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation
Number 3, Part. B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
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. (Regulation Number 1, Section II.A.5.)
11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
12. 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 and
emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2)
All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and
maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the
maximum extent practicable.
13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
a. The owner or operator shall inspect onsite loading equipment during loading operations
to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking,
or other liquid or vapor toss during loading and unloading. The inspections shalloccur at
least quarterly. Each inspection shall be documented in a log available to the Division on
request.
All compartment hatches at the facility (including thief hatches) shall be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
14. The owner or operator shall:
Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
Include devices to prevent the release of vapor from vapor recovery hoses not in use.
CDPH
Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
!COLORADO
11i PollUtiort Control Divssi.can
re e rc eto r Gage 3 of 7
PPosal equipment at a back -pressure lessthan the pressure
ort vehicles.
OPERATING It MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate II e on an ongoing basis withthe requirements of this permit. Revisions to
the OEtM plan ar , ubject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III :7.)
COMPLIANCE TESTING SAMPLING
Initial Testing Requirements
This source is not required to conduct initial testing, unless otherwise directed by the Division or other state
or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or activity,
or
Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection upon
request. The permit may reissued to a new owner by the APCD as provided in AQCC Regulation
Number 3, Part B, Section II.B: upon a request for transfer of ownership and the submittal of a
revised APEN and the required fee.
a final authorization has been granted, then the remainder
Otherwise, the issuance of this construction permit does not
provide " ma aut on y for t is ac ivity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activitycommences and has been verified by the APCD
as conformin spects with the conditions of the permit. Once self certification of all
points has be r ie ed and approved by the Division, it will provide written documentation of
such final authon Lion Details for obtaining final authorization to operate are located in the
Requirements to ` elf -Certify for Final Authorization section of this permit.
21. This permit is i in reliance upon the accuracyand 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:
Christian Lesniak
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
issued to Encana Oil & Gas (USA) Inc.
Notes Perm ,Q H 4 . t the •f th p mit issuance:
1) T -s :£F --- it h for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days
of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production
based on the consum
upon request of the
control regulation or
and complete appli.
terial processing limits and emission limits contained in this permit are
ion rates requested in the permit application. These limits may be revised
ner or operator providing there is no exceedance of any specific emission
y ambient air quality standard. A revised air pollution emission notice (APEN)
form must be submitted with a request for a permit reyisioa.
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 Il.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/agcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated inthis 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 #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
004
Benzene
71432
741
37
Toluene
108883
1308
65
Ethylbenzene
100414
55
3
Xytenes
1330207
575
29'
n -Hexane
110543
1837
92
2,2,4-
Trimethylpentane
540841
1
0
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds.
per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution
Emission Notice.
The emission levels contained in this permit are based on the following emission factors:
Point 004:
CAS #
Pollutant
Uncontrolled -
Emission Factors
lb/bbl
Controlled
Emission
Factors lb/bbl
Source
VOC
3.71 E-01
1.86E-02
AP -42 Ch. 5.2 - Site
Specific
71432
Benzene
3.49E-03
1.74E-04
Site Specific - Hysys
108883
Toluene
6.16E-03
3.08E-04
Site Specific - Hysys
1330207
Xylene
2.71 E-03
1.35E-04
Site Specific - Hysys
110543
n -Hexane
8..65E-03
4.32E-04
Site Specific- Hysys
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
r pr surer 8 ^ psia
mole ." : w 68 l
T (temperature of liquid loaded) = 512.12 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 V0C emission factor.
Controlled emissio
e based on a flare efficiency of 95% and a collection efficiency of 100%.
6) In accordance with C .S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid f. a term of five years from the date it was received by the Division.'A revised
APEN shall be subs • 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)-692-315O.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs
PSD or NANSR
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Applicable
9) 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
OLORADO
rpollution Control Division
Permit Number:
, AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1
TBD ( to g 0124 [Leave blank unless APCD has already assigned apermit# & AIRS ID] Emission Source AIRS ID: T9O 12?j- FO 2- UQ?j
Person To Contact:
E-mail Address:
Facility Equipment ID: Condensate Tank
Section 01— Administrative Information
Company Name: Encana Oil & Gas (USA) Inc.
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Section 02 — Requested Action (Check applicable request boxes)
N Request for NEW INDIVIDUAL permit
O Request for coverage under GENERAL PERMIT
Source Name: ZISCH 6H CONDENSATE STORAGE TANK ❑ GP01 ❑ GP08
Source Location: Zisch 6H -M368 County: Weld 0 Request MODIFICATION to existing INDIVIDUAL permit (check boxes below)
SW 1/4 SW 1/4 Sec. 6 Twp. 3N R 68W Elevation: 5163 Feet O Change process or equipment 0 Change company name
Mailing Address: Republic Plaza 370 17th St. Suite 1700 ZIP Code: 80202 0 Change permit limit 0 Transfer of ownership 0 Other
❑ APEN Submittal for Permit Exempt/Grandfathered source
Adam Berig Phone Number: 720-876-3884 ❑ APEN Submittal for update only (Please note blank APEN's will not be accepted)
Addl. Info.
& Notes:
NAICS, or 1311
SIC Code:
Denver , CO
adam.berig@encana.com Fax Number: 720-876-4884
Section 03 — General Information
For existing sources, operation began on: N/A
This Storage Tank is ® Exploration & Production ❑ Midstream or Downstream
Located at: (E&P) Site (Non-E&P) Site
Will this equipment be operated in any NAAQS nonattainment area? N Yes 0 No Are Flash Emissions anticipated at these tanks
Is actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ® Yes ❑ No If "yes", identify the stook tank gas -to -oil ratio:
► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105.
► Are you requesting≥ 6 ton/yr VOC emissions, or are uncontrolled actual emissions> 6 ton/yr?
General description of equipment purpose: Condensate Tanks
Section 04 — Storage Tank(s) Information
Condensate Requested Permit Limit:
Throughput: Actual:
Average API Gravity of Sales Oil: 47.1 degrees
Tank Design: Fixed Roof:
For new or reconstructed sources, the projected startup date is: 1/13/2015
Normal Hours of Source Operation: 24 hours/
day
7 days/ 52 weeks/
week year
• Yes ❑ No
m3/liter
O Yes El No
• Yes ❑ No
212,423 bbl/year
bbl/year Actual While Controls Operational:
RVP of Sales Oil 11.55
Internal Floating Roof: 0 External Floating Roof: 0
bbl/year
Storage
Tank
ID
# of Liquid Manifold
Storage Vessels in
Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of most recent
storage vessel in storage tank
(Month/Year)
Date Of First Production
(Month/Year)
Cond.
12
6000
December 2014
January 2015
Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
- -
Please see complete well list on attached pages.
■
-
IN
- -
■
- -
■
- -
■
FORM APCD-205
Colorado Department of Public Health and Environment
Air Pollution Control Division (APCD)This notice is valid for five
(5) years. Submit a revised APEN prior to expiration of five-year
term, or when a significant change is made (increase production, new
equipment, change in fuel type, etc).
Mail this form along with a check for $152.90 per APEN for non-
E&P, midstream and downstream sources or $152.90 for up to
five (5) APENs for E&P sources and $250 for each general permit
registration to:
Colorado Department of Public Health & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For guidance on how to complete this APEN form:
Air Pollution Control Division: (30V692-3150
Small Business Assistance Program (SBAP): (303) 692-3148 or
(303) 692-3175
APEN forms: http://www.colorado.gov/cdphe/oilgasAPENS
Application status: http://www.colorado.gov/cdphe/permitstatus
Page 1 of 2 2015.04.09_Zisch 6H M368_Condensate Tanks_APEN.docx
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1
Permit Number: TBD Emission Source AIRS ID: TBD
Section 05
— Stack Information
(For midstream sites onl )
Operator
Stack
ID No.
Stack Base
Elevation
(feet)
Stack Discharge
Height Above
Ground Level
(feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Moisture
(%)
Cond.
5163.00
NA
NA
NA
NA
NA
Direction of stack outlet (check one): ® Vertical
Exhaust Opening Shape & Size (check one): El Circular: Inner Diameter (inches) =
Section 07 — Control Device Information
Section 06 —Stack (Source, if
no combustion) Location (Datum & either Lat/Long or UTM)
Horizontal Datum
(NAD27, NAD83,
WGS84)
UTM
Zone
(12 or 13)
UTM Easting or
Longitude
(meters or degrees)
UTM Northing or
Latitude
(meters or degrees)
Method of Collection for
Location Data (e.g. map,
GPS, GoogleEarth)
NAD83
13
-105.05281
40.24827
GPS
0 Vertical with obstructing raincap
❑ Horizontal ❑ Down
O Other: Length (inches) =
❑ Other (Describe):
Width (inches) =
O Vapor Recovery Unit (VRU) used for control of the Storage Tank(s)
Size: Make/Model:
Requested VOC & HAP Control Efficiency:
Annual time that VRU is bypassed (emissions vented):
❑ Closed loop system used for control of the storage tank(s)
Description:
® Combustion Device used for control of the Storage Tank(s)
Type: Enclosed Combustor
Rating:
Make/Model 48" High -Capacity
MMBtu/hr
VOC & HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed:
Minimum temp. to achieve requested control: °F Waste gas heat content:
Constant pilot light? ® Yes 0 No Pilot burner rating:
0 Describe Any Other:
98+
Btu/scf
MMBtu/hr
Section 08 — Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 35 psig
Please describe the separation process between the well and the storage tanks: HLP Separator to VRU to Atmospheric Tanks
Section 09 — Emissions Inventory Information & Emission Control Information
El Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput in Sec. 04 (e.g. 2007):
Pollutant
Emission Factor
Actual Calendar Year Emission2
Requested Permitted Emissions
Emission Factor
Data Source
Uncontrolled Basis
Uncontrolled (Tons/Year)
Controlled (Tons/Year)
Uncontrolled (Tons/Year)
Controlled (Tons/Year)
NOx
0.068
lb/MMBtu
-
--
AP42
VOC
10.37
lb/bbl
1101.87
55.09
HYSYS/E&P Tanks
CO
•9rY7 0 , %f t
lb/MMBtu
6. (
--
AP42
Benzene
0.0242
lb/bbl
2.57
0.13
HYSYS/E&P Tanks
Toluene
0.0696
lb/bbl
7.39
0.37
HYSYS/E&P Tanks
Ethylbenzene
0.0024
lb/bbl
0.26
0.01
HYSYS/E&P Tanks
Xylenes
0.0175
lb/bbl
1.85
0.09
HYSYS/E&P Tanks
n -Hexane
0.3276
lb/bbl
34.79
1.74
HYSYS/E&P Tanks
2,2,4-Trimethylpentane
0.0127
lb/bbl
1.35
0.07
HYSYS/E&P Tanks
Please use the APCD Non -Criteria Re 6 ortable Air Pollutant Addendum form to re , ort • ollutants not listed above.
Section 10 —A licant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct.
04/13/2015 Adam Berig Manager, Air Permitting
Signature of Person Legally AuthSupply Data Date Name of Legally Authorized Person (Please print) Title
You will be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and needs to be resubmitted.
2 Annual emissions fees will be based on actual emissions reported here. If left blank, annual emissions fees will be based on requested emissions.
Additional Information
Required:
Attach a pressurized pre -flash condensate extended liquids analysis, RVP & API analysis of the post -flash oil
Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results)
Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses
Check box to request copy of draft permit prior to issuance.
Check box to request copy of draft permit prior to public notice.
FORM APCD-205
Page 2 of 2
2015.04.09 Zisch 6H M368_Condensate Tanks APEN.docx
ft
ra>
Wells serviced by this tank or tank battery
AIRS ID#: TB ) Tank Battery Name: Zisch 6H -M368
423—C(Wc —64-5
API #:
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0512337487
0512337494
0512337488
0512337491
Name:
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Name
Zisch 3A -6H -M368
Zisch 3B -6H -M368
Zisch 3C -6H -M368
Zisch 3D -6H -M368
Z Newly Reported Well
Z Newly Reported Well
Z Newly Reported Well
Z Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
O Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
O Newly Reported Well
O Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
O Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
O Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
El Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
❑ Newly Reported Well
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Hydrocarbon Liquid Loading
Permit Number: 11 VUL 0121
Facility Equipment ID: Condensate Loadout
Section 01— Administrative Information
Company Name: Encana Oil & Gas (USA) Inc.
Please use the Fuel Dispensing Station APEN to report emissions from service stations and fleet refueling stations.
[Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 123 /c o o/ o 04 -
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization.]
Source Name: Zisch 6H -M368 Battery
Source Location: SWSW Sec 6 T3N R68W
Mailing Address: Republic Plaza 370 17th St., Suite 1700
Denver CO
Person To Contact: Adam Berig
E-mail Address: Adam.Berig@encana.com
Section 03 — General Information
For existing sources, operation began on:
Normal Hours of Source Operation:
General description of equipment and purpose:
NAICS, or
SIC Code:
1311
Section 02 — Requested Action (Check applicable request boxes)
® Request for NEW permit or newly reported emission source
❑ Request MODIFICATION to existing permit (check each box below that applies)
County: Weld ❑ Change process or equipment ❑ Change company name
Elevation: 5,163 Feet
ZIP Code: 80202
Phone Number: (720) 876-3884
Fax Number: (720) 876-4884
❑ Change permit limit
El Transfer of ownership ❑ Other
Request to limit HAPs with a Federally enforceable limit on PTE
❑ Request APEN update only (check the box below that applies)
❑ Revision to actual calendar year emissions for emission inventory
Addl. Info.
& Notes:
Update 5 -Year APEN term without change to permit limits or previously
reported emissions
For new or reconstructed sources, the projected startup date is: 1/13/2015
24 hours/day 7 days/week 52 weeks/year
Hydrocarbon Liquid Loadout
► Is this source located at an oil and gas exploration and production site?
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
(hydrocarbon liquids that have an API gravity of 40 degrees or greater) per year or submerge 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) emissions?
► Will this equipment be operated in any NAAQS nonattainment area? (http://www.cdphe.state.co.us/ap/attainmaintain.html)
► Does this source load gasoline into transport vehicles?
A If "Yes", this source may be subject to 40 CFR 63, Subparts EEEE, CC, and R. Provide an applicability determination of these rules.
B If "Yes", this source may be subject to Regulation No. 3, Part B, Section III.D.2. Provide an applicability determination of these rules.
c If"Yes", this source may be subject to Regulation No. 7, Section VI.C, 40 CFR 63 Subpart BBBBBB or Subpart X.X. Provide an
applicability determination of these rules.
Section 04 — Loading Information
Product Loaded: Condensate
This product is loaded from tanks at this facility into: Tank Trucks (e.g, "rail tank cars," or "tank trucks")
Number of Loading Bays: Pump Capacity in Each Bay: gallons /min.
► If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Annual Volume Loaded: Requested': 212,423 bbl/year Actual calendar year:
Saturation Factor2: 0.6
True Vapor Pressure: 8.9 psia @ 60 °F Molecular Weight of Displaced Vapors:
► If this APEN is being filed for vapor losses from pressurized loading lines, complete the following:
Loads per year: Requested': #/yr.
Load Line Volume3: Ft3/truckload Vapor Recovery Line Volume3: Ft3/truckload
bbl/year
Average Temperature of Bulk Liquid Loaded: 52.45 °F
68 LbIlb-mol
Actual Calendar Year: #/yr. Product Density:
Lb/ft3
Requested values will become permit limitations.
2Please refer to AP -42, Table 5.2-1 for information on saturation factors (found online at: http://www.epa.gov/ttn/chief/ap42/ch05/index.html).
' List the total volume for all lines in each category and attach your calculations of these volumes.
® Yes ❑ No ❑ Don't know
® Yes ❑ No ❑ Don't know
El Yes" ® No ❑ Don't know
YesB ❑ No ❑ Don't know
❑ Yesc ® No ❑ Don't know
Colorado Department of Public Health and Environment
Air Pollution Control Division (APCD)
This notice is valid for five (5) years. Submit a revised APEN prior to
expiration of five-year term, or when a significant change is made
(increase production, new equipment, change in fuel type, etc).
Mail this form along with a check for $152.90 to:
Colorado Department of Public Health & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For guidance on how to complete this APEN form:
Air Pollution Control Division: (303) 692-3150
Small Business Assistance Program (SBAP): (303) 692-3148 or
(303) 692-3175
APEN forms: http://www.cdphe.state.co.us/ap/downloadfonns.html
Application status: http://www.cdphe.state.co.us/ap/ss/sspcbt.html
FORM APCD-208
57 -7
Page 1 of 2 2015.04.13 APEN_-_Hydrocarbon Liquid_Loading=_Zisch_6H-M368_Battery.docx
AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Hydrocarbon Liquid Loading
Permit Number:
Please use the Fuel Dispensing Station APEN to report emissions from service stations and fleet refueling stations.
Emission Source AIRS ID: / /
Section 05 — Stack Information (Combustion stacks must be listed here)
Operator
Stack
ID No.
Stack Base
Elevation
(feet)
Stack Discharge
Height Above
Ground Level
(feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Moisture
(%)
LO
5,163 15
Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM)
Horizontal Datum
UTM
UTM Easting or
UTM Northing or
Method of Collection for
(NAD27, NAD83,
WGS84)
Zone
(12 or 13)
Longitude
(meters or degrees)
Latitude
(meters or degrees)
Location Data (e.g. map,
GPS, GoogleEarth)
WGS84 13 -105.05281 40.24825
GoogleEarth
Direction of stack outlet (check one): ® Vertical ❑ Vertical with obstructing raincap
Exhaust Opening Shape & Size (check one): El
Section 07 — Control Device Information
Circular: Inner Diameter (inches) = 48
❑ Vapor Recovery Unit (VRU) used for control of the loadout emissions.
Size: Make/Model:
Requested VOC & HAP Control Efficiency:
Annual time that VRU is bypassed (emissions
vented):
The VRU recycles loadout emissions to :
❑ Describe Any Other:
❑ Horizontal ❑ Down
D Other: Length (inches) =
❑ Other (Describe):
Width (inches) =
Combustion Device used for control of the loadout emissions.
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model/Serial #: 48" High -Capacity
VOC & HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: 98+ %
Minimum temp. to achieve requested control: °F Waste gas heat content: Btu/scf
Constant pilot light? ® Yes ❑ No Pilot burner rating: MMBtu/hr
Section 08 — Emissions Inventory Information & Emission Control Information
E Emission Factor Documentation attached Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007):
projected
1
Pollutant
Control Device Description
Control Efficiency
(% Reduction)
Emission Factor
a
Actual Calendar Year Emissions4
Requested Permitted
Emissions
Estimation
Method or
Emission
Factor Source
Primary
Secondary
Uncontrolled Basis
Units
Uncontrolled
(Tons/Year)
Controlled
(Tons/Year)
Uncontrolled
(Tons/Year)
Controlled
(Tons/Year)
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
0.3708
lb/bbl
39.39
1.97
AP42
0.0035
lb/bbl
0.37
0.02
AP42
0.0062
lb/bbl
0.65
0.03
AP42
0.0027
lb/bbl
0.29
0.01
AP42
0.0086
lb/bbl
0.92
0.05
AP42
Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
4Annual emission fees will be based on actual emissions reported here. If left blank, annual emission fees will be based on requested emissions.
5If Requested Permitted Emissions is left blank, the APCD will calculate emissims based on the information supplied in sections 03 - 08.
Section 09 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct.
Signature of Person Le ally`Authorized to Supply Data
04/13/2015
Date
Adam Berig
Name of Legally Authorized Person (Please print) Title
Manager, Air Quality
Page 2 of 2
2015.04.13_APEN_-_Hydrocarbon_Liquid_Loading= _Zisch_6H-M368_Battery.docx
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