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HomeMy WebLinkAbout20151154.tiff covHs COLORADO co I Department of Public .• Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 April 14, 2015 Dear Sir or Madam: On April 15, 2015, the Air Pollution Control Division will begin a 30-day public notice period for Encana Oil a Gas USA Inc - DEVORE 34H-A366. 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, 'f� ✓f. --Ht %L RECEIVED Clara Gonzales APR 2 1 2015 Public Notice Coordinator Stationary Sources Program WELD COUNTY Air Pollution Control Division COMMISSIONERS Enclosure e/t? 2015-1154 filAbb-CJ :?1:-PLA))* Wt_. 104 4300 Cherry Creek Drive S.. Denver, CO 80246-1530 P 303.692.2000 www.colorado.govicdpne - John W. Hickenlooper, Governor i Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer • ' 1RTti,« CDPHE Air Pollution Control Division i =ce. Co :r Notice of a Proposed Project or Activity Warranting Public ' Comment Website Title: Encana Oil Et Gas USA Inc - DEVORE 34H-A366 - Weld County Notice Period Begins: April 15, 2015 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Encana Oil Et Gas USA Inc Facility: DEVORE 34H-A366 Oil and Gas Exploration and Production NENE SEC 34 T3N R66W Weld County The proposed project or activity is as follows: The applicant proposes to construct eighteen (18) new condensate storage tanks at this 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 application, the Division's analysis, and a draft of Construction Permit 14WE1010 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: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us c9LORDC 1 I k A tik irj 3P I J ill JR, a `t,gM ro 3 STATE OF COLORADO re- r i Saliia h �. :�n 53!i '7v pF CO O G`GLORAD0D DEPARTMENYOF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION h r pq TELEPHONE: (303) 692-3150 ' CONSTRUCTION PERMIT PERMIT NO: I4WEI UPI 0 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 exploration and production facility known as the DEVORE 34H-A366, located in the NENW Section 4, Township 1S, Range 42W, Weld County, Cplorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Eighteen (18) above ground 400 bbl atmospheric condensate Condensate 001 storage tanks. Emissions from the storage tanks are routed to an Tanks enclosed combustor that acheives a minimum destruction efficiency of 95%. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, I II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date AIRS ID: 123/9CD5 Page 1 of 10 IIolor. Depa en P :.Ii Health and Environment ' A .it Pollution Control Division on which suc cti - . w.- ` - ed to - :--mence 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, I I I.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 Condensate 001 7.3 65.2 39.7 Point Tanks 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 001 Enclosed Flare VOC and HAP Tanks • AIRS ID: 123/9CD5 Page 2 of 10 )' - ,olora iDepa en of P 4 lic Health and Environment ( it Pollution Control Division 1 53 El a ,fig-11 PROCESS LIM ITATi6NSIANG E c ® . =' psi" 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 Condensat 001 Condensate Throughput 442,694 BBL e Tank s Tanks 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. -1, Section II.A.5.) 13. 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. 14. 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. 15. 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 AIRS ID: 123/9CD5 Page 3 of 10 olor jk Depa en . .li Health and Environment AIL it Pollution Control Division r � control emissi - as = g m., -4 -:corn. h 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. 16. The condensate storage tanks covered by this permit are subject to Regulation 7, Section XVII emission control requirements. These requirements include, but are not limited to: Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas exploration and production operations, natural gas compressor stations, natural gas drip stations and natural gas processing plants. XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate storage tanks with uncontrolled actual emissions of volatile organic compounds equal to or greater than 20 tons per year based on a rolling twelve-month total shall operate air pollution control equipment that has an average control efficiency of at least 95% for VOCs on such tanks. XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is required to control volatile organic compound emissions pursuant to this section XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to ensure that it is operating at least as often as condensate is loaded out from the tank, unless a more frequent inspection or monitoring schedule is followed. In addition, if a flare or other combustion device is used, the owner or operator shall visually inspect the device for visible emissions at least as often as condensate is loaded out from the tank. XVII.C.4. Recordkeeping: The owner or operator of each condensate storage tank shall maintain the following records for a period of five years: XVII.C.4.a. Monthly condensate production from the tank. XVII.C.4.b For any condensate storage tank required to be controlled pursuant to this section XVII.C., the date, time and duration of any period where the air pollution control equipment is not operating. The duration of a period of non-operation shall be from the time that the air pollution control equipment was last observed to be operating until the time the equipment recommences operation. XVII.C.4.c. For tanks where a flare or other combustion device is being used, the date and time of any instances where visible emissions are observed from the device. OPERATING & MAINTENANCE REQUIREMENTS 17. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) AIRS ID: 123/9CD5 Page 4 of 10 • 'rColoral Depa%1eni4df PlipliejHealth and Environment it Pollution Control Division tr mild3 y T ii C: COMPLIANCE TES . r ND AM L Gcvrakan Initial Testing Requirements 18. Within 180 days, 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) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30`h whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO„) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 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 AIRS ID: 123/9CD5 Page 5 of 10 olor Depa en P .Ii `Health and Environment it Pollution Control Division appropriate as= u-. "re S :- (Re rce: 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. 26. 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. 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. AIRS ID: 123/9CD5 Page 6 of 10 ^'C .gym.y.. M. .iii i:lini lbHWig fl .tcrg•::••{......_.....!�` ...Hi S nE is..�. ,.. :;g..,.;..v : y_ �� .��.olora:i�._rDepar��nen�vf Pig olio Health and Environment _' rii .'- 'it -ra r �ir Pollution Control Division .: c a ill t s" ter: (_ Eii iii .7 IN Illii r' w.w«.7s::G:x+ m—.a:.v s:urr:a:aa. w.._.".aS' aii2a:S:;tIC Vila-IR By. cibitv.„...4(1___________ Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. AIRS ID: 123/9CD5 Page 7 of 10 olor Depa , en .li 'Health and Environment 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: 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 Rate Point Pollutant CAS # (lb/yr) reportable? (Ib/yr) Benzene 71432 10182 Yes 509.1 n-Hexane 110543 138120.5 Yes 6906 Toluene 108883 17132.3 Yes 856.6 001 Ethylbenzene 100414 247 No 12.4 Xylene 224 TMP AIRS ID: 123/9CD5 Page 8 of 10 Wolora 'tDeparjnenf PIiHealth and Environment - !J 'r' it Pollution Control Division g tibtl 5) The emission levels gt10fied i ,Aszpeitififilaift batectaft4 follows '.mission factors: Point 001: Emission Factors Uncontrolled Pollutant lb/BBL Source Condensate Throughput VOC 5.885 CO 0.37 (lb/MMBtu) NOx 0.068 (lb/MMBtu) Benzene 0.023 HYSYS and EPA n-Hexane 0.312 Tanks Ethylbenzene 0.000558 Toluene 0.0387 Xylene 0.0041 224 - TMP 0.0054 Note: The controlled emissions for this point are based on the flare 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/Major Source of: VOC and HAP PSD/NANSR Synthetic Minor/Major Source of: VOC and HAP 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.q poaccess.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 AIRS ID: 123/9CD5 Page 9 of 10 il olor- Depa en P •.Ii ''Health and Environment •it Pollution Control Division MACT 63.14- . e 5 St. ►Qr YYy r...k 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: 12319CD5 Page 10 of 10 Division Information TRUE Engineer: Christopher Kester Control Engineer: Stefanie Rucker Review Date: 01/29/2015 Application Date: 05/09/2014 Facility Identifiers Permit No. 14WE1010 AIRS County# 123 Weld Facility# 9CD5 Facility Type: exploration and production facility ❑' Located in the 8-hour non-attainment area? O True Minor ® Synthetic Minor for: P VOC F NOx F CO Administrative Information • Company Name: Encana Oil & Gas (USA) Inc. Source Name: DEVORE 34H-A366 Source Location: NENW Section 4, Township 1S, Range 42W SIC: 1311 Address 1: Encana Oil &Gas(USA) Inc. Mailing Address Address 2: 333 Corporate Drive City,State Zip: Anothertown, ST, 00000 Name: Wile E. Coyote Person To Phone: 000-000-0000 Contact Fax: 000-000-0000 Email: wiley@supergenius.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the DEVORE 34H-A366, located in the NENW Section 4,Township 15, Range 42W, Weld County, Colorado. Point Name Type Control Action Newly 001 Condensate Tanks Condensate Tanks None reported source 001 Eighteen(18)above ground 400 bbl atmospheric condensate storage tanks.Emissions from the storage tanks are routed to an enclosed combustor that acheives a minimum destruction efficiency of 95%. Requsted Throughput 442694 bbl Control Flare Volume of flared gas 83.45 MMSCF/yr HYSYS output Efficiency 95.00% Heating Value 2572 Btu/scf Interpolated based on MW Total Heat Content Flared 214633.4 MMBtu/yr Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source VOC 5.885 lb/bbl 1302.6 tpy 65.1 tpy HYSYS and EPA Tanks CO 0.37 lb/MMBtu 39.7 tpy 39.7 tpy NOx 0.068 lb/MMBtu 7.3 tpy 7.3 tpy AP-42 Table 13.5-1 Benzene 0.023 lb/bbl 10182 lb/yr 509 lb/yr n-Hexane 0.312 lb/bbl 138121 lb/yr 6906 lb/yr Ethylbenzene 0.000558 lb/bbl 247 lb/yr 12 lb/yr HYSYS and EPA Tanks Toluene 0.0387 lb/bbl 17132 lb/yr 857 lb/yr Xylene 0.0041 lb/bbl 1815 lb/yr 91 lb/yr 224-TMP 0.0054 lb/bbl 2391 lb/yr 120 lb/yr Regulatory Review Section II.A.1 -Except as provided in paragraphs 2 through 6 below,no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20%opacity.This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes.The approved reference test method for visible emissions measurement is EPA Method 9(40 CFR, Part 60,Appendix A(July, 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Re ulation 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 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 6-New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons(471 bbl) NSPS OOOO:for storage vessels in the natural gas production,transmission,and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Re ulation 7—Volatile Or anic Com ounds XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in a non attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is not currently subject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) 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) i Reason for APEN Submittal(Check all that apply) AIRS ID#': 123/4C>5/ Ot, [ ❑ APEN update only' 4/4Y ® New or previously)unreported battery ❑ Modification to existing source' JT 20,4 ❑ Previously grandfathered battery' ❑ Registration for coverage under general permit no-GP0I ® Synthetic minor facility PZ &cancellation request for individual permit': ® Located in the 8-hr Ozone Control Area' CG,.71o,2014 M Application for or Modification of an individual permit- ❑ Registered under general permit no. GP01 ❑ Administrative permit amendment' ❑ Permitted under individual permit: [L{W E IO)1D ® Other:Application for coverage under Construction Permit For individual permit applications,check if you wants: ❑A copy of the preliminary analysis conducted by the Division Z To review a draft of the permit prior to issuance Company Name9: Encana Oil&Gas(USA)Inc. OGCC Operator 4: 100185 Mailing Address1s: Republic Plaza 370 17th St Suite 1700 City: Denver State: CO Zip: 80202 E-mail: Adam.BerigE encana.com Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name' : DEVORE 34H-A366 Number of tanks: 18 Location''-(QQ Sec. Twp. Range.): NENE Sec. 34 T3N R66W County: Weld Total tank capacity [bbl]: 7200 Calendar year for which"Actual" data applies°: Projected Year(s)tank(s)were placed in service i4: 2014 Control Description's: Enclosed Combustor Control Efficiency" 95 Condensate Throughput" [bbl/year] Requested's: 442694 ' Maximum for PTE calculation19: 531233 Actual20: While Controls Operational'' 442694 "9 Other equipment at facility22: 3 VRU Engines,produced water tank and condensate loadout Comments: Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit ❑ Check if the Division is to calculate emissions. ® Check if site-specific emission factors provided to calculate emissions23. Emission Factor Battery Requested Emissions's Actual Emissions20 i Pollutant [lb/bbl] PTE" Uncontrolled26 Controlled2' Uncontrolled26 Controlled" 7 VOC[tons/year] 5.885 -9 1563.190 — -- -- 1302.660 — 65.130 'C NON [tons/year] 0.068 lb/MMbtu ' -4,99f1-3.3 -- -- -- 6a'73 CO [tons/year] 0.37 Ih/MMhtu "- 2.7-.1-40-39(,--1 -- -- -- )262t -3`f_ Gi Benzene[Ibs/year] 0.023 " 12323570 '' -- -- 10269-640 " 513.480 n-Hexane ribs/year] 0.312 i 165661.760 ' -- -- 138051.470 -I 6902.570 Wells serviced by this tank or tank battery28 N API#: 0512337228 Name: DEVORE ID-34H ®Newly Reported Well TS API#: 0512337232 Name: DEVORE 1H-34H ®Newly Reported Well _ API#: 0512337247 Name: DEVORE 1B-34H ® Newly Reported Well API#: 0512337231 Name: DEVORE 1A-34H ®Newly Reported Well API#: 0512337230 Name DEVORE 1F-34H Z Newly Reported Well API 4: 0512337233 Name: DEVORE IC-34H ®Newly Reported Well API 4: 0512337270 Name: DEVORE 1G-3411 ®Newly Reported Well The signature below indicates that I have knowledge of the facts herein set forth and that the same arc true,accurate,and complete to the best of my knowledge and belief If this is a registration for coverage under general permit GP0I, I further certify that this source is and will be operated in full compliance with each condition of ge al permit GP0I. ./": � l 05/07/2014 Signature of Legally Authori P n endor 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-BI 311'161 (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 l of3 APEN-E&P Condensate Storage Tank Battery NEW lin DEVORE 34H-A2662014-05-05 13-4I-23 doc doc 0L ?.r ?ai..- 5 zils- m = a v I 0 0 o ¢ o o >. 0 N D V N Q N a n co r a C c N — o 0 0 o U E O 2 -a Z .e\ O 1 a N N U x W ..... O_ N Ts CI' �' o 0 N a ED — I Y U T 5 Q ¢ 2 b � Q C W0 00 CO ca �" o I Q 01-0 co GD m I— z c E N N Y O D a O o - C > ` Z Cl) 0 Q r a) Z CD a O . . . .0 CD 0 = V) in U) , L N Q �.- _ 'N U CD T >. 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