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Home My WebLink About20141325.tiff STATE OF COLORADO John W.Hickenlooper,Governor F•co Larry Wolk,MD,MSPH 4,° to Executive Director and Chief Medical Officer Ne Dedicated to protecting and improving the health and environment of the people of Colorado rL i e j• 4300 Cherry Creek Dr.S. Laboratory Services Division 1816 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 and Environment Weld County -Clerk to the Board P0o 758 RECEIVED Greeley, CO 80632 APR 2 8 2014 April 22,2014 WELD COUNTY COMMISSIONERS': Dear Sir or Madam: On April 28, 2014,the Air Pollution Control Division will publish a public notice for Encana Oil &Gas (USA) Inc.—Liquids Handling Hub, 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-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, /; rte '. _ Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure TU-b eu CyL: Pt Lnim) P�( firn,ckr)Ift_CPI© Lf 1'301O ,-1 12g(l q 2014-1325 STATE OF COLORADO John W.Hickenlooper,Governor Larry Wolk, MD,MSPH .oe coLQ� Executive Director and Chief Medical Officer �� '- Dedicated to protecting and improving the health and environment of the people of Colorado *6l c '�* 4 4300 Cherry Creek Dr.S. Laboratory Services Division .•1876 * 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 and Environment Website Title: Encana Oil & Gas (USA) Inc.—Liquids Handling Hub—Weld County Released To: The Greeley Tribune On: April 22, 2014 Published: April 28, 2014 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: Liquids Handling Hub Liquids handling facility Intersection of County Road 5 and County Road 6 Weld County The proposed project or activity is as follows: New liquids handling facility going to public comment for two(2) produced water tanks and 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.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 Permits 13 WE2646, 13WE2645, 13 WE2647 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 h ut 51 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISIONi TELEPHONE:(303)692-3150 + 40,101): 41876• CONSTRUCTION PERMIT PERMIT NO: 1 3WE2646 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 Liquids Handling Hub, located at County Road 5 and County Road 6 in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Produced Two (2) above ground 5,000 bbl atmospheric produced water Water 002 storage tanks. Emissions from these tanks are controlled by an Tanks 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 commencement of operation, 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 commencement of operation, 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 AIRS ID: 123/9BCB Page 1 of 8 Produced Water Tank SM/M Version 2012-1 olor. . Depa, e .f bli 'Health and Environment 0it Pollution Control Division Produced Water 002 Enclosed combustor VOC Tanks PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following processing rate 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 Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID Produced 1,825,000 155,000 Water 002 Produced water throughput BBL/yr BBL/month Tanks The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations shall be required. After the first twelve (12) months of operation, compliance with only the annual limitation shall be required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 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. 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). AIRS ID: 123/9BCB Page 3 of 8 olor :A:= Depa e f bli '`Health and Environment it Pollution Control Division 17. This permit a ac oi •e rA1' • - d maa,= ailable 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. 18. 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. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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 AIRS ID: 123/9BCB Page 5 of 8 olor Depa e f bli Health and Environment it Pollution Control Division Notes to Permit HolderDR 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=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# (Ib/yr) reportable? Rate (lb/yr) Benzene 71432 12,775 Yes 639 002 n-Hexane 110543 40,150 Yes 2,008 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 lb/BBL Produced Water Throughput Water Throughput VOC 0.262 0.0131 PS Memo 09-02 110543 n-Hexane 0.022 0.0011 PS Memo 09-02 71432 Benzene 0.007 0.0004 PS Memo 09-02 Note: The controlled emissions factors for point 002 are based on the enclosed combustor control efficiency of 95%. AIRS ID: 123/9BCB Page 7 of 8 olor Depa e f bli Health Pollution andControl EnvironmentDivision it 6) In accordance with a of ' sion N (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, benzene,toluene, xylenes, 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: Mtp://ecfr.ppoaccess.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.colorado.qov/cdphe/oilqaspermits AIRS ID: 123/9BCB Page 8 of 8 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil and Gas (USA) Inc. Permit Number: 13WE2646 Source Location: Liquids Handling Hub County Rd 5 and County Rd 6, Weld County (non-attainment) Equipment Description: Produced water tanks AIRS ID: 123-9BCB-002 Date: 10/30/13; Picked up again after receiving revised application 4/1/14. 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? Initial application: August 14, 2013. On what date was this application complete? Received a modification on 3/26/14. Section 4—Source Description AIRS Point Equipment Description 002 Two (2)above ground 5000 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? Yes X No Is this tank located at a non-E&P, midstream or X Yes 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 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 Yes X 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(PTA AIRS Point Process Consumption/Throughput/Production 002 2,190,000 BBL per year(1,825,000 x 1.2)wastewater Basis for Actual Emissions Repotted Durina this APEN Fiiina (Reported to inventon4 AIRS Point Process Consumption/Throughput/Production Data Year 002 1,825,000 BBL per year wastewater 2013 Basis for Permitted Emissions(Permit Limits) AIRS Point Process Consumption/Throughput/Production 002 1,825,000 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 --- 286.9 --_ 24.1 31.8 (Hexane) Uncontrolled point 002 239.1 _ 20.1 26.5 source emission rate: (Hexane) Controlled point 002 12.0 - 1.0 1.3 source emission rate: (Hexane) Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled creme Controlled Emission Pollutant CAS# BIN Emission Rate emissions (III/yr) reportable? Rate(Ibtyr) Benzene 71432 A 12,775 Yes 639 n-Hexane 110543 C 40,150 Yes 2,008 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? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method 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 lton per year VOC) Part B—Construction Permit Exemptions 002 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg.3, Part B, Section II.D.2.a) Regulation 6- New Source Performance Standards Page 3 002 None Regulation 7—Volatile Oroanic Compound$ 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 0.1667 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). State-Developed Emission factors in lb/1000 gal are: Produced Water Tank Default County Emission Factors(lb/1000 gal) �,,� VOC Benzene n-Hexane Q, � ,4�$ms; `ahea.Boulder,Broomfield, Denver, 6,2381 01,70, 0.5238 a L" Lt r :3'C Pte.;(a and - Garfield, Mesa, Rio Blanco and Moffat 4.2381 0.0952 0.2381 Remainder of Colorado 6.2381 0.1667 0.5238 Page 4 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT rAIR POLLUTION CONTROL DIVISION TELEPHONE:(303)692-3150 Y f8T6* CONSTRUCTION PERMIT PERMIT NO: 13WE2645 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 Liquids Handling Hub, located at the intersection of County Road 5 and County Road 6, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID Oil Three (3) 35,000 BBL floating internal roof storage tanks used to Storage 001 store condensate. Emissions from these tanks are controlled using Tanks a floating internal roof. 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 seg),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 commencement of operation, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.cdphe.state.co.usfap/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 commencement of operation, 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 AIRS ID: 123/9BCB Page 1 of 12 Condensate Tank SM/M Version 2012-1 olor Depa e f bli Health and Environment it Pollution Control Division application as it ' p i)d' s con tion 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 complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: per AIRS Pounds Month Equipment ID Point NO, VOC CO Emission Type Oil Storage 001 ---- 2,633 --- Point Tanks (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment ID Point NO VOC CO Emission Type „ Oil Storage 001 --- 15.5 --- Point Tanks See°Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. AIRS ID: 123/9BCB Page 2 of 12 Jd. olor. ^ Depa e .f ' bli Health and Environment it Pollution Control Division 7. The emission ;fie • th •le( m „ sh- • - ated ; aintained 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 Oil Storage 001 Floating internal roof VOC Tanks PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Annual Monthly Limit Equipment Point Process Parameter Limit (31 days) ID Oil Storage 001 Condensate throughput 9,125,000 775,000 Tanks BBUyr BBL/month The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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. 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. AIRS ID: 123/9BCB Page 3 of 12 olor Depa e f bli Health and Environment it Pollution Control Division 13. The stabilized at k d S p ' 1 are subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels(Including Petroleum Liquid Storage Vessels)for which Construction, Reconstruction,or Modification Commenced after July 23, 1984 including, but not limited to, the following: • 40 CFR, Part 60, Subpart A—General Provisions • §60.112b-Standard for volatile organic compounds (VOC) • §60.112b(a) The owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 containing a VOL that, as stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa but less than 76.6 kPa...shall equip each storage vessel with one of the following: • §60.112b(a)(1) A fixed roof in combination with an internal floating roof meeting the following specifications: • §60.112b(a)(1)(i)The internal floating roof shall rest or float on the liquid surface (but not necessarily in complete contact with it) inside a storage vessel that has a fixed roof. The internal floating roof shall be floating on the liquid surface at all times, except during initial fill and during those intervals when the storage vessel is completely emptied or subsequently emptied and refilled. When the roof is resting on the leg supports, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible. • §60.112b(a)(1)(ii) Each internal floating roof shall be equipped with one of the following closure devices between the wall of the storage vessel and the edge of the internal floating roof: • (A) A foam- or liquid-filled seal mounted in contact with the liquid (liquid-mounted seal). A liquid-mounted seal means a foam-or liquid-filled seal mounted in contact with the liquid between the wall of the storage vessel and the floating roof continuously around the circumference of the tank. • (B) Two seals mounted one above the other so that each forms a continuous closure that completely covers the space between the wall of the storage vessel and the edge of the internal floating roof. The lower seal may be vapor-mounted, but both must be continuous. • (C)A mechanical shoe seal. A mechanical shoe seal is a metal sheet held vertically against the wall of the storage vessel by springs or weighted levers and is connected by braces to the floating roof. A flexible coated fabric (envelope) spans the annular space between the metal sheet and the floating roof. • §60.112b(a)(1)(iv) Each opening in the internal floating roof except for leg sleeves, automatic bleeder vents, rim space vents, column wells, ladder wells, sample wells, and stub drains is to be equipped with a cover or lid which is to be maintained in a closed position at all times (i.e., no visible gap) except when the device is in actual use. The cover AIRS ID: 123/9BCB Page 4 of 12 olor••, Depa" e f '+ bli Health and Environment ` it Pollution Control Division A s .+, •e ='a .,•-d )(,• - ket •ncq on each access hatch and automatic gauge float well shall be bolted except when they are in use. • §60.112b(a)(1)(v) Automatic bleeder vents shall be equipped with a gasket and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on the roof leg supports. • §60.112b(a)(1)(vi) Rim space vents shall be equipped with a gasket and are to be set to open only when the internal floating roof is not floating or at the manufacturer's recommended setting. • §60.112b(a)(1)(vii) Each penetration of the internal floating roof for the purpose of sampling shall be a sample well. The sample well shall have a slit fabric cover that covers at least 90 percent of the opening. • §60.112b(a)(1)(viii) Each penetration of the internal floating roof that allows for passage of a column supporting the fixed roof shall have a flexible fabric sleeve seal or a gasketed sliding cover. • §60.112b(a)(1)(ix) Each penetration of the internal floating roof that allows for passage of a ladder shall have a gasketed sliding cover. • §60.113b—Testing and procedures • The owner or operator of each storage vessel as specified in §60.112b(a) shall keep records and furnish reports as required by paragraphs(a), (b), or(c)of this section depending upon the control equipment installed to meet the requirements of§60.112b. The owner or operator shall keep copies of all reports and records required by this section, except for the record required by (c)(1), for at least 2 years. The record required by (c)(1) will be kept for the life of the control equipment. • §60.113b(a)(1)Visually inspect the internal floating roof,the primary seal,and the secondary seal (if one is in service), prior to filling the storage vessel with VOL. If there are holes, tears, or other openings in the primary seal,the secondary seal, or the seal fabric or defects in the internal floating roof, or both, the owner or operator shall repair the items before filling the storage vessel. • §60.113b(a)(2) and (3) If the roof is equipped with a liquid mounted or mechanical shoe primary seal or a double seal system then the testing will follow the procedures outlined in §60.113b(a)(2) or (3), respectively. • §60.113b(a)(4)Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is emptied and degassed. If the internal floating roof has defects, the primary seal has holes, tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears, or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area, the owner or operator shall repair the items as necessary so that none of the conditions specified in this paragraph exist before refilling the storage vessel with VOL. In no event shall inspections AIRS ID: 123/9BCB Page 5 of 12 olor Depa e f bli Health and Environment it Pollution Control Division co a ' h t 'on oc intervals greater than 10 years in the case of vessels conducting the annual visual inspection as specified in paragraphs (a)(2) and (a)(3)(ii) of this section and at intervals no greater than 5 years in the case of vessels specified in paragraph (a)(3)(i) of this section. • §60.113b(a)(5) Notify the Administrator in writing at least 30 days prior to the filling or refilling of each storage vessel for which an inspection is required by paragraphs (a)(1) and (a)(4) of this section to afford the Administrator the opportunity to have an observer present. If the inspection required by paragraph (a)(4) of this section is not planned and the owner or operator could not have known about the inspection 30 days in advance or refilling the tank, the owner or operator shall notify the Administrator at least 7 days prior to the refilling of the storage vessel. Notification shall be made by telephone immediately followed by written documentation demonstrating why the inspection was unplanned. Alternatively, this notification including the written documentation may be made in writing and sent by express mail so that it is received by the Administrator at least 7 days prior to the refilling. • §60.115b— Reporting and recordkeeping requirements • §60.115b(a)After installing control equipment in accordance with§60.112b(a)(1) (fixed roof and internal floating roof), the owner or operator shall meet the following requirements. • §60.115b(a) (1) Furnish the Administrator with a report that describes the control equipment and certifies that the control equipment meets the specifications of§60.112b(a)(1) and §60.113b(a)(1). This report shall be an attachment to the notification required by§60.7(a)(3). • §60.115b(a) (2) Keep a record of each inspection performed as required by §60.113b (a)(1), (a)(2), (a)(3), and (a)(4). Each record shall identify the storage vessel on which the inspection was performed and shall contain the date the vessel was inspected and the observed condition of each component of the control equipment (seals, internal floating roof, and fittings). • §60.115b(a) (3) If any of the conditions described in §60.113b(a)(2) are detected during the annual visual inspection required by§60.113b(a)(2), a report shall be furnished to the Administrator within 30 days of the inspection. Each report shall identify the storage vessel, the nature of the defects, and the date the storage vessel was emptied or the nature of and date the repair was made. • §60.115b(a) (4)After each inspection required by§60.113b(a)(3) that finds holes or tears in the seal or seal fabric, or defects in the internal floating roof, or other control equipment defects listed in §60.113b(a)(3)(ii), a report shall be furnished to the Administrator within 30 days of the inspection. The report shall identify the storage vessel and the reason it did not meet the specifications of§61.112b(a)(1) or§60.113b(a)(3)and list each repair made. • §60.116b—Monitoring of operations • §60.116b(a)The owner or operator shall keep copies of all records required by this section, except for the record required by paragraph(b)of this section, for at AIRS ID: 123/9BCB Page 6 of 12 . i olor * Depa e +f bli Health and Environment f ` 'it Pollution Control Division lea., T,r ._c +. ir-=e , + , .raph ,4t this section will be kept for the life of the source. • §60.116b(b) The owner or operator of each storage vessel as specified in §60.110b(a) shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. • §60.116b (c) Except as provided in paragraphs (f) and (g) of this section, the owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa or with a design capacity greater than or equal to 75 m3 but less than 151 m3 storing a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa shall maintain a record of the VOL stored, the period of storage, and the maximum true vapor pressure of that VOL during the respective storage period. • §60.116b (d) Except as provided in paragraph (g) of this section, the owner or operator of each storage vessel either with a design capacity greater than or equal to 151 m3 storing a liquid with a maximum true vapor pressure that is normally less than 5.2 kPa or with a design capacity greater than or equal to 75 m3 but less than 151 m3 storing a liquid with a maximum true vapor pressure that is normally less than 27.6 kPa shall notify the Administrator within 30 days when the maximum true vapor pressure of the liquid exceeds the respective maximum true vapor vapor pressure values for each volume range. • §60.116b(e) Available data on the storage temperature may be used to determine the maximum true vapor pressure as determined below. • §60.116b(e) (2) For crude oil or refined petroleum products the vapor pressure may be obtained by the following: • §60.116b(e) (2) (i) Available data on the Reid vapor pressure and the maximum expected storage temperature based on the highest expected calendar-month average temperature of the stored product may be used to determine the maximum true vapor pressure from nomographs contained in API Bulletin 2517 (incorporated by reference—see §60.17), unless the Administrator specifically requests that the liquid be sampled, the actual storage temperature determined, and the Reid vapor pressure determined from the sample(s). • §60.116b(e) (2) (ii) The true vapor pressure of each type of crude oil with a Reid vapor pressure less than 13.8 kPa or with physical properties that preclude determination by the recommended method is to be determined from available data and recorded if the estimated maximum true vapor pressure is greater than 3.5 kPa. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. AIRS ID: 123/9BCB Page 7 of 12 olor Depa e f bli Health and Environment it Pollution Control Division Deter JJ c erati d maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c. Written notification of construction and initial startup dates shall be submitted to the Division as required under§ 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under§ 60.7. e. Written notification of opacity observation or monitor demonstrations shall be submitted to the Division as required under§ 60.7. f. Excess Emission and Monitoring System Performance Reports shall be submitted as required under§ 60.7. g. Performance tests shall be conducted as required under§ 60.8. h. Compliance with opacity standards shall be demonstrated according to § 60.11. OPERATING & MAINTENANCE REQUIREMENTS 14. 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 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 30'"whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or 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 AIRS ID: 123/9BCB Page 8 of 12 D olor 4 Depa 4 e . 4bli <Health and Environment } it Pollution Control Division . a For so-'._ , itti•. • '0 r . - .er :=r ii ore, -; s,-nge 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 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 P 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. 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 AIRS ID: 123/9BCB Page 9 of 12 olor Depa e f bli Health and Environment it Pollution Control Division and upon suc c p • all d de ' b initio. This permit maybe 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 condensate tanks at a synthetic minor facility. AIRS ID: 123/9BCB Page 10 of 12 olor Depa e ff ' bli Health and Environment it Pollution Control Division iror Y Notes to Permit Holder = `" of .e 'ban " 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&childpapename=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# (Ib/yr) reportable? Rate(lb/yr) Benzene 71432 4,835 No 54 001 Hexane 110543 42,357 Yes 474 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Emission Factors Emission Factors Uncontrolled Controlled CAS# Pollutant lb/1000 gal lb/1000 gal Source Condensate Condensate Throughput Throughput VOC 7.2094 0.0807 Source 110543 n-Hexane 0.1105 0.0012 Source 71432 Benzene 0.0126 0.0001 Source Note: The controlled emissions factors for point 001 are based on the floating internal roof control efficiency of 98.88%. AIRS ID: 123/9BCB Page 11 of 12 olo DepF f bli Health and Environment it Pollution Control Division 6) In accordance with a of n N (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, benzene,toluene,xylenes, 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://ec fr.gnoacres s.aov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End SubpartA—SubpartKKKK 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 XXXX(X 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.colorado.00v/cdphe/ciloasperm its AIRS ID: 123/9BCB Page 12 of 12 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 13WE2645 Source Location: Liquids Handling Hub County Road 5 and County Road 6,Weld County (non-attainment) Equipment Description: Condensate tanks AIRS ID: 123-9BCB-001 Date: 10/30/13; Picked up again after receiving revised application 4/1/14. 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? Initial application: August 14, 2013. On what date was this application complete? Received a modification on 3/26/14. Section 4—Source Description AIRS Point Equipment Description Three(3) above ground 35,000 bbl atmospheric condensate storage tanks. 001 Emissions from these tanks are controlled using a floating roof. The floating roof will have a destruction efficiency of a minimum of 95%. Is this a portable source? Yes X No Is this location in a non-attainment area for any criteria X Yes No pollutant? If"yes", for what pollutant? PM10 CO X Ozone Is this location in an attainment maintenance area for Yes X No any criteria pollutant? If"yes", for what pollutant? (Note: These pollutants are subject to minor source PM10 CO Ozone RACT per Regulation 3, Part B, Section III.D.2) Is this source located in the 8-hour ozone non- attainment region?(Note: If"yes" the provisions of X Yes No Regulation 7, Sections XII and XVII.C may apply) Page 1 Section 5—Emission Estimate Information AIRS Point Emission Factor Source Source provided site-specific emission factors using EPA Tanks 4.0.9d (working + 001 breathing). Flash emissions are not anticipated from these tanks. Refer to Section 14 for calculations. Did the applicant provide actual process data for the emission inventory? Yes X No Pasts for Potential to Emit friTilt AIRS Point Process Consumption/Throughput/Production 001 10,950,000 BBL per year(9,125,000 x 1.2) Basis for Actual Emissions + _ Amino thisAPEN P ( ported to Inventon) AIRS Point Process Consumption/Throughput/Production Data Year 001 9,125,000 BBL per year 2013 Basis for Permitted Emissions(Permit Jt AIRS Point Process Consumption/Throughput/Production 001 9,125,000 BBL per year Does this source use a control device? Yes X No Section 6—Emission Summary (tons per year) Point NO„ VOC CO Single HAP Total HAP PTE: 001 --- 1381.5 --- 21.2 (n-hexane) 23.6 Uncontrolled point 001 — 1381.5 — 21.2 (n-hexane) 23.6 source emission rate: Controlled point 001 --- 15.5 --- 0.24(n-hexane) 0.26 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Rate Pollutant CAS# Emission Rate emsusns (Iblyr) reporbms? (Iblyr) The threshold for all reportable HAP emissions is 250 lb/yr Benzene 71432 4,835 Yes 54 n-Hexane 110543 42,357 Yes 474 Note: Regulation 3, Part A, Section ll.B.3.b APEN emission reporting requirements for non-criteria air pollutants are based on potential emissions without credit for reductions achieved by control devices used by the operator. Section 8—Testing Requirements Will testing be required to show compliance with any emission rate or regulatory X Yes No standard? If"yes", complete the information listed below AIRS Point Process Pollutant Regulatory Basis Test Method VOC, Liquids Analyses 001 01 HAPS PS Memo 05-01 according to PS Memo 05-01 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 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?VOC For Reg. 3, Part B, III.C.1.a (emissions increase > 25/50 tpy)? (total X Yes No facility delta change in emissions) For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No For Reg. 3, Part B, III.C.1.d(synthetic minor emission limits)? X Yes No Section 11 —Modeling Is modeling required to demonstrate compliance with National Ambient Yes X No Air Quality Standards (NAAQS)? If"yes", for which pollutants?Why? AIRS Point Section 12— Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which 001 is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15-second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Regulation 2—Odor Section I.A- No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are 001 measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3-APENs Construction Permits. Operating Permits PSD Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 001 each individual emission point in a non-attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant(pollutants are not summed) for which the area is non-attainment. (Applicant is required to rile 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 lLD.2.a) Regulation 6- New Source Performance Standards NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84. 001 Is this source greater than 19,800 gallons (471 bbl)? Yes Is this source subject to NSPS Kb?Yes WHY? Source is greater than 19,800 gallons and does not meet the exemption. Page 3 • Regulation 7-Volatile Organic canpouncle XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS (Applicant is subject to the emission control requirements for condensate tanks since it is located in an attainment area.) ' XVII STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS... XVII.A.15. "Storage Tank"means any fixed roof storage vessel or series of storage vessels that are manifolded together via liquid line. Storage vessel is as defined in 40 CFR Part 60, Subpart OOOO. Storage tanks may be located at a well production facility or other location. 001 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, except where the combustion device has been authorized by permit prior to May 1, 2014. These tanks are subject to Regulation 7 even though they are subject to emission standards in NSPS Kb. Regulation 8—HazardoutA r Pojlytante 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 Point Process Process Emission Pollutant/ Fugitive Emission Factor Source Control Description Factor CAS# (YIN) (%) • 7.2094 V0C No Tanks 4.0.9d 98.88 lb/1000 gal Condensate 0.0126 Tanks 4.0.9d and State 01Benzene No 98.88 001 Storage Tanks lb/1000 gal emission factor ratio 0.1105 Tanks 4.0.9d and State lb/1000 gal n-hexane No emission factor ratio 98'88 SCC 40400331 —Internal floating roof tank, Condensate,working+breathing+flashing losses Page 4 Section 14—Miscellaneous Application Notes AIRS Point 001 Condensate Storage Tanks A permit will be issued because the uncontrolled VOC emissions are greater than 2 TPY(permit threshold). The operator used EPA Tanks 4.0.9d to calculate an emission factor since flash emissions are not anticipated from these tanks. From EPA Tanks, total emissions from one tank are 10301.14 lb/yr. There are a total of 3 tanks: VOC =(10301.14 Ib/yr)*3/2000= 15.4517 TPY VOC E.F. = 15.4517*2000/9125000=0.003386676 lb/bbl* 1000/42=0.806 lb/1000 gal HAP emissions were not calculated with EPA Tanks, so I took the ratio of the state emission factors to see what the benzene and n-hexane could be from these tanks: Benzene ratio=0.024/13.7=0.00175 N-hexane ratio=0.21/13.7=0.01533 Benzene=(0.00175*15.4517*2000) =54.1 lb/yr(not reportable) n-hexane= (0.01533*15.4517*2000) =473.7 lb/yr(reportable) Benzene emission factors=54.1 lb/yr/9125000 bbl/yr=0.0000059 Ib/bbl*1000/42=0.0001 lb/1000 gal n-hexane emission factors=473.7 Ib/yr/9125000 bbl/yr=0.000052 lb/bbl*1000/42=0.0012 lb/1000 gal I emailed the operator on 4/1/14 for some clarification of the HAPS and that these tanks are in non-attainment and therefore subject to Reg 7, Section XII(control requirements). These tanks do not have a control device. I heard back from Encana 4/2/14. Encana agreed with the HAP emissions I calculated (so I redlined the APEN accordingly). Regarding the control device and Reg. 7: We were calling the internal floating roof the control-this gets well above 95%and 1 can send you another Tanks Run with the emissions from a fixed roof tank for comparison. This is similar to the controls claimed at places like the refinery, which use internal and external floating roof tanks for control and do not send any tank emissions to a combustor. Given that, our thought was that compliance with NSPS Kb, and Reg 7111 and VI would take the place of an O&M. I talked to C. Money about this because I have never heard a floating roof be accepted as a control device. She said that it's tricky because a floating roof is a control device under Kb(and these tanks are subject to Kb). I requested a Tanks Run with a fixed roof for comparison and for using those emissions as"uncontrolled" emissions since the internal floating roof will be considered a control device, the emissions from that Tanks run would be the controlled emissions. Page 5 AIRS Point 001 Condensate Storage Tanks -continued I received an email from P. Buck on 4/3/14 to answer the remaining questions I had regarding the tanks: • First re:the Rea 7: So, based on the language in the new Section XVII, we're not subject to that since the tanks are not fixed roof. It looks to me like we're subject to Reg 7 Section XII.C.1.b and XII.01.c. Installation of the floating roofs represent a control efficiency of 98.88%. The Tanks run and a quick control percentage calculation are attached. Also a bit off topic, but based on the definition of`stabilized"in Reg 7 Section XII.B.12, these tanks definitely store stabilized condensate. The only emissions from these tanks will be working and breathing. • As stated above, I ran a Tanks run with fixed roof tanks of the same dimensions and throughput. This tanks run and a quick control calc is attached. This shows that the internal floating roofs achieve a control of -98% I reviewed the tank runs, and here's the results: Component Floating Fixed Roof 95%of fixed Is the floating Internal roof internal roof Roof controlling more than 95%of fixed roof? VOC 15.45 TPY 1381.5 TPY -- Yes Benzene 54.08 lb/yr 4835.28 lb/yr 241.76 lb/yr Yes n-hexane 473.75 lb/yr 42357.15 lb/yr 2117.86 lb/yr Yes Since they are using a floating internal roof, I believe this documentation shows that it has much less emissions than a fixed roof tank. So, I will accept this as a control device and assume a minimum of 95% control efficiency. Emission factors for these emissions are based on the uncontrolled emissions: VOC=(1381.5 TPY*2000)/9125000 bbl/yr=0.3028 lb/bbl•1000/42=7.2094 lb/1000 gal Benzene=(4835.28)/9125000=0.0005 lb/bbl•1000/42=0.0126 lb/1000 gal n-hexane=(42357.15)/9125000=0.0046 Ib/bbl*1000/42=0.1105 lb/1000 gal Page 6 Construction Permit Application Preliminary Analysis Summary Section 1 —Applicant Information Company Name: Encana Oil &Gas (USA) Inc. Permit Number: 13WE2647 Source Name: Liquids Handling Hub Source Location: County Road 5 and County Road 6,Weld County(non-attainment) Equipment Description: Truck loadout AIRS ID: 123-9BCB-003 Review Date: 10/30/13; Picked up again after receiving revised application 4/1/14. Review Engineer: Stephanie Chaousy, PE Section 2—Action Completed X CP1 Modification APEN Required/Permit Exempt Final Approval 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? Initial application: August 14, 2013. On what date was this application complete? Received a modification on 3/26/14. Section 4—Source Description AIRS Point Equipment Description 003 Truck Condensate Loadout 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) Is this source located at an oil and gas exploration site? Yes X No Page 1 Is this source located at a facility that is considered a major source of hazardous air pollutant(HAP) Yes X No emissions? Will this equipment be operated in any NAAQS X Yes No nonattainment area? Does this source load gasoline into transport vehicles? Yes X No Section 5—Emission Estimate Information AIRS Point Emission Factor Source AP-42: Chapter 5.2, Equation 1 L= 12.46*S*P•M/T 003 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[lb/lb-mole] T= temperature of bulk liquid loaded [deg. R] Did the applicant provide actual process data for the emission inventory? X Yes No Basis for Potential to Emit(PTEI AIRS Point Process ConsumptionlThroughput/Production 003 9,125,000 BBL per year condensate loaded P ?�I L4t POOP"Reoo ,la$' � ipsiggpisilittivo,sosr l t tar•,t , AIRS Point Process Consumption/Throughput/Production 003 9,125,000 BBL per year condensate loaded Basis for Permitted Emissions tftermit Limits) AIRS Point Process Consumption/Throughput/Production 003 9,125,000 BBL per year condensate loaded Does this source use a control device? X Yes No % Reduction AIRS Point Process Control Device Description Granted 003 of Enclosed combustor(Point 005) 97 Section 6—Emission Summar/ (tons per year) Point NO. VOC CO Single HAP HAP PTE: 003 --- 1540.4 -- 35.9 (n-hexane) 88.3 Uncontrolled point 003 --- 1540.4 --- 35.9 (n-hexane) 88.3 source emission rate: Controlled point 003 --- 46.2 1.1 (n-hexane) 2.7 source emission rate: Section 7—Non-Criteria/Hazardous Air Pollutants Uncontrolled Are the Controlled Emission Pollutant CAS# BIN Emission Rate emissions (Iblyr) reportable? Rate ilb/yr) Benzene 71432 A 28959 Yes 869 Toluene 108883 C 51140 Yes 1534 Ethylbenzene 100414 C 2156 Yes 65 Xylenes 1130207 C 22489 Yes 675 Page 2 n-Hexane 110543 C 71781 Yes 2153 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? AIRS Point Process Pollutant Regulatory Basis Test Method 003 01 VOC, Regulation No. 3, Part B., Section III.G.3 Stack test HAPS 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)? X Yes 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)? AIRS Point I Section 12—Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of 003 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. (Reference: Regulation No. 1, Section II.A.1. &4.) 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 003 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. Page 3 jReoutation 3-APENs Construction Permits Operating Permits,PSI) Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: 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 Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold(Reg.3, Part B, Section II.D.2.a) 003 Part B, III.D.2- RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is/is not located in the 8-hour ozone nonattainment area, but not the 1-hour ozone area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8-hour ozone NA area designation). Since the tank battery from which loadout is occurring will be in service since after the date above this source is considered"new or modified." Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied. Regulation 6-New Source Performance Standards 003 No applicable subpart. This facility is not a bulk gasoline terminal. Reputation 7—Volatile Orasnie pounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 003 76,000 liters of gasoline(20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8—Hazardous Air Pollutants 003 MACT EEEE: Not subject because minor source of HAPs Section 13—Aerometric Information Retrieval System Coding Information Process/ Emission Process Emission Pollutant/ Fugitive Control Point Process Description throughput Factor CAS# (Y/N) Factor (%) Limit Source 8'04 V0C No AP-42 97 lb/1,000 gal 0.0756 Benzene/ Mass Ib/1,000 gal 71432 No Balance 97 0.1334 Toluene/ Mass Truck 9,125,000 lb/1,000 gal 108883 No Balance 97 01 Condensate 003 Loadout BBUyr 0.0056 Ethylbenzene/ No Mass 97 Ib/1,000 gal 108883 Balance 0.0587 Xylenes/ Mass Ib/1,000 gal 1130207 No Balance 97 0.1873 n-Hexane/ Mass lb/1,000 gal 110543 No Balance 97 SCC 40600132: Crude Oil: Submerged Loading (Normal Service) Page 4 Section 14—Miscellaneous Application Notes AIRS Point 003 Truck Condensate Loadout Units Basis S 0.6 Submerged loading: dedicated normal service P 9.5 Psia Based on API 2518 nomograph M 58 Lb/lb-mole Based on HYSYS model T 512.45 Deg R Based on EPA TANKs run L 8.04 Lb/t0^3 gal 0.338 Lb/bbl This value is used to calculate annual emissions 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[lb/lb-mole] T=temperature of bulk liquid loaded[deg. R] • L 8.041b/10^3 gal 3.38E-011b/bbl Annual requested Throughput 383250000ga1/yr Annual requested VOC emissions 30807151b/yr • 1540.36tpy Operator calculated HAPS based on a gas sample similar to the area the facility is being built in. This has been done for other Encana projects and I have approved these calculations(since typically operators do not calculate HAP emissions from loadouts). They used a wt%of VOC and multiplied it to the VOC emissions: Benzene=0.0094*2000*1540.36=28958.768 lb/yr/9125000=0.0032 Ib/bbl*1000/42 =0.0756 lb/1000 gal Toluene=0.0166*2000*1540.36=51139.95 lb/yr/9125000=0.0056 lb/bbl*1000/42=0.1334 lb/1000 gal Ethylbenzene=0.0007'2000*1540.36=2156.04 Ib/yr/9125000=0.00024 lb/bbl*1000/42=0.0056 lb/1000 gal Xylenes=0.0073'2000'1540.36=22489.26 lb/yr/9125000=0.0025 Ib/bbl*1000/42=0.0587 lb/1000 gal n-hexane=0.0233'2000'1540.36=71780.78lb/yr/9125000=0.0079 lb/bbl*1000/42=0.1873 lb/1000 gal I emailed the operator on 4/1/14. Responses are in italics which I received on 4/2/14 and 4/3/14: 1. Do you have the revised nomograph? The Molecular weight comes from the Hysys run that is attached-it's on line 25 of the attached stream run. I have now included a new nomograph and a revised true vapor pressure in the loadout ca/cs. As a result of this, the emissions from the loadout changed. The new ca/c sheet and facility-wide emissions are also attached. Would you like a whole new loadout APEN or do you want to red-line it? 3, Encana responded: the Molecular weight comes from the Hysys run that is attached-it's on line 25 of the attached stream run. 1 have now included a new nomograph and a revised true vapor pressure in the loadout talcs. As a result of this, the emissions from the loadout changed. The new talc sheet and facility-wide emissions are also attached. Would you like a whole new loadout APEN or do you want to red-line it? 2. The Division typically gives 95%control for flare and enclosed combustors. The APEN is requesting 97%. • This will change the VOC emissions to 61.6 TPY VOC. The HAPS will change as well. I can redline the APEN accordingly. /would rather test the loadout combustors—only one will ever operate at a time-and show 97%than use the 95%. This is the path that we have decided to go internally and with the combustors that we will have on site, we're confident that we meet and exceed the 97%control I wrote back: Okay, well, if you believe the combustor will reach 97%combustion, I will then definitely require testing in the permit. He responded: /understand that the combustors that control the loadout will need to be tested. Page 5 STATE OF COLORADO i0ccop COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT ��°T � AIR POLLUTION CONTROL DIVISION �4 ° TELEPHONE: (303) 692-3150 *1876* ,! CONSTRUCTION PERMIT PERMIT NO: 13W E2647 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 Liquids Handling Hub, located on County Road 5 and County Road 6, in 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 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 commencement of operation, 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 commencement of operation, 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 AIRS ID: 123/9BCB Page 1 of 9 Condensate Loadout TM Version 2012-1 Co do gp e o PubID lic PollutionHealthand Control DivisionEnvironment 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) Monthly Limits: Facility AIRS Pounds per Month Equipment Point Emission Type ID VOC Condensate 003 7,848 Point Loadout (Note: Monthly limits are based on a 31-day month.) The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall be less than 1,359 lb/month. Facility-wide emissions of total hazardous air pollutants shall be less than 3,398 lb/month. Annual Limits: Facility AIRS Tons per Year Equipment Point Emission Type ID VOC Condensate 003 46.2 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. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the AIRS ID: 123/9BCB Page 2 of 9 aCo A•do ■ p e o'Public Health and Environment Air Pollution Control Division 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. 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 Condensate 003 Enclosed 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) Process/Consumption Limits Monthly Limit AIRS Process Parameter Annual Limit (31 Days) Point 003 Condensate Loading 9,125,000 BBL 775,000 BBL The owner or operator shall calculate monthly process rates based on the calendar • month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 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. 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 AIRS ID: 123/9BCB Page 3 of 9 Co do p e o Public PollutionHealthand Control DivisionEnvironment 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 13. 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 14. A source initial compliance test shall be conducted on emissions point 003 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emission limits in this permit. The operator shall demonstrate the enclosed combustor achieves a minimum destruction efficiency of 97.0% for VOC. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part B., Section III.G.3) Volatile Organic Compounds using EPA approved methods. AIRS ID: 123/9BCB Page 4 of 9 Col do p e o Public Health and Environment Air Pollution Control Division ADDITIONAL REQUIREMENTS 15. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually by April 30`" whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5)tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) 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 d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 16. 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: 17. 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. 18. 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 AIRS ID: 123/9BCB Page 5 of 9 Co do p e o Pu and D Airblic PollutionHealth Control DivisionEnvironment 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 19. 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. 20. 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. 21. 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. 22. 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. 23. 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: 123/9BCB Page 6 of 9 Col do p e o Public Health and Environment Air Pollution Control Division Issuance Date Description Issuance 1 This Issuance Issued to Encana Oil & Gas (USA), Inc. Newly permitted loadout at a synthetic minor source. AIRS ID: 123/9BCB Page 7 of 9 DCo do D■p e o Public PollutionHealthand Control DivisionEnvironment 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.dov/cs/Satellite?c=Document C&childpaaename=CDPHE- Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&paaename=CBONWranner 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# (lb/yr) reportable? Rate(lb/yr) Benzene 71432 28,959 Yes 869 Toluene 108883 51,140 Yes 1,534 003 Ethylbenzene 100414 2,156 Yes 65 Xylenes 1130207 22,489 Yes 675 n-Hexane 110543 71,781 Yes 2,153 5) The emission levels contained in this permit are based on the following emission factors: Wt%of Emission Factors- Emission Factors— VOC Uncontrolled Controlled CAS Pollutant lb/BBL Source Lb/BBL Source loaded loaded VOC 8.04 AP-42 0.2412 AP-42 Mass Mass 71432 Benzene 0.94 0.0756 Balance 0.0023 Balance Mass Mass 108883 Toluene 1.66 0.1334 Balance 0.0040 Balance Mass Mass 100414 Ethylbenzene 0.07 0.0056 Balance 0.0002 Balance Mass Mass 1130207 Xylenes 0.73 0.0587 Balance 0.0018 Balance Mass Mass 110543 n-Hexane 2.33 0.1873 Balance 0.0056 Balance The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1 (version 1/95) using the following values: AIRS ID: 123/9BCB Page 8 of 9 Col do p e o Public Health and Environment Air Pollution Control Division L= 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 9.5 psia M (vapor molecular weight) = 58 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. Controlled emission factors are based on the 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, benzene, toluene, xylenes, 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 XX(XXX 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.colorado.qovicdphe/oilgaspermits AIRS ID: 123/9BCB Page 9 of 9 Laco 6 O N a Y ._ E /�W vi U Q. 6 T ... ... W c h c / .`0... n-\'r - Q O R c E Z u o . m m a Y al GJ pp�� v p� — O < W O W c CO A — o w l'.1 3 o c ❑ ❑ = CI '$ o < hE �� Q- r.;-.,' b ._ a 05 r�� /U� E c. v o 9 W > m 0. i `eat .. :<2..z o o K C j c , 4 ^ a o c 'J R a 9. ^ c o e / -O C lA o E a e L (la_ _ _ o 'z Z Z Z o - o_a m Ni 1.4 .. c o. o. co Ro. E V R 0 E ti EZED Pc j 0 A cd EP .. _ ^ Q w M 0 d O O J iC E N ._ 7 a cc U L w ^Q] CJ , 6 p. '_ Q' a' 0 -0 O Q. N .B tJ 4Oi G y m — U O W N CC CN V N n i d u c `v) F 3 `O-' .. - xv N cV 0 `L, 2 3 E s .? x s _ J - R a co L R C N O. 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