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HomeMy WebLinkAbout20142080.tiff STATE OF COLORADO John W. Hickenlooper,Governor Larry Wolk,MD,MSPH of•coto Executive Director and Chief Medical Officer rap!, Dedicated to protecting and improving the health and environment of the people of Colorado �k *� 4300 Cherry Creek Dr.S. Laboratory Services Division 'rave Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health www.colorado.gov/cdphe RECEIVED Environment Website Title: Encana Oil &Gas (USA) Inc.—Ione 10Hz—Weld County RECEIVE D Released To: Greeley Tribune JUL 10 2014 On: June 20, 2014 WELD COUNTY Published: June 25, 2014 COMMISSIONERS PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Encana Oil &Gas(USA) Inc. Facility: Ione 10Hz Gas Exploration and Production Facility NENE Sec. 10 T2N R66W Weld County The proposed project or activity is as follows: The applicant proposes to permit twenty-one (21)condensate storage tanks for a total battery capacity of 8400 bbl. In addition,the applicant proposes to permit the loadout operations at the Ion 10Hz facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3,Part B, Section 111.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.I.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application,the Division's analysis,and a draft of Construction Permit 14WE0259 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 www.colorado.gov/cdphe/AirPublicNotices 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 ROD"' Afijitlijet PL Ml tLie) ,lR 'tE(L 1 Cf J'M\ 2014-2080 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: David V.Thompson Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South,APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us • STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT A";of co AIR POLLUTION CONTROL DIVISION -, TELEPHONE: (303)692-3150 '*•••\116,J**. *1876#' CONSTRUCTION PERMIT PERMIT NO: 14WE0259 Issuance 1 DATE ISSUED: ISSUED TO: Encana Oil & Gas (USA) THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the lone 10Hz, located in the NENE Section 10 T2N R66W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Tanks 001 Twenty-One (21) above ground atmospheric condensate storage tanks with a combined capacity of 8400 bbl THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission(AQCC)Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days(180)after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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: 123/9C4A/001 Page 1 of 8 Condensate Tank SM/M Version 2012-1 T + Depa e f li Health and Environment it Pollution Control Division months or m Dolor t to ion w' 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 following information shall be provided to the Division within fifteen (15) days after issuance of permit. • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification,with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility AIRS Tons per Year Emission Type Equipment ID Point NOx VOC CO Tanks 001 53.8 Point See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID Tanks 001 Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS AIRS ID: 123/9C4A/001 Page 2 of 8 ' olor a :Depa en .4 • .li ^Health and Environment ill A it Pollution Control Division 8 This source s•J_ • it-„. •• t - -wi m pr+= ing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Tanks 001 Condensate Throughput 274354 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 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B). 12. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) 13. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General Provisions(State only enforceable). If a combustion device is used to control emissions of volatile organic compounds to comply with Section XII.D, it shall be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XII. 14. This source is subject to the recordkeeping, monitoring, reporting and emission control requirements of Regulation 7, Section XII. The operator shall comply with all applicable requirements of Section XII. 15. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to 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 AIRS ID: 123/9C4A/001 Page 3 of 8 Depa e f li Health and Environment • it Pollution Control Division device, or by Dolor p the ' n, determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 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 Condition 14, 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. These readings will be submitted with the Self Certification. (Reference: Regulation No. 7 Section XVII.AII) Periodic Testing Requirements 18. There are no periodic testing requirements for this source. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3, Part A, II.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC)and nitrogen oxides sources(NOx)in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or 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 AIRS ID: 123/9C4A/001 Page 4 of 8 ill olor Depa en .f • .li Health and Environment A it Pollution Control Division a a d. When; -'rm ,.� a, to=, , e•, st • -,• •s",.:-d, or ... e. No later than 30 days before the existing APEN expires. 20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted,then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit,the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the AIRS ID: 123/9C4A/001 Page 5 of 8 Depa e f li Health and Environment it Pollution Control Division Division in wri ' es ' ti ermit n notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under Sections 25-7-115 (enforcement),-121 (injunctions),-122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: David Thompson Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. AIRS ID: 123/9C4A/001 Page 6 of 8 a olor f Depa en f di Health and Environment it Pollution Control Division Notes to Permit Holder ' e o ''" •e " an ' 1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No.3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator 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=C8ONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s)operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS# (Ib/yr) reportable? (Ib/yr) Benzene 71432 7407.6 Yes 370.4 001 n-Hexane 110543 57888.7 Yes 2894.4 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Remove controlled emission factors if source not controlled. Only emission factors for pollutants above APEN thresholds are required. (i.e. if there is no VOC limit then don't need VOC emission factor). Emission Factors Emission Factors Uncontrolled Controlled CAS# Pollutant lb/BBL Ib/BBL Source Condensate Condensate Throughput Throughput VOC 7.85 E&P TANK 7.85 110543 n-Hexane 0.211 E&P TANK 0.211 71432 Benzene 0.027 E&P TANK 0.027 Note: The controlled emissions factors for point 001 are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated AIRS ID: 123/9C4A/001 Page 7 of 8 olor Depa e f li Health and Environment it Pollution Control Division with this permit. For io a p ion d I the Division at(303)-692- 3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD or NANSR Synthetic Minor Source of: VOC • MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.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 XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: www.coloradoxiov/cdphe/oilqaspermits AIRS ID: 123/9C4A/001 Page 8 of 8 II A STATE OF COLORADO ,CO� COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Fw= AIR POLLUTION CONTROL DIVISION »e' `�TELEPHONE: (303)692-3150 \74\141a876,1 CONSTRUCTION PERMIT PERMIT NO: 14WE0260 Issuance 1 DATE ISSUED: ISSUED TO: Encana Oil & Gas (USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the lone 10Hz, located in the NENE Section 10 T2N R66W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Condensate 002 Truck loadout of condensate. Emissions from the loadout Loadout are controlled by an enclosed flare THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days after issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.us/ap/downloadforms.html. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 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: 123/9C4A/002 Page 1 of 8 Condensate Loadout TM Version 2012-1 Co do p e o Pu and D Airblic PollutionHealth ControlEnvironment 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 Equipment Tons per Year ID AIRS Point Emission Type VOC Condensate 002 1.89 Point Loadout See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 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 Pollutants AIRS Point Control Device Equipment ID Controlled Condensate 002 Combustor VOC Loadout PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) AIRS ID: 123/9C4A/002 Page 2 of 8 Co do p e a Public Health and Environment I Air Pollution Control Division Process/Consumption Limits AIRS Process Parameter Annual Limit Point 002 Condensate Loading 329,224.4 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. 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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) 10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 11. 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 11 (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. 12. 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: 123/9C4A/002 Page 3 of 8 DCo do p e o PublicAir HealthPollution andControl EnvironmentDivision 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 that is controlled shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks and route the vapors to the control device listed in the equipment description of this permit. 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 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 AIRS ID: 123/9C4A/002 Page 4 of 8 Co A do Fe ' a Public Health and Environment Air Pollution Control Division 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 or Title V Operating Permit) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). 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. 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. AIRS ID: 123/9C4A/002 Page 5 of 8 Co do p e o Public PollutionHealthand Control DivisionEnvironment 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: David Thompson Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA) Inc. AIRS ID: 123/9C4A/002 Page 6 of 8 Co do p e o Public Health and Environment Air Pollution Control Division Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(lb/yr) n-Hexane 110543 C 1758 Yes 88 Benzene 71432 A 710 Yes 36 002 Toluene 108883 C 1253 Yes 63 Xylenes 1330207 C 551 Yes 28 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 VOC AP-42 AP-42 71432 Benzene AP-42 AP-42 The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.5 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 mass fraction of each NCRP in the vapors by the VOC emission factor. AIRS ID: 123/9C4A/002 Page 7 of 8 Co do p e o Pubro) lic PollutionHealthand Control DivisionEnvironment Controlled emission factors are based on a flare 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 PSD or 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 7777—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX 9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet. Please use this form to complete the self-certification requirements as specified in the permit P q P conditions. Further guidance on self-certification can be found on our website at: www.colorado.gov/cdohe/oiloaspermits AIRS ID: 123/9C4A/002 Page 8 of 8 Division Information Engineer: David Thompson Control Engineer: Chris Laplante Review Date: 05/14/2014 Application Date: 12/24/2013 Facility Identifiers Permit No. 14WE0259 & 14WE0260 AIRS County# 123 Weld Facility# 9C4A Facility Type: exploration and production facility Located in the 8-hour non-attainment area? O True Minor ®Synthetic Minor for: 17 VOC F NOx F CO Administrative Information Company Name: Encana Oil & Gas (USA) Source Name: lone 10Hz Source Location: NENE Section 10 T2N R66W SIC: 1311 Address 1: Encana Oil&Gas(USA) Mailing Address 2: Republic Plaza 370 17th St Suite 1700 Address ty,State Zip: Denver, CO 80202 Name: Adam Berig Person To Phone: 720-876-3884 Contact Fax: 720-876-4884 Email: adam.berig@encana.com 'Requested Action Self Certification Required? Yes Issuance Number: 1 Source Description: Oil and gas exploration and production facility known as the lone 10Hz, located in the NENE Section 10 T2N R66W,Weld County, Colorado. Point Name Type Control 001 Tanks Condensate Tanks Flare 002 Condensate Loadout Flare Loadout .- I I I I I 001 Twenty-One(21) above ground atmospheric condensate storage tanks with a combined cape Requsted Throughput 274354 bbl Control Flare Efficiency 95.00%I Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 7.85 lb/bbl 1076.83945 tpy 53.84197 tpy E&P TANK Benzene 0.027 lb/bbl 7407.558 lb/yr 370.3779 lb/yr E&P TANK n-Hexane 0.211 lb/bbl 57888.694 lb/yr 2894.435 lb/yr E&P TANK Regulatory Review Section II.A.1 -Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A(July, 1992)) in all subsections of Section II.A and B of this regulation. Section II.A.5-Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. 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 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7)or more volumes of odor free air. Regulation 6-New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. This source is not subject because each tank is less than 19,800 gallons (471 bbl) NSPS OOOO: for storage vessels in the natural gas production,transmission, and processing segments. This source is not subject because each tank emits less than 6 tpy VOC. Regulation 7—Volatile Organic Compounds XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... (Applicant is ubject to this since actual uncontrolled emissions are greater than 20 tpy of VOC.) 002 Truck Condensate Loadout • Calculations L= 12.46*S*P*M/T(AP-42:Chapter 5.2, Equation 1) L= loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source S Saturation Factor 0.6 AP-42 P True Vapor Pressure 5.5 psia Sales Oil Analysis M Molecular Weight of Var 68 lb/lb-mole AP-42 T Liquid Temperature 512.45 deg. R Field Data L 5.46 lb/10^3 gal 2.29E-01 lb/bbl Annual requested Throughput 329224.32 BBL/yr 13827421 gal/yr Annual requested V0C emissions 75445 lb/yr 37.72 tpy Control: Flare 1.8861256 Efficiency: 95.00% NCRPs Component Mass Fraction Benzene 0.0094 n-hexane 0.0233 Toluene 0.0166 Xylenes 0.0073 Source: Pressurized oil analysis Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source V0C 0.2292 lb/bbl 37.72 tpy 1.89 tpy AP-42 Benzene 0.0022 lb/bbl 709.18 lb/yr 35.46 Ib/yr AP-42 n-Hexane 0.0053 lb/bbl 1757.87 lb/yr 87.89 lb/yr AP-42 Toluene 0.0038 lb/bbl 1252.39 lb/yr 62.62 lb/yr AP-42 Xylenes 0.0017 lb/bbl 550.75 lb/yr 27.54 lb/yr AP-42 Regulatory Review !Regulation 7-Volatile Organic Compounds This facility is not condisdered aterminal (in Reg. 7)because average daily throughput will be below 20,000 gallons. This facility is not considered a bulk plant(in Reg. 7) because it does not distribute gasoline. 0 oo 0 Y C a f W K O Tog o *8 a r r r a nya ^ a ti ^ r z O z in J o 0 J z 0 o O rc C 5 F q z z z z m UO LL o > Q > z 0 a zna Z Z mrc n F o U 0 a i 0 0 � O> a z O x as m O o O 7 U col In—o Z Li O O 0 0 z 0 - 3 6 Z f r i_ O 00 a i_ c u 00 a a O 6 O C ^ o al d I a 0 J C a Q o0 W O 00 O U U O 1 J O O 0 0 Z K U O o 0 W I- LL > to m m n 3 " 8 eia '0(0 w d x o 0 0 Z To N o - E 3 a 0 a z - N z J_ co H co NCD C ^ i! 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E&P TANK 53.8 1076.8 95% Yes E&P TANK 370.4 7407.6 95% Yes E&P TANK 2894.4 57888.7 95% Yes AP-42 1.9 37.7 95% Yes AP-42 35.5 709.2 95% Yes AP-42 62.6 1252.4 95% Yes AP-42 27.5 550.7 95% Yes AP-42 87.9 1757.9 95% Yes 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) - ❑ APEN update only AIRS ID#I: 123 - ']CMA - 0 0 ® New or previously unreported battery ❑ Modification to existing sources -----..„_ ❑ Previously grandfathered battery2 ---- ❑ Registration for coverage under general permaji. 01 ® Synthetic minor facility AG &cancellation request for individual permits: 4��j3 ® Located in the 8-hr Ozone Control Area' 2li,/t,, 0 Application for or Modification of an individual permit ❑ Registered under general permit no. GPOI \ Administrative permit amendment? _i 0 Other:Application for Construction Permit for-COndensate ❑ Permitted under individual permit: [y WE:02.59 Storage Tanks 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 Address1s: Republic Plaza 370 17th St. Suite 1700 City: Denver State: CO Zip: 80202 E-mail: Adam.Berig@encana.com Contact Name: Adam Berig Phone: (720)876-3884 Fax: (720)876-4884 Tank Battery Name": lone 10 Hz Number of tanks: 21 Location"(QQ Sec.Twp.Range.): NENE Sec. 10 T2N R66W County: Weld Total tank capacity [bbl]: 8400 Calendar year for which"Actual"data applies1s: Projected Year(s)tank(s)were placed in service": 2013 Control Description's: Enclosed Combustor Control Efficiency's: 95 Condensate Throughput'?[bbUyear] Requested's: 274354 Maximum for PTE calculation19: 329224 Actual29: While Controls Operational' 274354 Other equipment at facility22: Producted Water Storage Tanks,Liquid Hydrocarbon Loadout,3 VRU engines Comments: Estimated emissions at throughputs listed above. Use NM for requested throughput/emission values unless requesting an individual permit O Check if the Division is to calculate emissions. ®Check if site-specific emission factors provided to calculate emissions23. Emission Factor Batter Requested Emissions's Actual Emissions'° Pollutant24 [Ib/bbl] PTEn Uncontrolled26 Controlled27 Uncontrolled26 Controlled27 VOC[tons/year] 7.85 1292.280 -- -- 1076.900 53.850 NOx[tons/year] 0.068 lb/MT/fbtu 2.760 -- -- -- 2.300 CO[tons/year] 0.37 lb/MMbtu 15.040 -- -- -- 12.540 Benzene[lbs/year] 0.027 8889.060 -- -- 7407.550 370.380 _n-Hexanefbs//ear] 0.211 69466.330 -- -- 57888.610 2894.430 Wells serviced by this tank or tank hatter? API#: 0512336775 Name: IONE 1E-10H 0 Newly Reported Well API#: 0512336780 Name: IONE 1G-10H 0 Newly Reported Well API#: 0512336774 Name: IONE IB-10H 0 Newly Reported Well API#: 0512336777 Name: IONE 1E-10H 0 Newly Reported Well API#: 0512336778 Name IONE IC-loll 0 Newly Reported Well API#: 0512336779 Name: IONE 1A-10H 0 Newly Reported Well API#: 0512336776 Name: IONE 1D-10H 0 Newly Reported Well The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of my knowledge and belief If this is a registration for coverage under general permit GPOI,I further certify that this source is and will be operated in full compliance with each condition of general permit GPOI. J 12/23/2013 Signature of Legally d of e (not a vendor or consultant) Date Adam Berig Lead,Air Quality Type or Print Name of Person Signing Above Official Title Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call: filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-B1 (303)692-3150 $250 General Permit fee for each new GP 4300 Cherry Creek Drive South 303599 registration to: Denver,CO 80246-1530 FORM APCD-205 Page 1 of 3 APEN-E&P Condensate Storage Tank Battery NEW for lone 10 Hz 2013-12-23 08-47- 23.doc.doc ° m a - 00 r o 0 0 0 0 ° E o 0 ,° E m .a 0 .k y y a. y ! en -4 - t t °.-° a T E �-. y 0 - p m m m c .. cts DI �V N m o q° 0° o Q 0 ck ` 'pWJ, g m I rn a. a o 0 o ❑ �4 UI • 0 c \O �° 9 .n r 0 L L a c 3 m 0 $ ❑ ❑ DOD W PqU. .'°->' a 00 y 000 3 y M _ v q a. W m `o e d .°�. ° ° m o ^O ]-' H c a G 0 0 0 0 0 i O ;° 0 °eg . C w a '' x OV o 0 s0 e. ns e . 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