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Home My WebLink About20170054.tiffCOLORADO Department of Public Health & 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 December 16, 2016 Dear Sir or Madam: RECEIVED DEC 2 7 2016 WELD COUNTY COMMISSIONERS On December 22, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for Encana Oil >:t. Gas (USA) Inc. - DALE 20H -O264; Sprague 9H -N267. 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. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Public v�ecv PLC O1 (o�-I / t�l RA) CRR/CH/Jm /c (c) trO/g1/(Co 2016-3866 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Encana Oil Et Gas (USA) Inc. - DALE 20H -O264; Sprague 9H -N267 - Weld County Notice Period Begins: December 22, 2016 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: DALE 20H -O264; Sprague 9H -N267 Two (2) Oil and Gas Wellsites SWSE SEC 20 T2N R64W Weld County The proposed project or activity is as follows: Fugitive component leaks and hydrocarbon liquid loading 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 15WE1216 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO 1 I '7 - HsaV.4 ie F�:vaoflinemt Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 01 /07/2016 Application Date: 06/09/2015 Facility Identifiers Permit No. 15WE1216 AIRS County# 123 (Weld Facility # 9E16 Facility Type: exploration and production facility Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor 0 Synthetic Minor for: VOC r Nox r co Company Name: Encana Oil & Gas (USA) Inc. Source Name: DALE 20H -O264 Source Location: SIC: SWSE SEC 20 T2N R64W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Encana Oil & Gas (USA) Inc. Republic Plaza 370 17th St., Suite 1700 Denver, CO 80202 Person To Contact Name: Phone: Fax: Email: adam berig 000-000-0000 000-000-0000 adam.berig(yencana.com Note: Asset sold to Crestone Peak Resources prior to issuance Requested Action Self Certification Required? Issuance Number: Yes 1 Source Description: Oil and gas exploration and production facility known as the DALE 20H -O264, located in the SWSE SEC 20 T2N R64W, Weld County, Colorado. Point Name Type ' Control Action 003 FUG Fugitives None Newly reported source 003 Fugitive equipment leaks Regulation 7 Information Operating Hours: 8760 hours/year Emission Factor Source Screening EFs - EPA -453/R-95-017 Table 2-8 Control Efficiency Source: Calculations None Service Component Type Count Emission Factor (kglhr- source) Table 2-4 Table 2-8 Control (%) Pollutant Mass Fraction Emissions (tpy) Reg. 3 Connectors 6886 2.00E-04 1.00E-05 0.0% VOC 0.358 0.4660096 Flanges 1258 3.90E-04 5.70E-06 0.0% Benzene 0.0019 0.0024732 Gas Open -Ended Lines 152 2.00E-03 1.50E-05 0.0% Toluene 0.0012 0.001562 Pump Seals 0 2.40E-03 3.50E-04 0.0% Ethylbenzene 0.0001 0.0001302 Valves 1655 4.50E-03 2.50E-05 0.0% Xylenes 0.0001 0.0001302 Other 126 8.80E-03 1.20E-04 0.0% n -Hexane 0.0071 0.0092421 Connectors 0 7.50E-06 7.50E-06 0.0% VOC 0.3 0 Flanges 0 3.90E-07 3.90E-07 0.0% Benzene 0.001 0 Heavy Oil Open -Ended Lines 0 1.40E-04 7.20E-06 0.0% Toluene 0.001 0 Pump Seals 0 0.00E+00 0.00E+00 0.0% Ethylbenzene 0.001 0 Valves 0 8.40E-06 8.40E-06 0.0% Xylenes 0.02 0 Other 0 3.20E-05 3.20E-05 0.0% n -Hexane 0.001 0 Connectors 3214 2.10E-04 9.70E-06 0.0% VOC 1 0.7183556 Flanges 402 1.10E-04 2.40E-06 0.0% Benzene 0.00323 0.0023203 Light Oil Open -Ended Lines 56 1.40E-03 1.40E-05 0.0% Toluene 0.01652 0.0118672 Pump Seals 48 1.30E-02 5.10E-04 0.0% Ethylbenzene 0.00073 0.0005244 Valves 761 2.50E-03 1.90E-05 0.0% Xylenes 0.00815 0.0058546 Other 23 7.50E-03 1.10E-04 0.0% n -Hexane 0.01669 0.0119894 Connectors 0 1.10E-04 1.00E-05 0.0% VOC 0.3 0 Flanges 0 2.90E-06 2.90E-06 0.0% Benzene 0.001 0 Water/Oil Open -Ended Lines 0 2.50E-04 3.50E-06 0.0% Toluene 0.001 0 Pump Seals 0 2.40E-05 2.40E-05 0.0% Ethylbenzene 0.001 0 Valves 0 9.80E-05 9.70E-06 0.0% Xylenes 0.02 0 Other 0 1.40E-02 5.90E-05 0.0% n -Hexane 0.001 0 Emissions Summary Table Pollutant Uncontrolled Emissions Controlled Emissions Source VOC 1.18 tpy 1.18 tpy Screenin E Benzene 9.59 lb/yr 9.59 lb/yr Screenin E Toluene 26.86 lb/yr 26.86 lb/yr Screenin E Ethylbenzene 1.31 lb/yr 1.31 lb/yr Screenin E Xylenes 11.97 lb/yr _ 11.97 lb/yr Screenin E n -Hexane 42.46 lb/yr 42.46 lb/yr Screenin E Regulatory Applicability Reg. 3 Reg. 6 Reg. 7 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 Review Regulation 3, Part B, Section III.D.2 to determine is RACT is required? Review 40 CFR, Part 60, Subpart KKK to determine if applicable to this source'? Review 40 CFR, Part 60, Subpart OOOO to determine if 60.5380 and/or 60.5385 is applicable? Review Section XVII.F to determine is LDAR is applicable? yes no no no AIRS (County/Plant) 123/9E16 Permit No. 15WE1216 Date 1/7/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 003 31000220 VOC 003 31000220 Benzene 003 31000220 n -Hexane 003 31000220 Toluene 003 31000220 Ethylbenzene 003 31000220 Xylenes Emisison Factor Source Controlled Actual Emissions (tpy)` Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? Screening EFs - EPA -453/R-95- 017 Table 2-8 1.2 1.2 0% Yes Screening EFs - EPA -453/R-95- 017 Table 2-8 9.6 9.6 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 42.5 42.5 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 26.9 26.9 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 1.3 1.3 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 12 12 0% No Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 01/07/2016 Application Date: 06/09/2015 Facility Identifiers Permit No. 15WE1217 AIRS County# 123 'Weld Facility # 9E16 Facility Type: exploration and production facility ❑� Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area True Minor Synthetic Minor for: voc Company Name: Encana Oil & Gas (USA) Inc. Source Name: DALE 20H -O264 Source Location: SIC: SWSE SEC 20 T2N R64W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Encana Oil & Gas (USA) Inc. Republic Plaza 370 17th St., Suite 1700 Denver, CO 80202 Person To Contact Name: Phone: Fax: Email: adam berig 000-000-0000 000-000-0000 adam.berig@encana.com Note: Asset sold to Crestone Peak Resources prior to issuance Requested Action Self Certification Required? Issuance Number: Yes 1 r NOx r CO Source Description: Oil and gas exploration and production facility known as the DALE 20H -O264, located in the SWSE SEC 20 T2N R64W, Weld County, Colorado. Point Name Type . Control Action 004 Condensate Loadout Loadout Flare Newly reported source 004 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded The table of inputs below enables you to calculate the loading loss emissions factor "L". If you choose to use a state default emissions factor, you may enter is directly into cell B14 in units lb/1,000 gallons which will overwrite Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 3.8 psia Sales Oil A M Molecular Weight of Vap 68 lb/lb-mole AP -42 T Liquid Temperature 512 deg. R Field Data L 3.77 lb/10^3 gal 1.58E-01 lb/bbl Annual requested Throughput Annual requested VOC emissions Control: Flare Efficiency: 95.00% NCRPs Component Mass Fraction Benzene 0.0094 n -hexane 0.0233 Toluene 0.0166 Xylenes 0.0073 Source: Pressurized oil Emissions Summary Table 706122 BBL/yr 29657124 gal/yr 111898 lb/yr 55.95 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific emissions factor, enter the modeled mass fraction for the Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.1585 lb/bbl 55.9 tpy 2.8 tpy AP -42 Benzene 0.0015 lb/bbl 1051.8 lb/yr 52.6 lb/yr AP -42 n -Hexane 0.0037 lb/bbl 2607 lb/yr 130 lb/yr AP -42 Toluene 0.0026 lb/bbl 1858 lb/yr 93 lb/yr AP -42 Xylenes 0.0012 lb/bbl 817 lb/yr 41 lb/yr AP -42 Regulatory Review Regulation 3'- APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 no yes no AIRS (County/Plant) 123/9E16 Permit No. 15WE1217 Date 1/7/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 004 40600132 VOC 3.773 lb/1000 ga 004 40600132 Benzene 0.036 lb/1000 ga 004 40600132 n -Hexane 0.088 lb/1000 ga 004 40600132 Toluene 0.063 lb/1000 ga 004 40600132 Xylenes 0.028 lb/1000 ga Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? AP -42 2.8 55.9 95% Yes AP -42 52.6 1051.8 95% Yes AP -42 130.4 2607.2 95% Yes AP -42 92.9 1857.5 95% Yes AP -42 40.8 816.9 95% Yes Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 01/04/2016 Application Date: 10/26/2016 Facility Identifiers Permit No. 15WE1425 AIRs County# 123 'Weld Facility # 9E32 Facility Type: exploration and production facility El Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor Synthetic Minor for: I✓ VOC Company Name: Encana Oil & Gas (USA) Inc. Source Name: Sprague 9H -N267 Battery Source Location: SIC: SESW SEC 9 T2N R67W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Encana Oil & Gas (USA) Inc. Republic Plaza 370 17th St., Suite 1700 Denver CO, 80202 Person To Contact Name: Phone: Fax: Email: Adam Berig 000-000-0000 000-000-0000 adam.berig@encana.com Requested Action Self Certification Required? Issuance Number: Source Description: Yes 1 r NOx r co Oil and gas exploration and production facility known as the Sprague 9H -N267 Battery, located in the SESW SEC 9 T2N R67W, Weld County, Colorado. Point Name Type Control Action 009 Condensate Loadout Loadout Flare Newly reported source 009 Hydrocarbon Loadout to Tanker Trucks Calculations L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded The table of inputs below enables you to calculate the loading loss emissions factor "L". If you choose to use a state default emissions factor, you may enter is directly into cell B14 in units lb/1,000 gallons which will overwrite Factor Meaning Value Units Source S Saturation Factor 0.6 AP -42 P True Vapor Pressure 5.75 psia Sales Oil A M Molecular Weight of Vap 68 lb/lb-mole AP -42 T Liquid Temperature 512 deg. R Field Data L 5.71 lb/10^3 gal 2.40E-01 lb/bbl Annual requested Throughput Annual requested VOC emissions Control: Flare Efficiency: 95.00% NCRPs Component Mass Fraction Benzene 0.0018 n -hexane 0.0153 Toluene 0.0153 Xylenes 0.0153 Source: Stable Sales Oil Analysis Emissions Summary Table 753038 BBL/yr 31627596 gal/yr 180569 lb/yr 90.28 tpy alysis If the operator provides HAP speciation from a stable "sales oil" analysis, enter the mass fraction from this data. Alternatively, if the operator modeled a pressurized oil to develop a site specific emissions factor, enter the modeled mass fraction for the Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 0.2398 lb/bbl 90.3 tpy 4.5 tpy AP -42 Benzene 0.0012 lb/bbl 903.6 lb/yr 45.2 lb/yr AP -42 n -Hexane 0.0159 lb/bbl 11973 lb/yr 599 lb/yr AP -42 Toluene 0.0037 lb/bbl 2786 lb/yr 139 lb/yr AP -42 Xylenes 0.0031 lb/bbl 2334 lb/yr 117 lb/yr AP -42 Regulatory Review Regulation 3 - APEN and, Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? no If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 yes no AIRS (County/Plant) 123/9E32 Permit No. 15WE1425 Date 1/4/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 009 40600132 VOC 5.71 lb/1000 ga 009 40600132 Benzene 0.029 lb/1000 ga 009 40600132 n -Hexane 0.379 lb/1000 ga 009 40600132 Toluene 0.088 lb/1000 ga 009 40600132 Xylenes 0.074 lb/1000 ga Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? AP -42 4.5 90.3 95% Yes AP -42 45.2 903.6 95% Yes AP -42 598.7 11973.3 95% Yes AP -42 139.3 2786.2 95% Yes AP -42 116.7 2334.4 95% Yes Division Information Engineer: Timothy Sharp Control Engineer: Stefanie Rucker Review Date: 01/04/2016 Application Date: 10/26/2016 Facility Identifiers Permit No. 15WE1426 AIRs County# 123 'Weld Facility # 9E32 Facility Type: exploration and production facility Located in the 8 -hour non -attainment area? Administrative Information Potentially located in ozone nonattainment area O True Minor 0 Synthetic Minor for: voc Company Name: Encana Oil & Gas (USA) Inc. Source Name: Sprague 9H -N267 Battery Source Location: SIC: SESW SEC 9 T2N R67W 1311 Mailing Address Address 1: Address 2: ty, State Zip: Encana Oil & Gas (USA) Inc. Republic Plaza 370 17th St., Suite 1700 Denver CO, 80202 Person To Contact Name: Phone: Fax: Email: Adam Berig 000-000-0000 000-000-0000 adam.berig@encana.com Requested Action Self Certification Required? Issuance Number: Yes 1 r NOx IW CO Source Description: Oil and gas exploration and production facility known as the Sprague 9H -N267 Battery, located in the SESW SEC 9 T2N R67W, Weld County, Colorado. Point Name Type Control Action 010 FUG Fugitives None Newly reported source 010 Fugitive equipment leaks Regulation 7 Information Operating Hours: 8760 hours/year Emission Factor Source Screening EFs - EPA -453/R-95-017 Table 2-8 Control Efficiency Source: Calculations Service Component Type Count Emission Factor (kglhr- source) Table 2-4 Table 2-8 Control (%) Pollutant Mass Fraction Emissions (tpy) Reg. 3 Connectors 12404 2.00E-04 1.00E-05 0.0% VOC 0.2953 0.6999349 Flanges 2022 3.90E-04 5.70E-06 0.0% Benzene 0.0012 0.0028443 Gas Open -Ended Lines 294 2.00E-03 1.50E-05 0.0% Toluene 0.0013 0.0030813 Pump Seals Valves 0 2962 2.40E-03 4.50E-03 3.50E-04 2.50E-05 0.0% 0.0% Ethylbenzene Xylenes 0.0011 0.0007 0.0026073 0.0016592 Other 262 8.80E-03 1.20E-04 0.0% n -Hexane 0.0157 0.0372129 Connectors 0 7.50E-06 7.50E-06 0.0% VOC 0.3 0 Flanges 0 3.90E-07 3.90E-07 0.0% Benzene 0.001 0 Heavy Oil Open -Ended Lines 0 1.40E-04 7.20E-06 0.0% Toluene 0.001 0 Pump Seals 0 0.00E+00 0.OOE.00 0.0% Ethylbenzene 0.001 0 Valves 0 8.40E-06 8.40E-06 0.0% Xylenes 0.02 0 Other 0 3.20E-05 3.20E-05 0.0% n -Hexane 0.001 0 Connectors 6000 2.10E-04 9.70E-06 0.0% VOC 1 1.5081281 Flanges 908 1.10E-04 2.40E-06 0.0% Benzene 0.0037 0.0055801 Light Oil Open -Ended Lines 94 1.40E-03 1.40E-05 0.0% Toluene 0.0111 0.0167402 Pump Seals 132 1.30E-02 5.10E-04 0.0% Ethylbenzene 0.0169 0.0254874 Valves 1372 2.50E-03 1.90E-05 0.0% Xylenes 0.0095 0.0143272 Other 10 7.50E-03 1.10E-04 0.0% n -Hexane 0.0242 0.0364967 Connectors 0 1.10E-04 1.00E-05 0.0% VOC 0.3 0 Flanges 0 2.90E-06 2.90E-06 0.0% Benzene 0.001 0 Water/Oil Open -Ended Lines 0 2.50E-04 3.50E-06 0.0% Toluene 0.001 0 Pump Seals 0 2.40E-05 2.40E-05 0.0% Ethylbenzene 0.001 0 Valves 0 9.80E-05 9.70E-06 0.0% Xylenes 0.02 0 Other 0 1.40E-02 5.90E-05 0.0% n -Hexane 0.001 0 None Emissions Summary Table Pollutant Uncontrolled Emissions Controlled Emissions Source VOC 2.21 tpy 2.21 tpy Screenin E Benzene 16.85 lb/yr 16.85 lb/yr Screenin E Toluene 39.64 lb/yr 39.64 lb/yr Screenin E Ethylbenzene 56.19 lb/yr 56.19 lb/yr Screenin E Xylenes 31.97 lb/yr 31.97 lb/yr Screenin E n -Hexane 147.42 lb/yr 147.42 lb/yr Screenin E Regulatory Applicability Reg. 3 Reg. 6 Reg. 7 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 Review Regulation 3, Part B, Section III.D.2 to determine is RACT is required? Yes/No Review 40 CFR, Part 60, Subpart KKK to determine if applicable to this source? Yes/No Review 40 CFR, Part 60, Subpart OOOO to determine if 60.5380 and/or 60.5385 is applicable? Review Section XVII.F to determine is LDAR is applicable'? Yes/No Yes/No AIRS (County/Plant) 123/9E32 Permit No. 15WE1426 Date 1/4/2016 Point # SCC Pollutant or CAS Uncontrolled Emission Factor 010 31000220 VOC 010 31000220 Benzene 010 31000220 n -Hexane 010 31000220 Toluene 010 31000220 Ethylbenzene 010 31000220 Xylenes Emisison Factor Source Controlled Actual Emissions (tpy)* Controlled Requested Emissions (tpy)* PTE (tpy)* Ctrl. Eff% NCRP = reportable ? Screening EFs - EPA -453/R-95- 017 Table 2-8 2.2 2.2 0% Yes Screening EFs - EPA -453/R-95- 017 Table 2-8 16.8 16.8 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 147.4 147.4 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 39.6 39.6 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 56.2 56.2 0% No Screening EFs - EPA -453/R-95- 017 Table 2-8 32 32 0% No STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1216 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the DALE 20H -O264, located in the SWSE SEC 20 T2N R64W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FUG 003 Fugitive equipment leaks 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 commencement of operation or issuance of this permit, whichever comes later, 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 commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the AIRS ID: 123/9E16 Page 1 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. 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: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO FUG 003 2.4 Fugitive See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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 Point 003: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in AIRS ID: 123/9E16 Page 2 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. Point 003: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 12. Point 003: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVI1.B.1. 13. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). Directed Inspection & Maintenance (DI&M), as required, shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). 14. Point 003: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. Auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,000 ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened using AVO to determine if the leak is repaired. AIRS ID: 123/9E16 Page 3 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO inspections, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post - repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 15. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 003: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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 AIRS ID: 123/9E16 Page 4 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This AIRS ID: 123/9E16 Page 5 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 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: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for fugitive component leaks at a synthetic minor facility. AIRS ID: 12319E16 Page 6 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 003 Benzene 71432 9.6 No 9.6 003 n -Hexane 110543 42.5 No 42.5 003 Toluene 108883 26.9 No 26.9 003 Ethylbenzene 100414 1.3 No 1.3 003 Xylenes 1330207 12 No 12 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Component Gas Heavy Oil Light Oil Water/Oil Connectors 6886 0 3214 0 Flanges 1258 0 402 0 Open-ended Lines 152 0 56 0 Pump Seals 0 0 48 0 Valves 1655 0 761 0 Other 126 0 23 0 VOC Content (wt. fraction) 0.358 0.3 1 0.3 Benzene Content (wt. fraction) 0.0019 0.001 0.00323 0.001 Toluene Content (wt. fraction) 0.0012 0.001 0.01652 0.001 AIRS ID: 123/9E16 Page 7 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Ethylbenzene (wt. fraction) 0.0001 0.001 0.00073 0.001 Xylenes Content (wt. fraction) 0.0001 0.02 0.00815 0.02 n -hexane Content (wt. fraction) 0.0071 0.001 0.01669 0.001 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil SWater/Oil ervi Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: Screening EFs - EPA -453/R-95-017 Table 2-8 Note that the emission limits included in this permit are derived by multiplying the equipment counts in the table above by a factor of 2.0 to accommodate other minor changes to the facility and to provide a conservative estimate of facility -wide emissions. Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ AIRS ID: 123/9E16 Page 8 of 9 Colorado Department of Public Health and Environment Air 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 YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 12319E16 Page 9 of 9 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1217 1217 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the DALE 20H -O264, located in the SWSE SEC 20 T2N R64W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Condensate Loadout 004 Hydrocarbon Loadout to Tanker Trucks 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 commencement of operation or issuance of this permit, whichever comes later, 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 commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date AIRS ID: 123/9E16 Page 1 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO„ VOC CO Condensate Loadout 004 --- 2.8 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Include control device requirements if using controls to achieve emission limits. If facility - wide permit, include all the equipment that has a control device. Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensat e Loadout 004 Enclosed Combustion Device VOC PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or AIRS ID: 123/9E16 Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Condensat e Loadout 004 Oil Loaded 706,122 BBL Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. Point 004: 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) 12. Point 004: 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.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (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. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. AIRS ID: 123/9E16 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 004: 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. OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change 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. 16. 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 AIRS ID: 123/9E16 Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. 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. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. AIRS ID: 12319E16 Page 5 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division By: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for hydrocarbon liquid loadout at a synthetic minor facility. AIRS ID: 12319E16 Page 6 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpaqename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 004 Benzene 71432 1060 Yes 53 004 n -Hexane 110543 2600 Yes 130 004 Toluene 108883 1860 Yes 93 004 Xylenes 1330207 820 Yes 41 5) The emission levels contained in this permit are based on the following emission factors: Point 004: Pollutant Emission Factors Uncontrolled Ib/BBL loaded - Source VOC 0.1583 AP -42 Benzene 0.0015 AP -42 n -Hexane 0.0037 AP -42 Toluene 0.0026 AP -42 Xylenes 0.0012 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) = 3.8 psia AIRS ID: 123/9E16 Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 532 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.cov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E16 Page 8 of 8 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1425 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Sprague 9H -N267 Battery, located in the SESW SEC 9 T2N R67W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Condensate Loadout 009 Hydrocarbon Loadout to Tanker Trucks 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 commencement of operation or issuance of this permit, whichever comes later, 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 commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date AIRS ID: 123/9E32 Page 1 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO Condensate Loadout 009 --- 4.6 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensat e Loadout 009 Enclosed Combustor VOC PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9E32 Page 2 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Condensat e Loadout 009 Oil Loaded 753,038 BBL Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. Point 009: 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) 12. Point 009: 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.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (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. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with the conditions (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. AIRS ID: 123/9E32 Page 3 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division 13. Point 009: 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. OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 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. 16. 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 AIRS ID: 123/9E32 Page 4 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. 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. 18. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. AIRS ID: 123/9E32 Page 5 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division By: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for hydrocarbon liquid loadout at a synthetic minor facility. AIRS ID: 123/9E32 Page 6 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Mainc/02FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 009 Benzene 71432 920 Yes 46 009 n -Hexane 110543 11940 Yes 597 009 Toluene 108883 2760 Yes 138 009 Xylenes 1330207 2360 Yes 118 009 Ethylbenzene 100414 4220 Yes 211 5) The emission levels contained in this permit are based on the following emission factors: Point 009: Pollutant Emission Factors Uncontrolled lb/BBL loaded - Source VOC 0.2398 AP -42 Benzene 0.0012 AP -42 n -Hexane 0.0159 AP -42 Toluene 0.0037 AP -42 Xylenes 0.0031 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) AIRS ID: 123/9E32 Page 7 of 8 Colorado Department of Public Health and Environment Air Pollution Control Division P (true vapor pressure) = 5.75 psia M (vapor molecular weight) = 68 Ib/Ib-mol T (temperature of liquid loaded) = 512 °R 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.clov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E32 Page 8 of 8 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1426 Issuance 1 DATE ISSUED: DRAFT ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Sprague 9H -N267 Battery, located in the SESW SEC 9 T2N R67W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description FUG 010 Fugitive equipment leaks 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 commencement of operation or issuance of this permit, whichever comes later, 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 commencement of operation or issuance of this permit, whichever comes later, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the AIRS ID: 12319E32 Page 1 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. 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: Facility Equipment ID AIRS Point Tons per Year Emission Type NO X VOC CO FUG 010 --- 2.2 --- Fugitive See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. 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. Point 003: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent gas analysis, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in AIRS ID: 123/9E32 Page 2 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. Point 010: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 12. Point 010: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. 13. Point 010: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). Directed Inspection & Maintenance (DI&M), as required, shall satisfy the requirement to apply Reasonably Available Control Technology (RACT). 14. Point 010: Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a). This requirement to apply RACT shall be satisfied by installing/implementing the following emission controls: a. Directed Inspection & Maintenance as described below shall satisfy the requirement to apply RACT. i. Auditory/visual/olfactory inspection (AVO) will be performed on a quarterly basis. ii. For each leak found in the AVO inspection, a gas detector may be used to determine the size of the leak. The gas detector shall be regularly calibrated. Component leaks greater than 10,000 ppm shall be managed in accordance with Item (vi) below, unless it is unfeasible to make the repair without shutting down the affected operation of the facility. Component leaks less than 10,000 ppm shall not require repair. For such component leaks that require a shutdown to be repaired, repair shall occur during the first shutdown of the affected operation after the leak is discovered. iii. For repair, valves adjacent to the equipment to be repaired will be closed if practicable, minimizing the volume released. iv. Repaired components shall be re -screened using AVO to determine if the leak is repaired. AIRS ID: 123/9E32 Page 3 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division v. The following records shall be maintained for a period of two years: • The name of the site screened via AVO inspection and the name of the inspector. • Components evaluated with the gas detector. • Repair methods applied. • Dates of the AVO inspections, gas detector calibrations, attempted repairs, successful repairs, repair delays, and post - repair screenings. vi. Leaks shall be repaired as soon as practicable, but no later than 15 calendar days after detection, unless it is technically or operationally infeasible to make the repair within 15 calendar days. Records documenting the rationale shall be maintained if it is technically or operationally infeasible to make the repair within 15 calendar days. OPERATING & MAINTENANCE REQUIREMENTS 15. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. Point 010: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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 AIRS ID: 123/9E32 Page 4 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 18. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This AIRS ID: 123/9E32 Page 5 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division 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: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for fugitive component leaks at a synthetic minor facility. AIRS ID: 123/9E32 Page 6 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641 &pagename=CBONWrapper 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 010 Benzene 71432 16.8 No 16.8 010 n -Hexane 110543 147.4 No 147.4 010 Toluene 108883 39.6 No 39.6 010 Ethylbenzene 100414 56.2 No 56.2 010 Xylenes 1330207 32 No 32 5) The emission levels contained in this permit are based on the following emission factors: Point 010: Component Gas Heavy Oil Light Oil Water/Oil Connectors 12404 0 6000 0 Flanges 2022 0 908 0 Open-ended Lines 294 0 94 0 Pump Seals 0 0 132 0 Valves 2962 0 1372 0 Other 262 0 10 0 VOC Content (wt. fraction) 0.2953 0.3 1 0.3 Benzene Content (wt. fraction) 0.0012 0.001 0.0037 0.001 Toluene Content (wt. fraction) 0.0013 0.001 0.0111 0.001 AIRS ID: 123/9E32 Page 7 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division Ethylbenzene (wt. fraction) 0.0011 0.001 0.0169 0.001 Xylenes Content (wt. fraction) 0.0007 0.02 0.0095 0.02 n -hexane Content (wt. fraction) 0.0157 0.001 0.0242 0.001 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 2.0E-04 7.5E-06 2.1E-04 1.1E-04 Flanges 3.9E-04 3.9E-07 1.1E-04 2.9E-06 Open-ended Lines 2.0E-03 1.4E-04 1.4E-03 2.5E-04 Pump Seals 2.4E-03 NA 1.3E-02 2.4E-05 Valves 4.5E-03 8.4E-06 2.5E-03 9.8E-05 Other 8.8E-03 3.2E-05 7.5E-03 1.4E-02 Source: Screening EFs - EPA -453/R-95-017 Table 2-8 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas and liquids analyses. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, HAP PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources AIRS ID: 123/9E32 Page 8 of 9 Colorado Department of Public Health and Environment Air Pollution Control Division NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX 9) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9E32 Page 9 of 9 onent Leak Emissions E • • Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: O N CO On O 0 0 C W C S 0. 0 0 •0 0 E W CO b P. Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information CC. O T R 773 R O . ❑ o O E. d U CL W y O i! C ti04 cn C •. L an C C 0 .0 0' H CC 0 d 4.. R '5 N OU O N ' m aU°' s ) C w i. ,, o s 00 34-4 C d O tO °' = U H 6, -E 0 CO 0 d a c E 0 i a+ a) o 0. ❑ ❑ >. O is 0 0 00 C) L .�... L C R r CO _ > y .p u ` •3 4' d d 0 .U°+ a. W C R L .0 >, z -, ZO a = C U Wp., E °' 3 ° Q W,,, L F O h r 0 0. a - CO C a> W '" A n Z w CO o ate) A E t a O b0 bA ,.O OA. 44 CO 0 a C) en . eLkd U U d 0 0 0 0 a a ❑ ❑ a a ❑ ❑ ® ❑ 'O 3 CD CD CD 7 R C ❑ ❑ • do ° b o -o U C-) U U a) P. Zv> W N 00 Source Name: SW 1/4, SE 1/4, Sec. 20, T 2N, R 64W Denver , CO 0D i co E R Po Person To Contact: Section 03 — General Information O O0 For new or reconstructed sources, the projected startup date is: For existing sources, operation began on: CO C) U N N 3 I Cd I- O Normal Hours of Source Operation: Brief description of equipment associated with these components: C E C O oA a CO a R C i .0 CO .7, a.) xA L 7 C o o U 44 o E CO C0 44 ). A' 0 CO CO L O U oa) 0 (O 0 8 C.cn F a, R C. }yu N = w > 0 N3 r L M O o cud c b0 C A In .+ 0 0 E d 0 o 0.O o., d 0 .0 cd > U R F L NO C o �C. o E a o0 O CI) ,.. b L N O T a) OAS? LQ U 0 0 C. 44: o aLi U CO O C 'O U1 It` i 'V C id a) L A C.)b C o U O > b4 �C U R O C C• [-• iii ',..t �UQaA w oL o�C (n M M CD CD C` w soso‘.0- r R M M M 0 O O O 3 O he.state.co.us/a E he.state.co.us/a 3 31 C APEN forms: htt Application status: h C 0 O Q 0 z CO C) C S C C 5 o C -C C/> C z T C CO C `d CO 0 a. o �. o g -0 N CN C � 0, "0 c� 3 Information Section 04 — Re .0 O C O Q 1C Q .Y ❑ ❑ ❑ ❑ z Is this equipment subject to NSPS 40 CFR Part 60, Subpart KKK? Is this equipment subject to NESHAP 40 CFR Part 63, Subpa List any other NSPS or NESHAP Subpart that applies to this equipment: Section 05 — Stream Constituents C) 0 O C C) C 0 a `CJ O C) 01 0 O 00 M 0 O N O N O\ en N M 0 00 M 0 0 CO Heavy Oil (or Heavy Liquid) C 0^ .0 0D L O O .0 00 Check box to request copy of draft permit prior to issuance. CO U C 0 S U 0 C. cn C. 0 O W w 00 76, C U C 'C C) 'O C C) U b C b CO CO O4 O C L Q. a> R C 00 Check box to request copy of draft permit prior to public notice. 2015.06.04 Dale 20H-O264_Fugitives_APEN.docx FORM APCD-203 onent Leak Emissions Emission Source AIRS ID: 5 Permit Number: & Control Information L_ R Section 07 —Leak Detection & Re .an an a) a) U 0 O CL o 0 0 a) ❑ No LDAR program Eo0 co = 0 N' Section 08 — Emission Factor Information u C = r. 9 � e = o E E U y obe c R y 0 U y C o W a a) 'a, o OA 5 C �a a) 0.0o U c o W 'o 0 0 a) a) a) a) E a) O a) C 0 C a a) a) O u y (4'U N ❑ Equipment Type mated Count ions" below. Section 09 — Emissions Inventory Information & Emission Control Information Estimation Method O rn rn G O EPA Tbl 2-8 N EPA Tbl 2-8 414 A A ..EPA Tbl 2-8 EPA Tbl 2-8 as w" A De Minimus Data year for actual calendar year emissions below (e.g. 2007): Emission Factor Documentation attached Actual Calendar Year Emissions2 0 0 Emission Factor Control Device Description 0 Uncontrolled Basis ea 'O 0 0 a) E •a a) a) C a) O .0 ca an 0 e c cat 0 a 0 0 E w 3 R C -C as a) C 0. C.) 0 0 a a ae •47. U 0 0 z U a d L a) a) d a U O a) N G a) C a) 0 C a) .0 C 2015.06.04_Dale 20H-O264_Fugitives_APEN.docx N 0 N a) oA a. uid Loadin drocarbon Li Permit Number: 0 N 00 O 0 O C U C N C 9 0. 0 0 CC 0 W w N •v_ O 0 Condensate Loadout Facility Equipment ID: nested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source d 0. a O .0 C O .0 x 0 .0 CO .C 4.4 CJ E L d ❑ a bD ac U GT. -60 Change company name Change process or equipment ) .C O ❑ Transfer of ownership Change permit limit a CO O E a) O u L CO C a) O L a) 'O a) ;I Cs .0 an E O y 7 C" a a) 0 CO O Z 0 0 0 O .0 a) a) a) U u C 0 a) O a z d O' a ®❑ on 1.0 O 3 N w 0\ N 00 00 Denver CO 0 N C C 0 9 a) 0 C 0 N S a) CO a) CO C a) CO CO CO 0 C 0 04 (720) 876-3884 Phone Number 00 L e CO Person To Contact: 0 O a) 0. O S 9 a) 0. O a.) oD C O .0 U 0 0 E 1 N at a) ate) 174z Section 03 — General Information N 00 For new or reconstructed sources, the projected startup date is: N 3 COC 0 o 'O CO 0 r CO T a O C 0 L O L N►�i Don't know 0 0 0 0 x ..V 0 0 O O A A A A z z zzz ❑ ® ®❑® a) v) O 0 a. -0 CO .0 .o C 0 0 0. a 0 '5 a U0. 6) a) 0 0 0 y VD C O 0 0 CA. 0 v) •.- v y. U � x -o ct 0 a) 0 0 w z C7 Q CO U CO 0 0 N � ® O ❑ ® ❑ as T L • a) a t) 0 CS U C 0 W c ww O 0 V1 a 00 0 C a) C O A 12. ed`' C o a) > xA v L 7 +' C 0 oU C o = CO O a A 0 a O L O 0 N N 0 •0. C. 'et., QW,. U 4C-i a+ 7! U C Cr) w oD O L U E z z 0 ER 3 ."'vi ` aci .7 CO ° For guidance on how to complete t 0 O 00 V1 vl M M M N N N O CD CD en en en 0 0 0 en en en O Pct O oD 0 v •N C d U N ❑ v 0 .0 o icra a7, Q c.) E -o O O 0 cal Cl CO O U CO C pLU lb.0 c .� a w, > C 11-. ,0 .2 C O O }' v 9 2 X 0- a.)-- E a) a 4 al w p a) •v 00 o C Cn Od ODD O O ai m O.0 CO CO U U W C � 7 a. a� 0 O O .0 CL A O m a 0 CO 0 -O CO U a 0T U a) •C C1. 3 `0� T n ° 3 a O i.b -d a) ° \ ry w a) C -oP_U 04 L a) U .--. TJ ti 0 6 0 ~ 0 O �... W rn J U W C.2y W m 0 O O .d u. E v b E [o .� .C Ec rn -o cC O O y d mob o ��'zz CO> w C.C�0 O p O y c/] U .3 1° .� o oD 70 0 O' > w m : ai GL cod o 0 o aa) aa) 0 X y v z O. 7 a, P4 O U C .a T C 0 o 0 r,.) - O y a) O COcn C '40 U N 0 i u at y C-, .o a-0 o O O ,-. a) 0 ) a al ,2 CO o 0 ._ > TTC E CCI o. CO o C � t° tEi 7•�:C� td)�,��,= CO ul C CO a° N' C c o a)-0 U 9 y.0 .N u^O O O c7d 0 A. O a s A'. O L vi C 0 0 N -a N -/C gma C T b CO N y >. ›.. >" I y..C 0 a m u CO 3 0 A ♦ A.♦ c Condensate Product Loaded: Y u \ 0 a0 CI 0 L O C O CO L a) Tank Trucks This product is loaded from tanks at this facility into: Pump Capacity in Each Bay: Number of Loading Bays: a) v ian � ° •c 3 oU O U y O a E 0 U L d L CO C 0 .0 00 .0 O u O N y„� N d O `) r �a a ^O ca m r, 0a.) a.) a O > ,a,/) W 0 CO •0 as .a .0 CO an 0 z 1�1 d r C N 0 •0 O 0 ..a b C C a�+ O a) L C. a) a) CO NL 0 CO w C 0 O C CO 00 w 00 True Vapor Pressure: Cn 0 w a) a) 0- 0 U CO OO C 0 O a a) d a .0 0 a) H O O a O L CO z .0 0 0 x a) W U C O Actual Calendar Year: C 0 a) C 0 O U O O 0 C w =o a) C o) a) anu— C 0 C ♦ a 0 42/ch05/index.hti C) C -0 0 a) Ca 0 0 0 "O C 0 c u � ti V O ≤v U U w 0 0 T � U c � o g c ti o ` 5 a O • Ew° c 4 N .c _ °' 0 o d hw 3N•"C) a 0 Ti 0 > C 'O w O y v a) FL, CC 2015.06.06_APEN_-_Hydrocarbon_Liquid_Loading_ _Dale_20H-O264_Battery.docx drocarbon L Permit Number: Datum & either Lat/Long or UTM ion) Location Section 06 —Stack (Source, if no combu Section 05 — Stack Information (Combustion stacks must be listed here) F^ o 0 N N L d0 O 0 o j d0 Z. C y 0O •0 N 0 4 Z C o H E 7 ste H E M 2,0 Q ' 0.0 00 o3O N x • 00 00 tn .--i 01 O Other (Describe 0 0 0 CO 0 0 N O ith obstructing rainca CO 0 >® a) 0 a) cu e s 0 . 0) co N d L 0.1 CU N oo C CO E X N w a 0 0 O y 0 00 a) I.-0 W Width (inches) = Other: Length (inches) = 00 Circular: Inner Diameter (inches) = Section 07 — Control Device Information 7 fo 0 CO 0 0 On a 0 CO 7,5 4. 0 0 0 0 4-4 0.0 I- 0 A c 0 0 a E 0 Enclosed Combustor 00 Manufacturer Guaranteed: 0 y On a 0 0, Control Efficiency: H > v, O a) 0 r control of the to cu cn 0 ❑ Vapor Recovery U Make/Model: 0) N Waste gas heat con w 0 Minimum temp. to achieve requested control: Pilot burner rating: O z on r1" Constant pilot light? Section 08 — Emissions Inventory Information & Emission Control Information a) U 0 Q Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Emission Factor Documentation attached Estimation Method or Emission Factor Source AP42 AP42 N Q AP42 AP42 Please use the APCD Non -Criteria Re ortable Air Pollutant Addendum form to re ort ollutants not listed above. Requested Permitted Emissions5 Controlled (Tons/Year) 2.79 o F -. 1 N O c 0.07 Uncontrolled (Tons/Year) 55.90 L 0.41 1.30 Actual Calendar Year Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units 40 .„.0 'S .0 .0 Uncontrolled Basis CO II) rdO 0 o 0 0 O 0 0 O © 0.0037 Control Efficiency (% Reduction) Identify in Section 07 Control Device Description Secondary Primary Pollutant DOA xON CO Benzene Toluene Ethylbenzene Xylene n -Hexane 0 O° N � O ti 7 0 0. O v U S. •o .5 N 0. ti C 0 w C owo o C 0) 0 0 C E O 00 -0 U 0 C. 3 2O o E g 0,22 N y .0 O N y L E 3 � E ,- 0 4L ,4 -c) g cd C a c Section 09 -A C 0 a. 0) En R 0 w a) 0. b • N 0 by a) 0 0) 0 z 2015.06.06_APEN_-_Hydrocarbon_Liqu id_Load ing_-_Dale_20H-O264_Battery. docx N O N a) b0 CO 0. onent Leak Emissions AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Fu Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] A Cri Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source Request MODIFICATION to existing permit (check each box below that applies) o a5 b U U U zC4 Change company name a) O Transfer of ownership ❑ ❑ Change process or equipment Change permit limit ❑ ❑ 3 00 Request to limit HAPs with a Federally enforceable limit on PTE Request APEN update only (check the box below that applies) ❑ ❑ N 00 00 Denver , CO ❑ ❑ E O O Person To Contact: CO C O • O 0 W ▪ z Section 03 — General Information — O N N For new or reconstructed sources, the projected startup date is: For existing sources, operation began on: CO O go T E a� a• ' d E O N w y O x .y a) 3 E v W d ≥ 0 w ro N 0 0 eV N Normal Hours of Source Operation: Brief description of equipment associated with these components: O z cn 0 ad C O L 0 W O C R .0 CO d O 0 0 a o. a) E A, 0 O CO 0 0 U _` a) 0 37., CO • aE z • LTAtt.cy U cn U O. UO O w O tall 0 n G n CO a)) Q) vi 3 >•• E o E C N O' O w ▪ >' cu > > w � 0 — C o a)0a cci a) 0 • 0. • • N U 0 O d o — 0 0 n0 ' vi�N- r M M M N N N C) ON C) 0 ac j en M M G e 000— E 8. PQ .}2 n { For guidance on ho U O 0 r2 a) 0• .FA 00 Q APEN forms: http://www.cdphc.state V C. C. C 0 CO 0. Q ❑ 0 0 0 Q.ki�X ❑ ❑ O 0 z z ® ❑ ❑ z CO L O C C .CO c�0 ^ 0 C cn C Z O � f CO O • J C )) 'O a) i ti .fr Information Section 04 — Re Is this equipment subject to NSPS 40 CFR Part 60, Subpart KKK? Is this equipment subject to NESHAP 40 CFR Part 63, Subpart HII? Subpart that applies to this equipment: List any other NSPS or NE Section 05 — Stream Constituents 2 a) cn a) O 0. CO .C CO 0 O C y C 0 U `S) U O Y b n -Hexane (wt. %) II LS'I i CV N • Xylene (wt. %) 0.07 C,, O Ethylbenzene (wt. %) p ,_. Toluene (wt. °/u) o --• Benzene (wt. %) 0.12 . 0.37 . 0� • N 1 o : Stream Gas Heavy Oil (or Heavy Liquid) Light Oil (or Light Liquid) Water/Oil Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. El El C 0 CO C U CO U C 0 N cu O cn C 0 H C C U C N T CO b V b C y O C Cr' 'LJ CO CO CO CO C a) C) CO E ci) 2015.10.23_Sprague 9H_Fugitives_APEN.docx N W O a) 01) CO OO /�\O WM v � Cr) C) FORM APCD-203 onent Leak Emissions Pzo CID RI a U i.i too tt F F 0 V1 Emission Source AIRS ID: Permit Number: & Control Information i.i Section 07 —Leak Detection & Re Section 06 — Location Information (Provide Datum and either Lat/Long or UTM) Check appropriate boxes to identify LDAR program conducted at this site: .a 0 z LDAR per NSPS 7 Section XVII O .. O ..o 0 a 3 (.j U o0 td)a L4 .E 0 o O • G o • E E L.z>, a) a> . o SD 0 0 D ® 0 a en - 8 t oil o U o • N U t2 on o ca 0 C QA a ▪ •o 0 - r CO OL 0 0 '� O y 00 2 00 'UO O • 0 Z 110 H 15 o �•. ' Ha E E -104.897644 cn .— U H o O ANN ❑ ❑ Section 08 — Emission Factor Information a) Y V .0 u o .0 L u C O E r U C u 0 'O C 0 • C C U a C o a o E • E U y R bq H • 41 o w C • E O w O a) .y O onW .E y • � a 4 a U an a u o � c C h wa U rA • Q C W O E ,) id N O -0 • U • 0 o 4 • x O o L A U C b❑ a) CID a O U lb/hr/component lb/hr/component lb/hr/component lb/hr/component lb/hr/component C C 0 E O U N O O O O O 0 O O O 0 O O O 0 0 N O O N O 0 O N N O 0 O 0 O 0 0 CO 0 o a, N en N en en Q w 0 CO U xC O U .C lb/hr/component lb/hr/component lb/hr/component lb/hr/component lb/hr/component lb/hr/component rIO V LI. N N O 0 O O M 0 0 0 O an m O O 0 O Vl an 0 O 0 0 0 O U 0 N N O N N N N CA O N N N Equipment Type Connectors 00 FL: Open -Ended Lines 0 c) E C a) U 0 0 0 U dE W 'Count shall be the actual or estimated number of components in each type of service used to calculate the "Actual Calendar Year E Section 09 — Emissions Inventory Information & Emission Control Information Data year for actual calendar year emissions below (e.g. 2007): U t u C O CO c E C u 0 L C CO Estimation Method or Emission Factor Source EPA Tbl 2-8 EPA Tbl 2-8 EPA Tbl 2-8 �EPA Tbl 2-8 EPA Tbl 2-8 EPA Tbl 2-8 on -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions3 Controlled (Tons/Year) W .o ter. Uncontrolled (Tons/Year) 2.20 De Minimus 0 De Maimus De Minimus 4E o 0 A g0 A Actual Calendar Year Emissions2 Controlled (Tons/Year) Uncontrolled (Tons/Year) Emission Factor Units Identify in Section 08 Uncontrolled Basis Control Efficiency (% Reduction) Identify in Section 07 Please use the APCD N Control Device Description a 0 N cip Primary Pollutant VOC Benzene Toluene ' Ethylbenzene n -Hexane N 0) en CI) .C C O 'O U ea .0 .0 C 0 N .0 cd a) a 0 o o �a- H C U a ZS' o a) E er aa) a > o Q 'L U .. U Caa O co � U o o E 0 0 .71 .E o U N 7 U 8 a a•C, O a 0 O E O O p E U y w a C • O 7 o ▪ C ra licant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Section 10 —A er, Air Permittin CO CO Adam Beri i Name of Legally Authorized Person (Please print) zed to Supply Data of Person Legally 2015.10.23_Sprague 9H_Fugitives_APEN.docx drocarbon [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] O RI O 14 V r.4 0 Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request for NEW permit or newly reported emission source 0. O. C 0 Ca s 0 0 .c 0 s E d O. lot C a z O U A O m 7 Cr A Change company name O O Transfer of ownership ❑ ❑ Change process or equipment Change permit limit ❑ ❑ Request to limit HAPs with a Federally enforceable limit on PTE ® ❑ ❑ ❑ o ni b UU U Z N N .ti 00 0\ 0 00 g 0 0 o c° U U O a. W N Denver CO J, 7 O > a) L O ¢ eu 0 c .Y C a O 0..� '� a) C G1. s 3 C ° o a 0 a' 00 o a .0 k V) 00 .0 • aI .-7.y O X >, 3 s -0 V .vi C C U W v 0 0 a ❑ o O .0 U O . E 0 a �', a„ Z o 0 0 a ; b o d V 0 cr O A ❑ ❑ w d • O •"5Z d� Person To Contact: Section 03 — General Information 0 N N For new or reconstructed sources, the projected startup date is: For existing sources, operation began on: Don't know Don't know Don't know O O OOO z z ZZ z U U V) N Vl a) a) VOW 5. J- c• CU O id 0 d R. v at y 0 a rQ U 4-, O 0 � a CCd MI 00 � N V N X a) U N a 0 .0 0 '17 T a. o 0 o at 5.,'O d .C v 0. cd 7 ti _.-z, c-• H 00 C O U-. 0 s.. 0 r• T. rNa ,b cuo U IU o ti -. -O 0 0 7 U R1 O O t, 0 o 0 CCICa 0 0 0 f/ O] E 0 0 p 0 o L-. 0 0. o� CO CO N xer C d0 0 0 00 0 0 ' P C oC O U C/D rzt O O CY FA O . NO a) El'"QCl O Z C N 0 C G1 00 .0 >O 0 G 00 o s' .d 9 o 7 •' 4, a a 0 0 • o CO o .6. O" 'O 0 a) s 0 v c ea o as cu o c.) y -E U O 9 0 0 -oo C.) a 7 T T 0 4-i -Oo "0 0) -01 N -,3 C 0 • a) C C 0. C Normal Hours of Source Operation: c7 ♦ IS tr." ttO v x O y U 0 O CO 0 7 r O a C R � 7.; CO 0 0) C 4) C O A w c a R C o Ca xA o C C O E 7 L O �a AQ 0 0 Ca L O 0 U V U Q) 00 0 on CO X19. 3 '7 cC O U EL) tin y .0 0 0 cu o 12 O •CO U C O R. U � CO ..0 H o 9 O o 9 000N -- M M M P. w - CV C k.. C G M M M C = o 0 0 O O m M C a `.0 a c ea. . I) .7 V o au tO o ¢ o o o Mail this form al ti vi vU 3 C) a. Y W > O 0 O C G. 0 O 1,5 a; -Op b N od U acla go R R a a f-' U O 'P- o O C) N y C 0 O -J R yL U U U O O o c C .Oo .0.0o c 000 bo C O E C) U U O o 0 0 O u 0 U Y . Y _U n. C C cC G 0 C HI C Ca 0 C 0 C.) Condensate Product Loaded: Tank Trucks This product is loaded from tanks at this facility into: 9 0 O OA Pump Capacity in Each Bay: Number of Loading Bays: 0 9 T .0 00 O N r 00 E• E -. L a) d O cd .0. to N True Vapor Pressure: C U CO E 0 H O T al I _O O L 0 L w W .C a) tG a� bD u C 6. .0 a.) .. It MU ;5 T a•[ - 0 0 A U U r9 0 > C V 0 G=4 0 > 2015.10.23 APEN_-_Hydrocarbon Liquid_Loading_-_Sprague_9H-N267_Battery.docx 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) .O 0 6.3 O O O O o � .54)'4 o 0 O zi E N 0 O OD tu c61) .77 • O W C a . • E -104.897644 • E Nv ti OO 00 '0 4) g E H C) 01) CO 0 u �Qa^ •O N O 411 .tAxL. 0 eT 0 0 Other (Describe): O Q O 0 ❑ O Width (inches) = 0 Vertical with obstructing raincap Other: Length (inches) = 00 Ve !k one): El Direction of stack outlet (check one): Section 07 — Control Device Information Section 08 — Emissions Inventory Information & Emission Control Information a) U a) Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Emission Factor Documentation attached O • O N W N N N V' N CV CV - rJ m 00 OO U H N • t) 0 O O N 0 N 0 00 7 Actual Calendar Year Emissions4 Emission Factor .0 .O .O .O .O .O 715 Uncontrolled Basis N 0 N O M O O O O 0 rr a en tin O O O 0 0 C O 3C a C o 4) 4) Q 00 0 , b " 674 0 a g N z 0 a U 0 0 U a) C N 0 C.) oa a) C) O O H C N C .O V C V V C -I O .O 0 O d O C C O 0.. 0 O. 4) O E w E O C 4) Q 0 O 7 O 44 0 a R 4) U C O z A U a d 4) .O y 0 a) 4) 0 4) s. O u L 4) a E 0 U 0 C▪ O u a 44 .0 '0 4) 4- E .0 O 0 acv E 0 G b C 44 C L 4) ^G O) C 44 a O u G 0 C4 E L 0 C R 44 r L a) C.1 0 4) s licant Certificatio Section 09 —A Adam Beri Name of Legally Authorized Person (Please print) 2015.10.23_APEN_-_Hydrocarbon Liquid_Loading_. _Sprague_9H-N267_Battery.docx 0 N 4) O Hello