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Home My WebLink About20152128.tiff A CDPHE COLORADO Irk 11 CoDepartment of Public • Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado RECEIVED Weld County - Clerk to the Board 1150O St JUL 202015 PO Box 758 Greeley, CO 80632 WELD COUNTY COMMISSIONERS July 13, 2015 Dear Sir or Madam: On July 15, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Encana Oil £t Gas (USA) Inc. - State 1 Hz . 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, _"/„.1'4,44_ Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure RUJO 2015-2128 ^aa-Is CC:Pc;?w; Ott, 7f o 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ry John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer / A CDPHE Air Pollution Control Division c Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Encana Oil Ft Gas (USA) Inc. - State 1 Hz - Weld County Notice Period Begins: July 15, 2015 Notice is hereby given that an application for a proposed project or activity has been submitted to the rof Colorado Air Pollution Control Division for the following source air pollution: Applicant: Encana Oil Et Gas (USA) Inc. Facility: State 1 Hz Oil and Gas Exploration and Production Facility SENE Section 16, T3N, R68W, in the vicinity of Mead, CO Weld County The proposed project or activity is as follows: The applicant is requesting to permit condensate storage vessels, produced water storage vessels, and condensate loadout operation at a new exploration and production facility. 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 applications, the Division's analyses, and drafts of Construction Permits 14WE0137, 14WE0138, and 15WE0516 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: Oluwaseun Ogungbenle 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 � rntr- • , a STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT , MA AIR POLLUTION CONTROL DIVISION y TELEPHONE: (303)692-3150 �� * *1876 6:* -/ PERMIT PERMIT NO: 14WE01 37 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 State 1 Hz Tank Battery, located in the SENE of Section 16, Township 3N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate Twenty-one (21) 400 BBL fixed roof storage vessels used to store Tank 002 condensate. Emissions from these storage vessels are controlled by an enclosed combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at 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. 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: 123/9C34/002 Page 1 of 11 Condensate Tank SM/M Version 2012-1 olor.A Depa en . - .Ii Health and Environment it Pollution Control Division permit applic..>° ,.•ci - .w ; - pe -iscon - - 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 AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type x Condensate 002 2.8 74.2 15.1 Point Tank See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Condensate 002 Enclosed Combustor VOC and HAPs Tank AIRS ID: 123/9C34/002 Page 2 of 11 olor_ Depa en P 41.li Health and Environment it Pollution Control Division PROCESS LIMITAT. N 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Condensate 002 Condensate throughput 269,296 BBUyr Tank The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XII. 12. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. AIRS ID: 123/9C34/002 Page 3 of 11 0 olorl Depa en . '' •Ii Health and Environment ' A it Pollution Control Division IP 14. The flare cov is i - 'je ' , elation, _ 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 15. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and AIRS ID: 123/9C34/002 Page 4 of 11 ettnz olor Depa ens P— IiclHealth and Environment F,. it Pollution Control Division XVII.C .. a40flib de i ed, i ction of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved AIRS ID: 123/9034/002 Page 5 of 11 olor., Depa en -'9..Ii 'Health and Environment •it Pollution Control Division i a u. -'1nt ni�., <-tee, m- pecti. - „n accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency >6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. AIRS ID: 123/9C34/002 Page 6 of 11 olor Depa Tied f P li .Health and Environment it Pollution Control Division OPERATING & M N 16. Upon issuance of this permit, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The operator shall complete site specific sampling including a compositional analysis of the pre-flash pressurized condensate routed to these storage tanks and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine a site-specific emissions factor using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7 Section XVII.AII) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 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 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. AIRS ID: 123/9C34/002 Page 7 of 11 olor- "„ Depa en . P 'Ii Health and Environment it Pollution Control Division b. When: e i-: th - -r ope of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR) 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 Parts C and D). 21. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 22. 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. 23. 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. 24. 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. 25. 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. AIRS ID: 123/9C34/002 Page 8 of 11 olor Depa en P li Health and Environment it Pollution Control Division 26. Each and ev & < ° io hi • it i ial pa eof 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. 27. 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. 28. 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: Oluwaseun Ogungbenle Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for condensate storage vessels at a Synthetic Minor facility. AIRS ID: 12319C341002 Page 9 of 11 Depa en . �.Ii b ill olor., Health' and Environment 4 it Pollution Control Division Notes to Permit Holder me o •e"�� an -. 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator prgviding 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. Uncontrolled Are the Controlled AIRS Emission Rate emissions Emission Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) Benzene 71432 9,319 YES 466 Toluene 108883 15,026 YES 751 002 Ethylbenzene 100414 1,443 YES 72 Xylenes 1330207 5,184 YES 259 n-Hexane 110543 67,455 YES 3,373 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors Emission Factors Uncontrolled Controlled CAS# Pollutant lb/BBL lb/BBL Source Condensate Condensate Throughput Throughput NOx 0.068 lb/MMBtu 0.068 lb/MMBtu AP-42 CO 0.37 lb/MMBtu 0.37 lb/MMBtu AP-42 VOC 11.02 0.55 Source/HYSYS 110543 n-Hexane 0.251 0.013 Source/HYSYS 71432 Benzene 0.035 0.002 Source/HYSYS 108883 Toluene 0.056 0.003 Source/HYSYS 100414 Ethylbenzene 0.005 0.0003 Source/HYSYS 1330207 Xylenes 0.019 0.001 Source/HYSYS AIRS I D: 123/9C341002 Page 10 of 11 olor Depa en P IicHealth and Environment it Pollution Control Division Note: The coy mi for • are on the combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, and total HAPs NANSR Synthetic Minor Source of VOC PSD True Minor Source MACT HH Major Source Requirements: Not Applicable Area Source Requirements: 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 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)OOXXX 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: 123/9O34/002 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 14WE0137 Source Name: State 1 Hz Tank Battery Source Location: SENE Section 16, Township 3N, Range 68W Equipment Description: Condensate Storage Tank AIRS ID: 123-9C34-002 Date: 08/07/2014 Review Engineer: Oluwaseun Ogungbenle Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X Initial Approval Transfer of Ownership APEN Exempt/Permit Exempt *If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first being issued an Initial Approval permit *Grandfathered exemption is for any tanks in service prior to December 30, 2002 Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? December 10, 2013 Section 4—Source Description AIRS Point Equipment Description 002 Twenty-one(21) above ground 400 bbl atmospheric condensate storage vessels. Emissions from these storage vessels are routed to an enclosed combustor. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section 111.0.2) Page 1 Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes"the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Section 5—Emission Estimate Information AIRS Point Emission Factor Source 002 Source provided site-specific emission factors using gas sample and HYSYS. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 002 323,155 BBL per year(269296 x 1.2) Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 Actual process data not provided N/A Basis for Permitted Emissions (Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 269,296 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 002 01 Enclosed combustor 95% Section 6—Emission Summary(tons per year) Point NO,, VOC CO Single HAP Total HAP PTE1: 002 --- 1780.4 --- 40.5 (n-Hexane) 59.1 Uncontrolled point 002 --- 1483.7 --- 33.7 (n-Hexane) 49.2 source emission rate: Controlled point z 002 2.8 74.2 15.1 1.7(n-Hexane) 2.5 source emission rate 2: 1. These numbers reflect a safety factor of 1.2 2. These numbers reflect 95%control applied to the uncontrolled(not PTE)source emission rate Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 N/A 9,319 Yes 466 Toluene 108883 N/A 15,026 Yes 751 Ethylbenzene 100414 N/A 1,443 Yes 72 Xylenes 1330207 N/A 5,184 Yes 259 n-Hexane 110543 N/A 67,455 Yes 3,373 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method VOC, Liquids Analyses 002 01 PS Memo 05-01 according to PS HAPS Memo 05-01 _ Section 9—Source Classification Is this a new previously un-permitted source? X Yes No P Y What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10—Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes",for which pollutants?VOC Why? For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 002 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II.A and B of this regulation. Regulation 2-Odor Section LA- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 002 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Page 3 I�- Regulation 3-'APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 002 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 002 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6-New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. Is this source greater than 19,800 gallons (471 bbl)? No 002 Is this source subject to NSPS Kb? No In addition to the fact that each of these storage vessels is less than 471 bbl, NSPS Kb does not apply to these storage vessels since they are located at an E&P site—prior to the point of custody transfer. NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. 002 For permitting purposes, this source is not subject to the requirements of this subpart because controlled actual emissions from each storage vessel are less than 6 tpy VOC. Regulation 7-Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non-attainment area.) 002 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this section since actual uncontrolled emissions are greater than 6 tpy of VOC.) Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic Liquids Distribution 002 This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH 002 This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Emission Pollutant/ Fugitive Emission Factor Control Description Factor CAS# (Y/N) Source (%) 262.3571 lb/1000 gal VOC No HYSYS 95 throughput 0.8240 Benzene/ lb/1000 gal 71432 No HYSYS 95 throughput 1.3280 Toluene/ lb/1000 gal 108883 No HYSYS 95 002 01 E&P Condensate throughput Storage Tanks 0.1273 Ethylbenzene/ lb/1000 gal 100414 No HYSYS 95 throughput 0.4580 Xylenes/ lb/1000 gal 1330207 No HYSYS 95 throughput 5.9644 n-Hexane/ lb/1000 gal 110543 No HYSYS 95 throughput Page 4 SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 002 Condensate Storage Vessels A permit will be issued because the uncontrolled VOC emissions from these storage vessels are greater than 2 TPY(permit threshold). Process Description The State 1 Hz Battery is an exploration and production wellsite. During extraction, the comingled stream enters a high-low pressure three-phase separator. High pressure gas from the separator is sent directly to the sales line. Low pressure gas from the separator(-35 psi) is routed to the vapor recovery unit and then compressed to the sales line. Water is routed to a storage tank. Condensate is routed to a storage tank (a storage tank is a single storage vessel or a series of storage vessels that are manifolded together via a liquid line). Vapors from both produced water and condensate storage tanks are controlled by a combustor. Water and condensate are removed from the site via tank truck. Page 5 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION (y ' TELEPHONE: (303) 692-3150 -t 1876,V CONSTRUCTION PERMIT PERMIT NO: 14WEO1 38 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 State 1 Hz Tank Battery, located in the SENE of Section 16, Township 3N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate 003 Truck loadout of condensate. Emissions from the loadout Loadout are controlled by an enclosed combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.ciov/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. 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: 123/9C341003 Page 1 of 9 Condensate Loadout TM Version 2012-1 Co i do i p e o Public Health and Environment 1 ID 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 9 ) Annual Limits: Facility Equipment Tons per Year ID AIRS Point Emission Type VOC Condensate 003 1.0 Point Loadout 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 AIRS Control Device Pollutants ID Point Controlled Condensate 003 Enclosed Combustor VOC and HAPs Loadout 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 rate shall be maintained by the owner or AIRS ID: 123/9C34/003 Page 2 of 9 it Col. ,..do i p e o 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 AIRS Process Parameter Annual Limit Point 003 Condensate Loading 323,155 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. 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) 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. 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 onsite at the time of inspections to monitor compliance with Condition 10 (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. 11. 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 12. Upon issuance of this permit, 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 AIRS ID: 12319C341003 Page 3 of 9 ilCo A do Bp e o Public Health and Environment Air Pollution Control Division 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.) 13. Flare shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 14. The owner or operator of a loadout operation at which an enclosed combustor is used to control emissions shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. g. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or AIRS ID: 12319C341003 Page 4 of 9 Co do p e of Public Health and Environment Air Pollution Control Division For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. 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 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. AIRS ID: 123/9C34/003 Page 5 of 9 ilCo A do I p e - o Public Health and EnvironmentI Ilk .. Air Pollution Control Division OW Mir 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. By: Oluwaseun Ogungbenle Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for condensate loadout operation at a Synthetic Minor facility. AIRS ID: 12319C341003 Page 6 of 9 Col do pa e o-Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# (lb/yr) reportable? Rate(lb/yr) n-Hexane 110543 965 YES 48 Benzene 71432 389 YES 19 003 Toluene 108883 688 YES 34 Ethylbenzene 100414 29 NO 1 Xylenes 1330207 302 YES 15 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/BBL Source Lb/BBL Source loaded loaded VOC 0.128 AP-42 0.0064 AP-42 Eng. Eng. 71432 Benzene 0.0012 Estimate 6.02E-05 Estimate Eng. Eng. 108883 Toluene 0.0021 Estimate 0.000106 Estimate 100414 Ethylbenzene 0.0001 Estimate E 4.49E-06 Estimate Eng. Eng. 1330207 Xylenes 0.0009 Estimate 4.68E-05 Estimate Eng. Eng. 110543 n-Hexane 0.0030 Estimate 1.49E-04 Estimate AIRS ID: 123/9C34/003 Page 7 of 9 Co A do P p e o Public Health and Environment Air Pollution Control Division 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) =4.62 psia M (vapor molecular weight) =45.3 Ib/Ib-mol T(temperature of liquid loaded) = 512.63 °R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a combustor efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor/Major Source of: VOC, n-Hexane, and total HAPs NANSR Synthetic Minor Source of VOC PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/9C34/003 Page 8 of 9 Co do p e o Public Health and Environment Air Pollution Control Division 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: 123/9C34/003 Page 9 of 9 Division Information Engineer Oluwaseun Ogungbenle Control Engineer: Chris Laplante Review Date: 04/09/2014 Application Date: 12/10/2013 Facility Identifiers Permit No. 14WE0138 County# 123 Weld AIRs Facility# 9C34 Point# 003 Section 01: Administrative Information Company Name: Encana Oil&Gas(USA)Inc. Source Name: State 1 Hz Battery SENE Section 16,Township 3N,Range 68W Source Location: In the vicinity of Mead,CO SIC: 1311 Elevation(feet) 5016 Portable Source? No Portable Source Homebase N/A Mailing Address 1: Encana Oil&Gas(USA)Inc. Address 2: Republic Plaza 370-17th Street,Suite 1700 Address City,State Zip: Denver,CO 80202 Name: Adam Berig Person To Phone: 720-876-3884 Contact Fax: 720-876-4884 Email: Adam.Berigfo encana.com AP-42.Chapter 5.2 Equation 1 L=12.46`S`P*M/T L=loading losses in lb per 1000 gallons loaded S=Saturation Factor P=true vapor pressure of liquid loaded[psia] M=molecular weight of vapors[lb/lb-mole] T=temperature of bulk liquid loaded[deg.R] 1 degree Fahrenheit=460.67 degree Rankine S 0.6 Submerged loading:dedicated normal service P 4.62 psia M 45.3 lb/lb-mole T 512.63 deg.R L 3.05 lb/103 gal 1.28E-01 lb/bbl Annual requested Throughput 323155 bbUyr Annual requested Throughput 13572510 gal/yr Annual uncontrolled VOC emissions 41425 lb/yr 20.71 tpy Annual requested VOC emissions 2071 lb/yr 1.04 tpy Regulatory Considerations Average daily(-37,185 gal/day)throughput will exceed 20,000 gallons.However,this facility is not condisdered a terminal(in Reg.7)... This facility is not considered a bulk plant(in Reg.7)because it does not distribute gasoline. NCRPs Component Wt.Frac. EF(lb/bbl) Emissions(lb/yr)Controlled emissions(Ib/yr) Notes Benzene 0.0094 0.0012 389.40 19.47 In order to estimate NCRP emissions,the op( Toluene 0.0166 0.0021 687.66 34.38 weight fraction of each component by the VO' Ethylbenzene 0.0007 0.0001 29.00 1.45 obtain the NCRP EF,the operator then multip Xylenes 0.0073 0.0009 302.40 15.12 the annual requested condensate throughput n-Hexane 0.0233 0.0030 965.21 48.26 AIRS(County/Plant) 123/9O34/003 Permit No. 14WE0138 Date 4/9/2014 Allowable Uncontrolled Emission Emisison Factor Emissions Point# Seg* SCC Pollutant or CAS Fug Dust Factor Source (tpy)* PTE(tpy)* Ctrl.Eff% 003 40600132 VOC n 3.05 lb/1000 gal AP-42,Ch.5,Eqn.1 1.0 20.71 95% 71432 Benzene n 0.02869 lb/1000 gal Eng.Calc. 19.47 389.40 95% 108883 Toluene n 0.050666 lb/1000 gal Eng.Calc. 34.38 687.66 95% 100414 Ethylbenzene n 0.002137 lb/1000 gal Eng.Calc. 1.45 29.00 95% 1330207 Xylenes n 0.022281 lb/1000 gal Eng.Calc. 15.12 302.40 95% 110543 n-Hexane n 0.071115 lb/1000 gal Eng.Calc. 48.26 965.21 95% NOTES *NCRPs are reported in'Ib/yr,'while criteria pollutants are in'tpy.' Benzene emissions from this loadout operation are reportable. This permit will be sent to public notice because emissions increase for this project exceed 25 tpy VOC in a non-attainment area. NCRP= reportable N/A Yes Yes No Yes Yes r STATE OF COLORADO .o los COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4 AIR POLLUTION CONTROL DIVISION TELEPHONE: (303)692-3150 /876,4%-/ CONSTRUCTION PERMIT PERMIT NO: 1 5W E051 6 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 State 1 Hz Tank Battery, located in the SENE of Section 16, Township 3N, Range 68W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point Produced Seven (7) 235 BBL fixed roof storage vessels used to store Water Tank 001 produced water. Emissions from these vessels are controlled by an enclosed combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at 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. 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 AIRS ID: 123/9C34/001 Page 1 of 11 Produced Water Tank SM/M Version 2012-1 I olor.i Depa en . " .li Health and Environment 'it Pollution Control Division of eighteen . -. (i - -. n `--." r-te c._- ction 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 AIRS Tons per Year Emission Type Equipment ID Point NO. VOC CO Produced 001 --- 2.8 --- Point Water Tank See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit(Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Produced 001 Enclosed combustor VOC and HAPs Water Tank PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following processing rate as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and AIRS ID: 123/9C34/001 Page 2 of 11 Diu r m-s ^ olora Depa en P li Health and Environment it Pollution Control Division made availab Di ec requ (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Produced 001 Produced water throughput 424,011.4 BBL/yr Water Tank 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. 9. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). These requirements include, but are not limited to: XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii) All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve- month total must operate air pollution control equipment that achieves an AIRS ID: 123/9C34/001 Page 3 of 11 a ill olor 3 Depa ens• ill Health and Environment it Pollution Control Division avera• I art.= o .- -ici , •'%. If bustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual, olfactory ("AVO") and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii) Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv) Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). AIRS ID: 123/9C34/001 Page 4 of 11 olor ;,Depar ` enef P •Ii =Health and Environment I it Pollution Control Division XVII.C.2.b. O , o•, •r` e,0 raged, >ubjecUolfbe control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency >6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section XVII.C.1.e. AIRS ID: 123/9C34/001 Page 5 of 11 olor. Depa en ' •li Health and Environment A it Pollution Control Division XVII.C T -- d: :' ation e owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 14. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance. This source shall meet the requirements to apply RACT and reduce emissions by installing and operating an enclosed combustor (Reference: Regulation No. 3, Part B, III.D.2.a). OPERATING & MAINTENANCE REQUIREMENTS 15. Flares shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 16. If a control device is used to comply with the emission limits of this permit, the following conditions must be met: a. Leakage of VOCs to the atmosphere must be minimized as follows: (i) Thief hatch seals shall be inspected for integrity annually and replaced as necessary. Thief hatch covers shall be weighted and properly seated. AIRS ID: 123/9C341001 Page 6 of 11 olor %Depa en f Pi,ill Health and Environment it Pollution Control Division (ii) e r- a ARV :- insp= for proper operation annually and replaced as necessary. PRVs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. (iii) Annual inspections of thief hatches and PRV shall be documented with an indication of status, a description of any problems found, and their corrective action. 17. Control devices shall be adequately designed, and operated and maintained according to manufacturer specifications to achieve a control efficiency of at least 95%, and to handle reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable. 18. The owner or operator shall monitor and document the proper operation of the control device. Time intervals between monitoring shall not exceed 14 days. Indications of improper operation for a flare include, but are not limited to, absence of pilot light, malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for recording proper operation. Improper operation of a control device shall be further documented with a description of the problem and its corrective action, the date range the control was inoperable, and the produced water production through the battery during the downtime. If the owner or operator cannot document the date that the control equipment became inoperable then downtime shall be assumed to have started directly after the last documented monitoring event. During control device downtime, emissions shall be considered to be uncontrolled. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one (1) minute in any fifteen (15) minute period during normal operation. (Reference: Regulation No. 7, Section XVII.A.II) Periodic Testing Requirements 20. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 21. 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 one hundred tons of VOC or AIRS ID: 123/9C34/001 Page 7 of 11 olor.i Depa en . - .ill Health and Environment it Pollution Control Division NO, p �. -�, a -- -1, - .-R u -missi- if 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. 22. 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 23. 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. 24. 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. 25. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. AIRS ID: 123/9C34/001 Page 8 of 11 olor Depa en f P li Health and Environment it Pollution Control Division 26. Unless specifi , :7 ed g d spe onditions 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. 27. 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. 28. 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. 29. 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: Oluwaseun Ogungbenle Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. for produced water storage vessels at a Synthetic Minor facility. AIRS ID: 123/9C34/001 Page 9 of 11 olor. b Depa en . ' .li Health and Environment �. �;A it Pollution Control Division Notes to Permit Holder - me o .e a -. 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: https://www.colorado.gov/pacific/cdphe/agcc-reps 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 Controlled Emission Are the Emission AIRS Rate emissions Rate Point Pollutant CAS# (lb/yr) reportable? (Ib/yr) Benzene 71432 2,968 Yes 148 001 n-Hexane 110543 9,328 Yes 466 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source lb/BBL Produced lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.013 CDPHE 110543 n-Hexane 0.022 1.1E-03 CDPHE 71432 Benzene 0.007 3.5E-04 CDPHE Note: The controlled emissions factors for point 001 are based on a combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: AIRS ID: 123/9C34/001 Page 10 of 11 olora' Depa en f P li Health and Environment jr Pollution Control Division Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n-Hexane, and total HAPs NANSR Synthetic Minor Source of VOC PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) 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: 123/9C34/001 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 15WE0516 Source Name: State 1 Hz Tank Battery Source Location: SENE Section 16,Township 3N, Range 68W Equipment Description: Produced Water Storage Tank AIRS ID: 123-9C34-001 Date: 06/16/2015 Review Engineer: Oluwaseun Ogungbenle Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X Initial Approval Transfer of Ownership APEN Exempt/Permit Exempt * If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first being issued an Initial Approval permit Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered "no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? October 30, 2014 Section 4—Source Description AIRS Point Equipment Description 001 Seven (7) above ground 235 bbl atmospheric produced water storage vessels. Emissions from these storage vessels are routed to an enclosed combustor. Are"flash"emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM,o CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? Page 1 If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less Yes X No than 1% by volume crude oil on an average annual basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 Yes X No Rule? If so, submit Form APCD-105 Section 5—Emission Estimate Information AIRS Point Emission Factor Source 001 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 001 424,011.42 BBL per year wastewater Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year --- Actual process data not provided N/A Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 424,011.42 BBL per year wastewater Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 001 01 Enclosed combustor 95% Section 6—Emission Summary(tons per ear) Point NO„ VOC CO Single HAP Total HAP PTE: 001 55.6 4.7 (n 6.1 Hexane) Uncontrolled point 001 source emission rate: Controlled point 0.2 (n- source emission rate: 001 2.8 Hexane) 0.3 Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 N/A 2,968 Yes 148 n-Hexane 110543 N/A 9,328 Yes 466 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR X MACT Is this a modification to an existing permit? Yes X No If"yes"what kind of modification? Minor Synthetic Major Minor Section 10— Public Comment Does this permit require public comment per CAQCC Regulation 3? X Yes No If"yes", for which pollutants?Why? VOC For Reg. 3, Part B, III.C.1.a (emissions increase> 25/50 tpy)? X Yes No For Reg. 3, Part B, III.C.1.c.iii (subject to MACT)? Yes No For Reg. 3, Part B, III.C.1.d (synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12—Regulatory Review Regulation 1 Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 001 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2—Odor Section I.A- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 001 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3-APENs, Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 001 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 001 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg. 3, Part B, Section ll.D.3.a) Regulation 6- New Source Performance Standards Page 3 NSPS OOOO: Tanks with the potential to emission equal to or greater than 6 TPY. 001 For permitting purposes, this source is not subject to the requirements of this subpart because controlled actual emissions from each storage vessel are less than 6 tpy VOC. Regulation 7'-Volatile Organic Compounds XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... 001 (Applicant is currently subject to this section since actual uncontrolled emissions are greater than 6 tpy of VOC.) Regulation 8—Hazardous Air Pollutants 001 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 6.238 lb/1000 CDPHE PS gallons VOC No Memo 09-02 95 throughput Produced Water Storage 0.167 lb/1000 CDPHE PS 01 Tanks gallons Benzene No Memo 09 02 95 001 throughput 0.524 lb/1000 CDPHE PS gallons n-Hexane No Memo 09-02 95 throughput SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 001 Produced Water Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). State-Developed Emission factors are: Produced Water Tank Default County Emission Factors (lb/bbl) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 0.262 0.007 0.022 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 0.178 0.004 0.010 Remainder of Colorado 0.262 0.007 0.022 Or State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors (lb/1000 gal) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 6.2381 0.1667 0.5238 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 GP05 coverage was initially requested for these storage vessels. However, before an approval letter was generated, Encana opted to apply for construction permit coverage for these vessels instead. Process Description The State 1 Hz Battery is an exploration and production wellsite. During extraction, the comingled stream enters a high-low pressure three-phase separator. High pressure gas from the separator is sent directly to the sales line. Low pressure gas from the separator(-35 psi) is routed to the vapor recovery unit and then compressed to the sales line. Water is routed to a storage tank. Condensate is routed to a storage tank (a storage tank is a single storage vessel or a series of storage vessels that are manifolded together via a liquid line). Vapors from both produced water and condensate storage tanks are controlled by a combustor. Water and condensate are removed from the site via tank truck. Page 5 Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY Current Status(Check all that apply) /7-5' u f Reason for APEN Submittal(Check all that apply) MRS ID#1: " 1�C�_f too� 0 APEN update only4 DEC j 410 ® New or previously unreported battery 0 Modification to existing sources Q - ❑ Previously grandfathered battery2 0 Registration for coverage under general permit no.GP01 ® Synthetic minor facility &cancellation request for individual permit6: ® Located in the 8-hr Ozone Control Area3 ® Application for or Modification of an individual permit ❑ Registered under general permit no.GP01 0 Administrative permit amendment? '��i3� ❑ Permitted under individual permit: 0 Other: For individual permit applications,check if you want8: 0 A copy of the preliminary analysis conducted by the Division 0 To review a draft of the permit prior to issuance Company Name9: Enema Oil&Gas(USA)Inc OGCC Operator#: 100185 Mailing Address10: Republic Plaza 370 17th St. Suite 1700 City: Denver State: CO Zip: 80202 E-mail: Adam.serig@encanacom Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name": State 1 Hz Number of tanks: 21 Locationt2(QQ Sec.Twp.Range.): SENE Sec. 16 T3N R68W County: Weld Total tank capacity[bbl]: 8400 Calendar year for which"Actual"data applies13: Projected Year(s)tank(s)were placed in service14: 2013 Control Description15: Enclosed Combustor Control Efficiency16: 95 Condensate Throughput17[bbl/year] Requested18: 269296 Maximum for PTE calculation19: 323155 Actual20: While Controls Operational21 269296 Other equipment at facility22: Produced Water Storage Tanks,VRU Engines and Condensate Loadout Comments: Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit 0 Check if the Division is to calculate emissions. 0 Check if site-specific emission factors provided to calculate emissions23. 6 Emission Factor Battery Requested t Emissions18 ActualEmissions20 z7 9(rt11q Pollutant24 [lb/bbl] PTE25 Uncontrolled Controlled27 Uncontrolled6 Controlled VOC[tons/year] 11.019 1780.420 f 4,53-{q `i`- 1g 1483.690 74.180 NOx[tons/year] 0.068 lb/MMbtu 3.320 -- ,---77 -- 2.770 CO[tons/year] 0.37 lb/MMbtu 18.070 -- f5- b 6- -- 15.060 Benzene[lbs/year] 0.035 11183.020 q3[9, (8' q-65-16- 9319.180 465.960 n-Hexane[lbs/year] 0.25 80945.900 6'7'(-.5q--g Z 3,37,2:75- 67454.920 3372.750 Wells serviced by this tank or tank battery28 API#: 0512336854 Name: STATE 1H-16H ®Newly Reported Well API#: 0512336857 Name: STATE 1G-16H ®Newly Reported Well API#: 0512336855 Name: STATE 1B-16H ®Newly Reported Well API#: 0512336856 Name: STATE 1C-16H ®Newly Reported Well API#: 0512336852 Name STATE 1F-16H ®Newly Reported Well API#: 0512336853 Name: STATE 1D-16H ®Newly Reported Well API#: 0512336851 Name: STATE lE 16H ®Newly Reported Well The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of my knowledge and belief. If this is a registration for coverage under general permit GP01,I further certify that this source is and will be operated in full compliance with each condition of general permit GP01. ._ 12/04/2013 Signature of Legally Authorized Persorr(not a vendor or consultant) Date Adam Berig ! Lead,Air Quality Type or Print Name of Person Signing Above Official Title Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call: filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B1 O (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South registration to: Denver,CO 80246-1530 FORM APCD-205 Page 1 of 3 APEN-E&P Condensate Storage Tank Battery NEW for State 1 Hz 2013-12-03 07-58- 41.doc.doc as Ws al co Q Jo O N _ .v-- N C) r— D. E . ` °.- .- ti u, m cO. \('5 c0 m N Q ® O U w d N W •j.. 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