HomeMy WebLinkAbout1.10A Air Quality PermitsAir Quality Permit
Grand River Gathering LLC
High Mesa Compressor Station
OA Project No. 012-0732
826 21 ½ Road | Grand Junction, CO 81505 | TEL 970.263.7800 | FAX 970.263.7456
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HE ALT H AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3 150
CONSTRUCTION PERMIT
PERM IT NO:
DATE ISSUED :
ISSUED TO:
08GA1199
JUL 3 ·1 2009
EnCana Oil & Gas (USA) Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED A ND LOCA TED AS FOLLOWS:
Natural gas compression facility, known as the H igh Mesa Compressor Station, located
in SENW Section 36, T ownship 7S, Range 96W, in Garfield County, Colorado .
THE S PECIFIC EQUIPMENT O R ACTIVITY S UBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Equipment Point Description
10
One (1) Ca terpillar, Model G3516LE , Serial Number 4EK04857,
natural gas-fired , turbo-charged , 4SLB reci procating internal
HM01 013 combustion engine, si te rated at 1 ,208 horsepower at 1,400 RPM .
This engine sh all be equipped with an oxidation catalyst and air-
fuel ratio contro l. This emission unit is used for natural gas
compression.
This en gine may be replaced w ith another engi ne in accordance with the temporary
engine replacement provision or with another Caterpill ar G351 6 LE engine in accordance
with the permanent replacement provision of the Alternate Operating Scenario (AOS),
included in this perm it as Attachment A.
THIS PERMIT IS GRANT ED SUBJ ECT TO ALL RULES AND RE G ULATIONS O F THE COLORADO
AIR QUALITY C ONTROL COMMISSIO N A ND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S . (25-7-101 et seq), TO THOSE GENERAL TERMS AND C ONDIT IONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1 . T his construction permit represents f inal perm it approval and authorit y to operate this
em iss ions source (Regulation 3 , Part B, Section II I.G.S).
A IRS 10: 045/1046/01 3 Page 1 of 17
NGEngine Versi on 2008-1
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part 8, Section II.A.4)
M h i L .. ont 1y 1m1ts:
Fa cility AIRS Pounds pe r Month
Equi pment 10 Po i nt NOx voc co Emission Type
HMOI 013 2972 486 306 Point
Monthly llm1ts are based on a 31-day month.
Annual Limits:
Facility AIRS Tons per Year
Equipment 10 Point NOx voc co Emission Type
HMOt 013 17 .5 2.9 1 .8 Point
See "Notes to Perm1t Holder #4 for mformat1on on em1ss1on factors and methods used to
calculate limits.
During the first twelve (12) months of operation , compliance with both the monthly and
yearly emission limitations sha ll be required. After the first twelve (12) months of
operation , compliance with only the yearly limitation shall be required.
Compliance with the synthetic minor status of this facility shall be determined by
recording the facility's annual criteria pollutant emissions , from each emission unit, on a
rolling (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
monthly emissions 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
emission units, requiring an APEN , at this facility.
3. This engine shall be equipped with an oxidation catalyst and air-fuel ratio cont rol. The
selective oxidation catalyst shall be capable of reducing uncontrolled emissions of VOC
and CO from the unit to the emission levels listed in Condition 2 , above . Operating
parameters of the control equipment are identified in the operation and maintenance
plan. (Reference: Regulation No.3, Part 8 , Section III.E.)
PROCESS LIMITATI ONS AND RECORDS
4 . This source shall be limited to the following maximum consumption , processing and/or
operational rates as listed below. Monthly records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulation 3, Part 8 , II.A.4)
Process/Consumpti on Limits
Facility AIRS Annual Monthly
Equ ipment Point Proces s Parameter Limit Limit (31
10 days)
HM01 013 Consumption of natural gas as a 90.9 7 .72
fuel MMscf/yr MMscf/month
AIRS ID: 045/1046/013 Page 2 of 17
!
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
During the first twelve (12) months of operation, compliance with both the monthly and
yearly consumption limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required .
Compliance with the yearly consumption 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. T he permit holder shall calculate monthly
consumption of natural gas and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
STATE AND FEDERAL REGULA TORY REQUIREMENTS
5 . 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. (Ref erence: R egulation No. 1, Section II.A.1. & 4.)
6. This source is subject t o the odor requirements of Regulation No. 2. (State only
enforceable)
7. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Nu mber 3 , Part 8 , III.E .) (State only
enforceable)
8. This source is subject to the requirement s of:
• Regulation No. 8, PartE, Subpart 11/.FFFF: National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and
• Regulation No. 8, PartE, Subpart I. A, National Emission Standards for
Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR
Part 63
including, but not limited to, the following:
• Emission and Operating Li mitations
o 63.6600(b) -If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more than 500 brake HP located at major source of
HAP emissions you must comply with t h e f ollowing emission limitations
(Table 2a, Subpart Zll..Z to Part 63):
• reduce CO emissions by 93 percent or more; or
• limit concent ration of formaldehyde in the stationary RICE exhaust to
14 ppmvd or less at 15 percent 02.
AIRS I D : 045/1046/013 Page 3 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o 63.6600(b)-If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more than 500 brake HP located at major source of
HAP emissions you must comply with the following operating limitations
(Table 2b, Subpart ZZZZ to Part 63):
•
•
maintain your catalyst so that the pressure drop across the catalyst
does not change by more than 2 inches of water at 1 00 percent load
plus or minus 10 percent from the pressure drop across the catalyst
that was measured during the initial performance test, and
maintain the temperature of your stationary RICE exhaust so that the
catalyst inlet temperature is greater than or equal to 450 oF and Jess
than or equal to 1350 °F.
• General Compliance Requirements
o §63.6605(a)-You must be i n compliance with the emission limitations and
operating limitations in this subpart that apply to you at all times, except
during periods of startup, shutdown, and malfunction.
o §63.6605(b) -If you must comply with emission limitations and operating
limitations, you must operate and maintain your stationary RICE, including air
pollution control and monitoring equipment, in a manner consistent with good
air pollution control practices for minimizing emissions at all times, including
during startup, shutdown, and malfunction.
• Testing and Initial Compliance Requirements
o §63.6610(a)-You must conduct the initial performance test or other initial
compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply
to you within 180 days after the compliance date that is specified for your
stationary RICE in §63.6595 and accordi ng to the provisions in §63.7(a)(2).
o §63.6615 -If you must comply with the emission limitations and operating
limitations, you must conduct subsequent performance tests semiannually (as
per Table 3 of Subpart ZZ.ZZ to Part 63). After you have demonstrated
compliance for two consecutive tests, you may reduce the frequency of
subsequent performance tests to annually. If the results of any subsequent
annual performance test indicate the stationary RICE is not in compliance
with the CO or formaldehyde emission limitation , or you deviate from any of
your operating limitations, you must resume semiannual performance tests.
o §63.6620 -You must conduct performance test and other procedures in
§63.6620 and in Tables 3 and 4 to Subpart ZZZZ of Pa rt 63 that apply to you .
o §63.6625(b) -If you are required to install a continuous parameter monitoring
system (CPMS) as specified in Table 5 of this subpart, you must install,
operate, and maintain each CPMS according to the requirements in §63.8.
AIRS ID: 045/1046/013 Page 4 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
A i r Pollution Control Division
o §63.6630(a)-You must demonstrate initial compliance with each emission
and operating limitation that applies to you according to Table 5 of Subpart
ZZZZ to Part 63.
o §63.6630(b) -During the initial performance test, you must establish each
operating limitation in Tables 1 band 2b of Subpart ZZZZ to Part 63 that
applies to you .
o §63.6630(c)-You must submit the Notification of Compliance Status
containing the results of the initial compliance demonstration according to the
requirement s in §63.6645.
• Cont inuous Compliance Requirements
o §63.6635(b)-Except for monitor malfunctions, associated repairs , and
required quality assurance or control activities (including , as applicable,
calibrat ion checks and required zero and span adjustments), you must
monitor continuously at all times that the stationary RICE is operating.
o §63.6635(c)-You m a y not use data recorded during monitoring
malfunctions, associated repairs , and required quality assurance or control
activities in data avera ges and calculat ions used to report emission or
operating levels. You must, however, use all t he valid data collected during all
other periods.
o §63.6640(a)-You must demonstrate continuous compliance w ith each
emission limitation and o p erating limitation in T ables 1 a and 1 b and Tables
2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods
specified in Table 6 of Subpart ZZZZ of P art 63.
o §63.6640(b)-You must report each instance in which you did not meet each
emission limitation or operating limitation in Tables 1 a and 1 b and Tables 2a
and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are
deviations from the emission and operating limitations in this subp art. These
deviations must be reported according to the requirements in §63.6650. If you
change you r catalyst , you must reestablish the values of the operating
parameters measured during the initial performance test. When you
reestablish the val ues of your operat ing parameters, you must also conduct a
performance test to demonstrate that you are meeting the required emission
limitation applicable t o your stationary RICE.
o §63.6640(d)-Consistent w ith §§63.6(e) and 63.7(e)(1 ), deviations from the
emission o r operating limitations that occur during a per iod of startup,
shutdown, or malfunction are not violations if you demonstrate to the
Administrator's satisf action that you were operating in accordance with
§63.6(e)(1 ). For new, reconstructed, and rebuilt stat ionary RI CE, deviations
from the emission or operating limitations that occur during t he first 200 hours
of oper ation from engine startup (engine burn-in period) are not violations.
AIRS ID: 045/1046/013 Page 5 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1199
Issuance 1
Colorado Department of Public Health and Envi ronment
Air Pollution Control Division
o §63.6640(e)-You must also report each instance in which you did not meet
the requirement s in Table 8 of Subpart ZZZZ to Part 63 that apply to you.
• Notifications, Reports and Records
o §63 .6645(a)-If you own or operate a stationary RICE with a site rating of
more than 500 brake HP located at a major source of HAP emissions you
must submit all of the notifications in §§63. 7(b) and (c), 63.8(e), (f)(4) and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates
specified .
o §63.6645(c)-If you start up your new or reconstructed stationary RICE with a
site rating of more than 500 brake HP located at a major source of HAP
emissions on or after August 16, 2004, you must submit an Initial Notification
not later than 120 days after you become subject to this subpart.
o §63.6645(g) -If you are requ ired t o conduct a performance test, you must
submit a Notification of Intent to conduct a performance test at least 60 days
before the performance test is scheduled to begin as required in §63.7(b)(1).
o §63.6645(h)-If you are required to conduct a performance test or other initial
compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to
Part 63, you must submit a Notification of Compl iance Status according to
§63.9(h)(2)(ii).
• §63 .6645(h)(2) -For each initial compliance demonstration required in
Table 5 of Subpart ZZZZ to Part 63 that includes a performance test
conducted according to the requirements in Table 3 to this subpart,
you must submit the Notification of Compliance Status, including the
performance test results , before the close of business on the 60th day
following the completion of the performance test according to
§63.1 O(d)(2).
o §63.6650(a)-You must submit each report in Table 7 of Subpart ZZZZ to
Part 63 that applies to you.
o §63.6650(b)-You must submit each report by the date in Table 7 of Subpart
ZZZZ to Part 63 and according to the requirements in paragraphs (b)(1)
through (5) of §63.6650.
o §63.6650(c)-The Compliance report must contain the information in
paragraphs (c)(1) through (6) of §63.6650.
o §63.6650(e)-F or each deviation from an emission or operating limitation
occurring for a stationary RICE where yo u are using a C M S to comply with
the emission and operating limitations in Subpart ZZZZ to Part 63, you must
include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of
§63.6650.
AIRS ID: 045/1046/013 Page 6 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6655(a) -If you must comply with the emission and operating limitations,
you must keep the records described in §63 .6655(a)(1) through (a)(3),
§63.6655 (b)(1) through (b)(3) and §63.6655 (c).
o §63.6655(d)-You must keep the records requ ired in Table 6 of Subpart
ZZZZ of Part 63 to show continuous compliance with each emission or
operating limitation that applies to you.
o §63.6660(a)-Your records must be in a form suitable and readily available
for expeditious review according to §63.1 O(b)(1 ).
o §63.6660(b)-As specif ied in §63.10(b)(1), you must keep each record f or 5
years following the date of each occurrence, measurement, maintenance,
corrective action , report , or record .
o §63.6660(c)-You must keep each record readily accessible in hard copy or
electronic form on -site for at least 2 years after the date of each occu rrence,
measurement, ma intenance, corrective action , report, or record , according to
§63.10(b)(1 ). You c an keep the record s off-site for the remaining 3 years.
• Other Requirements and Information
o §63.6665 -Table 8 to this subpart shows which parts of the General
P rovisions in §§63.1 through 63.15 apply to you .
OPERATING & MAINTENANCE REQUIREMENTS
9. Upon startup of this point, the applicant sha ll follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division , in or der to demon strate
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. (Refere nce:
Regulation No. 3 , Part 8 , Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Period ic Testing Requirements
10 . This engine is subject to the periodic testing requirements of 4 0 C .F.R Part 63, Subpart
ZZZZ .
11 . This engin e is subject to the periodic testing requi rements as specified in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approval. Replacements of this unit completed as Alternative
Operating Scenarios may be subject to additional test ing requi rements as specified in
Attachment A.
A IRS ID: 045/1046/013 Page 7 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQU IREMENTS
12. A revised Air Pollutant Emission Notice (APEN) shall be filed : (Reference: Regulation
No. 3 , Part A, II.C)
a. Annually whenever a significant increase in emissions occurs as follows :
For any crit eria pollutant :
For sources emitting less t han 100 t ons p er y e ar. a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; 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.
f . Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the permittee is
exercising an alternative-operating scenario and is installing a permanent
replacement engine.
13. This source is subject to the provisions of Regulation Number 3, Part C , Operating
Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this
construction permit must be incorporated into the operating permit. The application for
the modification to the Operating Permit is due within one year of commencement of
operation of the equipment or modification covered by this permit.
14 . Prevention of Significant Deterioration (PSD) requirements 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
PSD threshold will require a f ull PSD review of the sou rce as though construction had
not yet commenced on the source. The source shall not exceed the PSD threshold until
a PSD permit is granted . (Regulation No .3 Part D, VI.B.4)
GENERAL TERMS AND CONDITIONS :
15. 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
AIRS ID: 045/1046/013 Page 8 of 17
EnCana O il & Gas (USA) In c.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Cont rol Division
AQCC Regulation No. 3, Part B , Section II.B upon a request for transf er of ownersh ip
and the submittal of a revised APEN and the required fee.
16. Issuance of a construction permit does not provide ''final" authority for this activity or
operation of this source. Final authorization of t he permit must be secured from the
APCD i n writing in accordance w ith the provisions of 25-7-114.5 (12)(a) C .R.S . and
AQCC Regulation No.3, Part B, Section II I.G. F inal authorization cannot be granted
until the operation or activ ity commences and has been verified by the APCD as
conforming in all respects with the conditions of the permit. Once self-certification of all
poi nts has been reviewed and approved by the Division, it will p rovide written
d ocument ation of such f inal authoriz ation . Details for obtai ning final authorization to
operate are located in the Requirements to Self-Certify for Final Authorization
s ection of this permit.
17. T h is permit is issued in reliance upon the accuracy and completeness of information
supplied by the appl icant and is conditioned upon co nduct of the activity , or construction,
installation and operation of the source, in accordance with this information and with
represent ations made by the applicant or applicant's agents. It is valid only for t he
e quipment and operations or activity specifically identified o n the permit.
18. Unless s p ecifically stat ed otherwise, t he general and specific conditions contained in this
permit h ave been deter mined by t he APCD to be necessary to assure compliance with
the provisions of Section 25-7-1 14.5(7)(a), C .R.S .
19. E ach and every condition of this permit is a materia l part her eof and is not severable .
A n y challenge to or appeal of a condition hereof shall constitute a rejection of the e ntire
permit and upon such occurrence, this permit shall be deemed denied ab initio. T h is
permit may be revoked at any t ime prior to self-certification and final aut horization by the
Air Pollution Control D ivision (A PC D) on grounds set f orth in the Colorado A ir Quality
Control Act and regulations of the A ir Q ua lity Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If t he Division denies a
permit, conditions imposed upon a permit are contested by the applicant , or the Divis ion
rev okes a permit , the applicant or owner or operator of a source may request a hearing
before the AQCC for review o f the Division 's action.
20. Section 25-7-114.7 (2)(a), C .R.S. requires that all sources required to file an A ir P o llution
Emission N otice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is t o be d iscontinued, the owner must notify the
D ivision in writ ing requesting a cancellation of the permit. U pon not ification, annual fee
billing will term inate.
21 . V iolation of the terms of a permit or of the provisions of t he Colorado Ai r Pollution
Prevention and Control Act or the reg u lations of the AQCC may result in admin istrative ,
civil or crim inal enforcement actions under Sections 25-7 -115 (enforcement), -121
(inj unctions), -122 (c ivil penalties), -122.1 (crimi nal penalties), C .R.S.
22 . This permit replaces the following permit, w h ich is canceled upon issuance of t h is
permit:
AIRS ID: 045/1046/013 Page 9 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Permit No. AIRS ID Notes
05P00963 777126601001
1
Engine-~M01 :. This equipment wi.ll now be covered
under th1s stationary source perm1t.
By:
C iuissa Money rJ'
Permit Engineer
p "t H" t erm1 IS ory_
Issuance Date Description
Issuance 1 This Issuance Canceled portable permit 05P00963 and issued
as new stationary permit
lA, Modification July 17, 2007 Change in fuel use, emissions, addition of control
No. 1 for equipment
05P00963
Initial Approval April 14, 2006 Issued to EnCana Oil & Gas
for 05P00963
AIRS ID: 045/1046/013 Page 10 of 17
EnCana Oil & Gas (USA) Inc.
Per mit N o. 08GA 1199
Issuance 1
Notes to Permit Holder:
Colorado Department of P ublic Health and Environment
Air P o ll ution Control Division
1) 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 permittee 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
application form must be submitted with a request for a permit revision .
2) This source is subject to the Common Provisions Regulation Part II , Subpart E , Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any
malfunction condition which causes a violation of any emission li mit 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 t he
Division addressing all of the criteria set forth in Part II.E.1 . of the Common Provisions Regulation .
See: http://www.cdphe.s tate.co.us/regulations/airregs/1 001 02aqcccommonprovisionsreg.pdf.
3) 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 t he Controlled
AIRS Rate emissions Em issio n
Poin t Pollutan t CAS# B IN {lb/yr ) reportable? Rate (lb/yr)
Formaldehyde 5000 A 5599 Yes 2800
Acetaldehyde 75070 A 760 Yes 380
Acr olein 107028 A 467 Yes 234
013 Methanol 67561 c 227 No 114
n-Hexane 110543 c 101 No 50
Benzene 71432 A 40 No 20
Toluene 108883 c 37 No 19
4 ) The emission levels contained in this permit are based on the following emission factors:
Point 013 :
Emission Factors -Uncontrolled Emission Factors-Controlled
CAS Pollutant lb/MMBtu g /bhp-hr Sour ce lb/MMBtu g /bhp-hr Source
NOx 0 .3850 1.5000 Mfg 0.3850 1.5000 Mfg
co 0 .5673 2 .2100 Mfg 0.0397 0.1547 Mfg
voc 0 .1258 0.4900 Mfg 0.0629 0.2450 Mfg
5000 Formaldehyde 0 .0616 0.2400 Mfg 0.0308 0.1200 Mfg
AP-42; Table
75070 Acetaldehyde 0.0084 0.0326 3.2-2 (7/2000); 0.0042 0.0163 Mfg
Natural Gas
AP-42; Table
107028 Acrolein 0.0051 0.0200 3.2-2 (7/2000); 0 .0026 0.0100 Mfg
Natural Gas
67561 Methanol 0 .0025 0.0097 AP-42; T able 0.0013 0.0049 Mfg 3.2-2 (7 /2000);
AIR S ID : 0 4 5/1046/013 P age 11 of 17
EnCana Oil & Gas (USA) Inc.
Pe rmit N o. 08GA 1199
Issua nce 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Emission Factors -Un controlled Emis s i on Factors -Controlled
CAS Po llutant l b/MMBtu g /bhp-hr Sou rce l b /MMBtu g /bhp-hr
Natural Gas
AP-42; Table
110543 n-Hexane 0.0011 0.0043 3.2-2 (7/2000); 0.0006 0.0022
I Natural Gas
1 71432
AP-42; Table
Benzene 0.0004 0.0017 3.2-2 (7/2000); 0.0002 0.0009
Natural Gas
AP-42; Table
108883 Toluene 0.0004 0.0016 3.2-2 (7/2000); 0 .0002 0.0008
Natural Gas
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8,589 Btu/hp-hr, a
site-rated horsepower value of 1 ,208, and a fuel heat value of 1,000 Btu /scf.
5) In accordance with C .R.S . 25-7-114.1 , the Air Pollutant Emission Notice (APEN) associated with this
permit is valid for a term of five years. The five-year term for this APEN expires on Novem ber 9, 20 13.
A revised APEN shall be submitted no later than 30 days before the five-year term expires.
6) T his facil ity is classified as follows:
Applicable Status Requirement
Operating Permit Major Source: NOx, HAPs
Synthetic Minor Source : CO , VOC
PSD Synthet ic Minor Source: VOC
MACT HH Synthetic Minor Source: Toluene, Total HAP
MACT Z2.ZZ Major Source
7) 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 Pe rfor mance for New Stati onary So urces
NSPS 60.1-End Subpart A-Subpart KKKK
NSPS Part 60, Appendixes Appendix A-Appendix I
Part 63 : National Emission Standar ds for Hazardous Ai r Pollutants for Source Categories
MACT 63.1-63.599 Subpart A-Subpart Z
MACT 63.600-63.1199 Subpart AA-Subpart DOD
MACT 63.1200-63 .1439 Su bpart EE E -Su bp art P PP
MACT 63.1440-63.6175 Subpart QQQ -Subpart YYYY
MACT 63.6580-63.8830 Subpart Z2.ZZ-Subpart MMMMM
MACT 63.8980-End Subpart NN NNN -Subpart XXXXXX
AIRS ID: 045/104 6/013 P age 12 of 17
Source
Mfg
Mfg
Mfg
I
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1 199
Issuance 1
Colorado Department of Public Health and Environment
Ai r Pollution Control Division
ATT ACH MENT A :
ALTERNATIVE OPERATING SCENARIOS
REC IPROCAT ING INTERNAL C OMBUSTION ENGINES
December 1 0, 2008
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No. 3., Part A , Section IV.A , Operational Flexibility-Alternative Operating
Scenarios, Regulation No. 3, Part 8 , Construction Permits , and Regulation No . 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements . This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS , and the
permittee shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
A.1 Engine Replacement
The following AOS is incorporated into this permit in order to dea l with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanent" is defined as in the same service for more
than 90 operating days in any 12 month period . T he 90 days is the total number of days that the engine
is in operation . If the engine operates only part of a day, that day shall count as a single day towards the
90-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this
permit (including monitoring and reco rd keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of t he test if such testing is required to
demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for
five (5) years and made available to the Division upon request.
The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial
number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model
number, horsepower, and serial number of the replacement engine . In addition to the log, the permittee
shall maintain a copy of all Applicability Reports required under section A.1 .2 and make them available to
the Division upon request.
A.1 .1 T he permittee may t emporarily replace an existing compressor engine that is subject to the
emission limits set forth in this permit with an engine that is of the same manufacturer, mode l, and
horsepower or a different manufacturer, model , or horsepower as the existing engine without modifying
this permit, so long as the emissions from the temporary replacement engine comply with the emission
limitations for the existing permitted engine as determined in section A.2. Measurement of emissions
from the temporary replacement engine shall be made as set forth in section A.2.
A.1 .2 The permittee may permanently replace the existing compressor engine with an engine that is of
the same manufacturer, model and horsepower w ithout modifying this permit so long as the emissions
from the permanent replacement engine comply with 1) the permitted annual emission limitations for the
AI RS ID: 04 5/1046/013 Page 13 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3)
the applicable emission limitations as set forth in the Applicability Report submitted to the Division with
the Air Pollutant Emissios Notice (APEN) for the replacement engine (see
http://www.cdphe.state.co.us/ap/oilgaspermitting html for example applicability report formats).
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining
that the permittee is exercising an alternative operating scenario and is Installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability Reports can be found in at http://www.cdphe state.co.us/ap/oilqaspermittinq.html.
This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of
the source indicating that "based on the information and belief formed after reasonable inquiry, the
statements and information included in the submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The permittee shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
A.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing , this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition , if approved in advance by the Division .
The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust
from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division 's website at:
http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the resu lts of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 045/1046/013 Page 14 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% 02) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropri ate units as described in
the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary , the source may certify that the eng ine i s in compliance with
both the NOX and CO emission lim itations for the relevant time period .
Subject to the provis ions of C .R.S . 25-7-123 .1 and in the absence of credible evidence to the contrary , if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance w ith both the NOX and CO emission limitations or
until the engine is taken offline.
A.3 Applicable Regulati ons for Permanent Engine Replacements
A.3 .1 Reasonably Available Control Technology (RACT): Reg 3 , Part B § 11.0 .2
All permanent replacement engines that are located in an area that is classified as
attainmenUmaintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainmenUmaintenance or nonattainment. Note that both VOC
and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for
which the area is in attainmenUmaintenance or nonattainment, except as follows:
In the Denver Metropolitan PM1 0 attainmenUmaintenance area, RACT appli es to PM1 0 at any level of
emissions and to NOX and S02, as precursors to PM1 0, if the potential to emit of NOX or S02 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating
in ternal combustion engines:
VOC:
CO:
NOX:
S02:
PM10:
The emission limitations in NSPS JJJJ
The emission lim itati ons in NSPS JJJJ
The emission limitations in NSPS JJJJ
Use of natural gas as fue l
Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331 ) and 40 CFR Part 72 (§ 72 .2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
A.3.2 Control Requ irements and Emission Standards: Regulation No.7, Sections XVI. and XVII.E
(State-Only cond itions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No.7 , section XVI , as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission .
AIRS ID: 045/1046/013 Page 15 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
A ir Polluti on Control Division
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce e missions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications .
The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2 .
Emission Standards: Section XVII. E-State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written i nstructions or procedures to the extent practicable and consistent w ith
technological limitations and good engineering and maintenance practices over the entire life of the
eng ine so that it achieves the emission standards required in the table below:
I Max Engine Cons truction or Emission Standards in G/hp-hr HP Relocation Date
NOx co voc
IOO<Hp<500 January L 2008 2.0 4.0 1.0
January 1, 2011 1.0 2 .0 0.7
500:SHp July I, 2007 2.0 4.0 1.0
July 1, 2010 l.O 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2
A.3.3 NSPS for spark igmtion internal combustion engines: 40 CFR 60, Subpart JJJJ
A permanent replacement engine that i s manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp , 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject 40 CFR 60, Subpart
JJJJ. An analysis of applicable monitoring, record keeping , and reporting requirements for the permanent
engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any
testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required
by NSPS Subpart JJJJ can serve as the testing requ ired by this AOS under Condition A.2 , if approved in
advance by the Division , provided that such test is conducted within the time frame specified in Condition
A.2 .
Note that under the provisions of Regulation No.6 . Part B, section I. B. that Relocation of a source from
outside of the State of Colo rado into t he State of Colorado is considered to be a new source, subj ect to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of November 1, 2008 the Division has not yet adopted NSPS JJJJ. Until such time as it
does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts
NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the
provisions of Regulation No. 6, Part B.§ 1.8 (wh ich is referenced in Part A), any engine relocated from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of NSPS JJJJ.
AIRS ID: 045/1046/013 Page 16 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1199
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
A3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A.3.4.1 Area Source for HAPs
A permanent replacement eng ine located at an area source that commenced construction or
reconstruction after June 12, 2006 as defined in § 63.2 , will meet the requirements of 40 CFR Part 63,
Subpart Zll.Z by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the
applicable monitoring, recordkeeping , and reporting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Condition A.1 .2. Any testing required by the
MACT is in add it ion to that required by this AOS. Note that the in itial test required by the MACT can
serve as the testing required by this AOS under Condition A .2 , if approved in advance by the Division,
provided that such test is conducted with in the time frame specified in Condition A.2.
A.4.3.2 Major source for HAPs
A permanent replacement eng ine that is located at major source is subject to the requirements in 40 CFR
Part 63 Subpart ZZZZ as follows:
Exi sting , new or reconstructed spark ignition 4 stroke rich burn engines with a site rating of more
than 500 hp are subject to t h e requirements in 40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4
stroke lean burn engines with a site rating of more than 500 hp are subject to the requirements in
40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and
were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart
ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean
burn or 4 stroke rich burn engines with a site rating of 500 hp or less will meet the requirements of
40 CFR 63, Subpart Zll.Z by meeting the requirements of 40 CFR 60, Subpart JJJJ .
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of less than 250 hp w ill meet the requirements of 40 CFR 63,
Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ .
An analysis of the applicabl e monitoring , record keeping , and reporting requirements for the
permanent engine rep lacement shall be included in the Applicability Reports required under
Condition A.1 .2. Any testing required by the MACT i s in addition to that required by this AOS.
Note that the initial test required by the MACT can serve as the testing required by this AOS
under Condition A.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition A.2 .
A.3.5 Additional Sources
The replacement of an existing eng ine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for
any s ite; an eng ine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation .
AIRS ID: 045/1046/013 Page 17 of 17
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALT H AN D ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-31 50
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSU ED :
ISS UED TO:
08GA1200
JU L 3 1 2009
EnCana Oil & Gas (USA) Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCR IBED AND LOCATED AS FOLLOWS:
Natura l gas compression faci l ity, known as the High Mesa Compressor Station , located
in SE NW Section 36, Township 7S, Range 96W, in Garfield County, Colorado .
THE S PEC IFIC EQUIPMENT OR A CTIVITY SUBJECT TO THIS PERMIT INC L UDES THE FOLLOWING:
Facility AIRS Equipment Point Description
ID
One (1) Caterpillar, Model G3516LE, Serial Number 4EK04855,
natural gas-fired, turbo-charged , 4SLB recip rocating internal
HM02 014 combustion engine , site rated at 1,208 horsepower at 1,400 RPM .
This engine shall be equipped with an oxidation catalyst and air-
fuel ratio cont rol. T his emission unit is used for natural gas
compression.
This engine may be replaced with another engine in accordance with the temporary
engine replacement provision or with another Caterpillar G351 6LE eng ine in accordance
with the permanent replacement provision of the Alternate Operating Scenario (AOS),
incl uded in this permit as Attachment A.
THIS PERMIT IS GRANTED SUBJ ECT T O ALL RULES AND RE G ULATIONS OF THE COLORADO
AIR QUALITY C ONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL A C T C .R.S. (25-7-101 et s eq), TO THOSE GENERAL TERMS AND CONDITIONS
INC LUDED IN T HIS DOCUMENT AND T HE FOLL OWING SPECIFIC T ERMS AND CONDITIO NS:
REQUIREM E NTS TO SE LF-CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source (Regulation 3 , Part 8 , Section II I.G.5).
AIRS 10: 045/1046/014 Page 1 of 17
NGEngine Version 2008-1
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
2. 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)
M thl L" "t on IY 1m1s:
Facility AIRS Pounds per Month
Equipment ID Point NOx voc co Emission Ty pe
HM02 014 2972 486 306 Point
Monthly hm1ts are based on a 31-day month .
Annual Limits:
Facility AIR S Tons per Year
Equipment ID Point NOx voc co Emission Type
HM02 014 17.5 2 .9 1.8 Po int
See "Notes to Permit Holder #4 for mformat1on on em1ss1on factors and methods used to
calculate limits.
During the first twelve (12) months of operation , compliance with both the monthly and
yearly emission limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required .
Compliance with the synth etic minor status of this facility shall be determined by
recording the facility's annual criteria pollutant emissions , from each emission unit, on a
rolling (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
monthly emissions 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
emission units, requiring an APEN , at this facility.
3. This engine shall be equipped wit h an oxidation catalyst and air-fuel ratio control The
selective oxidation catalyst shall be capable of reducing uncontrolled emissions of VOC
and CO from the unit to the emission levels listed in Condition 2 , above . Operating
parameters of the control equipment are identified in the operation and maintenance
plan. (Reference: Regulation No.3 , Part B , Section III.E.)
PROCESS LIMITATIONS AND RECORDS
4. This source shall be limited to the following maximum consumption, processing and/or
operational rates as listed below. Monthly records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulation 3 , Part B , II.A.4)
P /C f L " . rocess onsump11on 1m1ts I Facility AIRS Annual Monthly
Equipment Point Process Parameter Limit Limit (31
ID days)
HM02 1 o14
Consumption of natural gas as a 90.9 7 .72
fuel MMscf/yr MMscf/month
AIRS ID: 045/1046/014 Page 2 of 17
I
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
D uring t he first twelve (12) months of operation , compl iance with both the monthly and
yearly consumption limitations shall be required. After the first twelve (12 ) months of
operation, compliance with only the yearly limitation shall be required .
Compliance wit h the yearly consumption limits shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve-month tot al is calculat ed
based on the previous twelve months' data. The permit holder shall calculat e monthly
consumption of n atura l gas and keep a compliance record on site or at a local field office
with site responsibi lity, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
5. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification , or adjust ment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in
any sixty consecutive minutes. (Reference: Regu lation No . 1 , Section II.A.1 . & 4 .)
6. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
7. The permit number and AI RS ID number sh all be marked on the subject equipment for
ease of id entif icat ion. (Reference: Regulation N umber 3 , Part B, Ill. E.) (State only
enforceable)
8. T his source is subject to the require ments of:
• Regulation No. 8, PartE , Subpart 11/.FFFF: National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and
• Regulation No. 8, Part E, Subpart /.A , National Emission Standards for
Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR
Part 63
including , but not limited to , the following:
• Emission and Operating Limitations
o 63.6600(b)-If you own or operate a new or reconst ru cte d 4SLB stationary
RICE with a site rating of more than 500 brake H P located at maj or source of
HAP emissions you must comply with the following emission limitations
(T able 2a, Subpart ZZZZ to Part 63):
• redu ce CO emissions by 93 percent or more; or
• limit concent ration of formaldehyde in the stationary RICE exhaust to
14 ppmvd or less at 15 percent 02.
A IRS ID: 045/1 046/014 Page 3 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o 63.6600(b)-If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more than 500 brake HP located at major source of
HAP em issions you must comply with the following operating limitations
(Table 2b, Subpart ZZZZ to Part 63):
• maintain your catalyst so that the pressure drop across the catalyst
does not change by more than 2 inches of water at 100 percent load
plus or minus 10 percent from the pressure drop across the catalyst
that was measured during the initial performance test; and
• maintain the temperature of your stationary RICE exhaust so that the
catalyst inlet temperature is greater than or equal to 450 oF and less
than or equal to 1350 °F.
• General Compliance Requirements
o §63.6605(a)-You must be in compliance with the em ission limitations and
operating limitations in this subpart that apply to you at all times , except
during periods of startup, shutdown, and malfunction.
o §63.6605(b) -If you must comply with emission limitations and operating
limitations, you must operate and mainta in your stationary RICE , including air
pollution control and monitoring equipment, in a manner consistent with good
air pollution control practices for minimizing emissions at all times , including
during startup, shutdown , and malfunction.
• Testing and Initial Compliance Requirements
o §63.6610(a)-You must conduct the initial performance test or other initial
compliance demonstrations in Table 4 to Subpart ZZZZ of Part 63 that apply
to you within 180 days after the compliance date that is specified for your
stationary RICE in §63.6595 and according to the provisions in §63.7(a)(2).
o §63.6615 -If you must comply with the emission limitations and operating
limitations, you must conduct subsequent performance tests semiannually (as
per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated
compliance for two consecutive tests , you may reduce the frequency of
subsequent performance tests to annually. If the results of any subsequent
annual performance test indicate the stationary RICE is not i n compliance
w ith the CO or formaldehyde emission limitation , or you deviate from any of
your operating limitations , you must resume semiannual performance tests .
o §63.6620 -You must conduct performance test and other procedures in
§63.6620 and in Tables 3 and 4 to Subpart ZZZZ of Part 63 that apply to you .
o §63.6625(b) -If you are required to install a continuous parameter monitoring
system (CPMS) as specified in Table 5 of this subpart, you must install,
operate, and maintain each CPMS according to the requirements in §63.8 .
AIRS ID: 045/1046/014 Page 4 of 17
EnCana Oil & Gas (USA) Inc.
Permit No . 08GA 1200
Issuance 1
Colorado Departm ent of P ublic Health and Envir onm ent
Air P o ll ution Control D ivision
o §63.6630(a)-You must demonstrate in itial compliance with each emission
and operating limitation that applies to you according t o T able 5 of Subpart
ZZZZ to Part 63.
o §63.6630(b) -Duri ng the in it ial performance test, you must establish each
operating limitation i n T ables 1 band 2b of Subpart Z ZZZ to Part 63 that
applies to you.
o §63.6630(c)-You must subm it the Notification of Compliance Status
containing the results of the initial complia nce demonstration according to the
requirements in §63.6645.
• Continuous Compliance Requirements
o §63.6635(b) -Except for monitor malfunctions, associated repairs , a nd
r equired quality assurance o r control activities (including, as applicable ,
calibration checks and required zero and span adj ustments}, you must
monitor continuously at all times that the stationary RICE is operating.
o §63.6635(c)-You may not u se data recorded d uring monitoring
malfunctio n s , associated repa irs, an d required quality assurance or control
act ivities in d ata averages and calculations used t o report emission or
operating levels. You must, however, use all the valid data collected during all
other periods.
o §63.6640(a)-You must d emonstrate continuous compliance with each
emission limitation and operati ng limitation in Tables 1a and 1b and T ables
2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods
specified in Table 6 of Subpart ZZZZ of Part 63.
o §63.6640(b)-You must report each instance in which you did not meet each
emission limitation or operating limitation in Tables 1 a a nd 1 b and Tables 2a
and 2b of Subpart ZZZZ of Part 63 that apply to you . These instances are
deviations from the emission a nd operati ng limitations in this subpart. The se
deviations must be reported according to the requirements in §63.6650. If you
change your catalyst, you must reesta blish the values of the oper ating
parameters measured during the in itial perfo r mance test. When you
reestablish the values of your operating parameters, you must also conduct a
performance test to demonstrate that you are meeting t he requir ed emission
limitation appl icable to your stationary RICE .
o §63.6640(d)-Consistent with §§63.6(e) and 63.7(e)(1), deviations from the
emission o r ope rating limitations that occur during a period of st artup,
shutdown , or malfunction are not violations if you demonstrate to the
Administrator's satisfaction that you were operat ing in accordance with
§63.6(e)(1). F or new, reconstructed , and rebuilt stationary RI CE , deviations
from the emission or operating li mitation s that occur during the first 200 hours
of operation from engine startup (engine bum-in period) are not violat ions.
A IRS I D : 045/1046/014 Page 5 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6640(e)-You must also report each instance in which you did not meet
the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you.
• Notifications, Reports and Records
o §63.6645(a) -If you own or operate a stationary RICE with a site rating of
more than 500 brake HP located at a major source of HAP emissions you
must submit all of the notifications in §§63. 7(b) and (c), 63.8(e), (f)(4) and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates
specified.
o §63.6645(c) -If you start up your new or reconstructed stationary RICE with a
site rating of more than 500 brake HP located at a major source of HAP
emissions on or after August 16, 2004, you must submit an Initial Notification
not later than 120 days after you become subject to this subpart.
o §63.6645(g) -If you are required to conduct a performance test, you must
submit a Notification of Intent to conduct a performance test at least 60 days
before the performance test is scheduled to begin as required in §63.7(b)(1).
o §63.6645(h)-If you are required to conduct a performance test or other initial
compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to
Part 63, you must submit a Notification of Compliance Status according to
§63. 9(h)(2)(ii).
• §63.6645(h)(2) -For each initial compliance demonstration required in
Table 5 of Subpart ZZZZ to Part 63 that includes a performance test
conducted according to the requirements in Table 3 to this subpart,
you must submit the Notification of Compliance Status, including the
performance test results , before the close of business on the 60th day
following the completion of the performance test according to
§63 .1 O(d)(2).
o §63.6650(a)-You must submit each report in Table 7 of Subpart ZZZZ to
Part 63 that applies to you.
o §63.6650(b)-You must submit each report by the date in Table 7 of Subpart
ZZZZ to Part 63 and according to the requirements in paragraphs (b)(1)
through (5) of §63.6650.
o §63.6650(c)-The Compliance report must contain the information in
paragraphs (c)(1) through (6) of §63.6650.
o §63.6650(e)-For each deviation from an emission or operating limitation
occurring for a stationary RICE where you are using a CMS to comply with
the emission and operating limitations in Subpart ZZZZ to Part 63, you must
include information in paragraphs (c)(1) through (4) and (e)(1 ) through (12) of
§63.6650.
AIRS ID: 045/1046/014 Page 6 of 17
EnCana Oil & Gas (U SA) Inc.
Permit No . 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6655(a) -If you must comply with the emission and operating lim itations ,
you must keep the records described in §63.6655(a)(1) through (a)(3),
§63.6655 (b )(1) through (b)(3) and §63.6655 (c).
o §63.6655(d)-You must keep the records requi red in Table 6 of Subpa rt
ZZZZ of Part 63 to show continuous compliance with each em ission or
operating l imitation that applies to you .
o §63.6660(a)-Your records must be in a form suitable and readily available
for expeditious review accor ding to §63.1 O(b )(1 ).
o §63.6660(b) -As specified in §63.1 O(b)(1 ), you must keep each record for 5
years following the date of each occurrence, measurement, maint enance,
corrective action , report, or record .
o §63.6660(c)-You must keep each record readily accessible in hard copy or
electronic form on -sit e for at least 2 years after the date of each occu rrence ,
measureme nt, maintenance, corrective act ion , report, or record , according to
§63.1 O(b)(1). You can keep the records off-s ite for the remaining 3 years .
• Other Requirements and Information
o §63.6665-Table 8 to this subpart shows which part s of the General
Provisions in §§63.1 through 63.15 apply to you.
OPERATING & MAINTENANCE REQUIREMENTS
9. Upon startup of this point, the appl icant shall f ollow the operating and maintenance
(O&M) plan a nd record keeping format approved by the Division , i n order to demonstrate
compliance on an ongoing basis with the requirements of t his perm it. Rev isions to your
O&M plan are subject to Division approval prior to implementat ion. (Refe rence:
Regulation No. 3 , Part B , Section III.G.7.)
COMPLIANCE T ESTING AND SAMPLING
Periodic Testing Requirements
10. Th is engine is subject to the periodic testing requ irements of 40 C .F.R Part 63, Subpart
ZZZZ.
1 1. T his engine is subject to the periodic testing requi rements as specified in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approv al. Replaceme nts of this unit com pleted as Alt ernative
Operati ng Scenarios may be subject to additional testing requirements as specif ied in
Attachment A.
A IRS ID: 045/1046/014 Page 7 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
12. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3 , Part A, II. C)
a. Annually whenever a significant increase in emissions occurs as follows :
For any c riteria 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 any non-criteria reporta ble 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 .
f . Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the permittee is
exercising an alternative-operating scenario and is installing a permanent
replacement engine.
13. This source is subject to the provisions of Regulation Number 3 , Part C , Operating
Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this
construction permit must be incorporated into the operating permit. The application for
the modification to the Operating Permit is due within one year of commencement of
operation of the equipment or modification covered by this permit.
14. Prevention of Significant Deterioration (PSD) requirements 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
PSD threshold will requi re a full PSD review of the source as though construction had
not yet commenced on the source. The source shall not exceed the PSD threshold until
a PSD permit is granted. (Regulation No.3 Part D, VI.B .4)
GENERAL TERMS AND CONDITIONS:
15. 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
AIRS ID: 045/1046/014 Page 8 of 17
EnCa na Oil & Gas (USA) Inc.
Permit No . 08GA1200
Issu ance 1
Colorado Department o f P ublic Health and Environment
Air Pollution Control Division
AQCC Regulation No. 3, Part 8 , Section 11 .8 upon a request for transfer of owner ship
a nd the submittal of a revised A PE N and the required fee.
16. Issu a nce of a construct ion permit does not p rovide "fin al " authority f or this activity or
operation of this source. Final authorization of the permit must be secured from the
APCD in writing in accordance with t h e p rovisions of 25-7 -1 14.5(12)(a) C.R.S. and
AQCC Regulation No. 3 , Part 8 , Section Il l. G. F inal authoriz ation cannot be granted
until the operation or activity commences and has been verifie d by the A P C D 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 t o Self-Certify for Final Authori zation
section of this permi t .
17. T his p erm it is issue d in reliance upon the accuracy and com pleteness of information
supplied by the applicant a nd is conditioned upon conduct o f the activity, or construction,
install ation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agent s. It is valid only for the
equipment and ope rations or activity specifically ide ntified on the permit.
18 . Unless specifically stat ed o therwise, the general a nd specific conditions contained in this
permit have been determine d by the APCD to be necessa ry to assure compliance wit h
the provisions of Section 25-7-114.5(7)(a ), C.R.S.
19. Each and eve ry condition of this permit is a material part hereof and is not severa ble.
Any challenge to or appe al of a condition hereof shall constitute a rejection of the ent ire
permit and upon such occurrence, t h is permit shall be deemed denied ab initio. T his
permit may be revoked at any time prior t o self-certification and final authoriz ation by the
Air Pollution Control Division (APCD) on g rounds set forth in the Colorad o A ir 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 D ivision denies a
permit, conditions imposed upon a permit are contested by the applicant, or the Division
revokes a permit , the a pplicant or own er or o p erator of a source may req uest a hearing
before the AQCC for review of t he Di vision 's action.
20. Section 25-7-114.7(2)(a), C .R.S . requires that all sources requ ired to file an Air Pollution
Emission Notice (APEN ) must pay an annual fee to cover the cost s of inspections and
admi nistration. If a source or activity is to be discontinued, the owner must notify t h e
Division in writing requesting a cancellation of the permit. Upon notification, annual f ee
billing will terminate.
21 . Viol ation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of t he AQCC may result in administrative,
civil or criminal enf orcement actions under Section s 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (crim inal penalties), C .R.S.
22 . This permit replaces the foll owing permit , which is canceled upon issuance of this
permit:
A IRS ID: 045/104 6/014 Page 9 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. OBGA 1200
Issuance 1
Colorado Department of Public Health a nd Environment
Air Poll ution Control Division
Permit No. AIRS ID Notes
05P00964 777/2661 /001 Engine-HM02: This equipment will now be covered
under this stationary source permit.
By: ~ , • • • h -=-(l'] (iV"\ I L.l
Carissa Money (f
Permit Engineer
p "t H. t erm1 IS Ory
Issuance Date Description
Issuance 1 This Issuance Canceled portable permit 05P00964 and issued
as new stationary permit
lA, Modification July 17, 2007 Change in fuel use, emissions, addition of control
No. 1 for equipment
05P00964
Initial Approval April14, 2006 Issued to EnCana Oil & Gas
for 05P00964
AIRS ID: 045/1046/014 Page 10 of 17
EnCana Oil & G a s (USA) Inc.
Permit N o. Q8GA1200
Issuance 1
Notes to Permit Holder:
Colorado Department of Public H e a lth and E nvir o n ment
Air Pollution Contro l Division
1) 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 permittee 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
application form must be submitted with a request for a permit revision .
2) This source is subject to the Common Provisions Regulation Part II , Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee 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. cdphe . state. co. us/reg u lations/airregs/ 1 001 02aqcccommon provisi onsreg. pdf.
3) The following emissions of non-criteria reportable air pollutants are estimated based upon t he
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysi s of the specific compounds emitted if the source(s) operate at the permitted
limitations.
U ncontro lled
Emis s i on Are the Cont ro lled
A I RS Ra te emis s ion s Emis sio n
Point Pollutant CAS# BIN (lb/yr) reportable? Rat e (lb/yr}
Formalde hyde 5000 A 5599 Yes 2800
Acetaldehy de 75070 A 760 Yes 380
A c rol e in 107028 A 467 Yes 234
014 Methanol 67561 c 227 No 114
n-Hexane 110543 c 101 No 50
Benzene 71432 A 40 No 20
Toluene 108883 c 37 No 19
4 ) The emission levels contained in this permit are based on the following emission factors:
Point 014 :
Emission Factors -Uncontrolled Emission Factors -Controlled
CA S Pollutant lb/MMBtu g /bhp-hr Source lb/MMBt u g /bhp-hr Sourc e
NOx 0.3850 1.5000 Mfg 0 .3850 1.5000 Mfg
co 0 .5673 2 .2100 Mfg 0 .0397 0 .1547 Mfg
voc 0.1258 0.4900 Mfg 0 .0629 0.2450 Mfg
5000 Formaldehyde 0 .0616 0 .2400 Mfg 0.0308 0 .1200 Mfg
AP-42 ; Table
75070 Acetaldehyde 0 .0084 0 .0326 3.2-2 (7/2000); 0.0042 0.0163 Mfg
Natural Gas
AP-42 ; Table
107028 Acrolein 0 .0051 0.0200 3.2-2 (7/2000); 0.0026 0.0100 Mfg
Natural Gas
67561 Methanol 0.0025 0.0097 AP-42; Table 0 .0013 0.0049 Mfg 3.2-2 (7/2000);
A I RS ID: 0 4 5/1046/01 4 P age 11 of 17
EnCana O il & Gas (USA) Inc. Colora do D epartment of Public H ealth and Environment
Permit N o. 08GA 1200 Air Pollution Contro l D ivision
Issuance 1
Emissi on Fa c tors -Uncontrolled Emission Factors -Co ntrolled
CAS Po llutant lb/MMBtu _g /bhp-hr Source lb/MMBtu g/bhp_-hr I Source
Natural Gas
AP-42 ; Table
110543 n-Hexane 0 .0011 0.0043 3.2-2 (7/2000); 0 .0006 0.0022 Mfg
Natura l Gas
AP-42 ; T able
71432 Benzene 0.0004 0.0017 3.2-2 (7/2000); 0.0002 0.0009 Mfg
Natura l Gas
AP-42 ; Table
108883 Toluene 0.0004 0.0016 3.2-2 (7/2000); 0 .0002 0 .0008 Mfg
'-· Natural Gas
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8,589 Btu/hp-hr, a
site-rated horsepower value of 1,208, and a fuel heat value of 1,000 Btu/scf.
5) In accordance with C.R.S. 25-7-114 .1 the Air Pollutant Emission Notice (APE N) associated with this
permit is valid for a term of five years. The five-year term for th is APEN expires on November 9, 20 13.
A revised APEN shall be submitted no later than 30 days before the five-year term expires.
6) This facility is classified as follows :
Applicable Status Requirement
Operating Permit Major Source: NOx, HAPs
S_ynthetic Minor Source: CO, VOC
PSD Synthetic Minor Source : VOC
MAC T HH Synthe t ic Minor Source: T oluene , Total HA P
MACT ZZZZ Major Source
7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regula tions can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Sta ndards of Performance for New Stationary Sources
NSPS 60 .1-End Subpart A-Subpart K KKK
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 DOD
MACT 63.1200-63.1439 Subpart EEE-Subpart PPP
MACT 63.1440-63.6175 S ubpa rt Q QQ -Subpa rt YYYY
MACT 63.6580-63 .8830 Subpart ZZZZ -Subpart MMMMM
MACT 63.8980-End Subpart NN NNN-Subpart XXXXXX
AI R S ID: 045/104 6/014 Page 12 of 17
EnCana Oil & G as (USA) Inc.
Permit N o. 08GA1 200
Issuance 1
Colorado Department of Public Health and E n v ironment
Air Pollution Control D ivision
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
December 10 , 2008
The following A lternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating i nternal combustion engi nes has been reviewed in accordance with the
requirements of Regulation No. 3 ., Part A , Section IV.A, Operational Flexibility-Alternative Operat ing
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No . 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration , and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Const ruction Permit for any engine replacement performed in accordance with this AOS, and the
permittee shall be all owed to perform such engine replacement w ithout applying for a revision to this
permit or obtaining a new Construction Permit.
A 1 Eng ine Replacem ent
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine . 'T emporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanentn is defined as in the same service for more
t han 90 operating days in any 12 month period . T he 90 days is the total number of days that the engine
is in operati on . If the engine operates only part of a day, that day shall count as a single day towards the
90-day total. T he compliance demonstrations and any periodic monitoring required by th is AOS are in
addition to any compliance demonstrations or periodic mon itoring required by this permit.
All replacement eng ines are subject to all federally applicable and state-on ly requirements set forth in this
pe rmit (includ ing monitoring and record keeping).
The results of all tests and the associated calculations requ ired by this AOS shall be submitted to th e
Division w ith in 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NS PS or MACT requirements. Results of all tests shall be kept on s ite for
five (5) years and made available to the Division upon request.
The perm ittee shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial
number of the engine(s) that are replaced during the term of this permit , and the manufacturer, model
number, horsepower, and serial number of the rep lacement engine. In addition to the log , the permittee
shall maintain a copy of all Applicability Reports required under section A 1.2 and make them available to
the Div ision upon request.
A.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the
emission limits set forth in this permit with an engine that is of the same manufacturer, model , and
horsepower or a different manufacturer, model, or horsepower as the existing engine without mod ify ing
th is permit, so long as the emission s from the temporary rep l acement engine comply with the emission
limitations for the exi sting permitted eng ine as determined in section A.2. Measurement of emissions
from the temporary replacement engine sha ll be made as set forth in section A2.
A.1 .2 The pe r mittee may permanently rep lace the ex isting compressor engine w ith an eng ine that is of
the same manufacturer, model and horsepower w ithout mod ifying thi s permit so long as the emissions
from t he permanent replacement engine comply w ith 1) the permitted annual emission limitations for t he
AI R S ID : 045/104 6/01 4 Page 13 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3)
the applicable emission limitations as set forth in the Applicability Report submitted to the Division w ith
the Air Pollutant Emissios Notice (APEN) for the replacement engine (see
http://www.cdphe.state.co.us/ap/OIIgaspermitting .html for example applicability report formats).
Measurement of emissions from the permanent replacement engine and compliance w ith the applicable
emission limitations shall be made as set forth in section 2.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencmg operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee , a cover letter explaining
that the permittee is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability Reports can be found in at http://www.cdphe .state co.us/ap/oilgaspermittinq.html.
This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of
the source indicating that "based on the information and belief formed after reasonable inquiry, the
statements and information included in the submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The permittee shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
A.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testmg requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing, this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition , if approved in advance by the Division .
The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust
from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Divis ion's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division 's website at:
http://www.cdphe.state. co. us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance . If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 045/1046/014 Page 14 of 17
EnCana Oil & Gas (USA) Inc.
Permi t No. 08GA 1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison w ith a short-term lim it that is either input based (lb/m m Btu), output based (g/hp-hr) or
concentration based (ppmvd@ 15% 02) that the existing unit is currently subject to or the replacement
engine will be subject to , the results of the test shall be converted to the appropriate units as described in
t he above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results ind icate compliance with both the NOX and CO emission limitations, in the
absence of cred ible evidence to the contrary, the source may certify that the eng ine is in compliance with
both the NOX and CO emission limitations for the relevant time period .
Subject to t he provisions of C .R.S. 25-7-123.1 and in the absence of cred ible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emi ssion
limitations, the engine will be considered to be out of compliance from the date of the portable anal yzer
test until a portable analyzer test indicates compliance with both t he NOX and CO emission lim itations or
until th e engine is taken offline.
A.3 Applicable Regulations for Permanent Engine Replacements
A.3.1 Reason ably Available Control Technology (RACT): Reg 3, Part B § 11.0 .2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenan ce or nonattainment m ust apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC
and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for
which the area is in atta inment/main tenance or nonattainment , except as follows:
In the Denver Metropolitan PM 10 attainment/maintenance area , RACT applies to PM10 at any level of
emissions and to NOX and S02, as precursors to PM10, if the potential to emit of NOX or S02 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating
internal combustion eng ines:
VOC:
CO:
NOX:
S02:
PM10 :
The emission limitations in NSPS JJJJ
The emission limitations in NSPS JJJJ
The emission limitations in NSPS JJJJ
Use of natural gas as fuel
Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331 ) and 40 CFR Part 72 (§ 72.2 ), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
A.3.2 Control Requ irements and Emission Standards: Regulation No.7 , Sections XVI. and XVII .E
(State-Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located w ith in the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulati on No.7 , section XVI , as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 h p shall use a non-
selective catalyst and air fuel controller to reduce emission.
AIRS ID: 045/1046/014 Page 15 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1200
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emiss1ons.
The above emission control equipment shall be appropriately s1zed for the engine and shall be operated
and maintained according to manufacturer specifications .
The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2 .
Emission Standards: Section XVII. E-State-only requirements
Any permanent engine that i s either constructed or relocated to the state of Colorado from another state,
after the date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine Construction or E mission Standards in Glhp-hr HP Relocation Date
NOx co voc
lOO <Hp<500 January 1, 2008 2.0 4.0 1.0
January 1. 2011 1.0 2.0 0.7
500~Hp July l , 2007 2.0 4.0 1.0
July 1. 2010 1.0 2.0 0 .7
The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2
A.3.3 NSPS for spark ignition internal combustion engines: 40 CFR 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1 ,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject 40 CFR 60, Subpart
JJJJ . An analysis of applicable monitoring, recordkeeping , and reporting requirements for the permanent
engine replacement shall be included in the Applicability Reports required under Condition A.1.2. Any
testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required
by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition A.2, if approved in
advance by the D ivision, provided that such test is conducted within the time frame specified in Condition
A.2.
Note that under the provisions of Regulation No. 6. Part B , section I. B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No.6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ
requirements).
However, as of November 1, 2008 the Division has not yet adopted NSPS JJJJ. Until such time as it
does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts
NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the
provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A}, any engine relocated from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of NSPS JJJJ.
AIRS ID: 045/1046/014 Page 16 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1200
Issuance 1
Color ado Department of Public Health and Environment
Air Pollution Control Division
A.3.4 Reciprocating in ternal combustion e ngine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A.3.4 .1 Area Source for HAPs
A permanent replacement engine located at an area source that commenced construction or
reconstruction after June 12 , 2006 as defined in § 63.2 , will meet the requirements of 40 CFR Part 63,
Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the
applicable monitoring , recordkeeping , and reporting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Cond ition A.1 .2 . Any testing required by the
MACT is in addition to that required by th is AOS . Note that the initial test required by the MACT can
serve as the testi ng requ ired by th is AOS under Condition A.2 , if approved in advance by the Division ,
provided that such test is conducted with in the time frame specified in Condition A.2.
A.4.3.2 Major source for HAPs
A permanent replacement eng ine that is located at maj or source is subject to the requirements in 40 CFR
Part 63 Subpart ZZZZ as follows:
Existing, new or reconstructed spark ign ition 4 stroke rich burn engines with a site rating of more
than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4
stroke lean burn engines w ith a site rating of more than 500 hp are subject to the requirements in
40 CFR Part 63 Subpart ZZZZ.
New or reconstructed (const ruction or reconstruction commenced after 6/12/06) 4 stroke lean
burn eng ines with a site rating of greater th an or equal to 250 but less or equal to 500 hp and
were manufactured on or after 1/1/08 are subject to t he requirements in 40 CFR Part 63 Subpart
ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean
burn or 4 stroke rich burn engines w ith a site rating of 500 hp or less will meet the requirements of
40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.
New or reconstructed (construction or reconstruction commenced after 6 /12/06) 4 stroke lean
burn engines with a site rating of less than 250 hp w ill meet the requirements of 40 CFR 63,
Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.
An analysis of the applicable monitoring, recordkeeping , and reporting requirements for the
permanent engine replacement shall be included in the Appl icability Reports requ ired under
Condition A.1 .2. Any testing required by the MACT i s in addition to that required by this AOS.
Note that the initial test requi red by the MACT can serve as the testing required by this AOS
under Condit ion A.2 , if approved in advance by the Division , provided that such test is conducted
w ithin the time frame specified in Condition A.2.
A.3.5 Additiona l Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a
new emissions unit, not "routine replacemenf of an existing unit. The AOS is therefore essentially an
advanced construction permit review. Th e AOS cannot be used for addition al new emission points for
any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go throu gh the appropriate
Construction/Operating perm itting process prior to installation .
AIRS ID: 045/1046/014 Page 17 of 17
STATE OF COLORADO
C OLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
A IR POLLUTION CONTROL DIVISION
TELEP HONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 08GA1194
DATE ISSUED: JUL 3 1 2009
Issuance 1
ISSUED TO: EnCana Oil & Gas (USA) Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Nat ural gas compression facil ity, known as the High Mesa Compressor Station , located
in SE NW Section 36 , Township 7S, Range 96W, in Garfield County, Colorado .
THE SPEC IFIC EQUIPMENT O R A CTIVITY S UBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS Equipment Point Description
10
One (1 ) Caterpillar, Model G3516LE, Serial Number WPW00191 ,
natural gas-fired, turbo-cha rged, 4SLB reciprocating intern al
HM03 008 combustion engine, site rated at 1 ,208 horsepower at 1,400 RPM .
This engine shall be equipped with an oxidation catalyst and ai r-
fuel ratio control. T his emission unit is used for natural gas
compression.
This engine may be replaced with another engine in accordance with the temporary
engine replacement provision or with another C aterpillar G 35 16 LE engine in accordance
with the permanent replacement provision of t he Alternate Operating Scenario (AOS),
included in this permit as Attachment A
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF T HE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
C ONTROL ACT C .R.S. (25-7-101 et s e q ), TO THOSE GENERAL TERMS AN D CONDITIONS
IN CLUDED IN THIS DOC UMENT AND THE FOLL OWING SPEC IFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. This construct ion permit represents final permit approval and authority to operate this
emissions source (Regulation 3 , Part B , Section II I.G .5).
A IRS 10 : 045/1046/008 Page 1 of 17
NGEngine Version 2008-1
EnCana Oil & Gas (U SA) Inc.
Permit No . 08GA1194
Issuance 1
Colorado Department of Publ ic Health and Environment
A ir Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
2 . Emissions of air pollutant s shall not exceed the following li mitations (as calculated in the
Division's preli minary ana lysis). (Reference: Regula tion No . 3, Part B , Section II.A.4)
M thl L " ·t on IY 1m1s:
Facility AIRS Pounds p er Month
Equipment 10 Point NOx voc co Em i ssion Type
H M03 008 2972 486 306 Po int
M onthly hm1 t s are based on a 31-da y mont h.
Annual Limits:
Facility AIRS Tons per Year
Equipment 10 Po int NOx voc co Em ission Type
H M03 008 17.5 2 .9 1.8 Poin t
See *Notes to P erm1t Holder #4 for mformat1on on e m1ss1on fa ctors a n d meth ods used to
c alculate lim its .
During the first twelve (12) months of operation , compliance with both the monthly and
yearly emission limitations shall be required . After the first twelve (12) months of
operation, compl ian ce w ith o nly the yearly limitation sha ll be required.
Compliance with the synthetic minor status of th is f acility shall be determined by
recording the facility's annual criteria pollutant emissions, from each emission unit , on a
roll ing (12) month total. By the end of each month a new twelve-month tota l is
calculated based on the previous twelve months' data . T he permit holder shall calculate
monthly e m issions and kee p a c om pliance record on site , or at a local field office w ith
s ite responsibi li ty, for Division re view. Th is rolling twelve-month tot al shall apply t o a ll
emission units, req uiring an APEN , at this facility .
3 . T his eng ine shall be equ ipped with an oxidat ion catalyst and air-fuel ratio cont rol. T he
selective oxidation ca talyst shall be c apable of reducing uncontrolled emissions of VOC
and CO from the unit to the emission levels listed in Condition 2 , above. Operating
parameter s of the control equipment are identified in the operation and maintenance
plan. (Reference: Regulation No.3, Part B , Section III.E.)
PROCESS LIMITATIONS AND RECORDS
4 . This sour ce shall be limited to the following maxi mum consumption . processing and/or
operat ional rates as listed below. Monthly records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon
request. (Reference: Regulat ion 3, Part B , II.A.4)
Process/Consumption Limits
Facility AIRS Annual Monthly
Equipment Point Process Parameter Limit Limit (31
10 days)
HM03 008 C onsump t ion of nat ural gas as a 90.9 7 .72
fuel MMscf/yr MMscf/month
AIRS ID : 045/1046/008 Page 2 of 17
I
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Departm ent of Public Health and Environ ment
Air Pollution Control Division
During the first twelv e (12) months of operation , compliance with both the monthly and
yearly consumption limitations shall be required. After the fi rst twelve (12) months o f
operation, compliance with only the yearly li m itation shall be required.
Compliance with the yearly consumption lim its 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. T he permit holder shall calculate monthly
consumption of natural gas and keep a compliance record on site o r at a local field office
with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
5. Visible emissions shall not exceed twenty percent (20%) opacity during normal oper at ion
of the source. During periods of startup, process modificat ion, or adjustment of control
equi pment v isible emissions shall not exceed 30% opacity for more than six m inutes in
any sixty consecutive minutes. (Reference: Regulation No. 1 , Section I I.A .1. & 4.)
6 . T h is source is subject to the odor requirements of Regulation No . 2. (State only
enforceab le)
7. The permit number and AIRS ID num ber s h all be marked on the subj ect equipment for
ease of identif icatio n . (Reference: Regulation Number 3 , P art B, Ill. E.) (State only
enforceable)
8. T h is source is subject to the requi rement s of:
• Regulation No. 8, PartE , Subpart 1//.FFFF: Nati onal Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and
• Regul ati on No. 8, Part E, Subpart /.A , National Emi ssion Standards for
Hazardous A ir Pollutants for Source Categories: General Provi sions, 40 CFR
Part 63
including, but not limited to, the following:
• Emission and Operating Limitations
o 63.6600(b)-If you own or operate a new or reconstructed 4SLB stationary
R ICE with a s ite rating of more than 500 b rake HP located at major source of
H AP emissions you must comply with the following emission limitations
(Table 2a, Subpart ZZZZ to Part 63):
• reduce CO emissions by 93 percent o r more; o r
• limit concentration of formaldehyde in the stationary RICE exhaust to
14 ppmvd or less at 15 percent 02.
A IRS ID: 045/1046/008 Page 3 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o 63.6600(b) -If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more than 500 brake HP located at major source of
HAP emissions you must comply with the following operating limitations
(Table 2b, Subpart UZZ to Part 63):
• maintain your catalyst so that the pressure drop across the catalyst
does not change by more than 2 inches of water at 1 00 percent load
plus or minus 10 percent from the pressure drop across the catalyst
that was measured during the initial performance test; and
• maintain the temperature of your stationary RICE exhaust so that the
catalyst inlet temperature is greater than or equal to 450 oF and less
than or equal to 1350 °F.
• General Compliance Requirements
o §63.6605(a)-You must be in compliance with the emission limitations and
operating limitations in this subpart that apply to you at all times, except
during periods of startup, shutdown, and malfunction.
o §63.6605(b) -If you must comply with emission limitations and operating
limitations, you must operate and maintain your stationary RICE, including air
pollution control and monitoring equipment, in a manner consistent with good
a ir pollution control practices for minimizing emissions at all times, including
during startup, shutdown, and malfunction.
• Testi ng and Initial Compliance Requirements
o §63.6610(a)-You must conduct the initial performance test or other initial
compliance demonstrations in Table 4 to Subpart UZZ of Part 63 that apply
to you within 180 days after the compliance date that is specified for your
stationary RICE in §63.6595 and according to the provisions in §63. 7(a)(2).
o §63.6615 -If you must comply with the emission limitations and operating
limitations, you must conduct subsequent performance tests semiannually (as
per Table 3 of Subpart UU to Part 63). After you have demonstrated
compliance for two consecutive tests, you may reduce the frequency of
subsequent performance tests to annually. If the results of any subsequent
annual performance test indicate the stationary RICE is not in compliance
with the CO or formaldehyde emission limitation, or you deviate from any of
your operating limitations, you must resume semiannual performance tests.
o §63.6620 -You must conduct performance test and other procedures in
§63.6620 and in T ables 3 and 4 to Subpart ZUZ of Part 63 that apply to you .
o §63.6625(b)-If you are required to install a continuous parameter monitoring
system (CPMS) as specified in Table 5 of this subpart, you must install,
operate, and maintain each CPMS according to the requirements in §63.8 .
AIRS ID: 045/1046/008 Page 4 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6630(a)-You must demonstrate initial compliance with each emission
and operating limitation that applies to you according to Table 5 of Subpart
ZZZZ to Part 63.
o §63.6630(b) -During the initial performance test, you must establish each
operating limitation in Tables 1 b and 2b of Subpart ZZ2Z to Part 63 that
applies to you.
o §63.6630(c)-You must submit the Notification of Compliance Status
containing the results of the initial compliance demonstration according to the
requir ements in §63.6645.
• Continuous Compliance Requirements
o §63.6635(b)-Except for monitor malfunctions , associated repairs , and
r equired quality assurance or control activities (including, as applicable,
calibration checks and required zero and span adjustments), you must
monitor conti nuously at all t imes that the stationary RICE is operating.
o §63.6635(c)-You may not use data recorded during monitoring
malfunctions, associated repairs, and required quality assurance or control
activities in data averages and calculations used to report emission or
operating levels . You must, however, use all the valid data collected during all
other periods.
o §63.6640(a)-You must demonstrate continuous compliance with each
emission limitation and operating limitation in Tables 1 a and 1 b and Tables
2a and 2b of subpart Z2ZZ of Part 63 that apply to you according to methods
specified in Table 6 of Subpart ZZZZ of Part 63.
o §63.6640(b)-You must report each instance in which you did not meet each
emission limitation or operating limitation in Tables 1 a and 1 b and Tables 2a
and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are
deviations from the emission and operating limitations in this subpart. These
deviations must be reported according to the requirements in §63.6650. If you
change your catalyst, you must reestablish the values of the operating
parameters measured during the initial perfor mance test. When you
reestablish the values of your operating parameters, you must also conduct a
performance test to demonstrate that you are meeting the required emission
limitation appli cable to your stationary RICE.
o §63.6640(d)-Consistent w ith §§63.6(e) and 63.7 (e)(1), dev iations from the
emission or operating lim itations that occur during a period of startup,
shutdown , or malfunction are not violations if you demonstrate to the
Admi nistrator's satisfaction that you were operating in accordance w ith
§63.6(e)(1 ). For new, reconstructed, and rebuilt stationary RICE, deviations
from the emission or operating limitations that occur during the first 200 hours
of operation from engine startup (engine bum-in period) are not violations.
AIRS ID: 045/1046/008 Page 5 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6640(e)-You must also report each i nstance in which you did not meet
the requirements in Table 8 of Subpart ZZZZ to Part 63 that apply to you .
• Notifications, Reports and Records
o §63.6645(a)-If you own or operate a stationary RICE with a site rating of
more than 500 brake HP located at a major source of HAP emissions you
must submit all of the notifications in §§63.7(b) and (c), 63 .8(e), (f)(4) and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates
specified .
o §63.6645(c)-If you start up your new or reconstructed stationary RICE w ith a
site rati ng of more than 500 brake HP located at a major source of HAP
emissions on or after August 16, 2004, you must submit an Initial Notification
not later than 120 days after you become subject to this subpart.
o §63.6645(g) -If you are required to conduct a performance test, you must
submit a Notification of Intent to conduct a performance test at least 60 days
before the performance test is scheduled to begin as required in §63.7(b)(1).
o §63.6645(h) -If you are required to conduct a performance test or other initial
compliance demonstration as specified in Tables 4 and 5 of Subpart ZZZZ to
Part 63, you must submit a Notification of Compliance Status according to
§63.9(h)(2)(ii).
• §63.6645(h)(2) -For each initial compliance demonstration required in
Table 5 of Subpart ZZZZ to Part 63 that includes a performance test
conducted according to the requirements in Table 3 to this subpart,
you must submit the Notification of Compliance Status , including the
performance test results , before the close of business on the 60th day
following the completion of the performance test according to
§63.1 O(d)(2).
o §63.6650(a)-You must submit each report in Table 7 of Subpart ZZZZ to
Part 63 that applies to you .
o §63.6650(b)-You must submit each report by the date in Table 7 of Subpart
ZZZ.Z to Part 63 and according to the requ irements in paragraphs (b)(1)
throug h (5) of §63.6650 .
o §63.6650(c)-The Compliance report must contain the i nformati on in
paragraphs (c)(1) through (6 ) of §63.6650.
o §63.6650(e)-For each deviation from an emission or operating limitation
occurring for a stationary RICE where you are using a CMS to comply with
the emission and operating limitations in Subpart ZZZZ to Part 63, you must
include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of
§63.6650.
AIRS ID: 045/1046/008 Page 6 of 17
EnCana Oil & Gas (USA) Inc.
Permit No . 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Poll ution Control Division
o §63.6655(a) -If you must comply with the em iss ion and operati ng limitations ,
you must keep the records described in §63 .6655(a)(1) through (a )(3),
§63.6655 (b)(1) through (b)(3) and §63.6655 (c).
o §63.6655(d)-You must keep the records required in Table 6 of Subpart
ZZZZ of Part 63 to show continuous compliance with each em ission or
operating limitation that applies to you .
o §63.6660(a) -Your records must be in a form suitable and readily available
for exped itious review according to §63 .1 O(b )(1 ).
o §63.6660(b) -As specified in §63.1 O(b)(1 ). you must keep each record f or 5
years following the date of each occurrence, measurement, maintenance,
corrective action , report, or record .
o §63.6660(c)-You must keep each record read ily accessible in hard copy or
electronic form on -sit e for at least 2 yea rs after the date of each occurrence ,
measurement, ma intenance, co rrective action , report, or record , accord ing to
§63.1 O(b)(1 ). You can ke ep the records off-site f or the remaini ng 3 years.
• Other Requirements and Information
o §63 .6665 -T able 8 to this subpart shows which parts of the General
P rovisions in §§63.1 through 63.15 apply to you .
OPERATING & MAINTENANCE REQUIREMENTS
9 . Upon startup of t his point , the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division , in orde r to demonst rate
compliance on an ongoing basis with the req uirements of this perm it. Revisions to your
O&M pla n are subject to Division a pproval prior to impleme ntation . (Reference:
Reg ulation No. 3 , Part B , Section III.G .7.)
COMPLIANCE TESTING AND SAMPLING
Periodi c Testing Requirements
10. T his engine is subject to the periodic test ing requirements of 40 C.F.R Part 63 , Subpart
ZZll..
11. T his engine is subject t o the periodic testing requirements as specified in the operat ing
and m ain tenance (O&M) plan as approved by the Division. Revisions to you r O&M pl an
ar e subject to Division approval. Replacements of t his unit completed as A lternative
Operating Scenarios may be subject to additional testing req uirements as specified in
Attachment A.
AIRS ID: 045/1046/008 Page 7 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
12 . A revised Air Pollutant Emission Notice (A PEN ) shall be filed : (Reference : Regulation
No. 3 , Part A , II.C)
a . Annually 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 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 facil ity, 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.
f . Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The A PEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the permittee is
exercising an alternative-operating scenario and is installing a permanent
replacement engine.
13. This source is subject to the provisions of Regulation Number 3 , Part C , Operating
Permits (Title V of the 1990 Federal Clean Air Act Amendments). T he provisions of this
construction permit must be incorporated into the operating permit. The application for
the modification to the Operating Permit is due within one year of commencement of
operation of the equipment or modification covered by this permit.
14. Prevention of Significant Deterioration (PSD) requirements shall apply to this source at
any such time that th is source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
PSD threshold will require a full PSD review of the source as though construction had
not yet commenced on the source. The source shall not exceed the PSD threshold until
a PSD permit is granted. (Regulation No.3 Part D , VI.B.4)
GENERAL TERMS AND CONDITIONS:
15. 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
AIRS ID: 045/1046/008 Page 8 of 17
EnCana Oil & Gas (USA) Inc.
Permit No . 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
AQCC Regulation No. 3, Part B, Section 11.8 upon a request for transfer of ownership
and the subm ittal of a revised A P EN and the required fee.
16. Issuance of a 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 a ut horization cannot be g ranted
until the operation or activity commences and has been verified by the A PC D as
conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by t he Division , it will provide w ritten
documentation of such fina l authorization . Details for obtai ning final authorizati on to
operate are located in the Requirements to Self-Certify for Final Authorization
section of this permit.
17. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant 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 applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identif ied on the permit.
18 . Unless specifically stated ot herwise, the general and specific conditions contained in this
permit have been determined by the A PCD to be necessary to assure compliance with
the provisions of Section 25-7-114 .5(7)(a), C.R.S.
19. Each and every condition of this permit is a material part hereof and is not severable.
Any cha ll enge to or appeal of a condition hereof shall const itute a rejection of the ent ire
permit a nd upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self-certification and f inal authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado A ir Quality
Control Act and regulat ions of the Ai r Quality Control Commiss ion (AQCC), including
failure to meet any express term or condition of t he permit. If the Division denies a
permit, conditions im posed upon a permit are contested by the applicant, or t he Division
revokes a permit, t he applicant or owner or oper ator of a source may request a hearing
before the AQCC for review of the D ivision 's action .
20 . Section 25-7-114.7(2)(a), C.R.S . requires that all sources required to file an A ir 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 not ificat ion, annual fee
billing will terminat e.
21. 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 crimin al enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties ), -122.1 (criminal penalties), C.R.S .
22. This permit replaces the following permit, wh ich is can celed upon issuance of this
permit:
AIRS ID: 045/1046/008 Page 9 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Permit No. AIRSID 1 Notes
03P00738 777121921001 I Engine-~M03 :. This equipment wi.ll now be covered
under th1s stat1onary source perm1t.
sy: , , .......... (n J:Y1 '·M
Carissa Money d
Permit Engineer
P "t H " t erm1 IS ory
Issuance Date Description
Issuance 1 This Issuance Canceled portable permit 03P00738 and issued
as new stationary permit
lA Modification November 28, Permit modified due to engine replacement with
No. 1 for 2007 higher HP. O&M plan included due to control
03P00738 device and ability to locate at Syn . Minor sources .
Final Approval November 15, Issued to EnCana Oil & Gas
for 03P00738 2005
Initial Approval October 29, Issued to EnCana Oil & Gas
for 03P00738 2003.
AIRS ID: 045/1046/008 Page 10 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1194
Issuance 1
Notes to Perm it Holder:
Colorado Department of P ublic Health and E nvironment
Air Pollution Cont rol D ivision
1) 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 permittee 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
application form must be submitted with a request for a permit rev ision .
2 ) This source is subject to the Common Provisions Regulation Part II , Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee 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 Provis ions Regulation .
See : http://www. cdphe. state . co. us/regulations/airregs/1 001 02aqcccommon provisionsreg . pdf.
3) The following emissions of non-criteria reportable air po llutants are estimated based upon the
process lim its as indicated in this perm it 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 .
Unco ntrolled
Emission Are the Contr olled
AIRS Rate emissi ons Emission
Point Pollutant CAS# B IN (lb/yr) reportable? Rate (lb/yr)
Formaldehy de 5000 A 5599 Yes 2800
A c etaldehyde 75070 A 760 Yes 380
A c rolein 107028 A 467 Yes 234
008 Methanol 67561 c 227 No 114
n-Hexane 110543 c 101 No 50
Benzene 71432 A 40 No 20
Toluene 108883 c 37 No 19
4 ) The emission levels contained in this permit are based on the following emission factors:
Point 008 :
Emissio n Factors -Uncontrolled Emission Factors -Controlled
CAS Pollutant lb/MMBtu g /bhp-hr Source l b/MMBtu g /bhp-hr Source
NOx 0.3850 1.5000 Mfg 0.3850 1.5000 Mfg
co 0.5673 2.2100 Mfg 0.0397 0 .1547 Mfg
voc 0 .1258 0.4900 Mfg 0.0629 0.2450 Mfg
5000 Formaldehyde 0 .0616 0.2400 Mfg 0.0308 0.1200 Mfg
AP-42; Table
75070 Acetaldehyde 0 .0084 0 .0326 3.2-2 (7/2000); 0.0042 0.0163 Mfg
Natural Gas
AP-42 ; Table
107028 Acrolein 0.0051 0 .0200 3.2-2 (7 /2000); 0.0026 0 .0100 Mfg
Natural Gas
67561 Methanol 0.0025 0.0097 AP-42 ; Table 0.0013 0.0049 Mfg 3.2-2 (7/2000);
AIRS 10: 045/1046/008 Page 11 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1194
Issuance 1
Colo r ado Department of Public Health and Environment
Air Pollution Control Division
Emission Factors -Uncontrolled Emissi on Factors-Controlled
CAS Pollutant lb/MMBtu g/bhp-hr Source lb/MMBtu g/bhp-hr
Natural Gas
AP-42 ; Table
110543 n-Hexane 0 .0011 0.0043 3.2-2 (7/2000); 0 .0006 0 .0022
Natural Gas
AP-42 ; T able
71432 Benzene 0 .0004 0.0017 3.2-2 (7/2000); 0 .0002 0 .0009
Natural Gas
AP-42 ; T able
108883 Toluene 0 .0004 0 .0016 3.2-2 (7/2000); 0 .0002 0.0008
Natu ral Gas
Emission factors are based on a Brake-Spec ific Fuel Consumption Factor of 8,589 Btu/hp-hr, a
site-rated horsepower value of 1,208, and a fuel heat value of 1,000 Btu /scf.
5) In accordance with C.R.S . 25-7-11 4.1 , the Air Po llutant Emission Notice (APEN ) associated w ith this
permit is valid for a term of five years. The five-year term for this APEN expires on November 9, 20 13.
A revised A PEN shall be subm itted no later tha n 30 days before th e fi ve-ye ar term expires.
6 ) This facility is classified as follows:
Applicable Status Requirement
Operating Perm it Major Source: NOx, HAPs
Synthetic Minor Source: CO, VOC
PSD Synthetic Minor Source: VOC
MACT HH Synthetic Minor Source: Toluene , Tota l HAP
MACT ZZZZ Major So urce
7) Full text of the T itle 40 , Protection of Enviro nment 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-Su bpart KKKK
NSPS Part 60, A ppend ixes Appendix A-A ppendix I
Part 63 : National Emi ssion Standards for Hazardous Air Pollutants for Source Categories
MACT 63.1-03.599 Subpart A-Subpart Z
MACT 63.600-63.1199 Subpart AA -Subpart DOD
MACT 63.1200-03.1439 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 NNNN N-Subpart XXXXXX
A I RS ID: 045/1046/008 Page 12 of 17
Source
Mfg
Mfg
Mfg
EnCana Oil & G as (USA) Inc.
Perm it No . 08GA 1194
Issuance 1
Colorado Department o f P ubli c Health and Environment
Air Pollut io n Control Division
A TTACHMENT A :
ALTERNATIVE OPERATING SCENARIOS
RECIPROCAT ING INTERNAL COMBUSTION E NG INES
December 10, 2008
The fo llowing A lternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion eng ines h as been reviewed in accordance w ith the
requirements of Regulation No.3 ., Part A , Section IV.A , Operational Flexibility-Alternative Operating
Scenarios, Regulation No . 3, Part B, Construction Permits , and Regu lation No. 3, Part D, Major Stationary
Source New Sou rce Review and Prevention of Significant Deterio ration , and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporat es and shall be considered a
Constr uction Permit for any engine replacement performed in accordance with this AOS, and the
perm ittee shall be allowed to perform such engine replacement w ithout applying for a revision to this
perm it or obtain ing a new Constructi on Perm it.
A.1 Engine Replacement
The following AOS i s incorporated into this perm it in order to dea l with a compressor engi ne breakdown
or periodic routine ma intenance and repa ir of an existing onsite engine th at requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period . "Permanent" is defined as in the same service for more
t han 90 operati ng days in any 12 month period . The 90 days is the total number of days that t he engine
is in operation . If the engine operates only part of a day, that day shall count as a single day towards the
90-day total. The compliance demonstrations and any periodic monitoring required by th is AOS are in
addition to any compli ance demonstrations or periodic monitoring required by this permit.
A ll rep lacement engines are subject to all federally applicabl e and state-on ly requirements set forth in this
perm it (including monitoring and record keeping).
The results of all tests and the associated ca lculations required by this AOS shall be submitted to the
Division within 30 calenda r days of the test or within 60 days o f the test if such testing is required to
demonstrate compliance with NSPS or MACT req ui rements. Results of all te sts shall be k ept on site for
five (5) years and made available to the Divi sion upon request.
The permittee shall maintain a log on-site and contemporaneously record th e start and stop date of any
e ngine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial
number of the engine(s) that are replaced during the ter m of this permit , and the manufacturer, model
nu mber, horsepower, and serial number of the rep lacement engine. In addition to the log, the permittee
shall maintain a copy o f all Applicability Reports required under section A.1 .2 and make them available to
t he D iv ision upon request
A.1.1 T he permittee may t emporarily replace an existing compressor engine that i s subject to the
emission limits set forth in this permit w ith an engine that is of the same manufacturer, model, and
horsepower or a different manu facturer, model , or horsepower as the existing engine without modifying
this permit, so long as the em issions from the temporary replacement engine comply with the emission
limitations for the existing permitted eng ine as determined in section A.2. Measurement of emissions
from the temporary replacement engine shall be made as set forth in section A.2 .
A.1.2 The permittee may permanently replace the existing compressor engine with an engine that is of
the same manufacturer, model and horsepower w ithout modifying thi s permit so long as the emissions
from the permanent replacement engine comply w ith 1) the permitted annual emission limitations for the
AIRS ID: 0 4 5/1046/008 P age 13 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
existing eng ine, 2) any permi tted short-term emission limitations for the existing perm itted engine, and 3)
the app li cable emission lim itations as set forth in the Applicability Report submitted to the Divisi on w ith
the Air Pollutant Emissios Notice (APEN ) for the replacement engine (see
http://www cd phe state .co.us/ap/o ilgasperm itting .html for example applicability report formats).
Measurement of emissions from the permanent replacement engine an d compliance with the applicable
emission limitations sha ll be made as set forth in section 2 .2.
An Air Pollutant Emissions Notice (APEN ) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the rep lacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee , a cover letter explaining
that the permittee is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a c opy of the relevant Applicability Reports for the rep lacement e ngine.
Example Applicability Reports can be found in at http://www.cd ph e .s tate .co .us/ap/oilgaspermitting .html.
This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of
the source indicating that "based on the information and belief formed after reasonable inquiry, the
statements and information included in the submittal are true , accurate and c omplete".
This AOS cannot be used for permanent engine replacement of a g randfathered or permit exempt engine
or an engine that is not subject to emission limits.
The permittee shall agree to pa y fees based on the normal permit processing rate for review of
information submitted to the Divis ion in regard to any permanent engine replacement.
A.2 Portable Analy zer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requ irements . In those instances, please contact the Division F ield Services Unit to discuss
streamlin ing the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements
specified by the permit for the relevant time period (i.e . if the permit requires quarterly portable analyzer
testing , this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition , if approved in advance by t he Division .
The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust
from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
A ll portable ana lyzer testing required by th is permit shall be conducted using the Division's Portable
Analyzer Monitonng Protocol (ver March 2006 or newer) as found on the D ivision's website at:
http://www.cdphe.state .co.us/ap/down/portanalyzeproto.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of th is unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit , the results of the
tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test resu lts w ill be multipl ied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 045/1046/008 Page 14 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% 02) that the existing unit is currently subject to or the replacement
engine will be subject to, the results of the test shall be converted to the appropriate units as described in
the above-mentioned Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the
absence of credible evidence to the contrary , the source may certify that the engine is in compliance with
both the NOX and CO emission limitations for the relevant time period.
Subject to the provisions of C .R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if
the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission
limitations, the engine will be considered to be out of compliance from the date of the portable analyzer
test until a portable analyzer test indicates compliance with both the NOX and CO emission lim itations or
until the engine is taken offline.
A.3 Applicable Regulations for Permanent Engine Replacements
A.3.1 Reasonably Availab le Control Technology (RACT): Reg 3 , Part B § 11.0 .2
All permanent replacement engines that are located in an area that is classified as
attainmenUmaintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainmenUmaintenance or nonattainment. Note that both VOC
and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for
which the area is in attainmenUmaintenance or nonattainment, except as follows:
In the Denver Metropolitan PM 10 attainmenUmaintenance area, RACT applies to PM10 at any level of
emissions and to NOX and S02, as precursors to PM10, if the potential to emit of NOX or S02 exceeds
40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating
internal combustion engines:
VOC:
CO:
NOX:
S02:
PM10:
The emission limitations in NSPS JJJJ
The emission limitations in NSPS JJJJ
The emission limitations in NSPS JJJJ
Use of natural gas as fuel
Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
A.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E
(State-Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is
subject to the applicable control requirements specified in Regulation No. 7, section XVI , as specified
below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-
selective catalyst and air fuel controller to reduce emission .
AIRS ID: 045/1046/008 Page 15 of 17
E nCana Oil & Gas (USA) Inc.
Permit No. 08GA 1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emission s.
The above emission control equipment s hall be appropriately sized for the engine and shall be operated
and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2 .
Fmis sion Standards · Sectio n XVII E-State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state ,
after t he date listed in the table below shall operate and maintain each engine according to the
manufacturer's written instructions or procedures to the extent practicable and consistent w ith
technological limitations and good engineering and maintenance practices over the entire life of the
engine so that it achieves the emission standards required in the table below:
Max Engine C onstruction or Emission Standards in G/hp-hr HP Relocation Date
NOx co voc
100<Hp<500 January 1, 2008 2.0 4.0 1.0
January 1, 2011 1.0 2.0 0.7
500~Hp July 1, 2007 2.0 4.0 1.0
July 1, 2010 1.0 2.0 0.7
T he source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2
A.3.3 NSPS for spark ign1tion internal combustion engines: 40 C FR 60, Subpart J J JJ
A permanent replacement engine that is manufact ured on or after 7/1/09 for emergency engine s greater
than 25 hp, 7/1/2008 for engines less th a n 500 hp, 7/1/2007 for engines g reater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 h p an d less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 h p and less than 1,350 hp are subject 40 CFR 60, Subpart
JJJJ. An a na lysis of applicable monitoring, record keep ing , and reporting requirements for the permanent
engine repla cement shall be included in the A pplicability Reports req uired under Condition A.1.2. Any
testing required by the NSPS is in addition to that required by this AOS. Note that the Initial test required
by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition A.2, if approved in
advance by the Division , provided that such test is conducted within the time frame specified in Condition
A.2.
Note that under the provisions of Regulation No. 6 . Part B, section I. B. that Relocation of a source from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes
equivalent t o t he manufac ture date for purposes of determining the applica bility of NSPS J J J J
requirements).
However, as of November 1, 2008 the Division has not yet adopted NSPS JJJJ. Until such time as it
does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts
NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the
provisions of Regulation No. 6, Part 8 , § 1.8 (which is referenced in Part A), any engine relocated from
outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to
the requirements of NSPS JJJJ.
A IRS ID: 04 5/104 6/008 Page 16 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1194
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
A.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart Zll.Z.
A.3.4.1 Area Source for HAPs
A permanent replacement eng ine located at an area source that commenced construction or
reconstruction after June 12, 2006 as defined in § 63.2, will meet the requ irements of 40 CFR Part 63,
Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the
applicable mon itoring , recordkeeping, and reporting requirements for the permanent engine replacement
shall be included in the Applicability Reports requ ired under Condition A.1 .2 . Any testing requ ired by the
MACT is in addit ion to that required by this AOS. Note that the initial test required by the MACT can
serve as the testing required by this AOS under Condition A.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition A .2 .
A.4.3.2 Major source for HAPs
A permanent replacement engine that is located at major source is subject to the requirements in 40 CFR
Part 63 Subpart Zll.Z. as follows:
Existing , new or reconstructed spark ignition 4 stroke rich burn engines with a site rating of more
than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart Zll.Z..
New or reconstructed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4
stroke lean burn engines w i th a site rating of more than 500 hp are subject to the requirements in
40 CFR Part 63 Subpart ZZZZ .
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and
were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart
ZZZZ.
New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean
burn or 4 stroke rich burn engines with a s ite rating of 500 hp or less will meet the requirements of
40 CFR 63, Subpart ZZZZ by meeting the requ irements of 40 CFR 60, Subpart JJJJ .
New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean
burn engines with a site rating of less than 250 hp will meet the requirements of 40 CFR 63,
Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ .
An analysis of the applicable monitoring , recordkeeping , and reporting requirements for the
permanent engine replacement shall be included in the Applicab ility Reports required under
Condition A .1 .2. Any testing required by the MACT is in addition to that required by this AOS.
Note that the initial test required by the MACT can serve as the testing required by th is AOS
under Condit ion A2, if approved in advance by the Division , provided that such test is conducted
within the time frame specified in Condition A2.
A.3.5 Additional Sources
The replacement of an existing engine w ith a new eng ine is viewed by the Division as the installation of a
new emissions unit, not "routine replacemenf' of an existing unit. The AOS is therefore essentially an
advanced constructi on permit review. The AOS cannot be used for additional new emission points for
any site; an eng ine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
AIRS 10 : 045/1046/008 Page 17 of 17
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHON E: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
08GA1196
lJU L 3 1 2009
EnCana Oil & Gas (USA) Inc.
Issuance 1
THE SOURCE TO W HICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Natural gas compression faci lity, known as the H igh Mesa Compressor Station, located
in S ENW Section 36, T ownship 7S, Range 96W, in Garfield County, Colorado.
THE S PECIFIC EQU IPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES T HE FOLL OWING:
Facility AIRS Equipment Point Description
ID
One (1 ) Caterpillar, Model G3516LE, Serial Number4E K05031 ,
natural gas-fired, turbo-charged , 4SLB reciprocating i nternal
HM04 0 10 combustion engine , si te rated at 1,208 horsepower at 1 ,400 RPM .
This engine sh all be equipped with an oxidation catalyst and air-
fuel ratio cont ro l. T his emission unit is used for natural gas
compression.
T his engine may be replaced w ith another engine in accordance with the temporary
eng ine replacement provision or with another Caterpillar G35 16LE eng ine in accordance
w ith the permanent replacement provision of the Alternate Operating Scenario (AOS),
included in this perm it as Attachment A.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE C OLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et s e q ), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOL LOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate t his
emissions source (Regulation 3 , Part B , Section II I.G.5).
A IRS 10: 045/1046/010 Page 1 of 17
NGEngine Versi on 2008-1
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference : Regulation No. 3, Part 8 , Section II.A.4)
M o n t h ly Limits:
Faci l ity I AIRS Pounds per Mont h
Equipment ID Po i nt NOx voc co Emission Type
HM04 010 2972 486 306 Point
Monthly limits are based on a 31-day month.
A n nual Lim its:
Faci l ity AIRS Tons per Year
Equipme nt ID Point NOx voc T co Emission Type
HM04 010 17.5 2 .9 I 1.8 Point
See "Notes to Perm1t Holder #4 for mformat10n on emiSSion factors and methods used to
calculate limits.
During the first twelve (12) months of operation, compliance with both the monthly and
yearly emission limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required.
Compliance with the synthetic minor status of this facility shall be determined by
recording the facility's annual criteria pollutant emissions , from each emission unit, on a
rolling (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
monthly emissions 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
emission units, requiring an APEN , at this facility.
3. This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. The
selective oxidation cata lyst shall be capable of reducing uncontrolled emissions of VOC
and CO from the unit to the emission levels listed in Condition 2 , above. Operating
parameters of the control equipment are identified in the operation and maintenance
plan. (Reference: Regulation No.3, Part 8 , Section III.E.)
PROCESS LIMITATIONS AND RECORDS
4 . This source shall be limited to the following maximum consumption. processing and/or
operational rates as listed below. Monthly records of the actual consumption rate shall
be maintained by the applicant and made available to the Division for inspection upon
request. (Reference : Regulation 3, Part 8 , II.A.4)
p c rocess/ ons u m ption Limits
Fac ility I A I RS I A nnu al M o nthly
Eq uipment p . t Process Parame ter Limit Limit (31
ID 01n davs)
HM04 010 Consumption of natural gas as a 90.9 7.72
fuel MMscf/vr MMscf/month
AIRS ID: 045/1046/010 Page 2 of 17
I
I
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
During the first twelve (12) months of operation, compliance with both the monthly and
yearly consumption limitations shall be required. After the first twelve (12) months of
operation, compliance with only the yearly limitation shall be required .
Compliance with the yearly consumption limits shall be determined on a rolling twelve
( 12) month total. By the end of each month a new twelve-month total is calcu lated
based on the previous twelve months' data. T he permit holder shall calculat e monthly
consumpt ion of natural gas and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
5. Visible emissions shall n ot 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. (Reference: Regulation No. 1 , Section II.A.1. & 4 .)
6. T his sour ce is subject to the odor requirements of Regulation No . 2. (State only
enforceable)
7. T he permit number and AIRS ID number shall be marked on the subject equipment f or
ease of identification. (Reference: Regu lation Number 3 , Part 8 , Ill. E .) (State only
enforceable)
8 . T his sou rce is subject to the requirement s of:
• Regulation No. 8, Part E , Subpart Ill. FFFF: National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion
Engines (RICE) of 40 C. F.R. Part 63, Subpart ZZZZ, and
• Regulation No. 8, Part E, Subpart /.A , National Emission Standards for
Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR
Part 63
including, but not limited to, the following:
• Emission a n d Operati ng Limitations
o 63.6600(b) -If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more t han 500 brake H P located at major source of
HAP emissions you must comply with the following emission limitations
(Table 2a, Subpart ZZZZ to Part 63):
• reduce CO emissions by 93 percent or more; or
• limit concentration of formaldehyde in the stationary RICE exhaust to
14 ppmvd or less at 15 percent 02.
AIRS ID : 045/1046/010 Page 3 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o 63.6600(b)-If you own or operate a new or reconstructed 4SLB stationary
RICE with a site rating of more than 500 brake HP located at major source of
HAP emissions you must comply with the following operating limitations
(Table 2b, Subpart ZZZZ to Part 63):
• maintain your catalyst so that the pressure drop across the catalyst
does not change by more than 2 inches of water at 1 00 percent load
plus or minus 10 percent from the pressure drop across the catalyst
that was measured during the initial performance test; and
• maintain the temperature of your stationary RICE exhaust so that the
catalyst inlet temperature is greater than or equal to 450 oF and less
than or equal to 1350 °F.
• General Compl iance Requ irements
o §63 .6605(a)-You must be in compliance with the emission limitations and
operating limitations in this subpart that apply to you at all times, except
during periods of startup, shutdown, and malfunction.
o §63 .6605(b) -If you must comply with emission limitations and operating
limitations, you must operate and maintain your stationary RICE, including air
pollution control and monitoring equipment, in a manner consistent with good
air pollution control practices for minimizing emissions at all times, including
during startup, shutdown, and malf unction.
• Testi ng and Initial Compliance Requirements
o §63 .6610(a)-You must conduct the initial performance test or other initial
compliance demonstrations in T able 4 to Subpart ZZZZ o f Part 63 that apply
to you within 180 days after the compliance date that is specified for your
stationary R ICE in §63.6595 and according to the provisions in §63.7(a)(2).
o §63 .6615 -If you must comply with the emission limitations and operating
limitations, you must conduct subsequent performance tests semiannually (as
per Table 3 of Subpart ZZZZ to Part 63). After you have demonstrated
compliance for two consecutive tests, you may reduce the frequency of
subsequent performance tests to annually. If the results of any subsequent
annual performance test indicate the stationary RICE is not in compliance
with the CO or formaldehyde emission limitation, or you deviate from any of
your operating limitations, you must resume semiannual performance tests.
o §63.6620 -You must conduct performance test and other procedures in
§63.6620 and in Tables 3 and 4 to Subpart ZZZZ of Part 63 that apply to you .
o §6 3.6625(b) -If you are required to install a continuous parameter monitoring
system (CPMS) as specified in Table 5 of this subpart, you must install,
operate, and maintain each CPMS according to the requirements in §63.8.
AIRS ID: 045/1046/010 Page 4 of 17
EnCana Oil & Gas (USA) In c.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Cont rol Division
o §63.6630(a)-You must demonstrate initial compliance w ith each emission
and operating lim itation that applies to you according to Table 5 of Subpart
ZZZZ to Part 63.
o §63 .6630(b) -During the initial performance test, you must establish each
operating limitation in Tables 1 b and 2b of Subpart ZZZZ to Part 63 that
applies to you.
o §63.6630(c)-You must submit the Notification of Compliance Status
containing the results of the i nitial compliance demonstration according to the
r equirements in §63.6645.
• Continuous Compliance Requirements
o §63.6635(b)-Except for monitor malfunctions, associated repairs, and
required quality assurance or control activities (including , as applicable,
calibration checks and required zero and span adjustments), you must
monitor continuously at all times that the stationary RICE is operating.
o §63.6635(c)-You may not use data recorded during monitoring
malfunctions, associated repairs , and required quality assurance or control
activities in data a v erages and calculations used to report emission or
operating lev els. You must, however, use all the valid data collected during all
other periods.
o §63.6640(a)-You must demonstrate continuous complianc e with each
emission limitation and operating limitation in Tables 1 a and 1 band Tables
2a and 2b of subpart ZZZZ of Part 63 that apply to you according to methods
specified in Table 6 of Subpart ZZZZ of Part 63.
o §63.6640(b)-You must report each instance in which you did not meet each
emission limitation or operating li mitation in Tables 1 a and 1 b and Tables 2a
and 2b of Subpart ZZZZ of Part 63 that apply to you. These instances are
deviations from the emission and operating limitations i n this subpart. These
deviations must be reported according to the requirements in §63.6650. If you
change your catalyst, you must reestablish the values of the operating
parameters measured during the initial performance test. When you
reestablish the values of your operating parameters, you must also conduct a
performance test to demonstrate that you are meeting the required emission
limitation applicable to your stationary RICE.
o §63.6640(d)-Consistent w ith §§63.6(e) and 63.7 (e)(1), deviations from the
emission or operating limitations that occur during a period of startup,
shutdown, or malfunction are not violations if you demonstrate to the
Administrator's satisfaction that you were operating in accordance with
§63.6(e)(1). For new, reconstructed, and rebuilt stationary RICE , deviations
from the emission or operating limitations that occur during the first 200 hours
of operation from engine startup (engine burn-in period) are not violations.
AIRS ID: 045/1046/010 Page 5 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6640(e)-You must also report each instance in which you did not meet
the requirements in Table 8 of Subpart Zll.Z to Part 63 that apply to you.
• Not ifications, Reports a nd Records
o §63.6645(a) -If you own or operate a stationary R IC E with a site rating of
more than 500 brake HP located at a major source of HAP emissions you
must subm it all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and
(f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates
specified .
o §6 3.6645(c)-If you start up your new or reconstructed stationary R ICE with a
site rating of more than 500 brake HP located at a major source of HAP
emissions on or after August 16, 2004, you must submit an Initial Notification
not later than 120 days after you become subject to this subpart.
o §63 .6645(g ) -If you are required to conduct a performance test, you must
submit a Notification of Intent to conduct a performance test at least 60 days
before the performance test is scheduled to begin as required in §63.7(b)(1 ).
o §63.6645(h) -If you are required to conduct a performance test or other initial
compliance demonstration as specified in Tables 4 and 5 of Subpart Zll.Z to
Part 63, you must submit a Notification of Compliance Status according to
§63. 9(h)(2)(ii).
• §63 .6645(h)(2)-For each initial compliance demonstration required in
T able 5 of Subpart Zll.Z to Part 63 that includes a performance test
conducted according to the requirements in Table 3 to this subpart,
you must submit the Notification of Compliance Status, including the
performance test results , before the close of business on the 60th day
following the completion of the performance test according to
§63.1 O(d)(2).
o §63.6650(a)-You must submit each report in Table 7 of Subpart ZZZZ to
Part 63 that applies to you .
o §63.6650(b)-You must submit each report by the date in Table 7 of Subpart
ZZZZ to Part 63 and according to the requi rements in paragraphs (b)( 1)
through (5) of §63.6650.
o §63 .6650(c)-The Compliance report must contain the information in
paragraphs (c)(1) through (6) of §63.6650.
o §63 .6650(e) -For each deviation from an emission or operating limitation
occurring for a stationary RI CE wh ere you are using a CMS to comply with
the emission and operating limitations in Subpart ZZZZ to Part 63, you must
include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of
§63.6650.
AIRS ID: 045/1046/010 Page 6 of 17
EnCana Oil & Gas (USA) Inc.
Permit No . 08GA1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
o §63.6655(a )-If you must comply with the emission and operating limitations,
you must keep the records described in §63.6655(a)(1) through (a)(3),
§63.6655 (b)(1) through (b)(3) and §63.6655 (c).
o §63 .6655(d)-You must keep the records required in T able 6 of Subpart
ZZZZ of Part 63 to show continuous compliance with each emission or
operating limitation that applies to you .
o §63.6660(a)-Your records must be in a form suitable and readily available
for expeditious review according to §63.10(b)(1 ).
o §63.6660{b)-As specified in §63.1 O(b)(1 ), you must keep each record for 5
years following the date of each occurrence, measurement , maintenance,
corrective action, report, or record .
o §63.6660(c)-You must keep each record readily accessible in hard copy or
electronic form on-site for at least 2 years after the date of each occu rrence ,
measurement, mai ntenance , corrective action , report, or record , according to
§63.10(b)(1). You can keep the records off-site for the remaining 3 years.
• Other Requirements and Information
o §63.6665 -T able 8 to this subpart shows which parts of t he General
Provisions in §§63.1 through 63.15 apply to you.
OPERATING & MAINTENANCE REQUIREMENTS
9. Upon startup of this point, the applicant shall follow the operating and maintenance
(O&M) plan and record keeping format approved by the Division , in order to demonstrate
compliance on an ongoi ng basis with the req uirements of this permit. Revisions to your
O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part 8 , Section III.G .7.)
COMPLIANCE TESTING AND SAMPLING
Periodic Testi ng Requirements
10. This eng ine is subject to the periodic testing requirements of 40 C .F.R Part 63, S ubpart
zzzz .
11 . This engine is subject to the periodic testing requ irements as specif ied in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approval. Replacements of this unit completed as Alt ernative
Operati ng Scenarios may be subject to additional testing requirements as specif ied in
Attachment A.
AIRS ID: 045/1046/010 Page 7 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
ADDITIONAL REQUIREMENTS
12. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3 , Part A , II.C)
a . Annually 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 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 t ype of control equipment; or
d . Whenever a permit limitation must be modified; or
e . No later than 30 days before the existing APEN expires.
f . Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the permittee is
exercising an alternative-operating scenario and is installing a permanent
replacement engine.
13. This source is subject to the provisions of Regulation Number 3 , Part C , Operating
Permits (Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this
construction permit must be incorporated into the operating permit. The application for
the modification to the Operating Permit is due within one year of commencement of
operation of the equipment or modification covered by this permit.
14. Prevention of Significant Deterioration (PSD) requirements 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
PSD threshold will require a full PSD review of the source as though construction had
not yet commenced on the source. The source shall not exceed the PSD threshold until
a PSD permit is granted. (Regulation No. 3 Part D, VI.B.4)
GENERAL TERMS AND CONDITIONS:
15. 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
AIRS ID: 045/1046/010 Page 8 of 17
EnCana O il & G as (USA) Inc.
Permit No . 08GA 1196
Issuance 1
Colorado Department of Public Health a nd Environment
Air Pollution Control Division
AQCC Regulation No. 3 , Part 8 , Section 11 .8 upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
16. Issuance of a construct ion permit does not provide ''final" authority f or this activity or
operation of this source. F inal author ization of the permit must be secured from the
APCD in writi ng in accordance with the provision s of 25-7-114.5(12)(a) C .R.S. a nd
AQCC Regulation No.3 , Part 8 , Section Ill. G. Final author ization cannot be granted
u ntil 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
point s has been reviewed and approved by the Division, it w ill p r ovide written
documentation of such final authorization . Details for obtai ning final authorization to
operate are lo c ated in the Requirements to Self-Certify for Final Authorization
section of this permit.
17. T his permit is issued in reliance upon the accuracy and completeness of information
supplied by the applica nt and is cond itione d upon conduct of the activity, or const ruction,
installation and operation of the source, in accor dance with this informat ion and with
represent at io ns made by the applic a nt or app licant's agents. It is v a lid only f or t h e
equipment and ope rations or activity specifically identified on the perm it.
18. Unless s pecif ically stated otherwise, t he genera l and specific condit ion s cont a ined i n this
permit have been deter mined by the APCD to be necessary to a ssure compliance with
the provisions of Section 25-7-1 14.5(7)(a), C .R.S.
19. E ach and every condition of this permit is a m aterial part hereof and is not severable.
Any challenge to or appeal of a condition here of shall constitute a rejection of the ent ire
permit and upon such occurrence, this permit shall be deemed denied ab initio. T his
permit may be revoked at any time prior to self-certification and final authorization by the
Air Pollution Control D ivision (APCD) on grounds set f orth in the Colorado Air Quality
Cont rol Act and regulations of the Air Quality Control Commission (AQCC), includi ng
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are conteste d by the applicant, or the Division
revokes a per mit, the applicant or owner o r operator of a source may request a hearing
before the AQCC f or review of the Division's action.
20. Section 25-7-114.7(2 )(a), C .R.S. requires t h at all sources required to file an Air Pollution
Emission Notice (A P EN ) 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 notificat ion, annual fee
billing wi ll terminate.
21 . Violation of the terms of a permit or of the provisions of the Colorado Air P ollution
Prevention and Control Act or the regulat ion s of the AQCC may result in administrative,
civil or crim i nal enfor cement actions und er Sections 25-7-1 15 (enforcement), -121
(inj unctions), -122 (civil penalties), -122.1 (criminal penalties), C .R.S.
22 . T h is permit replaces the following permit, which is canceled upon issuance of this
permit:
AIRS ID: 045/1046/010 Page 9 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
Permit No. AIRS ID
04P00443 777/2273/001
By:
Carissa Money
Permit Engineer
(f
P ·t H. t ermt IS Ory
Issuance Date
Issuance 1 This Issuance
Initial Approval August 11 ,
for 04P00443 2004
AIRS ID: 045/1046/010
Notes
Engine-HM04: This equipment will now be covered
under this stationary source permit.
Description
Canceled portable perm it 04P00443 and issued
as new stationary permit
Issued to EnCana Oil & Gas
Page 10 of 17
EnCana Oil & Gas (USA) Inc.
Permit No . 08GA 1196
Issua nce 1
Notes to Permit Holder:
Colorad o Department of P ublic Health a nd Environmen t
A ir P o ll ution Control Divis ion
1) 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 . T hese limits may be revised
upon request of the permittee providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard . A rev ise d air pollution emission notice (APEN) and
application form must be submitted with a request for a permit revision .
2) This source is subject to the Common Provisions Regulation Part II , Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The permittee 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 .cdphe . state . co. us/reg u la tions/airregs/1 001 02aqcccommonprovisionsreg . pdf.
3) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this perm it. 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
Em issi o n Are the Cont ro lled
AIRS Rate emissions Em iss ion
Po i n t Polluta nt CAS# BIN (lb/yr) reporta ble ? Rat e (lb/yr )
Fo rmaldehyd e 5000 A 5599 Yes 2800
A cetaldeh y d e 75070 A 760 Yes 380
A c r o l ein 107028 A 467 Yes 234
010 Methanol 67561 c 227 No 114
n-Hexane 110543 c 101 No 50
Benzene 71432 A 40 No 20
Toluene 108883 c 37 No 19
4 ) The emi ssion levels contained in this permit are based on the following emission factors :
Po int 0 10 :
Emission Factors -Uncon t ro lled Emi ssion Factor s -Contr o lled
CA S Po llutant lb/MMBtu g/b hp-hr Source l b/MMBtu g /bhp-hr Sourc e
NOx 0 .3850 1.5000 Mfg 0.3850 1.5000 Mfg
co 0 .5673 2 .2100 Mfg 0.0397 0.1547 Mfg
voc 0.1258 0.4900 Mfg 0.0629 0.2450 Mfg
5000 Formaldehyde 0 .0616 0.2400 Mfg 0 .0308 0 .1200 Mfg
AP-42; Table
75070 Acetaldehyde 0 .0084 0 .0326 3.2-2 (7 /2000); 0 .00 42 0 .0163 Mfg
Natura l Gas
A P-42 ; Table
107028 Acrole in 0.0051 0 .0200 3.2-2 (7/2000); 0.0026 0.0100 Mfg
Natural Gas
67561 M ethanol 0.0025 0.0097 AP-42; T able 0.0013 0.0049 Mfg 3.2-2 (7/20001;
AI RS ID: 04 5/1046/010 P age 11 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and E nvironment
Air Pollution Control Division
Emission Factors -Uncontrolled Emission Factors -Contr olled
CAS Pollutant lb/MMBtu g /bhp-hr Source lb/MMBtu g /bhp-hr
Natural Gas
AP-42 ; T able
110543 n-Hexane 0 .0011 0 .0043 3.2-2 (7/2000); 0 .0006 0 .0022
Natural Gas
AP-42 ; Table
71432 Benzene 0.0004 0.00 17 3.2-2 (7/2000); 0.0002 0 .0009
Natural Gas
AP-42 ; Table
108883 Toluene 0 .0004 0.0016 3.2-2 (7/2000); 0 .0002 0.0008
Natural Gas
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8,589 Btu/hp-hr, a
site-rated horsepower value of 1,208 , and a fuel heat value of 1,000 Btu/scf.
5) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notice (APEN ) associated with this
permit is valid for a term of fi ve years. The fi ve-year term for this APEN expires on No,·e mber 9, 2013 .
A revised APEN shall be su bmitted no later t ha n 30 days before the fi v e-year term expires.
6) This facility is c lassified as follows:
Applicable Status Requirement
Operating Permit Major Sou rce: NOx, HAPs
Synthetic Minor Source : CO, VOC
PSD Synthetic Minor Source: VOC
MACT HH Synthetic Minor Source: Toluene, Total HAP
MACT ZZZZ Major Source
7) Full text of the T itle 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the websi te listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standar d s of Pe rformance for New Stationary Sources
NSPS 60 .1-End Subpart A-S ubpart KKKK
NSPS Part 60, Appendixes Appendix A-Appendix I
Part 63 : National Emission Standards for Hazardous Air Pollutants for Source Categor ies
MACT 63 .1-63.599 Subpart A-Subpart Z
MACT 63 .600-63.1199 Subpart AA-Subpart DOD
MACT 63.1200-63.1439 Subpart EE E -Subpart PPP
MACT 63 .1440-63.6175 Subpart QQQ -Subpart YYYY
MACT 63 .6580-63.8830 Subpart ZZZZ-Subpart MMMMM
MACT 63 .8980-End Subpart NNNNN-Subpart XXXXXX
A I RS 10: 045/1046/010 P age 12 of 17
Sour ce
Mfg
Mfg
Mfg
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA1196
Issuance 1
Colorado Department o f Public Health and Environment
Air Pollution Control Division
A TTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
December 10, 2008
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of
natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the
requirements of Regulation No.3., Part A, Section IV.A, Operational Flexibility-Alternative Operating
Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary
Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all
applicable substantive and procedural requirements. This permit incorporates and shall be considered a
Construction Permit for any engine replacement performed in accordance with this AOS, and the
permittee shall be allowed to perform such engine replacement without applying for a revision to this
permit or obtaining a new Construction Permit.
A.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90
operating days or less in any 12 month period. "Permanenr is defined as in the same service for more
than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine
is in operation . If the engine operates only part of a day, that day shall count as a single day towards the
90-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in
addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this
permit (including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the
Division within 30 calendar days of the test or within 60 days of the test if such testing is required to
demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for
five (5) years and made available to the Division upon request.
The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial
number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model
number, horsepower, and serial number of the replacement engine. In addition to the log, the permittee
shall maintain a copy of all Applicability Reports required under section A.1.2 and make them available to
the Division upon request.
A.1 .1 The permittee may temporarily replace an existing compressor engine that is subject to the
emission limits set forth in this permit with an engine that is of the same manufacturer, model, and
horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying
this permit, so long as the emissions from the temporary replacement engine comply with the emission
limitations for the existing permitted engine as determined in section A.2. Measurement of emissions
from the temporary replacement engine shall be made as set forth in section A.2.
A.1.2 T he permittee may permanently replace the existing compressor engine with an engine that is of
the same manufacturer, model and horsepower without modifying this permit so long as the emissions
from the permanent replacement engine comply with 1) the permitted annual emission limitations for the
AIRS ID: 045/1046/010 Page 13 of 17
EnCana Oil & Gas (USA) Inc.
Permit No. 08GA 1196
Issuance 1
Colorado Department of Public Health and Environment
Air Pollution Control Division
existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3)
the applicable emission limitations as set forth in the Applicability Report submitted to the Division with
the Air Pollutant Emissios Notice (APEN) for the replacement engine (see
http://www.cdphe.state.co.us/ap/oilgaspermitting .html for example applicability report formats).
Measurement of emissions from the permanent replacement engine and compliance with the applicable
emission limitations shall be made as set forth in section 2 .2 .
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial
number and horsepower of the permanent replacement engine shall be filed with the Division for the
permanent replacement engine within 14 calendar days of commencing operation of the replacement
engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining
that the permittee is exercising an alternative operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability Reports can be found in at http://www.cdphe.state co.us/ap/oilgaspermitting .html.
This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of
the source indicating that "based on the information and belief formed after reasonable inquiry, the
statements and information included in the submittal are true, accurate and complete"
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine
or an engine that is not subject to emission limits.
The permittee shall agree to pay fees based on the normal permit processing rate for review of
information submitted to the Division in regard to any permanent engine replacement.
A.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping
Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss
streamlining the testing requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testmg requirements
specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer
testing , this test conducted under the AOS will serve as the quarterly test and an additional portable
analyzer test is not required for another three months).
The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition , if approved in advance by the Division.
The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust
from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of
commencing operation of the replacement engine.
All portable analyzer testing required by th is permit shall be conducted using the Division 's Portable
Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at:
http://www.cdphe.state.co.us/ap/down/portanalyzeproto .pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term {lbs/unit of time) emission limit, the results of the
tests shall be converted to a lb/hr basi s and multiplied by the allowable operating hours in the month or
year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation
the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever
applies.
AIRS ID: 045/1046/010 Page 14 of 17