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Home My WebLink About20142174.tiff• A CDPHE 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 1150O St PO Box 758 Greeley, CO 80632 RECEIVED September 18, 2014 SEP 2 3 2014 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On September 21, 2014, the Air Pollution Control Division will publish a public notice for Encana Oil & Gas (USA) Inc - Billings 34H-B268, 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 & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure co.. - P303-692-2000www.colorado.www.colorado.gov/cdphe — - - -4300 Cherry Creek Drive S., Denver, CO 80246 1530 g p ;F:/ John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer WMAA) /N]bss -29- �� et Pt:Tw, sr_ cl/23 20p-/-2)79 CDPHE Public Notice Of A Proposed Project CO ' ? Or Activity Warranting Public Comment Website Title: Encana Oil Et Gas (USA) Inc - Billings 34H-B268 - Weld County Released To: The Greeley Tribune On: September 18, 2014 Published: September 21, 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 a Gas (USA) Inc Facility: Billings 34H-B268 Oil and gas exploration and production facility NWNE Section 34, T2N, R68W Weld County The proposed project or activity is as follows: Oil and gas exploration and production facility consisting of condensate tanks, produced water tanks and a truck loadout. 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 14WE1077, 14WE1078 and 14WE1079 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 1 i& OtPRnpO LMIV ',,,, T F STATE OF COLORADO F s 06'C COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT � Q - , Q AIR POLLUTION CONTROL DIVISION „�,e,, „ TELEPHONE: (303)692-3150 a!g76• CONSTRUCTION PERMIT PERMIT NO: 14W E1077 077 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 Billings 34H-B268, located in the NWNE of Section 34, Township 2 North, Range 68 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: AIRS Description Point Eighteen (18) 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-permittinq-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: 123/9CE0 Page 1 of 11 Condensate Tank SM/M Version 2012-1 olor Depa e f bli Health and Environment it Pollution Control Division months or ms .o t to ion a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: AIRS Tons per Year Point Emission Type NO, VOC CO 001 4.0 70.8 21.9 Point See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) AIRS Control Device Pollutants Point Controlled 001 Enclosed combustor VOC and HAPS PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing 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 Process Parameter Annual Limit Point 001 Condensate throughput 355,148 BBUyr The owner or operator shall calculate monthly process rates based on the calendar month. AIRS ID: 123/9CE0 Page 2 of 11 ''' '' ... t..„1". Depaef .bliHealth and Environment it Pollution Control Division Compliance w' _ - n - yro _ li e det-, l ged on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. 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.) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XII. 12. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed, have no visible emissions during normal operations, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 14. 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. AIRS ID: 123/9CE0 Page 3 of 11 Depa e .f ' bli Health and Environment it Pollution Control Division 15. The storage - Polar er rm' 'ect t• -!ulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual, olfactory("AVO")and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7)days but must be conducted at least every thirty one(31)days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult,or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and 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 AIRS ID: 123/9CE0 Page 4 of 11 Color Depa' e 'Sf biHealth and Environment it Pollution Control Division during. ,,Zia-L, .p v easo ,�.! required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a documented Storage Tank Emission Management System ("STEM") plan to identify, evaluate, and employ appropriate control technologies, monitoring practices, operational practices, and/or other strategies designed to meet the requirements set forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as necessary to achieve or maintain compliance. Owners or operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i)STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty(30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor,as defined in Section XVII.C.1.e. AIRS ID: 123/9CE0 Page 5 of 11 Depa e 4 - bli Health and Environment •it Pollution Control Division XVII.C Polar T u e tion b - owner or operator that the selected STEM strategy(ies) are designed to minimize emissions from storage tanks and associated equipment at the facility(ies), including thief hatches and pressure relief devices. XVII.C.3. Recordkeeping XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C. must maintain records of STEM, if applicable, including the plan, any updates, and the certification, and make them available to the Division upon request. In addition, for a period of two (2) years, the owner or operator must maintain records of any required monitoring and make them available to the Division upon request,including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b.The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. OPERATING & MAINTENANCE REQUIREMENTS 16. 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 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) Periodic Testing Requirements 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Method 22 to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to AIRS ID: 123/9CE0 Page 6 of 11 Color Depa e f bli Health and Environment it Pollution Control Division one (1) minutes a, f ( ut uring al operation. (Reference: Regulation No. 7 Section XVII.All) ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN)shall be filed: (Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,per year,a change in annual actual emissions of one (1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5)tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR)shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Parts C and D). 21. MACT Subpart HH- National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this stationary source at any such time that this stationary source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9CE0 Page 7 of 11 olor Depa e .f bli Health and Environment it Pollution Control Division 23. If this permits•- st h ut ' has b- ranted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued,the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History AIRS ID: 123/9CE0 Page 8 of 11 Color Depa l: e� f bli Health and Environment it Pollution Control Division Issuance Je Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. Newly permitted condensate tanks at a synthetic minor facility. AIRS ID: 12319OE0 Page 9 of 11 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.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddlinkVew&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(lb/yr) Benzene 71432 A 7813 Yes 391 Toluene 108883 C 11720 Yes 586 001 Ethylbenzene 100414 C 355 Yes 18 Xylenes 1330207 C 4617 Yes 231 n-Hexane 110543 C 123947 Yes 6197 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/mm btu --- AP-42, Table 13.5-1 VOC 189.9136 lb/1000 9.4957 lb/1000 gal Engineering qal Calculation 110543 n-Hexane 8.3132 lb/1000 gal 0.4157 lb/1000 gal Engineering Calculation 71432 Benzene 0.5153 lb/1000 gal 0.0258 lb/1000 gal Engineering Calculation 108883 Toluene 0.7768 lb/1000 gal 0.0388 lb/1000 gal Engineering Calculation AIRS ID: 123/9CE0 Page 10 of 11 Color Depa e i yf :bli )Health and Environment •11ir Pollution Control Division i _ tt.0„act•R ra t„issio .a? ,..ors CAS# Pollutant Uncontrolled Controlled Source Throughput Throughput 100414 Ethylbenzene 0.0266 lb/1000 gal 0.0013 lb/1000 gal Engineering Calculation 1330207 Xylene 0.3084 lb/1000 gal 0.0154 lb/1000 gal Engineering Calculation Note: The controlled emissions factors for point 001 are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC 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.epoaccess.eov'% Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60,Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9CE0 Page 11 of 11 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 14WE1078 Source Location: Billings 34H-B268 NWNE Section 34,T2N, R68W, Weld County (non-attainment) Equipment Description: Produced water tanks AIRS ID: 123-9CE0-002 Date: August 19, 2014 Review Engineer: Stephanie Chaousy, PE Control Engineer: Chris Laplante 2—Action Section cCompleted 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 23, 2014 Section 4—Source Description AIRS Point Equipment Description 002 Three (3) above ground 230 bbl atmospheric produced water storage tanks. Emissions from these tanks are controlled by an enclosed combustor. Are"flash" emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? Mu) 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) Page 1 Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less X Yes No than 1%by volume crude oil on an average annual basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)805 Yes X No Rule? Section 5—Emission Estimate Information AIRS Point Emission Factor Source 002 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTEI AIRS Point Process Consumption/Throughput/Production 002 78970 BBL per year(65808 x 1.2)wastewater Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 65808 BBL per year wastewater 2013 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 65808 BBL per year wastewater 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 --- 10.3 0.87 1.1 (Hexane) Uncontrolled point 002 8.6 -- 0.72 0.95 source emission rate: (Hexane) Controlled point 002 0.4 0.04 0.05 source emission rate: (Hexane) Section 7—Non-Criteria/ Hazardous Air Pollutants Uncontrolled Are she Controlled Emission Pollutant CAS# BIN Emission Rate emissions (lb/yr) reportable? Rate(lb/yr) Benzene 71432 A 461 Yes 23 n-Hexane 110543 C 1448 Yes 72 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? 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? 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.iii (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. 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 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. Regulation 3-APENs. Construction Permits, Operating Permits, PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 002 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to file an APEN since emissions exceed 1 ton per year VOC) Part B—Construction Permit Exemptions 002 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 5.0 TPY threshold(Reg. 3, Part B, Section II.D.3.a) Regulation 6- New Source Performance Standards Page 3 Even though the APEN states that the tanks contain less than 1%by volume crude oil(division categorical exemption),the uncontrolled emissions are greater than 6 002 TPY,which would mean these tanks would be subject to NSPS OOOO. Since the operator is requesting a permitted limit less than 6 TPY, it is not subject to NSPS OOOO requirements. R-•ulation 7—Volatile Organic Compounds 002 None Regulation 8—Hazardous Air Pollutants 002 None Section 13—Aerometric Information Retrieval System Coding Information Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control Factor CAS# (Y/N) Source (%) 6.2381 VOC No CDPHE PS 95 lb/1000 gal Memo 09-02 01 Produced Water Storage a 1667 Benzene No CDPHE PS 95 002 Tanks lb/1000 gal Memo 09-02 0.5238 n-Hexane No CDPHE PS 95 lb/1000 gal Memo 09-02 SCC 40400315— Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 002 Produced Water Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Source does not meet the categorical exemption because uncontrolled emissions are greater than 6 TPY(NSPS OOOO threshold). Because they are requesting a permitted emission limit less than 6 TPY, the source will not be subject to NSPS OOOO. State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors (lb/1000 gal) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield,Denver, 6.2381 0.1667 0.5238 Douglas, Jefferson, Larimer and Weld Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 Page 4 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 14WE1077 Billings 34H-B268 Source Location: NWNE Section 34,T2N, R68W,Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9CE0-001 Date: August 19, 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 See Section 14 Information Request letter to the source? On what date was this application complete? May 23, 2014 Section 4—Source Description AIRS Point Equipment Description 001 Eighteen (18) above ground 400 bbl 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 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 001 Source may provide site-specific emission factors using gas sample, HYSYS (flashing)and EPA Tanks (working and breathing). See Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit IPTE) AIRS Point Process Consumption/Throughput/Production 001 426,178 BBL per year(355,148 x 1.2) Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 001 355,148 BBL per year 2014 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 001 355,148 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 NOs VOC CO Single HAP Total HAP PTE: 001 4.8 1699.7 26.3 74.4 (Hexane) 89.1 Uncontrolled point 001 4.0 1416.4 21.9 62.0 (Hexane) 74.1 source emission rate: Controlled point 001 4.0 70.8 21.9 3.1 (Hexane) 3.7 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (lb/yr) reportable? Rate(Ib/yr) Benzene 71432 A 7813 Yes 391 Toluene 108883 C 11720 Yes 586 Ethylbenzene 100414 C 355 Yes 18 Xylenes 1330207 C 4617 Yes 231 n-Hexane 110543 C 123947 Yes 6197 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 001 01 VOC, Regulation No.7 Section XVII.AII EPA Method 22 HAPS Page 2 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 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)? 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 11.O.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? These tanks have a capacity of 400 bbl each, therefore, they do not meet the criteria of this subpart. Page 3 Regulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks 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 are greater than 20 tpy of VOC.) Regulation 8—Hazardous Air Pollutants MACT EEEE: Organic 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—Aerometric Information Retrieval System Coding Information Process Emission Pollutant/ Fugitive Emission Factor Control Point Process Description Factor CAS# (Y/N) Source (%) 189.9136 Site-specific(HYSYS lb/1000 gal VOC No and EPA Tanks) 95 0.5153 Benzene/ Site-specific(HYSYS lb/1000 gal 71432 No and EPA Tanks) 95 0.7768 Toluene/ Site-specific(HYSYS 01 E&P Condensate lb/1000 gal 108883 No and EPA Tanks) 95 001 Storage Tanks 0.0266 Ethylbenzen Site-specific(HYSYS lb/1000 gal e/ 100414 N° and EPA Tanks) 95 0.3084 Xylenes/ Site-specific(HYSYS lb/1000 gal 1330207 No and EPA Tanks) 95 8.3132 n-Hexane/ Site-specific(HYSYS lb/1000 gal 110543 No and EPA Tanks) 95 SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks Operator used HYSYS and EPA tanks to generate emissions from the condensate tanks. The HYSYS model was based off of an extended gas analysis dated 04/09/2014. The gas analysis was performed less than a year of submittal. An updated extended gas analysis will not be required because an extended gas analysis was performed within a year of this submittal and included with this package. Using EPA tanks(Gasoline RVP-7)and HYSYS, the emissions calculated are as follows: Component EPA HYSYS Total Total Emission Emission Tanks (Ib/yr) uncontrolled uncontrolled factor factor (Ib/yr) (Ib/yr) (TPY) (lb/bbl) (lb/1000 gal) VOC 86304.78 3313048.644 3399353.42 1699.68 7.9764 189.9136 Benzene --- 9223.404 9223.404 4.61 0.0216 0.5153 Toluene --- 13904.748 13904.748 6.95 0.0326 0.7768 E-benzene --- 475.668 475.668 0.2378 0.0011 0.0266 Xylenes --- 5520.552 5520.552 2.76 0.0130 0.3084 n-hexane 148801.74 148801.74 74.4 0.3492 8.3132 The HAP emissions I calculated are a little different that what Encana calculated (although the emission factors are the same). I believe this is because of rounding issues in how each individually calculated their emissions. I will go with what Encana calculated: Component PTE Requested Emission (Ib/yr) (Ib/yr) factor(lb/bbl) Benzene 9376 7813 0.022 Toluene 14064 11720 0.033 E-benzene 426 355 0.001 Xylenes 5540 4617 0.013 n-hexane 148736 123947 0.349 The emissions listed on the APEN for xylenes were not correct. I emailed the operator on 8/19/14 requesting to redline the APEN. Page 5 • STATE OF COLORADO of_ce, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT �6 aA0 AIR POLLUTION CONTROL DIVISION - F ; �f �'I6r TELEPHONE: (303)692-3150 r 18 � * CONSTRUCTION PERMIT PERMIT NO: 14WE1078 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 Billings 34H-B268, located in the NWNE of Section 34, Township 2 North, Range 68 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Produced Three (3) 230 BBL fixed roof storage tanks used to store produced Water 002 water. Emissions from these tanks are controlled by an enclosed Tank 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 AIRS ID: 123/9CE0 Page 1 of 10 Produced Water Tank SMIM Version 2012-1 Color Depa e .f ` -bli ` Health and Environment it Pollution Control Division construction o. o as s- • h in the permit application associated with this permit; (ii)discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO, VOC CO Emission Type Produced 002 0.4 --- Point Water Tank See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Produced 002 Enclosed combustor VOC and HAPS Water Tank PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following processing rate as listed below. Annual records of the actual processing rate 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 AIRS ID: 123/9CE0 Page 2 of 10 Color Depa e1 f bliC°Health and Environment a it Pollution Control Division Produced Water 002 Produced water throughput 65,808 BBL/yr Tank The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. Records shall be kept in either an electronic file or hard copy provided that they can be promptly supplied to the Division upon request. All records shall be retained for a consecutive period of three years. STATE AND FEDERAL REGULATORY REQUIREMENTS 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 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. XVI1.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C emission control requirements. These requirements include, but are not limited to: Section XVII.C.1. Control and monitoring requirements for storage tanks XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six (6) tons per year based on a rolling twelve-month total must operate air pollution control equipment that achieves an 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. AIRS ID: 123/9CE0 Page 3 of 10 olor Depa e .f ` bli Health and Environment it Pollution Control Division XVII.C C • e ion 1.b. must be achieved by May 1, 2015. XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks constructed before May 1, 2014 subject to Section XVII.C.1. must conduct audio, visual, olfactory("AVO")and additional visual inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one(31)days. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult,or inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual inspections must include, at a minimum: XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other access point to ensure that they are closed and properly sealed; XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment; XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter and valves for piping of gas to the pilot light to ensure they are functioning properly; XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open; and XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the presence or absence of smoke. If smoke is observed, either the equipment must be immediately shut-in to investigate the potential cause for smoke and perform repairs, as necessary, or EPA Method 22 must be conducted to determine whether visible emissions are present for a period of at least one (1) minute in fifteen (15) minutes. XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it becomes feasible to do so. XVII.C.2.Capture and monitoring requirements for storage tanks that are fitted with air pollution control equipment as required by Sections XII.D. or XVII.C.1. XVII.C.2.a. Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment, and must operate without venting hydrocarbon emissions from the thief hatch (or other access point to the tank) or pressure relief device during normal operation, unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section XVII.C.2.b.(ii). 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 AIRS ID: 123/9CE0 Page 4 of 10 Color Depa e f bli Health and Environment it Pollution Control Division neces i c I Own- . operators are not required to develop and implement STEM for storage tanks containing only stabilized liquids. The minimum elements of STEM are listed below. XVII.C.2.b.(i) STEM must include selected control technologies, monitoring practices, operational practices, and/or other strategies; procedures for evaluating ongoing storage tank emission capture performance; and monitoring in accordance with approved instrument monitoring methods following the applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in Table 1. XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved instrument monitoring method in accordance with the following schedule: XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015. Approved instrument monitoring method inspections must begin within ninety (90) days of the Phase-In Schedule in Table 1, or within thirty (30) days for storage tanks with uncontrolled actual VOC emissions greater than 50 tons per year. XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 1. Table 1 — Storage Tank Inspections Threshold: Storage Tank Approved Instrument Phase-In Schedule Uncontrolled Actual VOC Monitoring Method Emissions (tpy) Inspection Frequency > 6 and < 12 Annually January 1, 2016 > 12 and < 50 Quarterly July 1, 2015 > 50 Monthly January 1, 2015 XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor,as defined in Section XVII.C.1.e. 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, AIRS ID: 123/9CE0 Page 5 of 10 olo Depa e f bli Health and Environment it Pollution Control Division for a p o erat st maintain records of any required monitoring and make them available to the Division upon request, including: XVII.C.3.a. The AIRS ID for the storage tank. XVII.C.3.b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance, gauging, or safety of personnel and equipment. XVII.C.3.c. The date and duration of any period where the air pollution control equipment is not operating. XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section XVII.C.1.d.(v). XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions. XVII.C.3.f. A list of equipment associated with the storage tank that is designated as unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an explanation stating why the equipment is so designated, and the plan for monitoring such equipment. 14. Minor sources in designated nonattainment or attainment/maintenance areas that are otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is nonattainment or attainment/maintenance. This source shall meet the requirements to apply RACT and reduce emissions by installing and operating an enclosed combustor(Reference: Regulation No. 3, Part B, III.D.2.a). OPERATING & MAINTENANCE REQUIREMENTS 15. 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 16. No compliance requirements under this section. ADDITIONAL REQUIREMENTS 17. 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 (NO,) in ozone nonattainment areas emitting less than one hundred tons of V0C or NO„per year, AIRS ID: 123/9CE0 Page 6 of 10 olor? Depa e n of bli °Health and Environment x r s it Pollution Control Division a Chan+ ua a ton •y ,;ar 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR)shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 19. 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. 20. 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. 21. 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. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. AIRS ID: 123/9CE0 Page 7 of 10 olo Depa e f bli Health and Environment it Pollution Control Division 23. Each and eve• ': • •n 's is part h 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. 24. 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. 25. 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. Newly permitted produced water tanks at a synthetic minor facility. AIRS ID: 123/9CE0 Page 8 of 10 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 maybe revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: http://www colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate (Ib/yr) Benzene 71432 A 461 Yes 23 002 n-Hexane 110543 C 1448 Yes 72 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 lb/BBL Produced Ib/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 Source 110543 n-Hexane 0.022 0.0011 Source 71432 Benzene 0.007 0.0004 Source Note: The controlled emissions factors for point 002 are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division.A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit.For any questions regarding a specific expiration date call the Division at(303)-692-3150. 7) This facility is classified as follows: AIRS ID: 123/9CE0 Page 9 of 10 olor Depa e f bli it PollutionHealthand Control DivisionEnvironment Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http/iecfr.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 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart)000 00( 9) A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at: httt ://www.colorado.cov/pacific/cdohe/air-permit-self-certification AIRS ID: 123/9CE0 Page 10 of 10 • Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil & Gas (USA) Inc. Permit Number 14WE1078 Billings 34H-B268 Source Location: NWNE Section 34,T2N, R68W, Weld County (non-attainment) Equipment Description: Produced water tanks AIRS ID: 123-9CE0-002 Date: August 19, 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 23, 2014 Section 4—Source Description AIRS Point Equipment Description 002 Three(3) above ground 230 bbl atmospheric produced water storage tanks. Emissions from these tanks are controlled by an enclosed combustor. Are"flash" emissions anticipated from these tanks? X Yes No Is this tank located at an E&P site? X Yes No Is this tank located at a non-E&P, midstream or Yes X No downstream site? Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? 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 PMio CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Page 1 Is this source claiming exempt status for this source based on the fraction of oil in the stored water(less than 1% by volume crude oil on an average annual X Yes No basis)? Are these produced water tanks located at a commercial facility that accepts oil production Yes X No wastewater for processing? Are these produced water tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)805 Yes X No Rule? Section 5—Emission Estimate Information AIRS Point Emission Factor Source 002 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02 Did the applicant provide actual process data for the emission inventory? Yes X No Basis for Potential to Emit(PTE) AIRS Point Process Consumption/Throughput/Production 002 78970 BBL per year(65808 x 1.2)wastewater Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory) AIRS Point Process Consumption/Throughput/Production Data Year 002 65808 BBL per year wastewater 2013 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 65808 BBL per year wastewater 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 — 10.3 — 0.87 1.1 (Hexane) Uncontrolled point 002 -- 8.6 — 0.72 0.95 source emission rate: (Hexane) Controlled point 0.04 source emission rate: 002 — 0.4 — (Hexane) 0.05 Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are me Controlled Emission Pollutant CAS# BIN Emission Rate emsslons (lb/yr) rePommex Rate(lb/yr) Benzene 71432 A 461 Yes 23 n-Hexane 110543 C 1448 Yes 72 Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on actual emissions without credit for reductions achieved by control devices used by the operator. Page 2 Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory Yes X No standard? 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? 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.iii (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. 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 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. Regulation 3-APENs, Construction Permits, Operating Permit yPSD 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 5.0 TPY threshold(Reg.3, Part B, Section/1.D.3.a) Regulation 6- New Source Performance Standards Page 3 Even though the APEN states that the tanks contain less than 1%by volume crude oil(division categorical exemption),the uncontrolled emissions are greater than 6 002 TPY,which would mean these tanks would be subject to NSPS OOOO. Since the operator is requesting a permitted limit less than 6 TPY, it is not subject to NSPS OOOO requirements. Regulation 7—Volatile Organic Compounds 002 None Regulation 8—Hazardous Air Pollutants 002 None Section 13—Aerometric Information Retrieval System Coding Information Emission Pollutant/ Fugitive Emission Factor Control Point Process Process Description Factor CAS# (Y/N) Source (%) 6.2381 CDPHE PS lb/1000 gal VOC No Memo 09-02 95 01 Produced Water Storage 0.1667 Benzene No CDPHE PS 95 002 Tanks lb/1000 gal Memo 09-02 0.5238 CDPHE PS lb/1000 gal n-Hexane No 95 Memo 09-02 SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses Section 14—Miscellaneous Application Notes AIRS Point 002 Produced Water Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). Source does not meet the categorical exemption because uncontrolled emissions are greater than 6 TPY (NSPS OOOO threshold). Because they are requesting a permitted emission limit less than 6 TPY, the source will not be subject to NSPS OOOO. State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors (lb/1000 gal) VOC Benzene n-Hexane Adams,Arapahoe, Boulder, Broomfield, Denver, 6.2381 0.1667 0.5238 Douglas, Jefferson, Latimer and Weld Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 _0.1667 0.5238 Page 4 Division Information Engineer: Stephanie Chaousy,PE Control Engineer: Chns Laplante Review Date. 08/19/2014 Application Date. 05/23/2014 SCC Code 40600132.Crude Oil:Submerged Loading(Normal Service) Facility Identifiers Permit No. 14WE1079 County# 123 Weld AIRs Facility# 9CE0 Point# 003 • Section 01: Administrative Information Company Name: Encana Oil 8 Gas(USA)Inc. Source Name: Billings 34H-8268 NWNE Section 34,T2N. R68W Source Location: SIC: 1311 Elevation(feet)4995 Portable Source' Portable Source Homebase Mailing Address 1. Encana Oil&Gas(USA)Inc. Address Address 2: Republic Plaza 370 17th Street,Suite 1700 City,State Zip- Denver.CO 80202 Name: Adam Beng Person To Phone: 720-876-3884 Contact Fax. 720-876-4884 Email adam benq(aencana.com AP-42:Chapter 5.2 Equation 1 L=12.46'S'P'M/T L=loading losses in lb per 1000 gallons loaded S=Saturation Factor P=true vapor pressure of liquid loaded[psia] M=molecular weight of vapors(Ibtb-mole] T=temperature of bulk liquid loaded(deg.RI 1 degree Fahrenheit=460.67 degree Rankine S 0.6 Submerged loading dedicated normal service P 4 2 Asia M 68 lb/lb-mole T 512 45 deg.R L 4.17 lb/10^3 gal I 750-01 lblbm Annual requested Throughput 17899459 gal/yr Annual requested VOC emissions 74579 lb/yr 37.29 tpy uncontrolled Controlled by an enclosed combustor: 1 86 tpy controlled Regulatory Considerations This facility is not condisdered a terminal(in Reg.7)because average daily throughput will be • below 20,000 gallons at 3,956 gallons per day. This facility is not considered a bulk plant On Reg.7)because it does not distribute gasoline. NCRPs emissions emissions emissions emissions (lb/yr)- (TPY)- (Ib/yr)- (TPY)- EF(woos • Component Wt%of VOC' uncontrolled unco ntrolled • • ea a nuea controlled controlled EF Itbtbbit gzU Benzene 0.94% n 701.0 0.35 35.05 002 0.0016 0.0392 Toluene 1.66% 12380 0.62 61.90 003 0.0029 0.0692 Ethylbenzene 0.07% 52.2 0.03 2.61 000 0.0001 0.0029 Xylenes 0.73% 544.4 0.27 2722 0.01 0.0013 0.0304 n-hexane 2.33% 1737.7 0.87 8688 0.04 00041 0.0971 W1%of VOC came from other surroundng fadlties estimation II r I STATE OF COLORADO OF COO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ew to, AIR POLLUTION CONTROL DIVISION E n TELEPHONE: (303) 692-3150 I{. CONSTRUCTION PERMIT PERMIT NO: 14WE1079 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 Billings 34H-B268, located in the NWNE of Section 34, Township 2 North, Range 68 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Hydrocarbon 003 Truck loadout of condensate. Emissions from the loadout Loadout are controlled by an enclosed combustor. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at https://www.colorado.qov/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 AIRS ID: 123/9CE0 Page 1 of 8 Condensate Loadout TM Version 2012-1 Co do p e o Public Health and Environment 1■�_ Air Pollution Control Division within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Equipment ID Point VOC Emission Type Hydrocarbon 003 1.9 Point Loadout See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 6. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Hydrocarbon 003 Enclosed combustor VOC and HAPS Loadout PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9CE0 Page 2 of 8 Colo do p e o Public Health and Environment Air Pollution Control Division 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits AIRS Process Parameter Annual Limit Point 003 Condensate Loading 426,177.6 BBL 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 8. This source is located in an ozone non-attainment or attainment-maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E. 9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 10. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations onsite at the time of inspections to monitor compliance with Condition 10 (a) and (b) above. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING & MAINTENANCE REQUIREMENTS AIRS ID: 123/9CE0 Page 3 of 8 Co do p e o Public Health and Environment Air Pollution Control Division 12. 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.) 13. Flare shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare, or by other convenient means approved by the Division, determine whether the flare is operating properly. 14. The owner or operator of a loadout at which vapor balancing is used to control emissions shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks and return these vapors to the enclosed combustor. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING 15. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 16. 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 (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per AIRS ID: 123/9CE0 Page 4 of 8 Col do p e o Public Health and Environment 9 Air Pollution Control Division year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 18. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 19. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 20. This permit is issued in reliance upon the accuracy and completeness of information supplied by the 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. AIRS ID: 123/9CE0 Page 5 of 8 Co do p e o Public Health and Environment Air Pollution Control Division It is valid only for the equipment and operations or activity specifically identified on the permit. 21. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 22. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a 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. 23. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Stephanie Chaousy, PE Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA), Inc. Newly permitted loadout at a synthetic minor facility. AIRS ID: 123/9CE0 Page 6 of 8 Cola do p et or Public Health and Environment Air Pollution Control Division • • Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: httc://vvww.colorado.qov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS # BIN (lb/yr) reportable? Rate(lb/yr) n-Hexane 110543 C 1738 Yes 87 Benzene 71432 A 701 Yes 35 003 Toluene 108883 C 1238 Yes 62 Ethylbenzene 100414 C 52 No 3 Xylenes 1330207 C 544 Yes 27 5) The emission levels contained in this permit are based on the following emission factors: Emission Factors - Emission Factors— Uncontrolled Controlled CAS Pollutant lb/BBL loaded Source Lb/BBL loaded Source Wt% VOC 0.175 AP-42 0.0088 AP-42 71432 Benzene 0.0016 Wt% 0.00008 Wt% 0.94 108883 Toluene 0.0029 Wt% 0.00015 Wt% 1.66 100414 Ethylbenzene 0.0001 Wt% 0.00001 Wt% 0.07 1330207 Xylenes 0.0013 Wt% 0.00007 Wt% 0.73 110543 n-Hexane 0.0041 Wt% 0.00021 Wt% 2.33 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) AIRS ID: 123/9CE0 Page 7 of 8 Co do p e o Public Health and Environment o Ft Air Pollution Control Division P (true vapor pressure) = 4.2 psia M (vapor molecular weight) = 68 Ib/Ib-mol T(temperature of liquid loaded) = 512.45°R The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the weight percent of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on an enclosed combustor efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-hexane, total HAPS NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A—Subpart KKKK NSPS Part 60, Appendixes Appendix A—Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A—Subpart Z MACT 63.600-63.1199 Subpart AA—Subpart DDD MACT 63.1200-63.1439 Subpart EEE—Subpart PPP MACT 63.1440-63.6175 Subpart QQQ—Subpart YYYY MACT 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: http://www.colorado.gov/pacific/cdphe/air-permit-selfcertification AIRS ID: 123/9CE0 Page 8 of 8 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#I: _ [ Z3 - c) CEO —O1)1 ❑ APEN updateonly4 _® New or previously unreported battery ❑ Modification to existing source` 41) ❑ Previously grandfathered battery2 ❑ Registration for coverage under general permit no:GP0I,, ® Synthetic minor facility &cancellation request for individual permit6: - - 7 ® Located in the 8-hr Ozone Control Area' ❑ Application for or Modification of an individual permit ❑ Registered under general permit no.GPO] ❑ Administrative permit amendment' - ❑ Permitted under individual permit:_ I LI 12 El 0? ❑ Other:coverage under contruct ion permit 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 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.Berig@encana.coin Contact Name: Adam Bed: Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name]I: Billings 3411-8268 Number of tanks: 18 Locationl2(QQ Sec.Twp. Range.): NWNE Sec. 34 T2N R68W County: Weld Total tank capacity[bbl]: 7200 Calendar year for which"Actual"data applies'3: projected Year(s)tank(s)were placed in service14: 2014 I Control Descriptions: Enclosed Combustor Control Efficiency16: 95 Condensate Throughputs'[bbl/year] Requestedls: 355]48 Maximum for PTE calculation19: 426178 Actual20: While Controls Operational21 355148 1 Other equipment at facility22: produced water tanks,condensate loadout Comments: J • Estimated emissions at throughputs listed above. Use NM 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 Emissionsls Actual Emissions20 Pollutant24 [lb/bbl] PTE25 Uncontrolled26 Controlled2J Uncontrolled26 Controlled21 VOC[tons/year] 7.976 1699.680 -- -- 1416.400 70.820 NOx[tons/year] 0.068 lb/MMbtu 4.830 -- -- -- 4.020 CO [tons/year] 0.37 lb/MMbtu 26.280 -- -- -- 21.900 Benzene[Ibs/year] 0.022 9375.910 -- -- 7813.260 390.660 n-Hexane[lbs/ ear] 0.349 148735.980 -- -- 123946.650 6197.330 Wells serviced by this tank or tank battery28 API #: 0512337110 Name: BILLINGS 1C-34H ®Newly Reported Well API #: 0512337105 Name: BILLINGS ID-34H ®Newly Reported Well API #: 0512337106 Name: BILLINGS IA-34H 0512337108 ®Newly Reported Well API#: Name: BILLINGS IF-34H ®Newly Reported Well I API#: 0512337109 Name BILLINGS 1E-34H ®Newly Reported Well API#: 0512337107 Name: BILLINGS IB-34H ®Newly Reported Well API#: Name: ❑Newl 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 GPO],I further certify that this source is and will be operated in full compl�ith each condition of eneral permit GPOI. /� 05/22/2014 Signature of Legally Authsernon (no . vendor or consultant) Date (_- ---' Adam Bed: Manager,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. 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