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Home My WebLink About20142850.tiff * CDPHE COLORADO IA CO Department of Public .- Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 RECEIVED Greeley, CO 80632 September 11, 2014 SEP 16 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 14, 2014, the Air Pollution Control Division will publish a public notice for Encana Oil Et Gas (USA), Inc - Marcus State 36H-M266, 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, 1, /) l c& C7 �k ca.,. Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 2014-2850 tel. PL, Pia 1 9 Rulo(.g,'aJtt3 �2m ��a iI 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I l,.„ > Tc0S John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer �y� Aa �" 9 a, , �;,,.�._IG CDPHE Public Notice Of A Proposed Project Or Activity Warranting Public CO Comment Website Title: Encana Oil Et Gas (USA), Inc - Marcus State 36H-M266 - Weld County Released To: The Greeley Tribune On: September 11, 2014 Published: September 14, 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 Et Gas (USA), Inc Facility: Marcus State 36H-M266 Exploration and Production Facility SWSW SEC 36 T2N R66W Weld County The proposed project or activity is as follows: Applicant proposes a new oil and gas production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 14WE0534 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO A 1 I w FT STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �°' AIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 . s 1876 CONSTRUCTION PERMIT PERMIT NO: 14WE0534 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 Marcus State 36H-M266, located in the SWSW of Section 36 Township 2N, Range 66W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate Fifteen (15) 500 BBL fixed roof storage tanks used to store Tanks 001 condensate. Emissions from these tanks are controlled by an enclosed flare. 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.dov/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 AIRS ID: 123/9C8C/001 Page 1 of 11 Condensate Tank SM/M Version 2012-1 olor-� Depa e f li Health and Environment it Pollution Control Division such constru or ' . • edu • t• •mmen as set forth in the permit application a - - - • '• • . 'i) • . - -s co 'on fora period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment Point NO, VOC CO Emission Type ID Condensate 001 2.29 58.55 12.47 Point Tanks See"Notes to Permit Holder'for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12)month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. AIRS ID: 123/9C8C/001 Page 2 of 11 olor Depa en f li Health and Environment it Pollution Control Division 8. The emission p V e bl elo sha e rated a maintained with the control equipment as -• n t e to I an or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Condensate 001 Enclosed Combustor VOC and HAP Loaout PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Condensate 001 Condensate Throughput 409,778 BBUyr Loaout The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. 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 10. The permit number and AIRS ID point number(e.g. 123/4567/890)shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 11. This source has been determined to be a storage vessel affected facility and is subject to the New Source Performance Standards requirements of Regulation No.6, Part A, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution. (40 CFR Part 60 §60.5395) 12. 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 AIRS ID: 123/9C8C/001 Page 3 of 11 olor Depa e f Ii Health and Environment 'r Pollution Control Division sixty consecut' -s. io con d s subj to Regulation 7, Sections XII.C.1.d or ' . . s a isi ions. rence: Regulation No. 1, Section II.A.1. &4.) 13. This source is subject to the odor requirements of Regulation No.2.(State only enforceable) 14. 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. 15. 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. 16. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions(State only enforceable). These requirements include, but are not limited to: XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII,it shall be enclosed,have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device,or by other convenient means approved by the Division,determine whether it is operating properly.The operator shall comply with all applicable requirements of Section XVII. XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown,whichever comes first. 17. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements.These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.If a combustion device is used,it must have a design destruction efficiency of at least 98%for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual,olfactory("AVO")and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment)at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven(7)days but must be conducted at least every thirty one(31)days.Monitoring is not required for storage tanks or associated equipment that are unsafe,difficult,or AIRS ID: 123/9C8C/001 Page 4 of 11 olor Depa en f li Health and Environment it Pollution Control Division inacces-''• • o or, s me n S tion XVI .1.e. The additional visual inspec - st i e, ini XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank)or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System("STEM")plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices,and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance.Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. AIRS ID: 123/9C8C/001 Page 5 of 11 olo Depa e f f Health and Environment it Pollution Control Division XVII.C.- n p to us chieve requirements of Sections . . .a. . .b. impl ing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b)A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty(30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 —Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions(tpy) Inspection Frequency >6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe,difficult,or inaccessible to monitor,as defined in Section XVII.C.1.e. XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification,and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request,including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b.The date and duration of any period where the thief hatch,pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance,gauging,or safety of personnel and equipment. XVII.C.3.c.The date and duration of any period where the air pollution control equipment is not operating. AIRS ID: 123/9C8C/001 Page 6 of 11 n Environment olor Depa en f li Health and Envir o it Pollution Control Division XVII.C.3.d. Wh!"> _ b ti de a is ein sed, th ate and result of any EPA Metho, "` or' ti ur ectio .C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 18. 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 19. The owner or operator shall demonstrate compliance with opacity requirements, 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 20. There are no periodic testing requirements under this section. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year,a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds(VOC)and nitrogen oxides sources(NOr)in ozone nonattainment areas emitting less than 100 tons of VOC or NO„ per year, a change in annual actual emissions of one (1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more,whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5)tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. AIRS ID: 123/9C8C/001 Page 7 of 11 olo Depa e f Health and Environment it Pollution Control Division b. Whene is ch ge the n or ope r of any facility, process, or activi c. Whenever new control equipment is installed,or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 22. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Parts C and D). 23. 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 24. 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. 25. 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. 26. 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. 27. 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. 28. 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 AIRS ID: 123/9C8C/001 Page 8 of 11 olor Depa en f li Health and Environment it Pollution Control Division Control DivisioD o ro ds t fo in Cobra Air Quality Control Act and regulations of •u o o QC , luding 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. 29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 30. 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: aittzte_______ Christopher Kester Oil and Gas Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. AIRS ID: 123/9C8C/001 Page 9 of 11 to Depa e f li Health and Environment it Pollution Control Division Notes to Permit HolderDf tt' uan 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&childoaoename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&oaaename=CBONWraooer 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (Ibyr) reportable? (Ibyr) Benzene 71432 8537 YES 427 Toluene 108883 12976 YES 649 001 n-Hexane 110543 49514 YES 2476 Ethylbenzene 100414 683 YES 34 Xylenes 1330207 3756 YES 188 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors Emission Factors Uncontrolled Controlled CAS# Pollutant lb/BBL lb/BBL Source Condensate Condensate Throughput Throughput — VOC 6.859 0.343 HYSYS Modeling — NO 0.068(Ib/MMBtu) - AP-42 - CO 0.37(lb/MMBtu) — AP 42 71432 Benzene 0.025 0.0013 HYSYS Modeling 108883 Toluene 0.038 0.0019 HYSYS Modeling 110543 n-Hexane 0.145 0.0073 HYSYS Modeling 100414 Ethylbenzene 0.002 • 0.0001 HYSYS Modeling , 1330207 Xylenes 0.011 0.0006 HYSYS Modeling AIRS ID: 123/9C8C/001 Page 10 of 11 olor Depa en f li Health and Environment it Pollution Control Division Note: The cont, I ssi s ors r p 00 re based n the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor/Major Source of: VOC and HAP NANSR Synthetic Minor/Major Source of: VOC and HAP MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.aov/ 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 7777-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://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9C8C/001 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil and Gas(USA) Inc. Permit Number: 14WE0534 Source Location: SWSW-36-2N-66W Equipment Description: Condensate Storage Tank AIRS ID: 123/9C8C/001 Date: 6/13/2014 Review Engineer: Christopher Kester Control Engineer: Stefanie Rucker Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval Transfer of Ownership APEN Exempt/Permit Exempt ' If tank is a true minor source at a true minor facility, it may be granted"Final Approval"without first being issued an Initial Approval permit 'Grandfathered exemption is for any tanks in service prior to December 30, 2002 Section 3—Applicant Completeness Review Was the correct APEN submitted for this source type? X Yes No Is the APEN signed with an original signature? X Yes No Was the APEN filled out completely? X Yes No Did the applicant submit all required paperwork? X Yes No Did the applicant provide ample information to determine emission rates? X Yes No If you answered"no"to any of the above, when did you mail an Information Request letter to the source? On what date was this application complete? April 30, 2014 Section 4—Source Description AIRS Point Equipment Description 001 15 above ground 500 bbl atmospheric condensate storage tanks Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section 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 Source provided site-specific emission factors using gas sample and E&P Tanks. 001 Will need to calculate emission factors from E&P Tanks. Did the applicant provide actual process data for the emission inventory? X Yes No Basis*Qr Potentito Emit IRPTE • AIRS Point Process Consumption/Throughput/Production 001 409,778 BBL per year Basis for Actual Emissions Resorted Sinethis APEN Fihna(Resorted to hwentorvt AIRS Point Process ConsumptioniThroughput/Production Data Year 001 341,481 BBL per year 2014 Bails for Penait siona(Permit Lhnitsl AIRS Point Process Consumption/Throughput/Production 001 409,778 BBL per year Does this source use a control device? X Yes No AIRS Point Process Control Device Description % Reduction Granted 001 01 Enclosed Combustor 95% Section 6—Emission Summary(tons per year) Point NO, VOC CO Single HAP Total HAP 5.12(Benzene); 29.7(n-Hexane); PTE: 001 2.75 1405.29 14.96 0.41 (EB); 45.27 7.79(Toluene); 2.25(Xylene) 4.26(Benzene); Uncontrolled point 24.8(n-Hexane); source emission rate: 001 — 1171.07 - 0.341 (EB); 36.08 6.49(Toluene); 1.878(Xylene) 0.213(Benzene); 1.23(n-Hexane); Controlled point 001 2.29 58.55 12.47 0.017(EB); 1.88 source emission rate: 0.324(Toluene); 0.093(Xylene) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled An in Controlled Emission Pollutant CAS# Emission Rate .•taco. OW) ble? Rate(ibM) Benzene 71432 8537 Yes 426.9 n-Hexane 110543 49514 Yes 2475 Ethylbenzene 100414 683.0 Yes 34.2 Toluene 108883 12976 Yes 648.8 Xylene 1330207 3756 Yes 187.8 Page 2 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 VOC, Liquids Analyses 001 01 HAPS PS Memo 05-01 according to PS Memo 05-01 Section 9—Source Classification Is this a new previously un-permitted source? X Yes No What is this facility classification? True X Synthetic Major Minor Minor Classification relates to what programs? X Title V PSD X NA NSR 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? -Facility is Synthetic Minor for VOC and HAP For Reg. 3, Part B, III.C.1.a(emissions increase>25/50 tpy)? Yes X 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 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, 001 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2—Odor Page 3 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-AiPENa . t aikirtPermit thmaratkist'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 I ton per year VOC) Part B—Construction Permit Exemptions 001 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility am greater than the 2.0 WY threshold(Reg.3,Part 8, Section II.D.3.a) Remittal ti--New _ •,1C."1 t NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. 001 Is this source greater than 19,800 gallons(471 bbl)?Yes Is this source subject to NSPS Kb?No There are 15 500bb1 tanks on site.This source is not applicable to NSPS Kb because it is located at an E&P Facility and is Pre-Custody Transfer. Reotikttlon 7—Volatile meound� XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks 001 since it Is located in a non-attainment area.) XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is currently subject to this since actual uncontrolled emissions am greater than 20 tpy of VOC. MACT EEEE: Organic Liquids Distribution Pick one: 001 • This source is not subject to MACT EEEE because it is not located at a major source of HAP. MACT HH 001 Pick one: • 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 Process Emission Pollutant/ Fugitive Control Point Process Description Factor CAS# (YIN) Emission Factor Source (%) 183.3 HYSYS and Tanks lb/1000 gal VOC No Modeling with Liquids 95 throughput Analysis 0.595 HYSYS and Tanks 01 Condensate lb/1000 gal Benzene/ No Modeling with Liquids 95 001 Storage Tanks throughput 71432 Analysis 3.45 n-Hexane HYSYS and Tanks lb/1000 gal /110543 No Modeling with Liquids 95 throughput Analysis SCC 40400311 —Fixed Roof Tank,Condensate,working+breathing+flashing losses Page 4 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) in the non-attainment area. Page 5 Air Pollutant Emission Notice(APEN)—and—Application for Construction Permit OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY Current Status(Check all thpt apply) Reason for APEN Submittal(Check all that apply) RECEIVED \\ AIRS ID#': 173 9CSC1 to I O APEN update only° I� 0 New or previously unreilorted battery O Modification to existing sources 4,' 14 20 iS ❑ Previously grandfathered battery2 O Registration for coverage under general permit no." 'I Rea �i ® Synthetic minor facility Pk &cancellation request for individual permit6:� s36o e, ® Located in the 8-hr Ozone Control Area3 c>3.2'1'1 0 Application for or Modification of an individual pe it ❑ Registered under general permit no.GPOI O Administrative permit amendment' ❑ Permitted under individual permit: 14'w G^_53 Q O Other:Register new Facility and anoly for Construction Permit For individual permit applications,check if you wants: O A copy of the preliminary analysis conducted by the Division ®To review a draft of the permit prior to issuance Company Name': 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.Berig@encana.com Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name": MARCUS STATE 36H-M266 Number of tanks: 15 Location12(QQ Sec.Twp.Range.): SWSW Sec.36 T2N R66W County: Weld Total tank capacity[bbl]: 7500 Calendar year for which"Actual"data applies13: projected Year(s)tank(s)were placed in service14: 2013 Control Description's: Enclosed Combustor Control Efficiency": 95 Condensate Throughput"[bN/year] Requested1s: 341481 Maximum for PTE calculation19: 409778 Actual20: While Controls Operational" 341481 Other equipment at facility22: produced water storage tank,VRU engines and condensate loadout Comments: Estimated emissions at throughputs listed above. Use NM for requested throughput/emission values unless requesting an individual permit O Check if the Division is to calculate emissions. ®Check if site-specific emission factors provided to calculate emission?. Emission Factor Battery Requested Emissions1° Actual Emission?) Pollutant24 [lb/bbl] PTE25 Uncontrolled26 Controlled2J Uncontrolled26 Controlled" VOC[tons/year] 6.859 1405.290 -- -- 1171.070 58.550 NOx[tons/year] 0.068 lb/MMbtu 2.750 -- -- -- 2.290 CO[tons/year] 0.37 lb/MMbtu 14.960 -- -- -- 12.470 Benzene[lbs/year] 0.025 10244.440 -- -- 8537.040 426.850 n-Hexane[lbs/year] 0.145 59417.770 — — 49514.810 2475.740 Wells serviced by this tank or tank batter? API It: 0512337440 Name: MARCUS STATE 3F-36H(M266) ®Newly Reported Well API#: 0512337442 Name: MARCUS STATE 3B-36H(M266) ®Newly Reported Well API it: 0512337443 Name: MARCUS STATE 3A-36H(M266) 0 Newly Reported Well API it: 0512337439 Name: MARCUS STATE 3D-36H(M266) ®Newly Reported Well API#: 0512337435 Name MARCUS STATE 3C-36H(M266) ®Newly Reported Well API it: 0512337437 Name: MARCUS STATE 3E-36H(M266) ®Newly Reported Well API if: Name: O 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. 03/11/2014 Signature of Legally Authori on(not a vendor or consultant) Date Adam Berig Lead,Air Quality Type or Print Name of Person Signing Above Official Title Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment !for information call: filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B 1 (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South 301 Z.85 registration to: Denver,CO 80246-1530 FORM APCD-205 Page I of 3APEN-E&P Condensate Storage Tank Battery NEW for MARCUS STATE 36H-M266 2014- 03-10 13-I 1-00.doc.doc CO \ / 02r / \ _ � - 2 � a / / \ � Ir / D © � ] en _ Z t_ ) _ ~ N o R - k 00 # - � I �� 2 \ R & J w i.: k © • \ § Sk / Tts U E 6 J k •5 co » ) z 2 k� O § 12 o o 1-5 - § z © f / < \ o a. z § k CO . . k - - ri & b ' ) » » 0 ® a _ $ 2 ) a E E � t + >. \ § 3 \ { W . c as — — — a) coLLI - ZE I • ) ffa ) \ « ° O - ] � 2 ce � k •` co k § , o o , ° \ : U \ i c � - | / k � � d § g § § « - _ � m u § 27 � U / E � � co/ CO I- - < 2 S ' k Ce O � k § /logo a Co O. * m e o ) 2 R Ill IX �.. k \ -o co « _▪ Q \ f f ■ - ' cv 2 m = p § / / _ w % m E r a @ . 1 < $ \ § § ) 2 = o ~ / { a , . 6 S _ ) /�, / / . ) in I / # § ) zE co ) - k2 Cl) / 7 } al � 2n22 © e c . � � k ; c \ % .z - n o , CO o Ce I { k § ( � n / % \ \ / \ ) a E a o O5 a w k cc e < z u_ Hello