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Home My WebLink About20161672.tiff A CDPHE COLORADO CO Is Department of Public ,,,• Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado RECEIVED Weld County - Clerk to the Board 1150 O St MAY 2 6 2016 PO Box 758 Greeley, CO 80632 WELD COUNTY COMMISSIONERS May 20, 2016 Dear Sir or Madam: On May 25, 2016, the Air Pollution Control Division will begin a 30-day public notice period for Encana Oil Et Gas (USA) Inc. - Gurtler Horizontal Pad . 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, a Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 2016-1672 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe k� 1O,, IFI +.o� John W. Hickentooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer 1. „, b(iu/R.tvc•cw ee: PL, HC-fL-�i) 5/�(v ' �c 1 f6t,' A CDPHE Air Pollution Control Division CO os Notice of a Proposed Project or Activity Warranting Public TS, Comment Website Title: Encana Oil a Gas (USA) Inc. - Gurtler Horizontal Pad - Weld County Notice Period Begins: May 25, 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 Ft Gas (USA) Inc. Facility: Gurtler Horizontal Pad Oil and gas production facility NWNW Sec. 30, T2N R64W Weld County The proposed project or activity is as follows: Applicant will operate an oil and gas production facility that will vent gas from a low pressure separator. All gas will be controlled by an enclosed combustor. 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): • 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 16WE0076 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I AVeo�.oaaao riFAaF s1¢s�mxrt. w Ill A STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �� a AIR POLLUTION CONTROL DIVISION c,- * __ TELEPHONE: (303)692-3150 " *1876' CONSTRUCTION PERMIT PERMIT NO: 1 6WE0076 Issuance 1 DATE ISSUED: ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Gurtler Horizontal Battery, located in the NWNW of Section 30, Township 2N, Range 64W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID LP Low-pressure separator controlled by enclosed combustors. Separator 006 Combustors have a minimum control efficiency of 95%. 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 A, 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. Within one hundred and eighty days (180) after issuance of this permit, the operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented from each low pressure separator. The operator shall use the gas flow rate listed in the AIRS ID: 123/9B7E Page 1 of 8 Wellhead Version 2012-1 ..... !w...w....v nA+*xTMe m,-«'*w*n `Wu+*i+usrt+Vsw._Y.k+r( ^il+*tNY'F W.^ my .,..w.re -nr .^t- nzpe2' 3 tr.w•.ewr•-+-4 +N+'+'rxw*nt'e Twhartw.a- .a+++ +-wM�. a `_^:4 _�..W i:.. ,:f5m! Ye.-.. 4. 11, 1 olo{ �, De ent f Public Health and Environment Air Pollution Control Division application for actual flow rate until the flow meter is installed, not to exceed one hundred and eighty (180) days after issuance of this permit. 4. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 5. 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.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO. VOC CO Emission Type LP Separator 006 --- 9.7 2.1 Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air collutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 8. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) AIRS ID: 123/9B7E Page 2 of 8 li I olo De !, ent f Public Health and Environment Air Pollution Control Division Facility AIRS Pollutants Control Device Equipment ID Point Controlled LP Separator 006 Enclosed Combustors (LEED High Capacity) VOC, HAPs PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point LP Separator 006 Natural gas vented from separators to 6.8 MMscf/yr enclosed combustors The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. Upon installation of the flow meter required by this permit, the owner or operator shall continuously monitor and record the flow rate of natural gas vented from the low pressure separator using a flow meter. The flow meter shall continuously measure flow rate and record total volumetric flow vented from the separators. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits specified and to calculate emissions as described in*his permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.) 13. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your AIRS ID: 123/9B7E Page 3 of 8 olo ;:1 De ent 3f Public PollutionHealth Controland DivisionEnvironment O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The operator shall comptlete an initial site specific extended gas analysis within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC (weight fraction) of this emission stream. Results of testing shall be used to calculate site-specific emission factors for the pollutants referenced above (in units of lb/MMSCF gas vented) using Division approved methods. Results of site- specific sampling and emissions factor analysis shall be submitted to the Division as part of the self-certification and demonstrate the emissions factors established through this initial testing are less than or equal to, the emissions factors established in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this sampling and analysis is greater than the emissions factors established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, a request for permit modification to update emissions factors and emissions limits specified in this permit. ADDITIONAL REQUIREMENTS 16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non-criteria reportable pollutant: If the emissions increase by 50°/p or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS AIRS ID: 123/9B7E Page 4 of 8 �� R oio . De, entf Public Health and Environment Air Pollution Control Division i n 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a k permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer AIRS ID: 123/9B7E Page 5 of 8 De ent f Public Health and Environment Air Pollution Control Division Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. Synthetic minor facility AIRS ID: 123/9B7E Page 6 of 8 olo4 De g ent f Public Health and Environment 111 Air Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reqs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 830 Yes 41 Toluene 108883 1178 Yes 59 006 Ethylbenzene 100414 225 No 11 Xylenes 1130207 470 Yes 23 n-Hexane 110543 10851 Yes 543 5) The emission levels contained in this permit are based on the following emission factors: Weight Emission Emission Fraction of Factors Factors CAS# Pollutant Gas (%) Uncontrolled Controlled Source (lb/MMscf) (Ib/MMscf) NOx --- --- 133.74 AP-42/HYSYS CO --- --- 609.68 AP-42/HYSYS VOC 61.42 56717.19 2835.86 71432 Benzene 0.13 122.13 6.11 108883 Toluene 0.19 173.45 8.67 HYSYS Version 1330207 Xylenes 0.07 69.12 3.45 8.4 110543 n-hexane 1.73 1597.46 79.87 Note: The uncontrolled VOC and HAP emissions for this point were calculated using the April 4, 2013 pressurized liquid sample analysis (collected from the Gurtler 2A-30H well) modeled through HYSYS. Separator operating conditions were 40 psi/110°FThe controlled VOC and HAP emissions factors for point 006 are based on the flare control efficiency of 95%. AIRS ID: 123/9B7E Page 7 of 8 olo De jj ent f Public Health and Environment Air Pollution Control Division 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT r 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: 123/9B7E Page 8 of 8 Colorado Air Permitting Project Project Details Review Engineer: Bradley Eades Package#: 342897 Received Date: 1/12/2016 Review Start Date: 1/21/2016 Section 01-Facility Information Company Name: Encana Oil&Gas(USA)Inc.. County AIRS ID: 123 Plant AIRS ID: 987E Facility Name: Gurtler Horizontal Physical Address/Location: NWNW Sec 30,T2N,R64W Type of Facility: Exploration&Production Weil Pad What industry segment? Oil&Natural Gas Production&Processing, Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? ❑Carbon Monoxide(CO) ❑Particulate Matter(PM) ❑r Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRs Point# Emissions Source Type Permit# Issuance# Action Engineering Remarks Control? Required? Permit initial 006 Separator Venting Yes 16WE0076 1 Yes Issuance Section 03-Description of Project Gurtler Horizontal is an E&P wellsite with current production from two(2)wells.Gas and liquid enter a 3-phase HLP separator.High pressure gas is sent to sales while low pressure gas is routed to an enclosed combustor for control.Condensate and produced water are also separated out and stored in respective tanks(also controlled by enclosed combustor). This site has been in operation since March of 2013 however the site was previously setup to route gas from the LP separator to sales via VRUs. Encana indicated that based on economic feasiblity and other factors,Ericana has removed the VRUs from the site and are now routing all LP gas to an enclosed flare.A meeting was held with Adam Berig,Paul Buck and Mike Cugnetti of Encana on 4/19/2016 to discuss the facilty design and monitoring strategies.Encana indicated that the site will be retrofitted with a meter to monitor gas throughput to the combustor from the LP Separator. k r Section 04-Public Comment Requirments Is Public Comment Required? Yes;;, If yes,why?1 Requesting Synthet€c Minor Permit Section 05-Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,explain what programs and which pollutants here: Title V Operating Permits(OP):VOC,n-Hexane Non-Attainment New Source Review(NANSR):VOC Is this stationary source a major source? No If yes,explain what programs and which pollutants here: One low-pressure separator controlled by enclosed combustor(s).Combustor has a minimum control 006 efficiency of 95%. Equipment Description This source vents natural gas from: a well head separator Emissions from this source are: routed to a flare Natural gas venting from a well head separator.Emissions from this source are routed to a flare. E Calculations Emission Calculation Method EPA Emission Inventory Improvement Program Publication:Volume II,Chapter 10-Displacement Equation(10.4-3) Ex=Q"MW"Xx/C Ex=emissions of pollutant x Q=Volumetric flow rate/volume of gas processed MW=Molecular weight of gas=SG of gas"MW of air Xx=mass fraction of x in gas C=molar volume of ideal gas(379 scf/lb-mol)at 60F and 1 atm Throughput(Q) 6.79265 MMscf/yr 775.4166667 scf/hr MW 35 Ib/Ib-mol 0.01861 MMscf/d mole% MW lbx/Ibmol mass fraction lb/hr lb/yr tpy Helium 0.00% 0.0000 0.00 0.00 CO2 2.38% 1.7043 14929.49 7.46 N2 0.07% 0.0501 439.10 0.22 methane - 13.79% 9.8748 86503.23 43.25 ethane 22.26% 15.9400 139634.66 69.82 propane 34.48% 24.6906 216289.45 108.14 isobutane 5.04% 3.6091 31615.39 15.81 n-butane 12.43% 8.9009 77972.09 38.99 isopentane 2.58% 1.8475 16184.07 8.09 n-pentane 2.96% 2.1196 18567.77 9.28 cyclopentane 0.00% 0.0000 0.00 0.00 n-Hexane 1.73% 1.2387 10851.01 5.43 cydohexane 0.00% 0.0000 0.00 0.00 Other hexanes 0.00% 0.0000 0.00 0.00 heptanes 0.86% 0.6158 5394.69 2.70 methylcyclohexane 0.00% 0.0000 0.00 0.00 224-TMP 0.13% 0.0921 806.80 0.40 Benzene 0.13% 0.0947 829.60 0.41 Toluene 0.19% 0.1345 1178.20 0.59 Ethyl benzene 0.04% 0.0257 225.10 0.11 Xylenes 0.07% 0.0536 469.50 0.23 C8+Heavies t 0.78% 0.5567 4876.32 2.44 VOC mass fract 0.6142 Total VOC(Uncontrolled) 192.63 Notes MW and mass fractions from HYSYS model.Encana used a pressurized liquid sample collected from the LP dump to tanks,and a sales gas sample collected from the HP Separator both at the Gurtler site.The model creates a combined gas/liquid stream upstream of the HLP Separator and vanes the temperature until the known stream compositions(sampled)are met.The operating conditions of the LP separator in the submitted model are 40psi/110F.Emissions are based on 8760 hours of operation per year. 16 W E0076.CP1.xls m One low-pressure separator controlled by enclosed combustor(s).Combustor has a minimum control 006 efficiency of 95%. Flaring Information Equipment Description Flare to combust low-pressure separator gas during VRU downtime. Manufacturer LEED Model High Capacity Serial Number *Gas Heating Value 1966.7 Btu/scf Throughput 13359.10476 MMBtu/yr *Gas HHV from HYSYS is 7.460E5 Btu/Ibmol.Calculated based on 379 scf/Ibmol VRU Information ALL VRU HAVE BEEN REMOVED FROM THIS PROCESS Equipment Description Make Model Requested Control Efficiency Annual Bypass Time Backup Overall Control 95.00% Combustion emission factor source: AP-42:Chapter 13.5 0.07 IIb NOX/MMBtu 0.31 Ilb CO/MMBtu Emissions Summary Table Pollutant Uncontrolled Emission Factor Controlled Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 56717.19 lb/MMscf 2835.86 lb/MMscf 192.6 tpy 9.63 tpy HYSYS Nox 133.74 lb/MMscf 133.74 Ib/MMBTU 0.5 tpy 0.5 tpy AP-42/HYSYS CO 609.68 lb/MMscf 609.68 lb/MMBTU 2.1 tpy 2.1 tpy AP-42/HYSYS Benzene 122.13 lb/MMscf 6.11 lb/MMscf 830 lb/yr 41 lb/yr HYSYS n-Hexane 1597.46 lb/MMscf 79.8732 lb/MMscf 10851 lb/yr 543 lb/yr HYSYS Toluene 173.452 lb/MMscf 8.6726 lb/MMscf 1178 lb/yr 59 lb/yr HYSYS Xylenes 69.119 lb/MMscf 3.4559 lb/MMscf 470 lb/yr 23 lb/yr HYSYS Ethylbenzene 33.139 lb/MMscf 1.6569 lb/MMscf 225 lb/yr 11 lb/yr HYSYS Regulatory Applicability AQCC Regulation 1 This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity.' AQCC Regulation 2 Section I.A applies to all emission sources."No person,wherever located,shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven(7)or more volumes of odor free air." AQCC Regulation 7 Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? No This separator is not subject to Reg 7 Section XVII.G Notes: *A meeting was held at CDPHE with Adam Berig,Paul Buck,and Mike Cugnetti of Encana to discuss monitoring requirements for low pressure separators on 4/19/2016.Encana expressed concern over accuracy of meters for this process(on low pressure stream).Ultimately the Division has not received any field data that demonstrates the meters are incapable of gathering accurate information.As a result,Encana has agreed to install a flow meter to measure the volume of gas vented to the enclosed combustors.Since the facility will be retrofitting this equipment,the permit will allow for up to 180 days for installation of the meter. In the meantime,Encana is to use the vent rate indicated on the APEN(775.41 scf/hr)as the actual flow rate until the meter has been installed. *The wells serviced by this separation equipment began producing prior to August 1,2014 and are therefore not subject to Reg 7 Section XVII.G control requirements. *An initial testing condition to demonstrate compliance with opacity is not being required since enclosed combustors are a common control device with the condensate tanks(GP01)and are subject to a more stringent requirement due to other equipment(i.e.the ECD only controls vapor from the LP Separator). *A site specific sample representative of the gas vented from the LP separator at this site is being required to demonstrate that the emission factors developed through the HYSYS model are less than or equal to those calculated using the actual gas composition. The sampling location was discussed with Paul Buck who indicated that the sample will be taken from the meter location on the LP separator to combustor stream. It was communicated to Encana that the sample is intended to include only the portion of the waste stream attributed to the LP Separator. 16WE0076.CP1.xlsm COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Encana Oil and Gas USA Inc. County AIRS ID 123 History File Edit Date 5/9/2016 Plant AIRS ID 987E Ozone Status Non-Attainment Facility Name Gurtler Horizontal Pad EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Previous Permitted Facility tota/ 0.0 0.0 0.0 0.0 0.0 00 0.0 0.0 0.0 00 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 001 13WE2237 Loedout 8.8 0.5 8.8 0.5 002 GP01 8 Condensate Tanks(2800 BBL) 189.9 6.5 39O 0.3 003 GP05 Produced Water Tank 5.0 0.5 10.0 0.0 006 16WE0076 LP Sep Venting 192.6 6.8 0.5 9.7 2.1 0.3 0.0 0.0 o.a o.o o.o o.o 0.0 0.0 o.o 0.o 0.0 00 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 396.3 0.0 0.0 14.4 0.0 0.0 0.0 0.0 0.5 67.5 0.0 2.1 1.2 VOC:Syn Minor(NANSR and OP) NOx:Minor(NANSR and OP) CO: Minor(PSD and OP) HAPS:syn minor n-hexane HH:area 7777:Syn Minor Permitted Faci/Ny Total 0.0 0.0 0.0 0.0 0.0 3963 00 0.0 14.4 0.0 0.0 0.0 0.0 0.5 67.5 0.0 2.1 1.2 Excludes units exempt from pennds/APENs (d)Change in Permitted Emissions 0.0 0.0 00 0.0 0.5 67.5 0.0 2.1 Pubcorn 8 modeling inoti required based on PI chance emissions) Total VOC Facility Emissions(point and fugitive) 67.5 Facility is eligible for GP02 because<90 tpy (d)Change in Total Permitted VOC emissions(print and fugitive) 67.5 Project emissions less than 25/50 tpy Note 1 Note 2 Page 4 of 5 Panted 5/20/2016 F COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name Encana Oil and Gas USA Inc. County AIRS ID 123 Plant AIRS ID 9B7E Facility Name Gurtler Horizontal Pad Emissions-uncontrolled(lbs per year) POINTIPERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 13WE2237 Loadout 165 292 12 128 410 _ 0.5 002 GP01 8 Condensate Tanks(2800 BBL) 749 1100 292 651 9519 741 6.5 003 GP05 Produced Water Tank 264 - 832 0.5 004 GP02 GM Vortec 5.7L NA 0.0 005 GP02 GM Vortec 5.7L NA 0.0 006 16WE0076 LP Sep Venting 830 1178 225 470 10851 6.8 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL1Jtpy) 0.0 0.0 0.0 1.0 1.3 - 0.3 0.6 10.8 0.0 0.4 0.0 0.0 14.4 "Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls(lbs per year) POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 IMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 13WE2237 Loadout 165 292 12 128 410 0.5 002 GP01 8 Condensate Tanks(2800 BBL) 37.45 , 55 14.6 32.55 475.95 0 37.05 0.3 003 GP05 Produced Water Tank ` 13 42 0.0 004 GP02 GM Vortec 5.7L NA 0.0 005 GP02 GM Vortec 5.7L NA 0.0 006 16WE0076 LP Sep Venting 41.5 58.9 11.25 23.5 542.55 0.3 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 _ 0.1 0.2 0.0 0.1 0.7 0.0 0.0 0.0 0.0 1.2 5 16WE0076.CP1.xlsm E0076.CP1.xlsm 5/20/2016 J _ 0 J 7 5 C :-`n Q f'•. 4 ^3 C C r - Ifl T 1.`— is —.O r .r J - l J Q. ❑ b C t ,� - C11 C.I r1 'r ` r ^I '� +L.. 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