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HomeMy WebLinkAbout20143103.tiff ,A, C DP H E COLORADO CO Department of Public „,• Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 October 6, 2014 Dear Sir or Madam: On October 9, 2014, the Air Pollution Control Division will publish a public notice for Encana Oil Et Gas (USA) Inc. - Gurtler Horizontal, State Peterson 1 20 ft 12 20 and Davis 1A 1B 1C Horizontal, in the The Greeley Tribune. 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 date the public notice is published. 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, ra 71/ .?.,a,a. Clara Gonzales RECEIVED Public Notice Coordinator Stationary Sources Program Air Pollution Control Division OCT 0 8 2014 Enclosure WELD COUNTY COMMISSIONERS �� s , 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.mlorado.gov/cdphe He "� John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I y d,`. :,e TO, x 1876 7Ll91 l G eke'Jlcu� 10 2014-3103 /0-13-.204 et:PL�l, H /1 GDPHE Public Notice Of A Proposed Project CO Or Activity Warranting Public Comment Website Title: Encana Oil & Gas (USA) Inc. - Gurtler Horizontal - Weld County Released To: The Greeley Tribune On: October 6, 2014 Published: October 9, 2014 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 & Gas (USA) Inc. Facility: Gurtler Horizontal, State Peterson 1 20 Et 12 20 and Davis 1A 1B 1C Horizontal Oil and gas production and exploration facilities NWNW Section 30 T2N, R64W, NWNW Section 20, T5N, R63W, and SWNE Section 9, T2N, R66W Weld County The proposed project or activity is as follows: Oil and gas exploration and production facilities with condensate tanks. 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 Permits 14WE1013, 14WE1014 and 14WE1015 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: Stephanie Chaousy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us .... .._.. ..... . . COLORADO 1I AY , DRAFT STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 �r + t I$78• CONSTRUCTION PERMIT PERMIT NO: 14WE1013 Issuance 1 DATE ISSUED: ISSUED TO: Encana Oil & Gas (USA), Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Gurtler Horizontal, located in the NWNW of Section 30, Township 2 North, Range 64 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Description Point Eight (8)fixed roof storage tanks used to store condensate with a 002 total storage capacity of 2800 BBL. Emissions from these tanks 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.aov/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 of eighteen AIRS ID: 123/9B7E Page 1 of 8 Condensate Tank SM/M Version 2012-1 olDo De f Health and Environment r Pollution Control Division months or 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: Regulatioft410. 3, Part B, Section II.A.4) Annual Limits: MRS Tons per Year Point NO, VOC CO Emission Type 002 — 54.1 21.5 Point See Notes to Permit Holder for infomration on emission actors and methods used to caM Mt 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 lekel)from each emission unit, on a rolling twelve (12) monih,:total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data.. Tom. permit holder shall calculate emissions each monthsnd keep a compliance record on site or at a local field office with site responsibility, for Qiy;sion review. This rolling twelvemonth 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.) MRS Control Device Pollutants Point Controlled 002 Enclosed combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall bs 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/Consumptlon Limits AIRS ID: 123/9B7E Page 2 of 8 olo Depa e f bli Health and Environment it Pollution Control Division AIRS ces An Imit Point 002 Condensate throughput 193200 BBL/yr 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. 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.1.c 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. 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. 13. 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. 14. 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. OPERATING & MAINTENANCE REQUIREMENTS 15. 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: 123/967E Page 3 of 8 lo De Health and Environment Pollution Control Division COMPLIANCE T Initial Testina Requirements 16. 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 XVJI.AII) Periodic Testing Requirements 17. 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.All) ADDITIONAL REQUIREMENTS This permit replaces the following permits and/or points,which are cancelled upon issuance of this permit. Existing Permit Existing No. Emission Point New Emission Point GP01 123/987E/002 123/967E/002 18. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually by April 30"'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 AIRS ID: 123/9B7E Page 4 of 8 olo Depa e f bli Health and Environment it Pollution Control Division e. No lat d e ex' N ex 19. 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). 20. 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 21. 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. 22. 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 6, 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. 23. 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. 24. 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. 25. 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. AIRS ID: 123/9B7E Page 5 of 8 . . .m ¢rqa• nTwiN 3i ... De Ii Health and Environment r Pollution Control Division 26. Section 25-7- ), ired to file an Air Pollution Emission Notice (APEN) must pay an annual feet() cover the costs of inspections and administration. If a source or activity is to be discontinued,Ma_owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. 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: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil&Gas (USA), Inc. Converting a GP01 to a construction permit. Source at a synthetic minor facility. AIRS ID: 123/9B7E Page 6 of 8 olor Depa e .f ' bli` Health and Environment it Pollution Control Division Notes to Permit Holder - e of er 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 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.aov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paciename=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# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 5,410 Yes 271 002 Hexane 110543 C 35,935 Yes 1,797 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Emission Factors Emission Factors CAS# Pollutant Uncontrolled Controlled Source Throughput Throughput NOx 0.068 Ib/mmbtu --- AP-42,Table 13.5-1 CO 0.37Ib/mmbtu AP-42, Table 13.5-1 VOC 11.203 Ib/bbl 0.5602 lb/bbl Previously permitted 110543 n-Hexane 0.186 lb/bbl 0.0093Ib/bbl Previously permitted 71432 Benzene 0.028 lb/bbl 0.0014 lb/bbl Previously permitted Note: The controlled emissions factors for point 002 are based on the enclosed combustor control efficiency of 95%. AIRS ID: 123/9B7E Page 7 of 8 De f Heh d Environment it Pollutionaltan Control Division 6) M accordance with - EN)associated with this permit is valid for a term of five years from the date it was received byte 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 breach emissions point associated with this permit. For any questions regarding a specific expiation 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, total HAPS PSD w NANSR O Minor Source of: MACT HH Area Source Requirements: Not Applicable 8) Full text of the Tile 40,Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below. http://ecfr.¢poaccess.Qov/ 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 M—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:htp://www.colorado.aov/oacific/cdphe/air-permit-self-certification • AIRS ID: 123/9B7E Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas(USA) Inc. Permit Number 14WE1013 Source Location: Gurtler Horizontal NWNW Section 30,T2N, R64 W,Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9B7E-002 Date: August 21, 2014 Review Engineer: Stephanie Chaousy, PE Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt 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? May 1, 2014 Section 4—Source Description AIRS Point Equipment Description Eight(8)above ground atmospheric condensate storage tanks with a total storage 002 capacity of 2800 BBL. Emissions from these tanks are controlled by 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? PKo 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 PKo CO Ozone RACT per Regulation 3, Part B,Section III.D.2) 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) Page 1 Section b—Emission Estimate Infomtation AIRS Point Emission Factor Source Operator provided site-specific emission factors with the GP01"(submitted 6/6/13). 002 Revised application came in within a year of the GP01 application. Operator used the same emission factors that were on the GP01. Did the applicant provide actual process data for the emission inventory? Yes X No , rlie AIRS Point Process Consumpdon/Throughput/Production' 002 231,840 BBL per year(193,200 x 1.2) ,3 1 ... ' i t s fit. i![:` i, z[ , _°. :t t id _ � � .xa.�ow�a,v-..raxim: ..r....�., ... mya AIRS Point Process Consumpdonf himughput/Production Data Year 002 176,109 BBL per year 2013 AIRS Point Process Consumption/Throughput/Production 002 193,200 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 PTE: 002 4.0 1298.7 21.5 21.6(Hexane) 24.8 Uncontrolled point 002 4.0 1082.2 21.5 18.0 (Hexane) 20.7 source emission rate: Controlled point 002 4.0 54.1 21.5 0.9 (Hexane) 1.0 source emission rate: Section 7-Non-Criteria/Hazardous Air Pollutants Uncontrolled .. ens. Controlled Emission Pollutant CAS# BIN Emission Rate effibbileneMtn z Rate IleNf Benzene 71432 A 5,410 Yes 271 n-Hexane 110543 C 35,935 Yes 1,797 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. 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 002 01 Opacity Regulation No.7 Section XVILAII Method 22 Section 9-Source Classification Is this a new previously un-permitted source? Yes X No(originally a GP01) Page 2 What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR 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? 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 X 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. R 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 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. Re ulation 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 ILD.2.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 WHY?There are 8-350 bbl tanks onsite(each less than 471 bbl), therefore,these tanks do not meet the criteria of this subpart. Page 3 ;t "-: . ... •(. i tr iii+il .da r.:. . .. 3 xmY..1 X14°♦ .,. p„fir ` :s"».3'ry»t XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control tsqulnmsnts for condensate tanks 002 since it is located in a non-attainment ant) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is cunentlysubject to this since actual uncontrolled emissions am @rsater than-20 -• of VOC.) Recant ' MALT EEEE:D"• Liquids D etribution -` ' 002 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 002 MACT HH This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13-Aerometrlc Information Retrieval System Coftjadomustion Process Emission Pollutant/ Control Point Proems Descnpfion Factor CAS# (Y�) Emission Fedor Source (%) 288'7381 V0C No Previously 16/1000 gal Pi )Y permitted 95 01 E&P Condensate 0.6667 Benzene/ tic Previousy permitted 95 002 Storage Tanks lb/1000 gal 71432 4.4286 n-Hexane No Previously permitted 95 Ib/1000 gal /110543 SCC 40400311 -Fixed.Roof Tank,Condensate,woridng+breathing+flashing losses Section 14-Miscellaneous Aptdion Notes AIRS Point 002 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greener than 2 TPY(permit threshold). Operator used the same emission factors used with the first APEN of this source as a GP01. Since then, the emissions have increased greater than the GP01 permit limit therefore,they require a CP. I converted the emission factors to lb/1000 gal: VOC= 11.203 lb/bbl*1000/42=266.7381 Ib/1000 gal Benzene=0.028 lb/bbl •1000/42=-0.6667 Ib/1000 gal - n-hexane=0.186 lb/bbl*1000/42=4.4286 Ib/1000 gal Page 4 DRAFT STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT stk . AIR POLLUTION CONTROL DIVISION - TELEPHONE:(303)692-3150 •1876• CONSTRUCTION PERMIT PERMIT NO: 14WE1014 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 Peterson 1 20 & 12 20, located in the NWNW of Section 20, Township 5 North, Range 63 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Description Point 001 Twenty(20) 400 BBL fixed roof storage tanks used to store condensate. Emissions from these tanks 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.aov/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 of eighteen months or more; (iii) does not complete construction within a reasonable time of the AIRS ID: 123/5170 Page 1 of 8 Condensate Tank SM/M Version 2012-1 estimated comDdro *. vsrr;T' 'r�Cgx9["Y ;vn,y�a #CAi `+^Mat+ rvJpl�a of Public Health and Environment r Air Pollution Control Division estimated coin d= �' t 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 pent*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: AIRS Tons per Year Point NO, VOC CO Emission Type 001 1.6 48.2 - 8.6 Point See'Notes to Pemrt Holder'forkubnnatbn on emission/actors and methods used to calculate Ant 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 rollir flaklve (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.) AIRS Control Device Pollutants Point Controlled 001 Enclosed combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits MRS Process Parameter Annual Limit Point 001 Condensate throughput 251,000 BBLlyr AIRS ID: 123/5170 Page 2 of 8 C do e art nt of Public Health and Environment Air Pollution Control Division The owner or o sh roc ates 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. 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.1.c 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. 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. 13. 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. 14. 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. OPERATING & MAINTENANCE REQUIREMENTS 15. 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.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements AIRS ID: 123/5170 Page 3 of 8 + o of Public Health and Environment i Air Pollution Control Division 16. The owner or s pl ' 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) Periodic Testinu Requirements 17. 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 XVILAII) ADDITIONAL REQUIREMENTS This permit replaces the following permits and/or points,which are cancelled upon issuance of this permit. Existing Permit Existing No. Emission Point New Emission Point GP01 123/5710/001 123/5710/001 18. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually by April 30"'whenever a significant increase in emissions occurs as fellows: 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-4N%)in ozone nonattainment areas emitting less than 100 tons of VOC or NO per year,a change in annual actual emissions of one(i)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. 19. Federal regulatory program requirements(i.e. PSD,NANSR)shall applyto this source at any such time that this source becomes major solely by virtue of a relaxation in any permit AIRS ID: 123/5170 Page 4 of 8 C do e artm nt of Public Health and Environment Air Pollution Control Division condition. Any r •n i e tenti 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). 20. 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 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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 AIRS ID: 123/5170 Page 5 of 8 do of PublicAirPollution Health andControl EnvironmentDivision in writing requeD f it. notification, annual fee billing will terminate. 27. 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: Stephanie Chaousy, PE Permit Engineer Permit History Bssuance Date Description Issuance 1 This Issuance Issued to Encana Oil&Gas(USA), Inc. Converting a GP01 to a construction permit. Source at a.synthetic minor facility. AIRS ID: 123/5170 Page 6 of 8 C do e artm nt of Public Health and Environment Air Pollution Control Division Notes to Permit Holder at e o p ss 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: htte://www.colorado.gov/cs/Satellite?c=Document C&childpaeename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWraoper 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# BIN (Ib/yr) reportable? Rate(Ib/yr) Benzene 71432 A 5271 Yes 264 001 Hexane 110543 C 43925 Yes 2196 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 Throughput Throughput NOx 0.068 lb/mmbtu --- AP-42,Table 13.5-1 CO 0.37Ib/mmbtu --- AP-42,Table 13.5-1 VOC 7.686Ib/bbl 0.3843 lb/bbl Previously permitted 110543 n-Hexane 0.175Ib/bbl 0.0088 lb/bbl Previously permitted 71432 Benzene 0.021 Ib/bbl 0.0011 lb/bbl Previously permitted Note: The controlled emissions factors for point 001 are based on the enclosed combustor control efficiency of 95%. AIRS ID: 123/5170 Page 7 of 8 C do e t of PublicPoll Healthution andControl Div Environment Air 6) In accordance with C. 7- 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, total HAPS PSD of NANSR Synthetic Minor Source of VOC MACT.HH Area Source Requirements: Not Applicable 8) Full text of the The 40,Protection of Environment Electronic Code of Federal Regulations can be found at the webaite listed below http://eeftwoaccess.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 M—Subpart DDD MACT 63.1200-63.1439 Subpart EEE-Subpart PPP MACT 63.1440-63.6175 Subpart OOO-Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXX( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: htto://www.colorado.gov/oacifiGcdohe/air-permit-self-certifica0gn AIRS ID: 123/5170 Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number 14WE1014 Source Location: State Peterson 1 20& 12 20 NWNW Section 20,T5N, R63W,Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-5170-001 Date: August 21, 2014 Review Engineer: Stephanie Chaousy, PE Control Engineer. Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt 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? May 1, 2014 Section 4—Source Description AIRS Point Equipment Description 001 Twenty (20)400 bbl above ground atmospheric condensate storage tanks. Emissions from these tanks are controlled b 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 PKo CO Ozone RACT per Regulation 3, Part B,Section III.D.2) 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) Page 1 Section 5—Emission Estimate Information • AIRS Point Emission Factor Source Operator provided Ste-specific emission factors with the GP01 (submitted 9/17/13). 001 Revised application came in within a year of the GP01 application. Operator used the same emission factors that wefe on the GP01. Did the applicant provide actual process data for the emission inventory? Yes X No AIRS Point Process Consumption/Throughput/Production 001 301,200 BBL per year(25.1,000 x 1.2) e , E k n t383�'or AEtl1e te A� • AIRS Point Process Consumpton/r'hroughput/Producton Data Year 001 176,073 BBL per year 2013 • e At �. < ?-11.1<nnIt AIRS Point Process ConsumptionlThroUghput/Production x" 001 251,000 BBL per year Does this source use a control device? [X Yes No AIRS Point Process Control Device Description 7G Reduction Granted 001 01 Enclosed combustor 95 Section 6—Emission Summary(tons per year) Point NO," VOC CO Single HAP Total HAP PTE: 001 1.6 1298.7 8.6 26.4(Hexane) 29.5 Uncontrolled point 001 1.6 1157.5 8.6 22.0(Hexane) 24.6 source emission rate: Controlled point 001 1.6 57.9 8.6 1.1 (Hexane) 1.2 source emission rate: Section 7—Non-Critsria/Hazardous AIFPollutants uncontrolled n Controlled olled Emission Pollutant CAS U BIN Emission Rate Rate Pehd Benzene 71432 A 5271 Yes 264 n-Hexane 110543 C 43925 Yes 2196 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. Section 8.Testing Requirements Wdl testing be required to show compliance with any emission rate or regulatory X Yea No standard? If'yes', complete the information listed below AIRS Point Process. Pollutant Regulatory Basis Test Method 001 01 Opacity Regulation No.7 Section XVII.AII Method 22 Section 9—Source Classification Is this a new previously un-permitted source? Yes X No(originally a GP01) Page 2 What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR 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? 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 X 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 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings 001 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 II.D.2.a) R-•ulation 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 001 Is this source subject to NSPS Kb? No WHY?There are 20-400 bbl tanks onsite(each less than 471 bbl),therefore,these tanks do not meet the criteria of this subpart. Page 3 • XII.VOLATILE GANIC COMPOUND ISSIONS FROM OIL AND GAS OPERATIONS (Applicant is suiriect to the emission control requirements for condensate tanks 001 since t is located In non-attainment am.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant Is currently subject to this since actual uncontrolled emissions are !greater than XI of VOC. Result 8'. _ .0 MACT EEEE:O" IC Liquids Distribution 001 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 001 MACT HH • This source is not subject to MACT HH because it is not located at a major source of HAP. Section 13—Aerometrlc Information Retrieval System� Control itrfomtatlon Pant Process Emission• Emission Pdksant/. ache Emission Factor S Description Factor CAS# (YIN) (%) 183.0 Previously permitted in• Ib/1000 gad VOC No GP01 95 01 E&P Condensate 0.5 Benzene/ No Previously permitted in 95 001 Storage Tanks lb/1000 gal 71432 GP01 4.1667 n-Hexane Previously permitted in 95 No lb/1000 gal /110543 GP01 SCC 40400311 —Fixed Roof Tank,Condensate,worldng+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 001 Condeneats Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Operator used the tame emission factors used with the first APEN of this source as a GP01. Since then, the emissions have increased greater than the GP01 permit limit therefore,they require a CP. I converted the emission fadorato lb/1000 gal: VOC=7.686 lb/bbl 1000/42= 183.0 lb/1000 gal Benzene=0.021 Ib/bbl*1000/42=0.5 lb/1000 gal n-hexane=0.175 lb/bbl.1000/42=4.1667 lb/1000 gal Page 4 STATE OF COLORADO cOzo COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ', ye AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 :e* •/896• CONSTRUCTION PERMIT PERMIT NO: 14WE1015 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 Davis 1A 16 1C Horizontal, located in the SWNE of Section 9, Township 2 North, Range 66 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Description Point Twelve (12) 400 BBL fixed roof storage tanks used to store 001 condensate. Emissions from these tanks 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 fora period of eighteen AIRS ID: 123/962A Page 1 of 8 Condensate Tank SM/M Version 2012-1 to De e i Health and Environment 'r Pollution Control Division months or m e ion a reasonable time of the -_ estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, IILF.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: AIRS Tons per Year Point NO, Emission Type VOC CO 001 3.2 46.7 17.4 Point See`Notes to Permit Holder'for information on emission factors and methods used to calculate trots. 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. Th®' 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.) MRS Control Device Pollutants Point Controlled 001 Enclosed combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits -- AIRS ID: 123/9B2A Page 2 of 8 Illolor- Depa e f bli Health and Environment A it Pollution Control Division AIRS .ces . . An imit Point 001 Condensate throughput 168,700 BBL/yr 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. 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.1.c 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. 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. 13. 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. 14. 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. OPERATING & MAINTENANCE REQUIREMENTS 15. 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: 123/9B2A Page 3 of 8 of Depa li ltn r PollutionHeahand Control Enviro Divmentision COMPLIANCE TE Initial Testing Requirements 16. 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) • Periodic Testing Requirements 17. 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 This permit replaces the following permits and/or points,which are cancelled upon issuance Of this permit. Existing Permit Existing No. Emission Point New Emission Point GP01 123/9B2A/001 123/9B2A/001 18. 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 (NQ,) 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 AIRS ID: 123/9B2A Page 4 of 8 olor Depa e f bli Health and Environment it Pollution Control Division e. No lab d e ex' N ex ' 19. 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). 20. 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 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. AIRS ID: 123/9B2A Page 5 of 8 ob De e f i Health and Environment it Pollution Control.Division 26. Section 25-7- ), urces ired 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 notifythe Division in writing requesting a cancellation of the permit. Upon notification;annual fee billing will terminate. 27. 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 AOCC 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. Stephanie Chaousy, PE Permit Engineer. Permit History Issuance Date Description, Issuance 1 This Issuance Issued to Encana Oil & Gas (USA), Inc. Converting a GP01 to a construction permit. Source at a synthetic minor facility. AIRS ID: 123/9B2A Page 6 of 8 Colo Depa e f bli Health and Environment it Pollution Control Division Notes to Permit Holder - ' e of er 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 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.aov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paciename=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# BIN (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 A 6914 Yes 346 001 Hexane 110543 C 47723 Yes 2386 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 Throughput Throughput NOx 0.068 lb/mmbtu --- AP-42, Table 13.5-1 CO 0.37Ib/mmbtu --- AP-42, Table 13.5-1 VOC 11.074 lb/bbl 0.5537 lb/bbl Previously permitted 110543 n-Hexane 0.283 lb/bbl 0.0142 lb/bbl Previously permitted 71432 Benzene 0.041 Ib/bbl 0.0021 lb/bbl Previously permitted Note: The controlled emissions factors for point 001 are based on the enclosed combustor control efficiency of 95%. AIRS ID: 123/9B2A Page 7 of 8 1 De e f Ii Health and Environment it Pollution ControlDivision 6) In accordance with - of 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 ewes. 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 expiation date call the Division at(303)-692- • 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: V0C,n-hexane, total HAPS 1'SD or NANSR Synthetic Minor Source of: V0C MACT HH Area Source Requirements: Not Applicable 8) Full text of the Title 40,Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below. http://ecfr.gpoaccess.gov/ Part 60:Standards of Performance for New Stationary Sources 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 htto://wwi.colorado.clovroacifickdohefair-Dermit-self-certification • AIRS ID: 123/9B2A Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 14WE1015 Source Location: Davis 1A 1B 1C Horizontal SWNE Section 9,T2N, R66W, Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-962A-001 Date: August 21, 2014 Review Engineer: Stephanie Chaousy, PE Control Engineer: Chris Laplante Section 2—Action Completed Grandfathered Modification APEN Required/Permit Exempt X CP1 Transfer of Ownership APEN Exempt/Permit Exempt 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? May 1, 2014 Section 4—Source Description AIRS Point Equipment Description 001 Twelve(12)400 bbl above ground atmospheric condensate storage tanks. Emissions from these tanks are controlled by 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 PM,() CO Ozone RACT per Regulation 3, Part B, Section III.D.2) 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) Page 1 :'R1 "k.-4-7, Section 5—Emission Estimate Information AIRS Point Emission Factor Source Operator provided site-specific emission factors with the GP01 (submitted 11/4/13). 001 Revised application cane in within a year of the GP01 application. Operator used the same emission factors that were on the GP01. Did the applicant provide actual process data for the emission inventory? Yes X No AIRS Point ProcessConsumption/Throughput/Production 001 202,360 BBL per year(168,700 x 1.2) p , r a _r�� ' to •i41 >l�i ^jl)� I r s s w s �.,. AIRS Point Process Consumption/Throughput/Production Data Year 001 168,633 BBL per year 2013 , -. rte' ` hiiasl- It: AIRS Point Process Consumption/Throughput/Production 001 168,700 BBL per year Does this source use a control device? X Yes No 76 Reduction AIRS Point Process Control Device Description Granted 001 of Enclosed combustor 95 Section 6—Emission Summar/(tons per year) Point NO■ VOC CO Single HAP Total HAP PTE: '001 3.2 1120.9 17.4 28.6 (Hexane) 32.8 Uncontrolled point 001 3.2 934.1 17.4 23.9(Hexane) 27.3 source emission rate: Controlled point 001 3.2 46.7 17.4 1.2(Hexane) 1.4 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate Rife(Ihyr) pbyrl noporlible Benzene 71432 A 6914 Yes 346 n-Hexane 110543 C 47723 Yes - 2386 Note: Regulation 3,Part A, Section lI.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. 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 001 01 Opacity Regulation No.7 Section XVILAII Method 22 Section 9—Source Classification Is this a new previously un-permitted source? Yes X No(originally a GP01) Page 2 • What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR 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? 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 X 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 ILD.2.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 001 Is this source subject to NSPS Kb? No WHY?There are 12-400 bbl tanks onsite(each less than 471 bbl), therefore, these tanks do not meet the criteria of this subpart. Page 3 ;:Reiru�iolt F.. - "Air-1104`: XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant Is subject to the emission control regWrements for condensate tanks 001 since It is located in a non-attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant Is currerttfy subject to this since actual uncontrolled emissions are @reater than 20 tp OfbnC.) _N t MACT EEEE:Organ ids Distribution 001 This source is not subject to MACT EEEE because it is not located at a major source of HAP. 001 MACT HH 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 ProcessProcess Emission Pdkitant Fugitive Emission Factor Source Contrd Description Factor CAS# (Y/N) (%) 263.6667 Previously permitted in lb/1000 gal V0C No GP01 95 01 E&P Condensate 0.9792 Benzene/ No Previously permitted in 95 001 Storage Tanks lb/1000 gal 71432 GP01 6.7381 n-Hexane Previously permitted in lb/1000 gal /110543 No GP01 95 SCC 40400311 —Fixed Roof Tank,Condensate,working+breathing+flashing losses Section 14-Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Operator used the same emission factors used with the first APEN of this source as a GP01. Since then, the emissions have increased greater than the GP01 permit limit;therefore,they require a CP_ I converted the emission factors to lb/1000 gal: VOC= 11.074 lb/bbl* 1000/42=263.6667 lb/1000 gal Benzene=0.041 lb/bbl*1000/42=0.9792 lb/1000 gal n-hexane= 0.283 lb/bbl*1000/42=6.7381 lb/1000 gal Page 4 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) Reason for APEN Submittal (Check all that apply) - AIRS ID#1: . f 3 — "I L3�-4-5-0°z- ❑ APEN update only° —MAY-1.- -- 2014 ❑ New or previously unreported battery ® Modification to existing source' , .✓ ❑ Previously grandfathered battery' ❑ Registration for coverage under general permit no\GPfllna' ® Synthetic minor facility &cancellation request for individual permit6: carpe 0 Located in the 8-hr Ozone Control Area' ❑ Application for or Modification of an individual pe?ntit 0 Registered under general permit no.GPO! . ,� 1 ❑ Administrative permit amendment? ❑ Permitted under individual permit: t(f l/-c-b/3 ® Other:Need coverage under CP. not GPOI For individual permit applications,check if you wane: ❑A copy of the preliminary analysis conducted by the Division ❑ To review a draft of the permit prior to issuance Company Name9: Encana 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.Berigq,encana.com I Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)8764884 Tank Battery Name": Gurtler Horizontal Number of tanks: 8 NWNW Sec.30 T2N Location2(QQ Sec.Twp. Range.): RR64W County: Weld Total tank capacity[bbl]: 2800 Calendar year for which"Actual" data applies 13: 2013 Year(s)tank(s)were placed in service 14: 2013 Control Description`: Enclosed Combustor Control Efficiency1s: 95 Condensate Throughput"[bbl/year] Requested": 193200 Maximum for PTE calculation19: 231840 i ' Actual": 176109 • While Controls Operational2l 193200 Other equipment at facility22: Produced water tanks,VRU engines,condensate loadout Comments: Estimated emissions at throughputs listed above. Ilse N/A for requested throughput/emission values unless requesting an individual permit I. ❑ Check if the Division is to calculate emissions. ❑Check if site-specific emission factors provided to calculate emissions23. Emission Factor Battery Requested Emissions16 Actual Emissions" Pollutant29 [lb/bbl] PTE2' Uncontrolled26 Controlled27 Uncontrolled" Controlled?' VOC[tons/year] 11.203 1298.650 j 09C -, 1} 54.110A ✓ 1E i...; ,y} 49.324 NOx[tons/year] 0.068 lb/MMbtu .P2462- -- -- -- 3.958 CO [tons/year] 0.37 lb/MMbtu .2,2S'- -- -- -- 21.536 Benzene[lbs/year] 0.028 6491.520 1 SV0-;4; 270.48 / y il 3l.OS 246.553 J n-Hexane fibs/year] 0.186 43122.240 ✓ 115" ,Z 1796.76 / 3)-}5b;L4 1637.818 Wells serviced by this tank or tank battery2s API 4: 0512335980 Name: GURTLER 2A-30H ❑Newly Reported Well API#: 0512335981 Name: GURTLER 2B-30H ❑Newly Reported Well • API#: .. Name: ❑Newly Reported Well API#: Name: ❑Newly Reported Well API#: Name ❑Newly Reported Well API#: Name: ❑Newly Reported Well API#: Name: ❑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 GPOI, 1 further certify that this source is and will be operated in full compliance with each condition of general permit GPOI. ‘C- 04/30/2014 Signature of Legally Authorized Person(not a vendor or consultant) Date Adam Berig Air Quality Lead 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 n r information call: .j filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B1 310 " (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South re•istration to: Denver,CO 80246-1530 Page I of 32014.04.18 E&P Condensate Storage Tank Battery Existing for Cartier Horizontal 2014-04-18 I I-I9-27.doc.doe Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit a OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY Current Status(Check all that apply) Reason for APEN Submittal(Check all that apply) AIRS ID#': 123-5170-001 ❑ APEN update only° MAN —1, �2014�.] ❑ New or previously unreported battery ® Modification to existing sources ..,.------j. ❑ Previously grandfathered battery ❑ Registration for coverage under general permit o.GP01" / ® Synthetic minor facility - - &cancellation request for individual permits:� ," ® Located in the 8-hr Ozone Control Area' 0 Application for or Modification of an individual dermit-- ® Registered under general permit no.GPOI t/ 0 Administrative permit amendment' 0 Permitted under individual permit: P41,06-1(.17 ® Other:Need coverage under CP-no longer need GP For individual permit applications,check if you wants: ❑A copy of the preliminary analysis conducted by the Division ❑To review a draft of the permit prior to issuance Company Names': Encana Oil&Gas(USA)Inc. OGCC Operator#: 100185 Mailing Address10: Republic Plaza 370 17th St. Suite 1700 City: Denver State: CO Zip: 80202 E-mail: Ada,mBerig«eneana.com Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Namel l: STATE PETERSON 120& 12 20 Number of tanks: 20 NWNW Sec.20 T5N Locations(QQ Sec.Twp.Range.): R63W County: Weld Total tank capacity[bbl]: 8000 Calendar year for which"Actual"data applies'': 2013 Year(s)tank(s)were placed in service14: 2000 Control Description's: Enclosed Combustor Control Efficiency 6: 95 Condensate Throughput'[bbl/year] Requested's: 251000 Maximum for PTE calculation's: 301200 ✓ Actual20: 176073 While Controls Operationaln 251000 Other equipment at facility22: VRU Engine,Produced Water STorage 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 Emissions'° Pollutant24 [lb/bbl] PTE25 Uncontrolled26 Controlled27 Uncontrolled26 Controlled27 VOC[tons/year] 7.686 1\ 17,4-9g-}0B- 16,t4, 94 48.23,.// 0(41, 33.832 1 NOx[tons/year] 0.068 lb/MMbtu -- -- -- 1.572 CO [tons/year] 0.37 lb/MMbtu -- -- -- 8.551 Benzene[lbs/year] 0.021 (0- y.4 QS43-7-04& hat\ -- 263.55 1 7la IZ 53 184.877 / n-Hexane[lbs/year] 0.175 ca }D - X361 as:- 2196.25✓ 3CE CD,3S 1540.642 .-11 Wells serviced by this tank or tank battery28 API#: 0512321601 Name: ' State Peterson 1-20 El Newly Reported Well API#: 0512321698 Name: State Peterson 12-20 ❑Newly Reported Well API#: 0512322415 Name: State Peterson 22-20 ❑Newly Reported Well API#: 0512325624 Name: State Peterson 11-20 ❑Newly Reported Well API#: 0512325625 Name State Peterson 21-20 ❑Newly Reported Well API#: 0512336630 Name: STATE PETERSON 2A-20H ❑Newly Reported Well i API #: 0512336632 Name: STATE PETERSON 2B-20H ❑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 GPOI,1 further certify that this source is and will be operated in full compliance with each condition of general permit GPOI. ‘3(7,--- 04/30/2015 Signature of Legally Authorized Person(not a vendor or consultant) Date . Adam Berig Air Quality Lead 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 n For information call: filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-BI 310 2 21 (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South registration to: Denver,CO 80246-1530 Page 1 of 32014 04.18 State P E&P Condensate Storage Tank Battery Existing for STATE PETERSON I 20&I?20 2014-04-18 10-54-24.doc.doc Y ti t / ���5pI1L Wells serviced by this tank or tank battery _ AIRS ID#: 123- Tank Battery Name: STATE PETERSON 1 20& 12 5170-001 20 API#: 0512336631 Name: STATE PETERSON 2C-20H 0 Newly Reported Well API it: 0512336627 Name: STATE PETERSON 2D-20H 0 Newly Reported Well API#: 0512336629 Name: STATE PETERSON 2E-20H lJ Newly Reported Well API#: 0512336628 Name: STATE PETERSON 2F-20H 0 Newly Reported Well API#: Name 0 Newly Reported Well API#: - Name: 0 Newly Reported Well API#: Name: 0 Newly Reported Well API#: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: - - 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name - 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: - 0 Newly Reported Well API it: Name: - 0 Newly Reported Well API#: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: - 0 Newly Reported Well API#: Name 0 Newly Reported Well. API it: Name: - - 0 Newly Reported Well _. API it: Name: _ . 0 Newly Reported Well API it: Name: ❑Newly Reported Well API#: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: - Name 0 Newly Reported Well API it: - Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API#: Name: 0 Newly Reported Well API it: Name: - - 0 Newly Reported Well API#: Name: 0 Newly Reported Well API#: Name: 0 Newly Reported Well API#: - Name ❑Newly.Reported Well API it: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: Name: 0 Newly Reported Well API it: • Name: 0 Newly Reported Well a API it: Name: 0 Newly Reported Well 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) Reason for APEN Submittal (Check all that apply) AIRS ID f': I23-982A-001 ❑ APEN update only4 h.-, ❑ New or previously unreported battery ® Modification to existing source' I 4j R ❑ Previously grandfathered battery' ❑ Registration for coverage under general permit no\GPOd " or„. ® Synthetic minor facility &cancellation request for individual permit6: ® Located in the 8-hr Ozone Control Area ❑ Application for or Modification of an individual permit__-- ® Registered under general permit no.GPOI /' 11i " ❑ Administrative permit amendment' ❑ Permitted under individual permit:6P&I /1 �✓C(G�'- ❑ Other:Need coverage under CP not GP For individual permit applications,check if you wants: ❑A copy of the preliminary analysis conducted by the Division ❑To review a draft of the permit prior to issuance L Company Name9: Encana 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.Berigo,ncana.com Contact Name: Adam Beri: Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name1I: DAVIS IA 1B IC HORIZONAL Number of tanks: 12 Location' (QQ Sec.Twp.Range.): SWNE Sec.9 T2N R66W County: Weld Total tank capacity[bbl]: 4800 Calendar year for which "Actual"data appliesl': 2013 Year(s)tank(s) were placed in service": 2012 Control Description": Enclosed Combustor Control Efficiency16: 95 Condensate Throughput12[bbl/year] Requested it: 168700 Maximum for PTE calculation 1B: 202366'-2'9,24 YG Actual20: 168633 While Controls Operational21 168700 Other equipment at facility22: 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 emissions'''. Emission Factor Battery Requested Emissions18 Actual Emissions20 Pollutant26 [lb/bbl] PTE25 Uncontrolled26 Controlled2' Uncontrolled26 Controlled2' VOC[tons/year] 11.074 10t.S11-4.20A6- Ci IA e t 4640 40, cIj , -) 46.686/ NOx[tons/year] 0.068 lb/MMbtu -- -- -- 3.192 CO [tons/year] 0.37 lb/MMbtu -- -- -- 17.369 Benzene[lbs/year] 0.041 E:ott e96,56- I cei i t., 345.84 ✓ (c`i 1 3,(IS- 345.698 ✓ n-Hexane[lbs/year 0.283 cilic.s$F264'S$ L( -1}H ti ] 2387.105 / ` 11A H 2386.161 / Wells serviced by this tank or tank battery28 )1✓ API#: 0512335365 Name: DAVIS 1A-9H ❑Newly Reported Well API#: 0512335366 Name: DAVIS 1C-9H ❑Newly Reported Well API#: 0512335421 Name: DAVIS IB-9H ❑Newly Reported Well API#: Name: . ❑Newly Reported Well API#: ,Name ❑Newly Reported Well API#: Name: ❑Newly Reported Well API#: Name: ❑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 GPOI, I further certify that this source is and will be operated in full compliance with each condition of general permit GPOI.l/ 04/30/2014 Signature of Legally Authorized Person (not a vendor or consultant) Date Adam Berig Air Quality Lead Type or Print Name of Person Signing Above Official Title 3102~ 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-B I (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South registration to: Denver,CO 80246-1530 Page ( of 3 2014.04:18 E&P Condensate Storage Tank Battery Existing for DAVIS IA I B IC HORIZONAL 2014-04-18 I2-14-48.doc.doc Hello