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HomeMy WebLinkAbout1.10B Air Quality PermitsEnCana Oil & Gas (U SA) Inc. Permit No. 08GA1196 Issuance 1 Colorado D epartment of P ublic H ealth and E nviron m e nt Air Poll ution Control Division For compari son 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 resu lts 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 i s in compliance with both the NOX and CO em ission 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 o r CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable an a lyzer test indicates compliance with both the NOX and CO emission limitations or until the engi ne is taken offline. A.3 Applicable Regulations 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 attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for wh ich the area i s 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 attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM1 0 attainment/maintenance area, RACT applies 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 internal combustion engines : VOC : CO: NOX: S02: PM10: The emission limitations in NSPS JJJJ The emission limitations in NSPS J J JJ The emission limitations in NSPS J J JJ 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 w ith in the boundaries of an ozone nonattainment area is subject to the applicable control requi rements 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 : 045/1046/010 Page 15 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1196 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 emissions. 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 copi es 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 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 Emission Standards in Glhp-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 SOO.::;Hp July 1, 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 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 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 10: 045/1046/010 Page 16 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1196 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division A.3.4 Reciproc ating internal combustion eng ine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A.3 .4 .1 Area Sou rce for HAPs A permanent replacement engine located at an area sou rce that commenced construction or reconstr uction after June 12 , 2006 as defined in§ 63.2, will meet the requi rements of 40 CFR Part 63, Subpart ZZZZ by meeting the requ irements o f 40 CFR Part 60, Subpart JJJJ. An analysis of the applicable monitoring , record keeping, and reporting require m ents for the permanent engine replacement shall be included in the Applicability Reports requ ired under Condition A.1 .2 . Any testing required by the MACT is in addit ion to that required by thi s AOS. Note that t h e initial test required by the MACT can serve as the testi ng requi red by th i s AOS under Condition A.2 , if approv ed in advance by the Division , provided that such test is conducted within the time frame specified in Condition A.2 . A.4.3.2 Maj or source for HAPs A permanent repl acement engine that is located at major source is subj ect to the requirements in 40 CFR Part 63 Subpart ZZZZ 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 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 t han 500 hp are subject to the requirements in 40 CFR Part 63 S ubpart ZZZZ. New or recon structed (construction or reconstruction commenced after 6 /12/06) 4 stroke lean burn engines with a s ite rating of greater than or equal to 250 but less or equal to 500 h p 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 o r 4 stroke rich bum engines w ith a site rating of 500 hp or less w ill meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requ irements of 40 CFR 60, Subpart JJJJ . New or reconstructed (const ruction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a site rating of less than 250 hp w i ll meet the requirement s 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 requ irements 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 addition to that required by th is 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 Divis ion , provided that such test i s conducted w ith in the time frame specified in Condition A.2 . A.3.5 Additional Sources The replacemen t of an exi sting engine w ith a new engine is viewed by the Division as the i nstallation 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: 045/1046/010 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: 08GA1197 JUL 3 ., 2009 EnCana Oil & Gas (USA) Inc. Issuance 1 THE SOURCE TO WHICH TH IS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the High Mesa Compressor Station , located in SENW Section 36 , T ownship 7S , Range 96W, in Garfield County, Colorado. THE SPECIFIC EQU IPMENT OR ACTIVITY SUBJECT TO THIS PERMIT IN CLUDES THE FOLLOWING: Facility A IRS Equipment Point Description 10 One (1 ) Caterpillar , Model G3516LE, Serial Number 4EK04910, natural gas-fired, turbo-charged, 4SLB reciprocating internal HMOS 0 11 combustion engine , site ra ted at 1 ,208 horsepower at 1 ,400 RPM . This engine shall be equipped with an oxidat ion catalyst and air- fuel ratio control. This 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 G35 16LE engine in accordance with the permanent replacement provision of the A lternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-10 1 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THI S DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS : REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority t o operate t his emissions source (Regulation 3, Part 8 , Section III.G .5). AIRS ID: 045/1046/011 Page 1 of 17 NGEngine Version 2008-1 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 o n IY 1m1 s: Facility AIRS Pounds per Mo nth I Equipment 10 Point NOx voc co Em ission Ty pe HMOS 011 2972 486 306 Point Monthly hm1ts are based on a 31-day month Annual Limits: Facility I A IRS Tons per Year Equipment 10 Point NOx voc co Em ission Type HMOS 011 17 5 2.9 1.8 Point See "Notes to Perm1t Holder #4 for mformat10n 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 t he yearly limitation shall be requ ired. 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 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 i n 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 applica nt and made available to the Division for inspection upon request. (Reference: Regulation 3 , Part B , II.A.4) P /C f L " "t rocess o n s u mp11on 1m1s I Fa cilit y I A IRS I Annu al Monthly Eq uipment I p . t Process Param ete r Limit Limit (31 10 o1 n days) HMOS I 011 I Consumption of natural gas as a 90.9 7 .72 fuel MMscf/yr MMscf/month AIRS ID: 045/1046/011 Page 2 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air P ollution 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 det ermined on a r olling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly consumption of n atural 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 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. (Reference: Regulation No . 1 , Section I I.A.1. & 4.) 6 . This source is subject to the odor requireme nts 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 Number 3 , P a rt B, Ill. E.) (State only enforceable) 8. T his source is subject to the req u irements 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 li mited to, the following: • Emission and Operating Limitations o 63.6600(b) -If you own or operate a new or reconst r u cted 4SL B stationary R ICE with a site rating of more than 500 brake H P locat ed at major source of HAP emissions you must comply with the f ollowing emission limitations (T able 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. A IRS ID: 045/1046/011 Page 3 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 Com pliance Req uirements 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 malfunct ion. 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. • Te sting and Initial Compliance Requiremen ts o §63.6610(a)-You must conduct the initial performance test or other initial compliance demonstrations in Table 4 to Subpart ZZZZ o f Part 63 that apply t o 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 §63.66 15 -If you must comply w ith the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually (as per Table 3 of Subpart llll 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 ZZZZ of Part 63 that apply to you . o §63.6625(b)-If you are required to install a continuous paramet er 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: 045/1046/011 Page 4 of 17 EnCana Oil & Gas (USA) Inc. Permit No . 08GA 1197 Issu ance 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 T able 5 of Subpart ZZZZ to Part 63. o §63.6630(b)-D uring the initial performance test, you must establish each operating limitation in Tables 1b and 2b of Subpart ZZZZ to Part 63 that applies to you . o §63.6630(c)-You must submit the No tification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Requi rements 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 adjustm e nts), you must mon itor continuously at all times that the stationary RICE is operati ng . o §63.6635(c)-You ma y not use data recorded during monitoring malfunctions, associated repairs, and required q ua li ty assurance or control activities in data averages and calculat ions used to report emission or operating levels. You must, however, use all the va li d d ata collected during all other periods. o §63.6640(a)-You mu st demonstrate continuous compliance with each emission limitation and operating lim it ation in T ables 1 a and 1 b and T ables 2a and 2b of subpart ZZZZ of Part 63 that apply to you acco rding to methods specified in T able 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 T ables 1a a nd 1b and T ables 2a and 2b of Subpart ZZZZ of Part 63 t hat apply to you . These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to t he requirements in §63.6650. If you chan ge your catalyst , you must reestabl ish the values of the operating parameters measured during the initia l performan ce test. W hen 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 with §§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 t he Administrator's sat isf action that you were operating in accordance with §63.6(e)(1 ). F or 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 (engi ne bum-in period) are not violat ions . AIRS 10: 045/1046/011 Page 5 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 Zll2. to Part 63 that apply to you. • N otifications, Reports and Records o §63 .6645(a) -If you own or operate a stationary R ICE 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 Zll2. to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)(ii). • §63.6645(h)(2) -F or each in itial 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 subm it the Not ification 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 f rom an emission or operating limitation occurring for a stationary R IC E w here you are using a CMS to comply with the emission and operating limitations in Subpart Zll2. to Part 63, you must include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of §63.6650. AIRS ID: 045/1046/011 Page 6 of 17 En Cana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 Table 6 of Subpart ZZZZ of Part 63 to show continuous compliance wit h 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 specified in §63.10(b)(1), you must keep each record fo r 5 years following the date of each occurrence, measurement, maintenance, corrective action , report , or record. o §63.6660(c)-You m ust keep each record readily accessible in hard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action , report , or record , according to §63.10(b)(1). You can keep the records off-site for the remaining 3 years. • Other Requ irements and Information o §63.6665 -Table 8 to this subpart shows which parts of the 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 ongoing basis with the requirements of t his 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 Testing Requireme nts 10. T his engine is subject to the periodic testing requirements of 40 C .F.R Part 63, Subpart ZZZZ. 11 . T his 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 you r O&M plan are subject to Division approval. Replacement s of this unit completed as A lternative Operating Scenarios may be subj ect to additional testing requirements as specified in Attachment A. A IRS ID: 045/1046/011 Page 7 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 , I I. C) a . Annually whenever a significant increase in emissions occurs as follows : For any criteria pollutant: F or 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 d ifferent 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 (T itle 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 w ithin 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: 045/1046/011 Page 8 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1197 Issuance 1 Colorado Department of Public Health and 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 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 8 , Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respect s with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization . Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 17. This permit is issued i n 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 identified on the permit. 18. Unless specifically stated otherwise , the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 19. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Div ision revokes a permit , the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division 's action. 20 . Section 25-7-114.7(2)(a), C .R.S. requi res that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be d iscontinued , the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will term inate. 21 . Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the reg ulations of the AQCC m ay result in administrative, civil or crimina l enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (c ivil penalties), -122.1 (criminal penalties), C .R.S . 22 . This permit replaces the following permit, which is canceled upon issuance of this permit: AIRS ID: 045/1046/011 Page 9 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Permit No. AIRSID Notes 04P01278 777/2408/001 Engine-HM05: This equipment will now be covered under this stationary source permit. By: ~ . 1 QY \LU Carissa Money (/ Permit Engi neer p . H' erm1t 1storv Issuance Date Description Issuance 1 This Issuance Canceled portable permit 04P01278 and issued as new stationary permit Final Approval April 14, 2006 Issued to EnCana Oil & Gas for 04P01278 Initial Approval January 13, Issued to EnCana Oil & Gas for 04P01278 2005 AIRS ID: 045/1046/011 Page 10 of 17 EnCana Oil & Gas (USA) Inc. Permit No . 08GA 1197 Issuance 1 Notes to Permit Holder: Colorado De pa rt ment of Public Health and Environment Air Poll 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 li mits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regu lation or any ambient air quality standard . A revised a ir pollution emission notice (APEN) and application form must be subm itted with a req u est for a permit revision . 2 ) This source is subject to the Common Provisions Reg ul ation Part II , Subpart E, Affirmative Defense Provision for Excess Em issions Du r ing Malfunctions. The permittee sha ll 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 b y written notice to the Division addressing all of the c riteria set forth in Part II.E .1. of the Common Provisions Regulation . See: http://www. cdphe. state . co . u s/reg u lations/airregs/ 1 00 1 02aqcccommonprovisionsreg . pdf. 3) The following emissions of non-criteria reportable air po ll utants are estimated based upon the process limits as indic ated in this permi t. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if t he source(s) operate at the permitted lim itations. Uncon t ro lled Em issi on A re t he Contro lled AIRS Rate emissi ons Emissi o n Po int Po llutant CAS# BI N (lb/y r) r eportable? Rate (lb/y r) Fo r maldeh yd e 5000 A 5599 Yes 2800 Acetaldehyde 75070 A 760 Yes 380 A crol ein 107028 A 467 Yes 234 011 Methanol 6756 1 c 227 No 11 4 n-Hexane 110543 c 101 No 50 Benzene 71 4 32 A 40 No 20 Toluene 108883 c 37 No 19 4) The emissio n levels contained in t his permit are based on the following emission fact ors: Po i nt 01 1 : Emission Fac tors -U ncontrolled Emissio n Factors-Cont rolled C A S Po llutant lb/MMBtu g/bhp-hr Source lb/MMBtu g /b hp-hr Sou rc 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 Aceta ldehyde 0.0084 0.0326 3.2-2 (7/2000); 0.0042 0.0163 Mfg Natural Gas AP-42; T able 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 I D: 04 5/104 6/01 1 Page 11 of 17 EnCana Oil & Gas (USA) Inc. Perm it No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Emission Factors -Unc ontrolled Emission Factors -Controlled CAS Po lluta nt lb/MMBtu g/bhp-hr So urc e 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 ; Table 71432 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 th is APEN exp1res on NoYember 9, 2013 . A revised APEN shall be submitted no later than 30 days before the fi ve-year term expires. 6) This facility is classified as follows: Applicable Status Requirement Operating Permit Major Source : 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 Title 40, Protection of En vironme nt Electron ic Code of Federal Reg ula t ions can be f ound at the website listed below: http://ecfr.gpoaccess .gov/ Part 60: Standards o f Performance for New Stationary Sources NSPS 60.1-End Subpart A-Subpart KKKK NSPS Part 60 , Appendixes Appendix A -Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A-Subpart Z MACT 63.600-63 .1199 Subpart AA-Subpart D OD MACT 63.1200-63.1439 Subpart EEE-Subpart PPP MACT 63.1440-63.6175 Subpart QQQ -Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ-Subpart MMMMM MACT 63.8980-End Subpart NNNNN -Su bpart XXXXXX A IRS I D: 045/1046/011 Page 12 of 17 Source Mfg Mfg Mfg EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACH MENT A : ALTERNATIVE OPERATING SCENARIOS RECI P ROCATING I NT ERNAL C O MBUSTION 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 o r 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 T he 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 th e 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 The permittee may permanently replace the existing compressor engine w ith 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 : 0 45/1046/01 1 Page 13 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division existing engine, 2) any perm itted short-term emission lim itations for the existing permitted engine, and 3) the applicable emission limitations as set forth in the Applicability Report submitted to the D ivision 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 em1ssion limitations sha ll be made as set forth in section 2 .2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufact urer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement eng ine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropri ate 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 replacement engine. Example Applicability Reports can be found in at http://www.cdphe.state.co .us/ap/o ilqaspermittinq.htm l. Th is 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 a re true, accurate and complete". Th1 s AOS cannot be used for permanent e ngine replacement o f a grandf athered or permit e xempt e ngine 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 dupl icative testing requirements due to overlapping Applicable Requirements . In those instances, please contact the Division F ield 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 ni trogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement eng ine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing requ ired 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. cd phe. state . co. us/a p/d own/portana lyzeproto . 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 t ime) 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 w ill be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 045/1046/011 Page 14 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1197 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 limitations or until the engine is taken offline. A.3 Applicable Regulations 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 attainment/maintenance or nonattainment must 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 attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 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 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. A IRS I D: 045/1046/011 Page 15 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1197 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 emissions. 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 cop1es of the relevant Applicability Reports required under Condition A.1.2. Emission Standards: Section XV/I.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 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 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 500SHp July 1, 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, 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 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 8 , section I. 8_ 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 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. AIRS ID: 045/1046/011 Page 16 of 17 EnCana Oil & Gas (USA) Inc. Perm it No. 08GA 1197 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division A.3.4 Reciprocating internal combustion en gine (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 ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the applicable monitoring , record keeping , and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Cond ition 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 ZZZZ as follows: Existing, new or reconstructed spark ignition 4 stroke rich burn eng ines 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 subj ect 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 w ill 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 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 Applicability Reports required under Condition A.1 .2 . Any testing required by the MACT is in addition to that requ ired by this AOS. Note that the initial test required 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 within the time frame specified in Condition A.2. A.3 .5 Additional Sources The replacement of an existing engine w ith 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 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 through the appropriate Construction/Operating perm itting process prior to installati on . AIRS ID : 045/1046/011 Page 17 of 17 STATE OF COLORI\00 C OLO RADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHON E: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO : 08GA1198 JUL 3 ., 2009 EnCana Oil & Gas (USA) Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility, known as the High Mesa Compressor Station , located in SENW Section 36 , Township 7S, Range 96W, in Garfield County, Colorado . THE SPEC IFIC EQUIPMENT OR A CTIVITY SUBJECT TO THIS PE R MIT INCLUDES THE FOLLOWING: Facility AIRS Equipment Point Description ID One (1) Caterpillar, Model G3516LE, Serial Number 4EK04903, natural gas-fi red, turbo-cha rged , 4SLB reciprocating internal HM06 0 12 combustion engine , site rated at 1 ,208 horsepower at 1 ,400 R PM . This engine shall be equipped with an oxidation catalyst and a ir- fuel ratio control. This emission unit is used for natural gas compression. T his engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G35 16LE 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 GRANTED SUBJECT TO ALL RU L ES AND REGULAT IONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE C OLORADO AIR POLLUTION PREVENTION AND C ONTROL A CT C.R.S. (25-7-101 et seq), TO THOSE G ENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPEC IFI C TERMS AND CONDITIONS: R EQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1 . This construction permit represents final permit approval and authority to operate this emissions source (Regulation 3, Part B , Section III.G.5). AIRS 10: 045/1046/012 Page 1 of 17 NGEngine Version 2008-1 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1 198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division EMISSION LIMIT AllONS 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 hi L " . ont 1y 1m1ts: Fac ility A IRS Pounds per Month Equipment 10 Point NOx VOC co Emission Type HM06 012 2972 486 306 Point Monthly hm1ts are based on a 31-day month. Annual Limits: Fac ility I AIRS Tons per Year Equipment 10 I Point NOx voc co Emission Type HM06 I 01 2 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 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 facil ity shall be determined by recording the facility's annual criteria pollutant emissions, from each emission unit, on a rolling (12) month total. B y 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 T he 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 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 i nspection upon request. (Reference: Regulation 3, Part 8 , II.A.4) P /C f L" . rocess onsump11on 1m1ts Facility AIRS Annual Monthly Equipment Point Process Parameter Limit Limit (31 10 days) H M06 012 Consumption of natural gas as a 90.9 7 .72 fuel MMscf/yr MMscf/month AIRS ID: 045/1046/012 Page 2 of 17 I I EnCana Oil & Gas (USA) Inc. Permit No . 08GA 1198 Issuance 1 Color ado Department of Public Health and E nvir onment Air P ollution Control Division During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After t he first twelve (12) months of operation, compliance w ith only the yearly limitation s hall be requi red . Compliance with the yea rly consumption limits s h all be det ermined on a rolling twelve (12) month tot a l. B y the end of e a ch month a new twelve-month total is calculated based on the previous twelve months' dat a. T he permit holder shall calcu late monthly consumption of natural gas and keep a compliance recor d on site o r at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 5 . Visible emissio n s shall not exceed twent y percent (20%) opacity during normal operat ion of the source. During periods of startup, process modification, or adjustment of control equip ment visible emissions shall not exceed 30% opacity for more than six m i nutes in any sixty consecutive minutes. (Refe rence: Regulation No . 1 , Section I I.A .1. & 4.) 6 . T h is source is subject t o the odor req uirements of Regulation No . 2 . (State only enforceable) 7. The per mit number and A IRS ID num ber shall be marked on the subject equipment for e a se of identification. (Reference: Regulation Number 3 , P a rt B, Ill. E.) (State only enfor ceable) 8 . T his sour ce is subject to the requ irements of: • Regulation No. 8, Part E , Subpart Ill. FFFF: National Emi ssions Standards for Hazardous Air Pollutants for Stationary Reciprocating I nternal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and • Regulati on No. 8, Part E, Subpart /.A , National Emissi on Standards for Hazardous A ir Pollutants for Source Categories: General Provisions, 40 CFR Part 63 including , but not limited to, the following : • Emission and Operating Limitati ons o 63.6600(b) -If you own or ope rate a new or reconst ructed 4SLB stationary RICE with a site rating of more than 500 brake H P located at major source of H A P emission s you must comply with t he f ollowing emission limitations (Ta ble 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 per cent or more; or • limit concentration of form aldehyde in the stationary RI C E exhaust to 14 ppmvd or less at 15 percent 02. A IRS 10: 045/1046/012 Page 3 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division o 6 3 .6600(b)-If you own or operate a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake H P 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. • G ene ral Co mplia nce Re quireme nts 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 R ICE, in cluding air pollution control and monitoring equipment, in a manner consistent with good air pollution control p r actices for minimizing emissions at all times, including during startup, shutdown, and malfunction. • Testing and Initial Compl iance Requirements o §63.661 O(a)-You must conduct the initial p erformance 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 RIC E in §63.6595 and accordi ng to the provisions in §63.7(a)(2). o §63.6 615 -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 T ables 3 and 4 to Subpart ZZZZ of Part 63 that apply to you . o §63.662 5 (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: 045/1046/012 Page 4 of 17 EnCana Oil & Gas (USA) Inc. Permit No . 08GA1198 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 T able 5 of Subpart ZZZZ to Part 63. o §63.6630(b) -During the initial performance test, you must establish each operating limitation in T ables 1 b and 2b of Subpart ZZZZ to Pa rt 63 that applies to you . o §63.6630(c)-You must submit the Notification of Compliance Status containing the results of the initial compliance de monstration according to t he requirements in §63.6645 . • Continuous Compliance Requirements o §63.6635(b) -Except for monitor malfunctions, associated repairs , and req uired q uality assurance or control activities (including, as applicable, calibration checks and required z ero and span adjustme nts), you must monitor continuously at all times that the st ationary RICE is operat ing. o §63.6635(c)-You may not use data recorded durin g monitoring malfunctions, associated repairs, and requi red quali ty assurance or control activities in data averages and calcula tions used to report emission or operating levels . You must, however, use all the valid data collect ed during all other periods. o §63.6640(a)-You must demonstr ate continuous compliance with each emission limitation and operating limitation in T ables 1 a and 1 b and T ables 2 a and 2b of subpart ZZZZ of Part 63 th at apply to you acco rding to methods s pecified in Table 6 of Subpart ZZZZ of P art 63. o §63.6640(b)-You must report e ach instance in which you d id not meet each emission li mitation o r operating limitation in T ables 1 a and 1 b and T ables 2a and 2b of Subpart ZZZ Z of Part 63 that a pply to you . These instances are deviations from the emission a nd operating limitations in this subpa rt. T hese deviations must be reported according to the requirements in §63.6650. If you change your catalyst, you must reestablish the values of the operati ng parameters measured during the initial performance test. When you reestablish t he 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 st ationary RICE. o §63.6640(d)-Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occu r during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Admin istrator 's satisfaction t hat you were operating in accordance wit h §63.6(e)(1). F or new, reconstructed , and rebuilt stat ionary RI C E , deviations f rom the emission or operating limitations that occu r during the first 200 hours of operation from engine startup (engine burn-in period) are not violat ions. AIRS ID: 045/1046/012 Page 5 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 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 llll 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 llll 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 llll 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 0( d)(2). o §63.6650(a)-You must submit each report in Table 7 of Subpart Zll2. 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 i n 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 stat ionary RIC E where you are using a C M S to comply with the emission and operating limitations in Subpart llll to Part 63, you must include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of §63.6650. AIRS ID: 045/1046/012 Page 6 of 17 EnCana O il & Gas (USA) Inc. Permit No . 08GA 1198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division o §63.6655(a)-If you must comply with the em ission and operating limitations , you must keep the records described in §63.6655(a)(1 ) through (a)(3), §63.6655 (b)(1) t hrough (b)(3) and §63.6655 (c). o §63.6655(d)-You must keep the records requi red in Table 6 of Subpart ZZZZ of Part 63 to sh ow continuous co m pliance with each emission o r operating limitation that applies to you . o §63.6660(a)-You r 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 specified in §63.1 O(b)(1 ), you must k eep 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 -site for at least 2 years after the date of each occurrence, measurement, mai ntenance, corrective action , report, or record , according to §63.1 O(b )(1 ). You c an keep the records off-site for the remaining 3 year s. • Other Requirements and Information o §63.6665 -Table 8 to this subpart shows wh ich parts of the General Provisions in §§63.1 through 63.15 apply to you . OPERATING & MAINTENANCE REQUIREMENTS 9. Upon startup of this point, the applicant shall f ollow the operating and maintenance (O&M) plan and r ecord keeping format approved by the D ivision , in order to demonstrate compliance o n an ongoing basis with the requirements of t his permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference : Regulation No. 3 , Part B , Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 10. T his eng i ne is subj ect to the periodic testing requirements of 40 C.F.R Part 63, Subpart ZZZZ . 11. This engine is subject to the periodic test ing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisio ns to you r O&M plan are subject to D ivision approval. Replacements of this unit completed as A lternative Operating Scenarios may be subject to additional testing requirements as s pecified in Attachment A. AIRS I D: 045/1046/0 12 Page 7 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 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 f ive (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, wh ichever 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 an y 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 . Wheneve r 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. Prev ention of Significant Deterioration (PSD) requirements shall apply to thi s source at any such t ime that th is source becomes major solely by vi rtue 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: 045/1046/012 Page 8 of 17 EnCana Oil & Gas (USA) Inc. P ermit No . 08GA 1198 Issuance 1 Colorado Department of P ublic Health and Environment Air Poll utio n Control Division AQCC Regulation No .3 , Part 8 , Section 11 .8 upon a request f or transfer of own ership and the submittal of a revised APE N and the required fee. 16. Issuance of a constr uct ion permit does not provide "final" aut hority for this activ ity o r operation of t his source. Final authorization of the permit must be secured f rom the APCD in w r iting i n accordance w ith the prov isions of 25-7 -114.5(12)(a) C .R.S. and AQCC Regulation No. 3, Part 8 , Section III.G. F ina l author ization cannot be granted until t he operat ion or activit y commences and has been verified by t he A P C D as conforming in a ll respe cts with the conditions of the permit. Once self-ce rtification of all points has bee n reviewed and approved by the Division, it will p rovide w ritten document ation of such fina l authorizat ion. Details for obtaining final authorization to operate are located in the Requirements t o Self-Certify for Final Authorization sec tion of this permit. 17. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant a nd is conditioned upon conduct of the act iv ity, or construction, installation and operation of the source, in accordance with this information and wit h representations made by the applic a nt or a pplicant's agent s. It is valid only for the equipment and operations or activity specifically identified on the permit. 18. U nless specifically sta t ed otherwise, the general a n d specific cond itions conta ined in this permit have be en determined by the APCD to be necessary to assure compliance with the provisions of Se ction 25-7 -114.5(7)(a ), C.R.S. 19. Each and every condition of this permit is a m ater ial part hereof and is not severable. Any challenge to or app eal of a condit ion hereof shall constitute a rejection of the ent ire permit and u p on such occurrence, this permit s h a ll be deemed denied ab initio. T his permit may be revoked at any t ime p rior to self-certification and final authoriz ation by the Air Poll ution Control Division (A PC D) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failu re to meet any express term or condition of the permit. If the Division denies a permit, conditions im p osed upon a permit are contested by the applicant, or the D ivision rev okes a per mit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 20 . Section 25-7-114.7(2)(a), C.R.S. requi res tha t all sources required t o file an Air Pollut io n Emission N otice (APEN) must pay an annual fee to cover the costs of inspections and administrat ion . If a source or activity is to be d iscontinued, the owner m ust notify the Division in writing requesting a cancellat ion of the permit. Upon notification, annual fee billing will terminat e . 21 . Violation of the terms of a permit or of the p r ovis ions of the Color ado Air Pollution Prevention and Control Act o r the r eg u lat ions of the AQCC may result in administrative, civil or criminal enf orcement actions under Sections 25-7-1 15 (enforcement), -121 (injunctions), -122 (c ivil penalties), -1 22.1 (criminal penalties), C.R.S. 22. This permit replaces the following permit, which is canceled upon iss u ance of this permit: AIRS ID: 045/1046/012 Page 9 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Permit No. AIRSID Notes 04P01436 777/2445/001 Engine-HM06: This equipment will now be covered under this stationary source permit. By: \,., . -[YJRY\ 1~ Carissa Money (} Permit Engineer p ·t H" t erm1 IS ory Issuance Date Description Issuance 1 This Issuance Canceled portable permit 04P01436 and issued as new stationary permit Final Approval February 7 , Issued to EnCana Oil & Gas for 04P01436 2007 Initial Approval March 31 , 2005 Issued to EnCana Oil & Gas for 04P01436 AIRS ID: 045/1046/012 Page 10 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 Issuance 1 Notes to Permit Holder: Colorado Department of Public Health and Environment Air Pollution Control Division 1) T he production or raw materia l processing limits and em issio n li m its contai ned in th is permit are based on the consumption rates requested in the permit applicat ion . T hese limits may be revised upon request of t he permittee providing there is no exceedance of an y specific emi ssion control regulation or an y ambient air quality standard . A rev ised air poll utio n emission noti ce (APEN ) and application form must be s ubm itted with a request for a permit re vi sion . 2) T his source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Em issions During Malfunctions. The permittee shall notify the Division of any malfunction cond ition which causes a violation of any emission limit or limits stated in th is permit as soon as possible , but no later than noon of the next working day, foll owed by written notice to the Division addressing a ll of the criteria set forth in Part II.E.1 . of the Common Provisions Regulation . See: http://www.cdphe .state .co.u s/regu lations/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 analys i s of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Contr o lled A IRS Rate emissions Em issi on Point Po llutan t CAS# BIN (l b/yr ) reportable? Rate (lb/yr) Formaldehyde 5000 A 5599 Y es 2800 Acetaldehyde 75070 A 760 Yes 380 Acro l ein 107028 A 467 Yes 234 0 12 Methanol 67561 c 227 No 114 n-Hexane 110543 c 101 No 50 Benzene 71 432 A 40 No 20 Toluene 108883 c 37 No 19 4 ) The emission levels conta ined in this permit are based on the following emission factors : Point 0 12: Emission Factors -Uncon trolled Emission Factors-Controlled CAS Pollutant l b/MMBtu g /bhp-hr Source 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 7 5070 Acetaldehyde 0.0084 0.0326 3.2-2 (7/2000); 0 .0042 0 .0163 Mfg Natural Gas AP-42 ; Table 107 028 Acrolein 0 .0051 0 .0200 3.2-2 (7 /2000); 0 .0026 0 .0100 Mfg Natura l Gas 67561 Methanol 0 .0025 0 .0097 A P-42 ; Table 0.001 3 0.0049 Mfg 3.2-2 (7/2000); A IRS ID: 0 4 5/1046/012 Page 11 of 17 E nCa na Oil & Gas (USA) Inc. Permit No. 08GA1198 Issuance 1 Colorado D epartment of Public Health and E nvironment Air P ollution Control Division Emission Facto rs -Uncontrolled Emissi on Factors-Controlled CAS Po llutant l b/MMBtu g/bhp-hr So urce 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; Table 71432 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 i 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 Novembe r 9, 20 13 . A revised APEN shall be submitted no later than 30 days before the five-year term expires . 6) T his facility is classified as follows: Applicable Status Requirement Operating Permit Major Source: NOx, HAPs Syntheti c Minor Source: CO , VOC PSD Synth etic Minor Source: V OC MACT HH Synthetic Minor Source: Toluene, Total HA P MACT ZZ.ZZ Major Source 7) Fu ll text of the T itle 40, Protection of Environment Electronic Code of Fede ral Regula ti ons can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60 : Standards o f Performance for New Statjonary So urces NSPS 60.1 -End Subpart A -Subpart KKKK NSPS Part 60, Appendixes Appendix A-Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Sourc e Categories MACT 63.1-63.599 Subpart A-Subpart Z MACT 63.600-63.1199 Subpart AA-Subpart DOD MACT 63.1200-63 .1439 S ubpa rt EEE -Subpart PPP MACT 63 .1440-63.6175 Subpart QQQ -Subpart YYYY MACT 63.6580-63.8830 Subpart ZZ.ZZ -Subpart MMM MM MACT 63.8980-End Subpart NNNNN-Subpart XXXXXX A IRS ID: 045/1046/01 2 Page 12 of 17 So urce Mfg Mfg Mfg EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division A T TACH MENT A : ALTERNATIVE OPERATING SCENARIOS R ECI PROCATI NG INTERNAL C OMBUSTION 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. "Permanent" 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 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 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 NSP S 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 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 The 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 AI RS I D: 04 5/1046/012 Page 13 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1198 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/ao/o ilgaspermittinq . html for example applicability report formats). Measurement of emissions from the permanent replacement engine and compliance with the applicabl e 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 fi led with the Division for the permanent replacement engine w ithin 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropri ate APEN filing fee, a cover letter explainin g that the permittee is exercising an alternative operating scenario and is installing a perm anent replacement engine, and a c opy 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 accompa nied 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 inclu ded in the submittal are t rue , accurate and complete". T his AOS cannot be u sed for permanent engine replacement o f a grandfathered or permit exempt eng ine or an engine that is not subj ect to emi ssion lim its. 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 requ irements due to overlapping Applicable Requirements. In those instances, please contact the Divisi on Field Services Unit to d iscuss streamlin ing the testing requirements. Note that the testing requ ired 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) em issions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement eng ine. All portable analyzer testing requ ired by this permit shall be conducted using the D ivi sion'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 w ith 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 w ill be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 045/1046/012 Page 14 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1198 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 limitations or until the engine is taken offline . A.3 Applicable Regulations 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 attainmenVmaintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainmenVmaintenance 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 attainmenVmaintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainmenVmaintenance 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 a nd air fuel controller to reduce emission . AI R S 10 : 0 4 5/104 6/012 Page 15 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1198 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 catal yst to reduce emissions. The above emission control equ ipment shall be appropriately s ized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relev ant Applicability Reports requ ired under Condition A.1 .2 . Emission Standards: Section X VII. E-State-only requirements Any permanent engine that is e ither 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 stan da rds re quired in the table below: Max Eng in e Cons tructio n o r Emission Standard s in G /hp-hr HP Relocation D ate N O x 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, 2 007 2.0 4.0 1.0 July 1, 2 010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicabi lity Reports required under Condition A 1.2 A 3.3 NSPS for spark ignition internal combustion eng ines: 40 CFR 60, Subpart JJJJ A permanent replacement eng ine 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 sh all 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 A2, if approved in advance by the Divisio n , provided that such test is conducted within the time frame specified in Condit ion A2. Note that under t he provisions of Regulation No. 6 . Part 8 , section I. B. that Relocation of a source from outside of t he S ta te of Colorado into the State o f Colorado is considered to be a n ew so urce, subj ect to the req u irements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado beco mes 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 re located from outside of the State of Col orado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. AIRS ID: 045/1046/012 Page 16 of 17 EnCana O il & Gas (USA) Inc. Permit No. 08GA 1198 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division A.3.4 Reciproc ati ng internal combustion eng ine (RICE) MACT: 40 CFR Part 63, Subpa rt ZZZZ A.3.4.1 Area Sou rce for HAPs A permanent replacem ent eng ine located at an area source t hat c ommenced con struction or rec onst ruction after J une 12, 20 06 as defined in § 6 3.2 , will meet t he requ irements o f 40 CFR Part 6 3, Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Su bpart JJJJ . A n analysis of t he applicable monitoring , recordkeeping , and reporting requirements for the permanent engine replacement s hall be included in the Applicability Reports requ ired under Cond ition A.1 .2 . Any testing requ ired by the MACT is in addit ion to that requi red by this AOS. Note that the in iti al test required by the MACT 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 c onducted within the time frame specified in Condition A.2. A.4. 3.2 Major source for HAPs A perm anen t replacement engine t hat is located at maj or source is subj ect to the requirements in 40 CFR Part 63 Subpart ZZZZ 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 ZZZZ. New or recon structed (construction or reconstruction commenced after 12/19/02) 2 stroke and 4 strok e lean burn engines w ith a s ite rating of more than 500 hp are subj ect 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 equ al 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 bu rn e ngines w ith a s ite rating of 500 hp or less w ill meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ . New or recon structed (const ruction 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 4 0 CFR 63, Subpart ZZZZ by meeting t he requirements of 40 CFR 60, Subpart JJJJ. An analysis of the applicable monitoring , recordk eeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports requi red under Condition A.1 .2 . Any testi ng required by the MACT is in addit ion to that required by this AOS. Note that the initial test required by the MACT c an serve as the test ing requ ired by this AOS under Condit ion A.2, if approved i n advance by the D iv is ion , provided that such test is conducted w ithin the time frame specified in Condition A.2 . A.3.5 Additional Sources The replacemen t of an exi sting engine w ith a new eng ine is viewed by the Division as the i nstallation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advan ced construction permit review. The AOS cannot be used for additional new emission points for any site; an eng ine t h at is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an e xisti ng onsite engine has to go through the appropriate Const ruction/Operating permitting process prior to installation . AIRS ID: 045/1046/012 Page 17 of 17 STATE OF COLORADO C OLORADO DEPARTMENT O F PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-31 50 CONSTRUCTION PERMIT PERMIT NO: DATE ISSUED: IS SU ED TO : 08GA1195 JUL 3 ·1 2009 EnCana Oil & Gas (USA) Inc. Issuance 1 THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED A ND LOCATED AS FOLLOWS: Natural gas compression facility , known as the High Mesa Compressor Station , located in S ENW Section 36, Townsh ip 7S , Range 96W, in Garfield County, Colorado. THE SPEC IFIC EQU I PMENT OR ACTIVITY SUBJ ECT TO THIS PE R MIT INCLUDES T HE FOLLOWIN G: Facility AIRS Equipment Point Descri ption ID O ne (1 ) Ca terpillar, Model G3516LE, Serial Number WPW00189, natura l gas-fired, turbo-charged , 4S LB reciprocating internal HMO? 009 combustion engine , site rated at 1,208 horsepower at 1 ,400 RPM . This eng ine shall be equipped with an oxidation catalyst and air- fuel ratio control. This emission unit is used for natural gas compression . This engine may be replaced w ith another engine in accordance with the temporary engine replacement provision or with another Caterp ill ar G351 6LE engine in accordance wi t h the permanent replacement provision of t he Alternate Operating Scenario (AOS), in cluded in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJ ECT TO ALL RULES AND REGULATIONS OF T HE COLORADO AIR QUALITY C ONTROL COMMISSION AND THE COLORADO AIR POLLUT ION PREVENTION AND C ONTROL A CT C .R.S. (25-7-1 01 et seq ), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DO C UMENT AND THE FOLLOWING SPEC IFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1 . This construction permit represents final permit approva l and au thority to operate this emissions source (Regulation 3 , Part B, Section III.G.5). A IRS I D: 045/1 046/009 Page 1 of 17 NGEngine Version 2008-1 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1195 Issuance 1 Colorado Department of Public Health and Environment A ir 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 thl L. ·ts on IY 1m1 Facility I AIRS Pounds per Month Equipment 10 Point NO,. voc co Emission Type HM07 009 2972 486 306 Point Monthly lrm1ts are based on a 31-day month. Annual Limits: Facility : AIRS Tons per Year Equipment ID Point NO,. voc co Emission Type HM07 009 17.5 2.9 1.8 Poi nt See "Notes to Pemut Holder #4 for mformat1on on em1ss1on factors and methods u sed to calculate 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, 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 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 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 f L . ·ts recess onsump11on 1m1 Facility I AIRS I Annual Monthly Equipment p . t Process Parameter Limit Limit (31 ID om days) HMO? 009 Consumption of natural gas as a 90.9 7 .72 fuel MMscf/yr MMscf/month AIRS ID: 045/1046/009 Page 2 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 Issuance 1 Colorad o Department of P ublic Health and Environment Air Pollution Control D ivision During the first twelve (12) months of o peration, compliance with b oth the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation , compliance with only the yearly limitation s hall be req u ired. Complian ce with the yearly consumption limit s shall be det ermined on a rolling twelve (12) month total. B y the end o f each month a new twelve-mont h total is calculate d based on the previous twelve months' data. T he permit holder shall calcul ate mont hly consumption of natural gas and keep a compliance recor d 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%) opacit y 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 consecut ive minutes. (Reference: R egulation No. 1 , Section II.A.1. & 4 .) 6. This source is subject to the odor req uire ments of Regulation No .2. (State only enforceable) 7. T he permit number and AI RS ID number sha ll be marked on the subject equipment for ease of identification. (Reference: Regulation N umber 3 , P a rt B, Ill. E.) (State only enforceable) 8. T h is source is subject t o the req uirem e nts 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 reconstructed 4SL B st ationary R ICE with a site rating of more than 500 b r ake HP located at major source of HAP emissions you must comply with the following emission limitations (T able 2a, Subpart ZZZZ to Part 63): • reduce CO emissions by 93 percent or more; or • limit concentration of formaldehyde in the st ationary RICE exh au st to 14 ppmvd or less at 15 percent 02. AIRS ID: 045/1046/009 Page 3 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 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 R ICE exhaust so that the catalyst inlet temperature is greater than or equal to 450 oF and less than or equal to 1350 oF. • General Co m pliance Req uirements 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 malfunction. • Testi ng and Initial Compliance Requirements o §63.66 10(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 t o 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 §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: 045/1046/009 Page 4 of 17 EnCana Oil & Gas (USA) Inc. Perm it No. 08GA 1195 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 lim itation that applies to you according to Table 5 of Subpart Z2ZZ 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 initial compl iance demonstration according to the requirements in §63.6645. • Continuous Compliance Requirements o §63.6635(b)-Except for monitor malfunctions, associated repairs , and required quality assurance or control activities (includ ing , 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 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 lim itation in Tables 1a and 1b 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 em ission 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 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 appli cab le to your stationary RICE. o §63.6640(d)-Consistent with §§63.6(e) and 63.7(e)(1), deviations from the em ission 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: 045/1046/009 Page 5 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1195 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 ZZ2Z to Part 63 that apply to you. • Noti fic ations, Re ports 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 §63.664 5(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 o f Subpart ll2.Z to Part 63 that includes a performance test conducted according to the requirements in T able 3 to this subpart, you must submit the Notification of Compliance Status, including the performance test results , bef ore t h e 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 Zll2. to Part 63 that applies to you. o §63 .6650(b)-You must submit each report by the date in Table 7 of Subpart ll2.Z 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 R ICE where you are using a CMS to comply with the emission and operating limitations in Subpart ll2.Z to Part 63, you must include information in paragraphs (c)(1) through (4) and (e)(1) through (12) of §63.6650. AIRS I D : 045/1046/009 Page 6 of 17 EnCana Oil & Gas (USA) Inc. Perm it No. 08GA 1195 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division o §63.6655(a) -If you must comply with the em ission 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 .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, maintenance, corrective action, report, or record. o §63 .6660(c)-You must keep each record readily accessible in h ard copy or electronic form on-site for at least 2 years after the date of each occurrence, measurement , ma intenance, corrective action , rep ort, or record, according to §63.1 O(b)(1 ). You can keep the records off-site for the remaining 3 year s. • Other Requirements and Information o §63.6665 -Table 8 to this subpart shows which parts of the General Provisions in §§63.1 through 63.15 a pply 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 com pliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Ref erence : Regulation No. 3, Part B , Section III.G .7.) COMPLIANCE TESTING AND SAMPLING Per iodic Testing Requirements 10 . This engine is subject to the periodic testing requirements of 40 C .F.R Part 63, Subpart ZZZZ. 11 . This engine is subject to the periodic testing requirements 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 testing requirements as specified in Attachment A. AIRS ID : 045/1046/009 Page 7 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 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 t ype 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 S ignificant Deterioration (PSD) requirements shall apply to this source at any such time that th is source becomes major solely by virtue of a rela x ation in any permit condition . Any relaxation that increases the potential to em it 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. (Regu lation No .3 Part D , VI.B.4) GENERAL TERMS AND CONDITIONS : 15. This permit and any attachments must be retained and made ava ilable for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AIRS ID: 045/1046/009 Page 8 of 17 EnCana Oil & Gas (USA) Inc. Permit No . 08GA1195 Issuance 1 Colorado Department of Publi c Health and Environment Air Pollution Control Division AQCC Regulation No .3 , Part 8 , Section 11 .8 upon a request for transf er of ownership and the submittal of a re v ised AP EN and the required fee . 16 . Issuance of a construction permit does not provide "fina l" authority for this activity or operat ion of t his source . Final aut horization of the permit must be secu red from the APCD in writing i n accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part 8 , Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the A PC D as conforming in all respects wit h the conditions of the permit. Once self-certification of all points has been rev iewed and approved by the Di vision , it will provide written documentation of such final authorization . Det ails for obtaining final authorization to operate are located in the Requirements to Self-Certi fy for Final Authorization section of this permit. 17. T his permit is issued in reliance upon the accuracy and compl eteness of inform ation supplied by the applicant and is con ditioned upon conduct of the activity, or construction , insta ll ation and operation of the source, in accordance with this information and with rep resentations made by the applicant or applican t's agents . It is va lid only for the equipment and operations or activity specifica lly identified on the permit. 18. Unless specifically stated otherwise, the general and specific condit ions co ntained in this perm it have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7 )(a), C .R.S. 19. Each an d every condition of this permit is a material part hereof and is not severable . Any cha llenge to or appeal of a condition hereof shall constit ute a rejection of the ent ire permit and upon such occurrence , this perm it sh all be deemed denied ab initio . T his permit may be revoked at any t ime prior to self-cert ification and final aut horization by the Air Poll ution Contr ol D ivision (APC D) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including fa ilure to meet any express term or con d ition of the perm it. If t he Division denies a permit, conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit , the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Divi sion's action . 20 . Section 25-7-114 .7(2)(a), C.R.S . requ ires that all sources required to file an Air Pollution Emission Not ice (AP EN ) must pay an annual fee to cove r the costs of inspections and admin istrat ion . If a source o r activity is to be discontinued, the owner must notify t he Di v ision in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 21 . Violation of the terms of a permit or of the provisions of the Colorado Air Po ll ution Prevention and Control Act or the regulations of the AQCC may result in adm inistrative, civil or crim inal enforcement actions under Sections 25-7-115 (enf orcement), -121 (injunctions), -122 (c ivi l penalties), -122.1 (crim inal penalties), C .R.S . 22 . This perm it replaces the following pe rmit , which is canceled upon issuance of this permit: AIRS ID: 045/1046/009 Page 9 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 Issu ance 1 Colorado Depa rtment of Public Health and En vironment A i r Pollution Control Division Permit No. AIRSID Notes 03P00929 777/2213/001 Engine-HM 07 : This equipment will now be covered under this stationary source perm it. By: !}/TV\ . • ' I '--"'' I Carissa Money (f Permit Engineer p . H " ermtt I Story Issuance Date Description Issuance 1 This Issua nce Canceled portable p ermit 03 P00929 and issued a s new sta t ionary per m it Final Approva l March 7 , 2007 Issued to EnCana Oil & Gas for 03P00929 Initial Approval February 3 , Issued to EnCana O il & Gas for 03P00929 2004 AIRS ID : 045/1046/009 Page 10 of 17 EnC a na O il & Gas (USA) Inc. Permit N o . 08GA 1195 Issu ance 1 Notes to Pe rmit Holder: Colorado Department o f Public Health and Environment Air Pollution Control D iv i sion 1) The production or raw materia l pro cessing limits and emission limits con t ained in this permit are based on t he consu m ption rates requested in the perm it applicati on . These limits may be revised upon request of the permittee pro viding there is no exceedance of any specific emission control regulation or a ny ambient air quality standard . A revised a ir pollution em ission notice (APEN ) and application form must be submitted w ith a request for a permit revi sion . 2) Th is source is subject to the Common Provisions Regu lation Part II, Subpart E, Affirmative Defense Provision for Excess Em issions During Malfunctions. The perm ittee shall notify the Division of any malfunction condition which causes a vio lation of any emiss ion li mit or limits stated in th is permit as soon as possible, but no later than noon of the next working day, foll owed by written not ice to the Div ision addressing a ll of the criteria set forth in Part II.E.1. of the Common Provis ions Reg ulatio n. See: http://www. cd phe . state. co . us/reg ulati ons/a irregs/1 00 1 02aqcccommonprovisionsreg . pdf. 3) T he foll owing emissions of non-criteria reportable air pollutants are estimated based upon the process limits as ind icated in this permit. Thi s inform ation is listed to inform the operator of the Division's analysis of the specific compounds emitted if t he source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate (lb/y r) Formaldehyde 5000 A 5599 Yes 2800 A cetaldehyde 75070 A 760 Yes 380 Acrolein 107028 A 467 Yes 234 009 Metha nol 67 561 c 227 No 114 n-Hexane 110543 c 101 No 50 Benzene 71432 A 40 No 20 Toluene 108883 c 37 No 19 4 ) T he emiss io n levels contained in th is perm it are based on the foll owing em ission factors : Point 009: Emission Factors -Uncontroll ed Emission Factors -Controll ed CAS Pollutant lb/MMBt u g/bhp-hr Source lb/MMBtu g /bhp-hr Source NO x 0.3850 1.5000 Mfg 0 .3850 1.5000 Mfg co 0.56 73 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 ; T able 75070 Aceta ldehyde 0 .0084 0 .0326 3.2-2 (7/2000); 0.0042 0 .0 163 Mfg Nat ura l Gas AP-42 ; Table 10 7028 Acrolein 0.0051 0.0200 3.2-2 (7/2000); 0.0026 0 .0 100 Mfg Natural Gas 6756 1 Methanol 0 .0025 0.0097 AP-42; T able 0 .0013 0 .0049 Mfg 3.2-2 (7/2000); AIRS ID: 045/104 6 /009 Page 11 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 Issuance 1 Colorado Department of Public Health and Environment Air Pollut ion Cont ro l Division Emission Factors -Unc ontrolled Emission Factors-Controlled CAS Pollutant lb/MMBtu g /bhp-hr Source lb/MMBtu g/bhp-hr Natural Gas A P-42; Table 110543 n-Hexane 0.0011 0 .0043 3.2-2 (7/2000); 0 .0006 0.0022 Natural Gas AP-42 ; Table 71 432 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 va lue of 1 ,208, and a fuel heat va lue of 1,000 Btu /sc f. 5) In accordance with C .RS. 25-7-114.1, the Air Pollutant Emission Notice (APEN ) associated w ith th is permit is valid for a term of five years. T he five-year term for this APEN expires on Nov e m ber 9, 2013 . A revised APEN shall be submitted no later than 30 days before the five-year term e xpires. 6 ) This facility is classified as follows: Applicable Status Requirement Ope rating Permit Major Source: NOx, HAPs Synthetic Minor Source: CO, VOC PSD Synthetic M inor Source: VOC MACT HH Synthetic Minor Source: Toluene. Total HAP MACT ll.ll. Major Source 7) Full text of the T itle 40 , Protec tion of Environmen t Electron ic Code of Federa l Regulat ions can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A-Subpart KKKK NSPS Part 60, Appendixes Appendix A-Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A-Subpart Z MACT 63.600-63 1199 Subpart AA -Subpart DDD MACT 63.1200-63.1439 Subpart EEE-Subpart PPP MACT 63.1440-63.6175 Subpart QQQ -Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ-Subpart MMMMM MACT 63.8980-End Subpart NNNNN -Subpart XXXXXX AIRS ID: 04 5/1046/009 Page 12 of 17 Source Mfg Mfg Mfg EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 Issuance 1 Colorado Department of P ublic Health and Envir onment Air Po ll ution Control Division ATTACHMENT A : ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INT ERNAL COMBUSTION E N GINES 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 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 procedura l requirements. T his 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 applyi ng 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 . "Permanenf' 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 demonst rations 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 o f the test if such testing is required to demonstrate compliance with NSP S 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 The 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 A IRS ID: 045/104 6/009 P age 13 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 Issuance 1 Colorado Department of Public Health and Environment A ir Pollution Control Division existing engine , 2) any permitted short-term emission lim itations 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/oilgaspermittinq .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 installi ng a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicabil ity Reports can be found in at http://www.cdphe.state.co.us/a p/o ilqaspermitting.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 in cl uded in the submittal are true , accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or perm it exem pt eng ine 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 d iscuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the period ic testing requirements specified by the permit for the relevant time period (i.e. if the permit requ ires 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 with in 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 w ith 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 w ill be multiplied by the maximum number of hours in the month or year (8760), whichever applies. AIRS ID: 045/1046/009 Page 14 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA1195 Issuance 1 Colorado Department of Public H ealth and E nvironm ent 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 rep lacement 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 portabl e 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 provis ions of C .R.S. 25-7-123 .1 and in the absence of credible evidence to the contrary , if the portable analyzer resu lts 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 portab le analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. A.3 Applicable Regu lations for Pe rmanent Engine Replacements A.3.1 Reasonably Avai lable Control Technology (RACT): Reg 3 , Part B § 11.0 .2 A ll permanent replacement eng ines that are located in an area that is classified as attainmenUma intenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area i s 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 nonatta inment, except as follows: In the Denver Metropolitan PM1 0 attainmenUmaintenance area, RACT applies 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 sh all 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 NS PS 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 1 00 standard cubic feet. A.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVI I.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 . A IRS ID: 045/104 6/009 Page 15 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 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 c atal yst to reduce e m issions. The above emission control equ ipment shall be appropriately sized for the engine and shall be operated and mai ntained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports requ ired 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 engi ne 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 achiev es the emission standards required in the table below: I M ax Eng ine Cons tructio n 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 J anuary 1, 2011 1.0 2 .0 0.7 SOO_::::Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2 .0 0.7 The source shall submi t copies of the relevant Applicability Reports required under Condition A.1 .2 A.3.3 NSPS for spark ign it ion 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, record keeping , 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 NSPS is in addition to that required by this AOS. Note that the initial test requ ired by NSPS Subpart JJJJ can serve as the testing required by th is AOS under Cond it ion A.2, if approved in advance by the Divisi on , prov ided that such test is conducted within the t ime frame specified in Cond it ion A.2 Note that under the provis ions of Regulation No.6 . Part 8 , section 1.8. that Relocation of a source from outside of the State of Colorado into the 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 D ivision 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 outs ide 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: 045/1046/009 Page 16 of 17 EnCana Oil & Gas (USA) Inc. Permit No. 08GA 1195 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 ZZZ.Z 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 ZllZ 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 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.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 ZZZ.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 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 llZZ. 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 ZZZ.Z. 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 llZZ 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 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 Applicability 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 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 engine 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 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 through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 045/1046/009 Page 17 of 17 STAT E OF COLORI\00 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 10GA1959 Issuance 1 DATE ISSUED: JlJNE 21, 2 011 ISSUED TO: EnCana Oil & Gas {USA) Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas compression facility , known as the High Mesa Compressor Station, located in SENW Section 36, Township 7S , Range 96W, in Garfield County, Colorado . THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Descri pti on Equipment ID Poi nt One (1) Caterpillar, Model 3616TALE, Serial Number To Be Determ ined, natural gas-fired , turbo-charged , 4SLB CE08 016 reciprocating internal combustion engine, design-rated at 4735 horsepower at 1000 RPM. This engine shall be eq uipped with an oxidation catalyst and air-fue l ratio control. I This em ission 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 3616TALE engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO A LL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C .R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: R E QUIREMEN T S TO SEL F-CER TIFY FO R F I N A L AUTHORIZ ATI ON 1. YOU MUST notify t he A PCD no later than fifteen days after commencement of the per m itted oper ation or activity by submitting a Notice of Startup (NOS) f o rm to t he A PCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state co us/apidownloadfo,...,s ""tml. Fa ilure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part 8 , Section III.G.1 and can result in the revocat ion of the permit 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the AIRS ID: 045/1046/016 Page 1 of 16 NGEngine Version 2009-1 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Division It is the permittee's responsibility to self-certify compliance with the conditions . Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No.3, Part B. III.G.2). 3 This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit, (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date The Division may grant extensions of the deadline per Regulation No. 3 , Part B , III.F 4 .b. (Reference: Regulation No. 3, Part B, III.F.4.) 4 . The operator shall complete all initial compliance testing and samplmg as required in this permit and subm1t the results to the D1vision as part of the self-certification process (Reference: Regulation No 3 , Part B Sect1on Ill E) 5 The serial number of the subject equipment shall be provided to the Division within fifteen days (15) after commencement of operat1on . This information shall be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3 , Part B , III.E .) 6. The operator shall retain the permit f inal authorization letter issued by the Division after completion of self-certificat ion , with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source . EMISSION LIMITATIONS AND RECORDS 7 Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference. Regulation No. 3 , Part B. Section II A4) Monthly Limits: Facility AIRS Pounds per Month Equipment 10 Point NO x voc CEOS 016 3884 4000 Monthly limits are based on a 31-day month . Annual Limits: I Facility Equipment 10 1 CEOS I AIRS Point 016 Tons per Year voc 22.9 23.6 Emission Type -co 1496 Point co Emission Type 8.8 Point See "Notes to Permit Holder #4 for information 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 requ1red . After the first twelve (12) months of operation, compliance with only the yearly limitation shall be required . AIRS ID: 045/1046/016 Page 2 of 16 I I I EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control D iv ision Compliance with the annual limits shall be determined 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. T he 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 . 8 This engine shall be equipped with an oxidation catalyst and air-fuel ratio control. The oxidation catalyst shall reduce uncontrolled emissions to the emiss1on levels listed in this section , 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 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3 , Part B, II.A.4) Proc ess/Cons umptio n limits Fac ility AIRS An n ual M onthly Limit Eq uipment Po int Process Param eter Limit (3 1 days) ID CE08 016 Consumption of natura l gas as a fuel 350 29.7 i MMscf/yr MMscf/month 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. The 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 REGULATORY REQUIREMENTS 10 The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification . (Reference: Regulation Number 3 , Part B, Ill E.) (State only enforceable). 11 . 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 m inutes in any sixty consecutive minutes. (Reference: Regulation No. 1 , Section II.A.1 . & 4.) 12. This source is subject to the odor requirements of Regulation No. 2 . (State only enforceable) 13 This source is subject to the requirements of: • Regulation No. 8, Part E , Subpart Ill. FFFF: National Emissi ons Standards for Hazardous Air Pollut ants for Stationary Reciprocating Internal Combustion Engines (RICE) of 40 C.F.R. Part 63, Subpart ZZZZ, and AIRS ID: 045/1046/016 Page 3 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division • Regulation No. 8, Part E, Subpart I A National Emission Standards for Hazardous Air Pollutants for Source Categories: General Provisions, 40 CFR Part 63 mcluding 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 RICE with a site rating of more than 500 brake HP 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 • hm1t concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent 02. o 63.6600(b) -If you own or operate a new or reconstructed 4SLB stat1onary 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 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 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 lim itations 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 pract1ces for minimizing em1ssions at all times , including during startup, shutdown , and malfunction . • Testing and Initial Compliance Requirements o §63 .661 O(a) -You must conduct the initial performance test or other mitial com pliance 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 1n §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 A IRS ID: 045/1046/016 Page 4 of 16 EnCana Oil & Gas (USA) Inc Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment A1r Pollution Control Division annual performance test indicate the stationary RICE is not in compliance with the CO or forma ldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests. o §63 .6625(a) -If you elect to install a GEMS as specified in Table 5 of this subpart, you must install , operate, and maintain a CEMS to monitor CO and either oxygen or C02 at both the inlet and the outlet of the control device according to the requirements in paragraphs 63 6625(a)(1) through 63.6625(4) of Subpart ZZ.ZZ to Part 63. 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 i n §63.8. 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 imtial 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 initial compliance demonstration according to the requirements in §63.6645. • Continuous Compliance Require ments Delete this entire section if the engine is not one of the following : o §6 3.6635(b) -Except for monitor malfunctions, associated repairs , and requ1red 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 repa irs , 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 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 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 performance test. When you reestablish the values of your operating parameters, you must also conduct a AIRS ID: 045/1046/016 Page 5 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 10GA1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division performance test to demonstrate that you are meeting the required emission limitation app licable to your stationary RICE. o §63.6640(d) -Consistent with §§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 c §63.6640(e) -You must also report each 1nstance 1n wh1ch you d1d 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 ratmg 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(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 schedu led 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 m 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)(1) -For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test , you must submit the Notification of Compliance Status before the close of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h)(2) -For each m1t1al compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that includes a performance test conducted according to the requirements m 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 §63.6655{a) -If you must comply w ith the em ission and operat1ng 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 emission or operating limitation that applies to you. AIRS ID: 045/1046/016 Page 6 of 16 EnCana O il & Gas (USA) Inc Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Envi ronment Air Pollution Control Division o §63.6660(a) -Your records must be in a form suitable and readily available for exped it rous 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 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-s ite for at least 2 years after the date of each occurrence measurement, ma intenance. 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 -Table 8 to th is subpart shows which parts of the General Provisions in §§63.1 through 63.15 apply to you . OPERATING & MAINTENANCE REQUIREMENTS 14. 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 compl iance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation . (Reference: Regulation No. 3, Part 8 , Section III.G.7 .) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15 . A source initial compl iance test shall be conducted on emissions point 016 to measure the em ission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing . No compliance test shall be conducted without prior approval from the Division . Any compliance test conducted to show compliance with a monthly or annual emission l imitation shall have the results projected up to the monthly or annual averag ing time by mu ltiplyi ng the test results by the allowable number of operating hours for that averaging time (Reference : Regulation No . 3 , Part B ., Section III.G 3) Oxides of Nitrogen Carbon Monoxide Periodic Testing Requirements 16. This engine is subject to the periodic testing requirements as specified in the operatrng and mai ntenance (O&M) plan as approved by the D ivision . Revisions to your O&M plan are subject to Divis ion approval. Replacements of th is unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS 17. 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 fo llows : AIRS ID: 045/1046/016 Page 7 of 16 EnCana Oil & Gas (USA} Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 reportabl e 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 tn the owner or operator of any factlity process , or activity; or c . Whenever new control equ1pment 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 existi ng 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. 18. This source is subject to the provtsions of Regulation Number 3, Part C , Operating Permits (Title V of the 1990 Federa l Clean A1r 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 withm one year of commencement of operation of the equipment or modification covered by th1s permit. 19. Prevention of Significant Deterioration (PSD} requirements shall apply to this source at any such time that th1s 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: 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No . 3, Part B , Section 11.8 upon a request for transfer of ownership and the submittal of a revised APEN and the requ1red fee 21 . If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable . Otherwise , the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance w ith the provisions of 25-7-114.5(12)(a) C .R.S . and AQCC Regulation No.3, Part B , Section III.G Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the AIRS ID: 045/1046/016 Page 8 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to ope rate are located in the Requirements to Self- Certify for Final Authorization section of this permit. 22 . 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 identified on the permit. 23 Unless specifically stated otherwise , the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-1 14.5(7)(a), C.R.S. 24 Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence , this permit shall be deemed denied ab initio . This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the applicant , or the Division revokes a permit, the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division 's action. 25 Section 25 -7-114.7(2)(a), C .R.S . requires that all sources required to file an Air Pollution Emission Notice (APEN) must pa y an annual fee to cover the costs of inspections and administration . If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate . 26 V iolation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative , civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By : Stephanie Chaousy, PE Permit Engineer P 't H ' t e nm IS O ry Issuan ce Date Issuance 1 This Issuance AIRS ID: 045/1046/016 De scription New engine at a major source facility. Page 9 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Notes to Permit Holder: Colorado Department of Public Health and Environment Air Pollution Control Division 1) The production or raw material processing limits and emiSSIOn limits conta1ned m th1s perm1t are based on the consumption rates requested m the permit application. These lim1ts may be rev1sed upon request of the permittee providing there IS no exceedance of any specific emission control regulation or any ambient a1r 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 Prov1s1ons Regu lation Part II. Subpart E, Affirmative Defense Provision for Excess Em1ssions During Malfunctions The permittee shall notify the Division of any malfunction condition which causes a VIOlat ion of any em1ss1on lim1t or limits stated 1n this perm t as soon as possible, but no later than noon of the next work1ng day followed by written not1ce to the Division addressing all of the criteria set forth m Part II.E 1. of the Common Provisions Regulat1on See. http.//www.cdphe.state .co. us/regulations/alrregs/1 001 02aqcccom monprovisionsreg . pdf. 3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated n th1s permit This information .s listed to inform the operator of the DIVISion·s ana.ysis of the spec•fic compounds em1tted ·f the source(s) operate at the permitted limitations I I I Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS# BIN (lb/yr) reportable? Rate (lb/yr) Formaldehyde 50000 A 36578 Yes 9145 - Acetaldehyde 75070 A 2972 Yes 1486 - Acrolein 107028 A 1828 Yes 914 016 Methanol 67561 c 889 No 889 n-Hexane 110543 c 395 No 395 Toluene 108883 c I 145 I No 145 - 1 ,3-Butadiene 106990 A 95 Yes 95 4) The emission levels contained in this permit are based on the following emiss1on factors: Point 016: Emission Factors -Emission Factors- Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 0.1286 0 .5 0.1285 0.5 -co 0.7073 2 .75 I 0.0495 0.1925 -voc 02649 1.03 0 13?5 0 515 -50000 Formaldehyde 0.1029 0.4 0.0257 0 1 ~5070 Acetaldehyde 0.0084 0.0325 I 0 .0042 00163 - 107028 Acrolein 0.0051 0.0199 0.0026 0.0099 -67561 Methanol 0.0025 0.0097 0.0025 0 0097 110543 n-Hexane 0.0011 0.0043 0.0011 0.0043 -108883 Toluene 0 .0004 0.0016 0.0004 0.0016 106990 1,3-Butadlene 0.0003 0.0010 0.0003 0.0010 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 8572 Btu/hp-hr, a site-rated horsepower value of 4735, and a fuel heat value of 1020 Btu/scf AIRS ID: 045/1046/016 Page 10 of 16 EnCa n a O il & G a s (U SA) Inc. Permit N o . 1 OGA 1959 Issuance 1 Colorado Department of Public Health a nd E nvironme nt Air P ollution Control Division Emission Factor Sources· CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufactu rer Manufacturer co Manufactu rer Manufacturer voc Ma nufacturer Manufacturer 50000 Formaldehyde Manufacturer Manufacturer 5 ) In accordance w 1th C R S. 25-7-114 .1 , the Air Pollutant Emission Notice (APEN ) associa ted w ith th 1s perm it is valid for a term of five years. The five-year term for th is APEN expires on 8/24/2015. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6 ) This facility is class ified as follows: Applicable Status Requirement Opera ting Permit Major Source NOx, VOC, HAPs PSD Synthetic Minor Source CO, VOC MACT HH Area Source Requirements: Not Applicable MACT ZZ ZZ Maj or Source Requiremen ts: Applicable 7) Fu ll text of the Tit le 4 0, Protection of Environment Electronic Code of Federal Regulations can be found a t the websi te listed below: http://ecfr.gpoa ccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSP S 60.1-End Subpart A-Subpart KKK K NSPS 1 Part 60, Append ixes A ppendix A-Appendix I Part 63: National Emi ssion 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 ODD MACT 63.1200-63 1439 Subpart EEE-Subpart PPP MACT 63.1440-63.61 75 Subpart QQQ -Subpart YYYY MACT 63 6580-6 3 8830 Subpart ZZZZ-Subpart MMMMM MACT 63.8980-End S ubpart N NNNN -Subp art XXX XXX 8 ) An Oil and Gas Industry Construction Perm it Se lf-Certification Form is mcluded with this perm1t packet. Please use th is form to complete the self-certification requ iremen ts as specified in the perm1t conditio ns . Further gu1dance on se lf-certification can be found on our webs1te at nt<p ,wv • .,;..cdphe s:a:e.co.us,ap/0 lgasperm1tt1;,~.htn .. A IRS ID : 045/104 6/016 P a ge 11 o f 16 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES December 1 0, 2008 The following Alternative Operating Scenano (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulatron No. 3 Part A , Sect1on IV A , Operational Flexibility-Alternative Operating Scenarros. Regulation No. 3 Part B, Construction Permits. and Regulation No. 3, Part D . Major Stationary Source New Source Review and Prevent ion of Significant Deterioration, and it has been found to meet a ll applicable substantive and procedural requirements This permit incorporates and shall be considered a Construction Perm1t for any engine replacement performed in accordance with this AOS and the permittee shall be allowed to perform such engrne replacement without applying for a rev1sion to this permit or obtarnrng 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 eng1ne 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 The 90 days is the total number of days that the eng1ne 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 penod1c mon1torrng required by this AOS are in addition to any compliance demonstrations or periodiC monitoring required by th is perm1t. 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 assoc1ated calculatrons required by th1s AOS shall be submitted to the Division withrn 30 calendar days of the test or w1th rn 60 days of the test 1f such testrng 1s requ1red to demonstrate compliance with NSPS or M ACT requirements. Results of all test s shall be kept on s ite for f ive (5) years a nd 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 durrng the term of this perm1t. and the manufacturer, model number. horsepower, and serial number of the replacement engine In addition to the log, the permittee shall mainta1n a copy of all Applicability Reports required under sectron A 1.2 and make them available to the Division upon request. A.1.1 The perm1ttee may temporarily replace an exrsttng compressor engine that Is subject to the emission limits set forth in th1s permit with an engine that is of the same manufacturer model and horsepower or a different manufacturer, model, or horsepower as the ex1sting engine Without modifying th1s permrt , so long as the emiss1ons from the temporary replacement eng ine comply with the emission limitations for the existing permitted eng ine as determined in section A.2. M easurement of emissions f rom the temporary replacement engine s hall be made as set forth 1n section A.2. A.1 2 The perm1ttee may permanently replace the existing compressor engine with an engine that 1s of the same manufacturer, model and horsepower without modifying this permit so long as the emissions from the permanent repla cement e ng1ne comply with 1) th e permitted annual emission limitations for the AIRS ID: 045/1046/016 Page 12 of 16