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Home My WebLink About1.10C Air Quality PermitsEnCana Oil & Gas (USA) Inc Permit No. 1 OGA 1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division exi sting engine, 2 ) any permitted short-term emiss1on limitations for the existing permitted engine, and 3 ) the applicable emission limitations as set forth in the Applicability Report submitted to the D i visi on with the Air Pollutant Emissions Notice (APEN) for the replacement engine (see http://www.cdphe.state.co us/ap/oilgaspermittinq .html for example applicabil ity report formats). Measurement of emissions from the permanent replacement engine and compliance w ith the applicable e m 1ss1on limitations shall be made as set forth m sect1on A.2 A n Air Pollutant Emissions Notice (APEN) that incl udes the specific manufacturer model and seri a l number and horsepower of the permanent replacement engine shall be filed w ith the D ivisi on for the permanent replacement engme w ithin 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropnate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and i s installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicabi lity Reports can be found at http·//www cdphe.state.co.us/ap/oilgaspermitting .html. Th1s submittal shall be accompanied by a certification from a person legally authorized to act on behalf of the source indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and compl ete" Thi s AOS cannot be used for permanent engine replacement of a grandfathered o r permit exempt engine or an engine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. A.2 Portable Analyzer Testing Note: I n some cases there may be conflicting and/o r duplicative testing reqUirements due to overlapping Applicabl e Requi rements. In those instances, please contact the D ivision Fie l d Services Unit to discuss str eamli ning the testing reqwem ents. Note that the testi ng 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 D ivision. The permittee shall measure n itrogen oxide (NOX) and ca r bon mon oxide (CO) emissions i n the exhaust from the repl acement engi ne usi ng a portable f lue gas anal yzer w ithin seven (7) calendar days of commenci ng operation of the replacement engine A ll portable analyzer testing required by thi s permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the D iv i sion'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) em1ssion lim1t, the results of the tests shall be converted to a lb/hr basis and multip lied by the allowable operating hours in the month or year (whi chever applies) m order to monitor compliance If a source i s not limited in its hours of oper ation the test resu lts w ill be multipli ed by the maximum n umber of hours i n the month o r year (8760), whichever applies. AIRS ID: 045/1046/016 Page 13 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 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 umts 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 limitat ions, 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 prov1s1ons 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 md1cates 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 Contro1 Technology (RACT). Reg 3, Part 8 § 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/mamtenance 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 1n attainment/maintenance or nonattainment except as follows· In the Denver Metropolitan PM10 attamment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and S02, as precursors to PM 10, 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 emiss1on 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 1n 40 CFR Part 60 Subparts GG (§ 60 331) and 40 CFR Part 72 (§ 72 2), natural gas contams 20.0 grains or less of total sulfur per 100 standard cubic feet. A.3.2 Control Requirements and Emission Standards: Regulat ion N o.7, Sect ions 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 s ubject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's des1gn rate greater than 500 hp shall use a non- selective catalyst and a1r fuel controller to reduce emission AIRS I D: 045/1046/016 Page 14 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 10GA1959 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Lean burn eng1nes with a manufacturers design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emiss1on 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 XVII.E-State-only requirements Any permanent engine that 1s 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 limi tations 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 HP Construction or Emission Standards 1n G /hp-hr Relocation Date NOx co voc January 1, 2008 2 .0 4 .0 1.0 100<Hp<500 January 1, 2011 1.0 2 .0 0.7 500,:::Hp July 1, 2007 2 .0 4 .0 1.0 July 1, 2010 1.0 2.0 0 .7 The source shall submit copies of the relevant Applicability Reports required under Condition A.1 .2 A3.3 NSPS for spark ignrtion 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 l ess 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 monitori ng, recordkeep1ng, 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 th is 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 with in the time frame specified in Condition A2 Note that under the provisions of Regulation No.6 Part 8 , section 1.8 . that Relocat1on 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 A 3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ AIRS ID: 045/1046/016 Page 15 of 16 EnCana Oil & Gas (USA) Inc. Permit No. 1 OGA 1959 Issuance 1 A.3.4.1 Area Source for HAPs Colorado Department of Public Health and Environment Air Pollution Control Division 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 ZZll by meetmg 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 mcluded in the Appl1cabillty Reports required under Condition A 1 2 Any testmg required by the MACT is in addition to that required by this AOS Note that the in1tJal test requ1red by the MACT can serve as the testing requ1red by this AOS under Condition A 2 if approved in advance by the Div·sion provided that such test is conducted within the time frame specified in Condition A .2 . A.3.4.2 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 Existmg , new or reconstructed spark ignition 4 stroke rich burn engines w:th a s!te rating of more than 500 hp are subJect to the requirements m 40 CFR Part 63 Subpart ZZZZ New or reconstructed (construction or reconstruction commenced after 12. 19/02) 2 stroke and 4 stroke lean burn eng1nes with a site rating of more than 500 hp are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and were manufactured on or after 1/1/08 are subject to the requirements 1n 40 CFR Part 63 Subpart ZZll. New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean burn or 4 stroke nch burn engmes w1th a s1te rating of 500 hp or less will meet the requirements of 40 CFR 63, Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean burn engines with a s ite 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 record keeping, and reporting requirements for the permanent eng1ne replacement shall be mcluded m the Applicability Reports required under Condition A.1 2 Any testmg requ1red by the MACT 1s m addition to that reqUired by this AOS Note that the mit1al test required by the MACT can serve as the testing required by this AOS under Condition A 2 1f 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 rev1ew. The AOS cannot be used for additional new emiss1on 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: 045/1046/016 Page 16 of 16 Colorado Department of Public Health and Envi ro nment A ir Poll ution Control Division OIL AND GAS INDUSTRY CONSTRUCTION PERMIT SELF- CERTIFICATION FORM PERMIT NO: 10GA1959 A IRS ID: 045/1046/016 Issuance 1 ISSU E D TO: EnCana Oi l & Gas (USA) Inc. I MPORT ANT NOTICE TO PERMIT HOLDER: The following Self-Certi fication document must be completed and submitted withi n 180 days of starting any and all equipment described in the above permit. PURSUANT TO C .R.S.§25-7-114.5, FAILURE TO SUBMIT A COMPLETE SELF-CERTI FICATION FOR EACH UNIT W ITHIN 180 DAYS OF START-UP MAY RESULT IN FORMAL ENFORCEMENT ACTION AUTHORIZED BY C.R.S. §25-7-115, UP TO AND INCLUDING PERMIT REVOCATION . This document must be completed and signed by a responsible official as defined u nder Colorado Air Qualit y Contr ol Commission Regu lation No. 3 , Part A , §1.8.38. To complete this form, initial on the appropriate lines below. All supporting documentation must be submitted with this form. A Construction Permit Final Authorization to Operate will be issued only if all perm it conditions are being met. P lease save a copy of this completed form for your records. 1. Start-up The following equipment as described in permit number 10GA1959 has been installed and started: All equipment described in this permit has been installed and started. Notice of Start-up(s) have been filed, and thi s self-certifi cation document encompasses all equipment listed on the permit. 2. Opacity I certify this equipment is generating no visible emissions in excess of per mit limits. (Formal Visi ble Emi ssions r eading NOT r equired). 3. Emissions a n d Process Limits AIRS I D: 045/1046/016 Perm it Number: 10GA1959 Issuance 1 Page 1 of 3 Colo rado Department of Public Health and Envi ronment A ir Poll utio n Control Div is ion I certify that this source is in compliance with the permit's process limits for Natural Gas Consumption. 4. Operations and Maintenance Plan I certify that upon start-up, this sour ce began following the O&M plan submitted with the permit application, and continues to do so. I certify that to calculate emissions, this source is using the emission factors or methodology described in the permit. I c ertify t hat this sour ce is in c omp liance with the p ermit's s h o rt-term emis sions limits. 5 . Compliance Testing and Sampling I certify that the required compliance testing for the equipment described in Section 1 above has been completed, and the results: D were submitted to the Division on ______ (DATE). D will be submitted to the Division on or before ______ (DATE). 6. NSPS & MACT I certify this source is in compliance with the applicable requirements of: NSPS NESHAP/MACT Not applicable 40 CFR 63 Subpart ZZZ2 requirements for engines greater than 500 hp at major sources of HAPs Note that NSPS JJJJ, MA CT ZZZZ requirements for engines at area sources and MA C T ZZZZ re quirements for engines less than or equal to 500 horsepower at major sources of HAP are not currently adopted in to Colorado Regulation No. 6 and are therefore not incorpora ted into Issuance 1 of Permit No. 1 OG A 1959 7. Other Requirements I certify that the serial #was submitted with the Notice of Start-up. A IRS 10 : 045/1 046/0 16 Perm it Number : 10 GA1959 Issuance 1 Page 2 of 3 Colorado Department of Public Health and Envi ronment Air Poll ution Control D ivision I certify that the each piece of equipment has been marked with the permit number and A IRS I D. The responsib le official whose signature appears below further certif ies to the follow ing : I have reviewed the above paragraphs, the ter ms and conditions of the Construction Permit referenced above, and the information b e ing submitted for fi nal approval of this permit in its enti rety. Based on i nformation and belief formed after reasonable inquiry, I certify that the source is in full compliance with each permit conditi on of this construction per mit, and the statements and informat ion contained i n this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 1 8-1-501(6), C .R.S., makes any false material statement, representation, or certification in this appli cation is guilty o f a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or T yped Name Signature AIRS ID: 045/1046/016 Permit Number: 1 OGA 1959 Issuance 1 T itle Date Signed Page 3 of 3 STATE OF COLORI\00 CO LORADO DEPARTMENT OF PUBLIC HEAL TH AN D ENVIRONMENT AIR PO LLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 10GA1308 Issuance 1 DATE ISSU E D: FEBRUARY 8, 20 ll ISSUED TO: EnCana Oil & Gas (USA), Inc. THE SO URCE T O WHI CH THIS PERM IT APPLIES IS DESC RIBED AND L O CATED AS FOLLOWS: Natural gas compression f acility, known as the H igh Mesa Compressor Station , located at Section 36, Township 7 South, Range 96 West, in Garfield County, Colorado. THE SPECIFIC EQUIPMENT OR A CTIVITY S UBJECT TO T HIS PERMIT INC LUDES THE FOLLOWING: Facility AIRS Equipment Point Description 10 One (1 ) Triethylene glycol (TEG) natural gas dehydration unit (make: TBD, 75 M M SCF/D , serial number: TBD) with a design capacity of 75 MMscf per day. This emissions unit is equipped with two (2) electric-glycol pumps (make and model: TBD) w ith a DU03 015 design capacity of 9 .0 gallons per minute. This unit is equipped with a flash tank, reboiler and still vent. Stripping gas is not used. Emissions from the still vent are routed to an air-cooled condenser and then to the combustor (TCI 2000). Emissions from the flash tank are routed d irectly to the combustor (TCI 2000). T H IS PERMIT IS GRANTED SUBJECT T O ALL RULES AND REGULATIONS O F THE CO LORADO AIR QUALITY C ONTROL COMMISSION AND THE COLO RADO AIR POLL UTIO N PREVENT ION AND CONTROL A CT C .R.S. (25-7 -101 et s eq), TO THOSE G ENERAL TERMS AND CONDI TIONS INCLUDED IN T HIS DOC UMENT AND THE F O LLOWIN G SPECIFIC TERMS AND CONDITIONS : REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Y OU M U ST notify the APCD n o late r than thi rty days afte r commencement of the p e rmitte d o p e r ation or a c tiv i ty by submitting a No tice of Startup (NOS} form to the AP C D . The Notice of Startup (N OS) form may be downloaded online at www cdphe.state.co .us/ap/dow n loadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3 , Part B , Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contai ned on this permit shall be demonstrated to the D ivision . It is the permittee's responsibility to self-certify compliance with the conditions. Failure to AIRS ID: 045/1046/015 Page 1 of 13 Dehy Ve rsion 2009-1 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3 . Part B , II.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 withrn 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 sampling as required in this permit and submit the results to the Division as part of the self-certification process . (Reference: Regulation No. 3 , Part B , Section Ill E.) 5. The manufacturer and serial number of the subject equipment shall be provided to the Divisron within thirty days (30) after commencement of operation. 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 final authorization letter issued by the Division, after completion of self-certification , with the most current constructron permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITAT IONS AND RECORDS 7 Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's prelim inary analysis). (Reference : Regulation No. 3 , Part B, Section II.A.4) M o n t hly Limits: Faci lity AIRS Pounds per Month Equ ipment 10 Point NOx voc DU03 I 015 1638 Monthly limits are based on a 31-day month. A nnual Limits: Facility I AI RS Tons per Year Equipment 10 Poin t N Ox voc I DU03 015 I 9 .64 I L-I -- co Emission T ype Point I co Emission Type I Point I See "Notes to Permtt Holder #4" for mformat10n on em1ss1on factors and met/10ds used to calculate limits. During the first twelve (1 2) months of operatron , 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 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 . The permit holder shall calculate monthly emissions and keep a compliance record on srte or at a local field office with site responsibility for Division review. AIRS ID: 045/1046/015 Page 2 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Env ironment Air Pollution Control Division 8. Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4 .0 or higher on a monthly basis using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate , and other operational values specified in the O&M Plan). Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into GRI GlyCalc. 9. This un it shall be configured such that the flash tank vapors are routed to the combustor and still vent vapors are routed to an air-cooled condenser then the combustor. The combustor shall be capable of reducing uncontrolled emissions ofVOC from the TEG dehydration unit to the emission levels listed in Condition 7 , above. Operat ing parameters of the control equipment are identified in the operation and maintenance p lan. (Reference: Regulation No.3 , Part 8 , Section II I.E.) PROCESS LIMITATIONS AND RECORDS 1 o. This source shall be limited to the fo ll owing maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual natural gas throughput rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part 8 , II.A.4) Process/Consumption Limits Facility AIRS I Annual Monthly Limit Equipm ent P . t Process Parameter ID om Limit (31 days) DU03 015 I 27 ,375 2 ,325 Natural gas throughput MMscf/yr MMscf/month During the first twelve (12) months of operation , compliance with both the monthly and yearly natural gas throughput 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 natural gas throughput li mits 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 natural gas throu ghput and keep a compliance record on site or at a local f ield office with site respons ibility, for Division review. 11 . This source shall be limited to a maximum lean glycol reci rculation pump rate as calculated per 40 CFR, Part 63, Subpart HH , §63.764 (d)(2). The owner or operator shall maintain monthly records of the actual lean glycol recirculation rate and make them available to the Division for inspection upon request. If operator demonstrates exemption from §63.764(d)(2), then m aximum recirculation rate shall not exceed 9 .0 gallons per minute. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification . (Reference : Regulation Number 3, Part 8 , II I.E.) (State only enforceable) 13. Visible emissions shall not exceed twenty per cent (20%) opacity during normal operation of the source. During periods of startup, process modification , or adj ustment of control equipment v isible emissions shall not exceed 30% opacity for more than s ix minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4 .) 14. This source is subject to the odor requirements of Regulation No.2 . (State only enforceable) AIRS ID: 045/1 046/015 Page 3 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division 15. The flare covered by this permit is subject to Regulation No. 7 , Section XVII.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII , it shall be enclosed , have no visible emissions during normal operations , and be designed so that an observer can , by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division , determine whether it is operating properly. The operator shall comply with all applicable requirements of Section XVII. 16. This equipment is subject to the control requirements for glycol natural gas dehydrators under Regulation No .7 , Section XVII.D (State only enforceable). Beginning May 1, 2008, uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by an average of at least 90 percent through the use of air pollution control equipment. This source shall comply with all applicable general provisions of Regulation 7 , Section XVII. 17. When this source is not subject to area source requirements of 40 CFR, Part 63, Subpart HH , Section §63. 760, this source is subject to the TEG dehydrator area source requirements of 40 CFR, Part 63, Subpart HH -National Emission Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities including , but not limited to, the following: • §63.764-General Standards o §63.764 (e)(1) -The owner or operator is exempt from the requirements of paragraph (c)(1) and (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1 ). • §63.764 (e)(1 )(i)-The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day (3 .0 MMSCF/day), as determined by the procedures specified in §63.772(b)(1) of this subpart; or • §63.764 (e)(1)(ii)-The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0 .90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. • §63.772-Test Methods, Compliance Procedures and Compliance Demonstration o §63.772(b) -Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1 ). • §63. 772(b)(1) -The determination of actual flowrate of natural gas to a glycol dehydration unit shall be made using the procedures of either paragraph (b)(1)(i) or (b)(1)(ii) of this section. • §63. 772(b)(1 )(i )-The owner or operator shall install and operate a monitoring instrument that directly measures natural gas flowrate to the g lycol dehydration unit with an accuracy of plus or AIRS ID: 045/1046/015 Page 4 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment A i r Pollution Control Division minus 2 percent or better. The owner or operator shall convert an nual natural gas flowr ate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehy d ratio n unit processed natura l gas. • §63.772(b)(1)(ii)-The owner or operator shall document, to the Administrator's satisfaction, that the actual a nnual average natural gas flowrate t o the glycol dehyd rati on unit is less t han 85 thousand standard cubic meters per day. • §63.772(b)(2)-The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this sectio n. Em issions shall be determined either uncontrolled, o r with federally enforceable controls in place. • §63.772(b)(2)(i)-The owner or operator shall determine actual average benzene emissions using the model GRI-GL YCalc T M , Version 3 .0 or h igher, and the procedu res presented i n the associated GRI-GL YCalc ™Technical Reference Manual. Inputs to the model shall be r ep resentati ve of actual operati ng conditions of the glycol dehydration unit and m ay be determined using the procedures documented in the Gas Resea rch In stit ute (GRI) report entitled "Atmospheric R ich/Lean Method for Determining Glycol Dehydrat or Emissions" (G RI -95/0368 .1 ); or • §63 .772(b)(2)(ii) -The owner or operator sha ll determine an averag e mass rate of benzene emissions in kilograms per h our through direct measurement using the methods in §63.772(a)(1 )(i) or (ii ), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to m e gagrams per yea r. • §63 .774 -Recordkeepi ng Requirements o §63.774 (d)(1) -An owner or operator of a glycol dehydration unit that m e ets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1 )(ii) shall maintain the records specified in paragraph (d)(1 )(i) or paragraph (d )(1 )(ii) of this section, as appropriate, for that glycol dehydration unit. • §63.774 (d)(1 )(i)-The actual annual average natural gas throu g hput (in terms of natural gas flowrate to the glycol dehydration unit per day) as determined in accordance with §63.772(b)(1), or • §63. 77 4 ( d)(1 )(ii) -The actual average benzene emissions (i n terms of benzene emissions per year) as determined in accordance with §63. 772(b )(2). 18 . When this source is not subj ect t o area source requ i rement s of 40 CFR , Part 63, Subpart HH. Section §63.764, it is subject to the TEG dehydrat or area source requirements of 40 CFR, Part 63, Subpart HH -National Emission Standards for Haz ardous Air Pollut ants for AIRS ID: 0 45/1046/015 Page 5 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Source Categories from Oil and Natural Gas Production Facilities including, but not limited to, the followmg : • §63.760-Applicability and designation of affected source o §63.760 (f) -The owner or operator of an affected major source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(1) and (f)(2) of this section. The owner or operator of an affected area source shall achieve compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. • §63.760 (f)(6)-The owner or operator of an affected area source that is not located in an Urban-1 county, as defined in §63.761 , the construction or reconstruction of which commences on or after July 8, 2005, shall achieve compliance with the provisions of this subpart immediately upon initial startup or January 3, 2007, whichever date is later. • §63 .764-General Standards o §63.764 (d)(2) -Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63 761) shall comply with the provisions specified in paragraphs (d)(2(i) through (iii) of this section. • §63.764 (d)(2)(i)-Determine the optimum glycol circulation rate using the following equation: L =ll-*~OgaiTEG*(F*(/ 0 ) on · ) .>. lb H 2 0 24hr day , Where: Lopr =Optimal circulation rate. gal/hr. F = Gas flowrate (MMSCF/D) I = Inlet water content (lb/MMSCF) 0 = Outlet water content (lb/MMSCF) 3 .0 = The in dustry accepted rule of thumb for a TEG-to water ratio (gal TEG/IbH 20) 1.15 =Adjustment factor included for a margin of safety. • §63.764 (d)(2)(ii) -Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) ofth1s section. If the TEG dehydratron unit IS unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i), the owner or operator must calculate an alternate circulation rate using GRI-GL YCalcTM , Version 3.0 or higher The owner or operator must document why the TEG dehydration unit must be operated us1ng the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7) • §63.764 (d)(2)(iii)-Mamtain a record of the determination specified in paragraph (d)(2)(ii) in accordance with the requirements in §63.774(f) and submit the Initial Notification in accordance with the requirements in §63 775(c)(7). If operating conditions change and a modification to the AIRS ID: 045/1046/015 Page 6 of 13 EnCana Oi l & Gas (USA), In c. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Poll ution Control Division optimum g lycol circulation rate is required, the owner or operator shall prepa re a new dete rmi nation in a ccordance wit h p aragraph (d )(2)(i) or (ii) of t his section and submit the informati on specified under §63.775(c)(7)(ii ) through (v). • §63.774 -Rec ordkeeping Requirements o §63.774 (b)-E xcept as specified in paragraphs (c), (d ), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1 ) through (11 ) of this section : • §63.774 (b)(1)-The owner or operator of an affected source subject to the provisions of this subp art shall maintain files of all infor mation (including all reports and not ifications) requi red by this subpart. The f iles shall be retained f or at le ast 5 ye ars followin g the date of e ach occurrence, measurement, maintenance, corrective action , report or period . • §63.774 (b)(1)(i) -All appl icable records shall be maintained in such a manner that they can be readily accessed . • §63.774 (b)(1)(ii)-T he most recent 12 months of records shall be retained on site or sha ll be accessible from a centr al location by computer or othe r mea ns that provides access within 2 hours after a request. • §63.774 (b)(1)(iii)-The rema ining 4 years of records may be reta ined offsite. • §63.774 (b)(1)(iv)-Records may be maintained in h a rd copy or com p ut er-readable f orm including , but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or m icrofiche. o §63.774 (f)-The owne r or operator of a n area source not locate d w it h in a UA p l us offset and UC bound ary must kee p a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.7 6 4 (d)(2)(i) o r §63.764(d)(2)(ii ), as applicable. • §63.775-Reporting Requirements o §63.775 (c)-Except as provided in paragraph (c)(8), each owner or ope rator of an area source subje ct to this subpart sh all submit the informat ion listed in paragraph (c)(1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs (c)(2) through (6) of this s e ction . If the source is not located with in any UA plus offset and UC boundaries, the owner or operator s hall also submit the information listed w ithin paragraph (c)(?). • §63.775 (c)(1)-T he initial notifications requi red unde r §63 .9(b)(2) not later than January 3 , 2008. In addition to s ubmitting your initial notification to the addressees specified under §63.9(a ), you must also submit a copy of the initial notification to EPA's Offi ce of Air Qu a lity Planning and . Standards. Send your notifi cation via e-mail to CCG- ONG@EPA.GOV or via U.S . mail or other mail delivery service to U .S. EPA, Sector Poli cies and Programs Division/Coatings and Chemicals AIRS ID : 045/1046/015 Page 7 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division Group (E143-01), Attn: Oil and Gas Project Leader, Research Triangle Park, NC 27711. • §63.775 (c)(?)-The information listed in paragraphs (c)(1}(i) through (v) of this section . This information shall be submitted with the initial notification. • §63.775 (c)(7)(i)-Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in an urban cluster with 10,000 people or more; and the names of the nearest urban cluster with 10,000 people or more and nearest urbanized area. • §63.775 (c)(7)(ii)-Calculation of the optimum glycol circulation rate determined in accordance with §63. 764(d)(2)(i). • §63.775 (c)(7)(iii) -If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GL YCalcTM, Version 3 .0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate. • §63.775 (c)(7)(iv)-The name of the manufacturer and the model number of the glycol circulation pump(s) in operation. • §63.775 (c)(7)(v)-Statement by a responsible official , with that official's name, title, and signature, certifying that the facility will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with §63.764(d)(2)(i) or §63. 764(d)(2)(ii), as applicable. o §63. 775 (f) -Notification of process change. Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under paragraph (e) of this section, whichever is sooner. The report shall include: • §63.775 (f)(1) -A brief description of the process change: • §63. 775 (f)(2) -A description of any modification to standard procedures or quality assurance procedures • §63.775 (f)(3) -Revisions to any of the information reported in the original Notification of Com.p liance Status Report under paragraph (d) of this section; and • §63. 775 (f)(4) -Information required by the Notification of Compliance Status Report under paragraph (d ) of this section for changes involving the addition of processes or equipment. OPERATING & MAINTENANCE REQUIREMENTS AIRS ID: 045/1046/015 Page 8 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment A i r Pollution Control D ivision 19. 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 compli ance on an ongoing basis with the requirements of this per mit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No.3 , Part B, Section 111.8 .7 .) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 2 0 . The owner or operator shall demonstrate compliance with Condition 15, using EPA Method 22 to measure opacity from the flare . 21. The owner or operator shall complete the in itial annual extended wet gas analysis testing required by this permit and submit the results to the D ivision as part of the self-certification process to ensure compliance with emissions lim its. (Reference: Regulation No. 3, Part B , Section III.E.) 22. A source initial compliance test shall be conducted on emissions point 015 to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained i n this permit. The test protocol must be in accordance with the requirements of the A ir Pollution Contr ol 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 shal l be conducted without prior approval from the Division . Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operati ng hours for that averaging time (Reference: Regulation No. 3 , Part B., Section 111.8 .3) Volatile Organic Compounds using EPA approved methods. Benzene, Toluene, Ethylbenzene, Xylenes and n-Hexane using EPA approved methods. Periodic Testing Requirements 23. The owner or operator shall complete an extended wet gas analysis prior to the inlet of the TEG dehydrator on an annual basis. Results of the wet gas analysis shall be used to ca lculate emissions of criteria pollutants and hazardous a ir pollutants per Condition no. 7 . ADDITIONAL REQUIREMENTS 24 . A revised A ir 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 no n-criteria re portable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above t he level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facil ity , process, or activity; o r AIRS ID: 045/1046/015 Page 9 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division c. Whenever new control equipment is installed , or whenever a different type of control equipment replaces an ex1sting type of control equipment; or d Whenever a permit limitation must be modified· or e. No later than 30 days before the existing APEN expir es. 25 Th1s 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 within one year of commencement of operation of the equipment or modification covered by this permit. 26 Prevention of Significant Deterioration (PSD) requirements shall apply to this source at any such time that this sou rce becomes major so lely 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: 27 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 . 28 If this permit specifically states that final authorization has been granted, then the remainder of th1s cond ition is not applicable. Othe rwise , the 1ssuance 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 m accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final auth orization ca nnot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentati on of such fin al authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 29. This permit is issued in reliance upon the accuracy and com p leteness 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. 30 . Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by th e APCD to be necessary to assure compliance with t he provisions of Se ction 25-7 -114.5(7)(a) C .R.S 31 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 enti re permit and upon such occurren ce , this permit shall be deemed den ied ab initio. T his permit may be revoked at any time prio r to self -certification and final authorization by the Air Pollut io n Control Division (APC D) on grounds set forth in th e Colorad o Air Q uality Co ntrol A ct and regulations of t he A ir Quality C ontrol Commission (AQCC), including failure to m eet any A IRS ID: 045/1046/015 Page 10 of 13 EnCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 32 . Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 33. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122 .1 (criminal penalties), C.R.S. By: sfep~'anle Chaousy, P .E. 1 \ Permit Engineer l..J p 't H " t erm1 IS Ory Issua n ce Date Descriptio n Issuance 1 This Issuance Addition of 75 MMSCFD TEG dehydrator at a Major Facility for NOx, VOC and HAPs. Synthetic minor facility for CO. AIRS ID: 045/1046/015 Page 11 of 13 E nCana Oil & Gas (USA), Inc. Permit No. 1 OGA 1308 Issuance 1 Notes to Perm it Holder: Colorado Department of Public Health and Environment Air Pollution Control Division 1) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application . These limits may be revised upon request of the permittee provid ing there is no exceedance of any specific emission control regulat ion or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be subm itted with a request for a perm it revision . 2) This source is subject to the Common Provisions Regulation Part II , Subpart E, Affirmative Defense Provision for Excess Emissions Dunng Malfuncti ons. The permittee shall notify the Div ision of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation . See: http://www. cdphe .state. co. us/requlations/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 Divis ion's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontro lled Emission A re the Contro lled A IRS Rat e emiss ions Emission Point Polluta nt CA S# BIN (lb/yr) r~ortabl e? Rate (lb/yr ) Benzene 71432 A 42164 Yes 2108 Toluene 108883 c 113267 Yes 5663 015 Ethyl benzene 10041 4 c 5591 Yes 280 Xylene 1330207 c 78168 Yes 3908 Hexane 110543 c 4917 Yes 246 4) The emission levels contained in this permit are based on information provided in the application and t he GRI GlyCa lc 4 .0 model. 5) The following equipment is currently exempt from construction permitting requ irements and/or APEN reporting requirements based on information provided by the operator for the Division 's analysis: AIRS ID Facility ID Description Notes I NA DU03 Dehy unit reboile r, rated This unit is exempt from APEN reporting Re boiler at 1.0 MMBt u/hr requ irements becau se the design rate is Burner less t han 5 M M Btu/hr (Regulation No. 3, Part A , II .D.1.k), a nd is therefore al so exempt from construc tion permitting requ irements (Reg u lation no . 3, Part B, II.D .1.a). 1 Criteria poll utan t emission levels for this unit are based on fa ctors from AP-42 , Chapter 1.4, Small Boilers < 100 MM Btu/h r (7/1 998). 6) In accordance with C.R.S. 25-7-11 4 .1 , t he A ir Pollutant Emissio n Notice (APE N) a ssociated with t his perm it is v alid f or a term of five years. The five-year term for this APE N expi res on March 23, 2015. A revised APEN shall be submitted no later than 30 days before the five-year term expires. AIRS ID : 045/1046/015 Page 12 of 13 EnCana Oil & Gas (USA), Inc. Permit N o. 1 OGA 1308 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division 7) This facility is classified as follows: Applicable Statu s Requirement Operating Perm it Major Source : NOx, HAPs Synthet ic Minor Source : CO , VOC PSD Synthetic Minor Source : VOC MACT HH Area Source Requirements: Applicable 8) Fu ll text of the Title 40, Protection of Environment Electron ic Code of Federal Regulations can be found at the w e bsite listed below: http://ecfrgpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NS PS 60.1-End Subpart A-Subpart KKKK NSPS Part 60, Appendixes Appendix A-Append ix I Part 63: National Emissio n Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63 .599 Subpart A-Subpart Z MACT 63.600-63.1199 ' Subpart AA-Subpart DOD MACT 63.1200-63.1439 Subpart EEE-Subpart PPP MACT 63.1440-63.6175 Subpa rt QQQ-Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ -Subpart MMMMM MACT 63.8980-End Subpart NNN NN -Subpart XXXXXX 9) An O il and Gas Industry Construction Permit Self-Certification Form is included with th is permit packet. Please use this form to complete the self-certification requirements as spec ified in the permit conditions. Further guidance on self-certification can be found on our website at: http://www.cdphe .state.co.us/ap/o ilgaspermitting.html AIRS 10:045/1046/015 Page 13 o f 13 Co lorado Department of Public Health and Environment Air Po ll ution Control Divi sion OI L AND GAS IN D USTRY CONSTRUCT ION P E RM IT SEL F-C E RT IFICAT ION FORM PERMIT NO : 1 OGA 1308 AIRS 10 : 045/1046 Issuance 1 ISSUED TO: EnCana O il & Gas (USA), Inc. IMPORTANT NOTICE TO PERMIT HOLDER: The following Self-Certification document must be completed and submitted within 180 days of starting any and all equipment described in the above permit. PURSUANT TO C.R.S.§25-7-114.5, FAILURE TO SUBMIT A COMPLETE SELF-CERTIFICATION FOR EACH UNIT WITHIN 180 DAYS OF START-UP MAY RESULT IN FORMAL ENFORCEMENT ACTION AUTHORIZED BY C.R.S. §25-7-115, UP TO AND INCLUDING PERMIT REVOCATION . This document must be completed and signed by a respons ible official as defined under Colorado A ir Quality Control Commission Regu lation No. 3 , Pa rt A , §1.8 .38. To complete this form, initial on the appropriate lines below. All supporting documentation must be submitted with this form. A Construction Permit Final Authorization to Operate will be issued only if all perm it condit ions are being met. Please save a copy of this com pleted form for your records. 1. Start-up The following equipment as described in permit number 10GA1308 has been installed and started: All equipment described in this permit has been installed and started. Notice of Start-up(s) have been filed, and this self-certification document encompasses all equipment listed on the permit. 2. Opacity I certify this equipment is generating no visible emissions in excess of permit limits. (Formal Visibl e Emissions reading NOT required). 3. Emissions and Process Limits A IRS 10 : 0 45/1046/015 Perm it Number: 1 OGA 1308 Issuance 1 Page 1 of 3 Colorado Department of Public Health and Environment Air Pollution Control Division I certify that this source is i n compliance with the permit's process limits for natural gas throughput. I certify that this source is in compliance with the permit's process limits for maximum lean glycol recirculation pump rate. 4. Operations and Maintenance Plan I certify that upon start-up, this source began following the O&M plan submitted with the permit application, and continues to do so. I certify that to calculate emissions, this source is using the emission factors or methodology described in the permit. I certify that this source is in compliance with the permit's short-term emissions limits. 5. Compliance Testing and Sampling I certify that the required compliance testing for the equipment described in Section 1 above has been completed, and the results: 0 were submitted to the Division on ______ (DATE). 0 will be submitted to the Division on or before ______ (DATE). 6. NSPS & MACT I certify this source is in compliance wit h the applicable requirements of: NSPS NESHAP/MACT Not a pp ·cable 40 CFR 63 Subpa rt HH 7. Other Require ments I certify that the make and serial #were submitted with the Notice of Start-up. A I RS 10 : 045/1 046/01 5 Permit Number: 1 OGA 1308 Issuance 1 Page 2 of 3 Colorado Department of Public Health and Environment Air Pollution Control Division I certify that the each piece of equipment has been marked with the permit number and AIRS 10. Results of the GRI GlyCalc model run using the most recent wet gas analysis and recorded operational values (including gas throughput, lean glycol recirculation rate and inlet gas temperature) have been submitted to the Division as part of the self-certification process. I certify that this dehydrator is in compliance with the emission standards of Colorado Regulation No. 7, XVII I.D. The responsible official whose signature appears below further certifies to the following: I have reviewed the above paragraphs, the terms and conditions of the Construction Permit referenced above, and the information being submitted for final approval of this permi t in its entirety. Based on information and belief formed after reasonable inquiry, I certify that the source is in full compliance with each permit condi tion of this constructi on permit, and the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S ., makes any false material statement, representation, or certifi cation in this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Signature AIRS ID : 045/1046/015 Permit Number: 1 OGA 1308 Issua nce 1 Title Date Signed Page 3 of 3 STATE OF COLORADO C OLORADO DEPARTMENT OF PUBLIC HEALT H AND ENV I RONMENT AIR POLLUTION CONTROL DIV IS ION TELEPHONE: (303) 692-3 150 CONSTRUCTION PERMIT PERMIT NO: 08GA0887 Issuance 1 DATE ISSUED: FEBRUARY 3,. 2009 ISSUED TO: EnCana Oil & Gas (USA) Inc. THE SOURC E TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas gathering facility , known as the High Mesa Compressor Station , located at Section 36 , Range 96 West, Township 7 South, in Garfield County, Colo rado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING : I Facility AIRS I .. Equipment P . t Descnpt1on 10 om FUG-2 006 Equipment leaks (fugitive VOCs) from a natural gas compression facili ty. 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 -1 01 et seq ), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than thirty days after commencement of the permitted operation or activity by submitting a Notice of Startup (NOS) form to the APCD. The Notice of Startup (NOS) form may be downloaded online at www.cdphe.state .co .us/ap/downloadforms html. Failure to notify the APCD of startup of the permitted source is a violation of Section 25-7-114 .5(12)(a), C .R.S. and AQCC Regulation No . 3 , Part B , Section III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions. Failure to demonst rate compliance within 180 days may resul t in revocation of the permit. (Reference: Regulation No. 3 , Part B , II .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 A IRS 10: 045/1046/006 Page 1 of 6 Fugiti ve Version 2008-1 EnCana Oil & Gas (USA) Inc. Permit No. 08GA0887 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division 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 8 , III.F.4.b. (Reference: Regulation No. 3, Part B , III .F.4.) 4 . The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Reference: Regulation No. 3 , Part 8 , Section III.E.) 5 . The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6 . Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference : Regulation No. 3, Part B, Section II .A.4) Annual lim its : Facility AIRS To ns p e r Yea r Emissi on Ty p e Equi pme nt 10 Point NOx voc co FUG-2 006 12.0 Fugitive See "Notes to Permit Holder #4" for mformat1on on em1ss1on factors and methods used to calculate limits. 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. 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. 7. Compliance with the emission limits in this permit shall be demonstrated using the most recent gas analysis. PROCESS LIMITATIONS AND RECORDS 8. There are no requirements under this heading. STATE OR FEDERAL REGULATORY REQUIREMENTS 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup , process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1 . & 4 .) 10. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 11 . There are no requirements under this heading. AIRS ID: 045/1046/006 Page 2 of 6 EnCana O il & Gas (USA) Inc. Permit No. 08GA0887 Issuance 1 Colorado Department of Public Health and Environment Air Pollution Control Division COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 12. The permittee shall complete extended gas analysis of gas samples that are representative of gas that may be released as fugitive emissions. 13. Within one hundred and eighty days (180) after commencement of operation , the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy l iquid service", "light liquid service" and "gas service". Periodic Testing Requirements 14. The permittee shall complete extended gas analysis on an annual basis of gas samples that are representative of gas that may be released as fugitive emissions. Results of the extended gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per Condition no. 6 . ADDITIONAL REQUIREMENTS 15. 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 facil ity , process, or activity; or c. Whenever new control equipment is installed , or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified ; or e. No later than 30 days before the existing APEN expires. 16. This source is s ubject to the provisions of Regulation Number 3 , Part C , Operating Permits (Title V of the 1990 Federal Clean A ir 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. GENERAL TERMS AND CONDITIONS: 17 . This per mit and any attachments must be retained and made av ailable for inspection upon request at the loc ation set forth herein. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3 , Part 8 , Section 11 .8 upon a request for transfer of ownership and the submittal of a revised A PEN and the required fee. A IRS ID: 045/1046/006 Page 3 of 6 EnCana Oil & Gas (USA) Inc. Permit No. 08GA0887 Issuance 1 Colorado Department of Public Health and Environment A ir Pollution Control Division 18. Issuance of a construction permit does not prov ide "final" authority for this activ ity 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 8 , Section II I.G . Final auth orization cannot be granted until the operation or activity commences and has been verified by the APCD as conformi ng in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization . Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 19. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity, or construction , installation and operation of the source, in accordance with this i nformation 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. 20. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5 (7)(a ), C .R.S. 21 . Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio . This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control D ivision (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. 22 . Section 25-7-114.7(2)(a), C .R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 23. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties}, C .R.S. By: Carissa Money, P .E. Permit Engineer P 't H ' t erm1 IS ory Issuance Date 16r-14 () Issuance 1 This Issuance AIRS ID: 045/1046/006 Description Issued to EnCana Oil & Gas (USA) Inc. Page 4 of 6 EnCana Oil & Gas (USA) Inc. Permit N o. 08GA0887 Issuance 1 Colorado Department of P ublic Health and E nvironment Air Pollution Control D ivision Notes to Permit Holder: 1} The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application . These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN } and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emiss ions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division add ressing all of the c riteria set forth in Part II.E.1 . of the Common Provisions Regulation . See: http://www. cd phe.s tate. co . us/requlations/airregs/1 001 02agcccom man provisionsreg . pdf. 3} The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emissi on Are the Controlled AIRS Rate emissio ns Emission Point Pollutant CAS# BIN (IbM re~ortable ? Rate (lb/yr) Benzene 71 432 A 85 YES N/A Toluene 108883 c 127 NO N/A 006 Ethyl benzene 1004 14 c 2 NO N/A Xylene 1330207 c 40 NO N/A Hexane 110543 c 531 NO N/A 4 } T he emission levels contained in this permit are based on the following emission factors : Component Count: Compo nent Gas Service Water/Oil Light Oil Heavy Oil Service Valves 500 35 255 0 Connectors 1240 85 640 0 Flanges 170 15 90 0 Seals 0 0 9 0 Open-ended Lines 150 15 80 0 Other* 50 0 0 0 VOC Content (wt%) 6.7% 0% 100% 0% *Other equipment type includes compressors , pressure relief valves, relief va lves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component}: Component Gas Service Water/Oil Service Light Oil Heavy Oil Valves 4 .5E-03 9.8E-05 2.5E-03 8.4E-06 Connectors 2.0E-04 1.1 E-04 2.1E-04 7.5E-06 AIRS 10: 045/1046/006 Page 5 of6 EnCana O il & Gas (USA) Inc. Colorado Department of Public Health and E nvironment Permit No. 08GA0887 Air Pollution Control Division Issuance 1 Flanges 3.9E-04 2.9E-06 1.1 E-04 3.9E-07 Seals 2.4E-03 2.4E-05 1.3E-02 NA Open-ended Lines 2 .0E-03 2 .5E-04 1.4E-03 1.4E-04 Other 8 .8E-03 1.4E-02 7.5E-03 3.2E-05 Source: EPA-453/R95-01 7 Compliance with emissions limits will be demo nstrated by using the TOC emission factors (listed in the table above) multiplied by the VOC content from the most recent gas analysis. 5) In accordance with C.R.S. 25-7-11 4 .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 September 11 , 2011 . A revised APEN shall be submitted no later than 30 days before the five-year term expires. 6) This facility is classif ied as fo llows: Applicable Requirement Status Operating Permit Synthetic Minor VOC Major Source: NOx, CO, HAPs PSD True Minor: NOx, CO, VOC MACT HH Synthetic Minor: Toluene , Total HAP MACT ZZZZ Major Source : Formaldehyde, Toluene, Total HAP 7) Full text of the Title 40 , Protection of Environment Electron ic Code of Federal Regu lations 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, Appendi xes Appendix A-Appendix I Part 63 : National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A-Subpart Z MACT 63.600-63.1199 Subpart AA-Subpart DOD MACT 63.1200-63.1439 Subpart EEE -Subpart PPP MACT 63.1440-63.6175 Subpart QQQ-Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ-Subpart MMMMM MACT 63.8980-End Subpart NNNNN -Subpart XXXXXX 8) An Oil and Gas Industry Construction Permit Self-Certification Form is included w ith this permit packet. Please use this fo rm to complete the self-certificatron requ irements as specif ied in the permit conditions. Further guidance on self-certification can be found on our website at: http . 'www cdphe.state.co.us.ap/or gasperm1tting.htrr .. A IRS ID: 045/1046/006 Page 6 of6 STATE OF COLORI\00 Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improv ing the health and environment of th e people of Colorado 4300 Cherry Creek Dr. S. Laboratory Services Division Denver, Colora do 80246-1530 8100 Lowry Blvd . Phone (303) 692-2000 Denver, Colorado 80230-6928 TOO Line (303) 691-7700 (303) 692-3090 Located in Glendale, Colorado http://www.cdphe.state.co.us MAf< L 4 2010 Cindy A!!en Encana. USA, Inc. 370 17th Street Suite 1700 Denver, CO 80202 Ms. Allen: OIL AND GAS CONSTRUCTION PERMIT FINAL AUTHORIZATION TO OPERATE Colorado Department of Public Health and Environment The Air Pollution Control Division has re viewed and approved the information supplied with the self- certification for the pennit li sted below. Accordingly, you are now issued this final authorization to operate under the tenns and conditions of the pennit. This Final Authorization to Operate letter is valid upon issuance and a copy must be maintained with the associated permit. This letter must be made availabl e to the Division for inspection upon request. Company Name: Encana USA, Inc. Source Name: H ig h Mesa Co m presso r Station Source Location: Section 36, T7S, R96W, in Garfield County AIRS ID: 045/1046/006 Permit Number: 080/\0887 Issuance Number: I I I Authorization Letter Issue Date: If you have any questions about this authorization le tter, please contact the Division at 303 -692-3189. Sincerely, Doug Ryde Final Approva Coordinator Air Pollution Contr ol Division Page I of I STATE O F COLOAADO COLORADO D EPARTMENT OF PUBLI C H EALTH AN D ENVIRONMENT A IR POLLUTION CONTROL DIVISION TELEP HONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO : DATE ISSUED: 06GA0851 MAY 1 8 2010 Issuance 2 ISSUED TO: EnCana O il & Gas (USA) Inc. THE SOURCE TO WH ICH TH IS PERMIT APPLIES IS DESCRIBED A ND LOCATED AS FOLL OW S: Natural gas gathering facility , known as the High Mesa Compressor Station , located at Section 36 , Range 96 West, T ownsh ip 7 South , in Garfield County , Colorado . THE SP ECIF IC EQUIPME NT OR ACTIVITY SUBJECT TO THIS PERM IT INCLUDES THE FOLLOWI NG: Fa c ility AIRS Equi p m e nt Point Des cription I D CT-01 00 5 Two (2) 300 BBL fixed roof storag e ta nks used to store conden sate. T HIS PERMIT IS GRANTED SUBJ ECT TO A L L RU L ES AND REGU L AT IO NS OF T HE COLO RADO AIR Q UALITY CON T RO L CO MMISSION A ND TH E COLORADO AIR PO L LU TION PREVENTIO N AND CO NTROL A CT C.R.S. (25 -7-10 1 etseg), TO THOSE GENERAL TERM S A ND CO NDIT IO NS INCLUD ED IN THIS DOCUMENT AN D T HE FO L LOWIN G SPECIFIC TERM S A ND CO NDI TIO NS: REQU IREMENT S TO SELF-CERTI FY FOR FINAL A UTHORIZATION 1. This construction perm it represents fin al permit approva l and authority to operate this emissions source (Regu lation 3, Pa rt 8 , Section III.G.5). 2. The permit number sha ll be marked on the subject equipment for ease of identification . (Reference: Regulation Number 3, Part B, Ill. E.) (State only enforceab le) EMISSION LIMITATIONS AND RECORDS 3. 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) A n nual Limits: Facility AIRS T on s per Year Equ ipm ent ID Point NOx voc co Emission Ty p e CT-01 005 4 .8 Point " See Notes to Permil Holder #4" for mfo rmatton on em1ss1on factors and methods used to calculate limits. AIRS ID : 045/1046/005 Page 1 of 6 Condensate Ta nk Ve rsion 2008-1 EnCana Oil & Gas (USA) Inc. Perm it No. 06GA0851 Issuance 2 Colorado Department of Public Health and Environment Air Pollution Contro l Division Compliance with the annual limits shall be determined on a rolling (12) month total. By the end of each month a new twe lve month total is ca lculated 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 fie ld office with site responsibility for Division review. PROCESS LIMITATIONS AND RECORDS 4. This source shall be limited to the following maximum consumption , processing and/or operationa l rates as listed below. Monthly records of the actua l consumption rate shall be maintained by the applicant and made available to the D ivision for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility AIRS Process Parameter Annual Limit Equipment ID Point CT-01 005 Condensate processed 913 bbl Compliance with the yearly consumption limits sha ll be determined on a ro lli ng 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 perm it holder shall calculate month ly consumption of natural gas and keep a comp li ance record on site or at a local field office with site responsibility, for Division review. STATE O R F E DER AL REGULATORY REQUIREM E NTS 5. Visib le 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 consecutive minutes. (Reference: Regulation No. 1, Section II.A.1. & 4.) 6. This source is subject to the odor requirements of Regulation No .2. (State only enforceable) O P ERATING & MAINTENANCE REQUIREMENTS 7. There are no requirements under this heading. COM PLIANCE TESTING AND SAMPLING 8. The operator shall complete site specific sampling including a compositional analysis of the pre-flash pressurized condensate routed to these storage tanks and a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05-01. Resu lts of testing shall be used to determine a site-specific emissions factor using Division approved methods. Results of site-specific samp ling and ana lysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. ADDIT I ONAL R E Q UIREMENTS 9. A revised Air Pollutant Em ission Notice (APEN) shall be f iled: (Reference: Regulation No.3, Part A, II. C) a. Annuall y whenever a significant increase in emissions occurs as follows: AIRS ID: 045/1046/005 Page 2 of 6 EnCana Oil & Gas (USA) Inc. Permit No. 06GA0851 Issuance 2 Colorado Department of Publ ic Health and Environment Air Pollution Control Division For any crite ria p ollutant: 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 a ny no n-c riteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division . b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed , or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified ; or e. No later than 30 days before the existi ng APEN expires. 10 . This source is subject to the provisions of Regulation Number 3 , Part C , Operating Permits (Title Vofthe 1990 Federa l Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The app lication for the modification to the Operating Permit is due with in one ye ar of commencement of operation of the equipment or modification covered by this permit. GENERAL TERMS AND CONDITI ONS 11 . This permit and any attachments must be retained and made available for inspection upon request at the location set forth herein . The permit may be reissued to a new owner by the APCD as provided in 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. 12 . Issuance of a construction permit does not provide "fina l" 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 8 , Section III.G . Final authorization cannot be granted until the operation or activity commences and has been verified by t he APCD as co n forming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division , it will provide written documentation of such final authorization . D etails f or obtaining final authorization to operate are located in the R equi r em ents to Self-Certify for Final Authorization section of this permit. 13 . This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of tlhe 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. 14 . Unless specifically stated otherwise, t he genera l and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provis ions of Section 25-7-114.5(7)(a), C .R.S . 15 . Each and every condition of this permit is a m aterial part hereof and is not severable. Any challenge to or appeal of a condition h e reof sh a ll constitute a rejection of the entire permit and upon such occurrence, this permit s h a ll be deemed denied ab initio. This perm it may be revoked at any time prior to self-certifi cation and final authorization by the Air Pollution AIRS ID: 045/1046/005 Page 3 of 6 EnCana Oil & Gas (USA) Inc. Permit No. 06GA0851 Issuance 2 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 16 . Section 25-7-114.7(2)(a), C .R.S . requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration . If a source or activity is to be discontinued , the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 17 . Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C .R.S. By: hanie Chaousy , P.E. Permit Engineer Air Pollution Control Division . H" Permtt tstory Issuance Date Description Issuance 1 February 26, Issued to Encana Oil & Gas (USA) Inc. 2009 Issuance 2 This Issuance Rev ised equ ipment description . AIRS ID: 045/1046/005 Page 4 of 6 EnCana Oil & Gas (USA) Inc. Perm it No. 06GA0851 Issuance 2 Colorado Department of Publ ic Health and Environment Air Pollution Control Division Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific em ission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be subm itted with a request for a permit revis ion . 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any ma lfunction condition which causes a violation of any emission lim it or limits stated in this perm it as soon as poss ib le, but no later than noon of the next working day, followed by written notice to the Division addressing al l of the criteria set forth in Part II. E.1 of the Common Provisions Regulation . See: http://www. cdphe. state. co . us/regulations/a irregs/1 001 02aqcccommonprovisionsreg . pdf. 3) The following em issions of non-criteria reportab le air pol lutants are estimated based upon the process limits as indicated in this permit Th is information is listed to inform the operator of the Division's ana lysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Uncontrolled Emission A re the Contro lled A IRS Rate em issions Emission Point Pollutant CAS# BIN (lb/yr) reportab le? Rate (lb/yr) Benzene 71432 A 55 YES NA 005 Toluene 108883 c 61 NO NA 4) The emission levels conta ined in this perm it are based on the following emission factors: Points 005: Emission Factors Emission Factors CA S# Pollutant Uncontrolled Controlled Source l b/BBL Condensate lb/BBL Condensate Throughput Th roughpu t voc 10.5 10.5 Source 71432 Benzene 0.059 0.059 Source 108883 Toluene 0.067 0.067 Source 5) In accordance with C.R.S. 25 -7-114.1 , the Air Po llutant Em ission Notice (APEN) associated with this permit is va lid for a term of five years . The f ive-year term for this APEN expires on Sept ember 11 , 2011. A rev ised APEN shall be submitted no later than 30 days before the five-year term expires . 6) This facility is classified as fo llows: Applicable Status Requi rement Operating Permit Synthetic Minor Source: voc Major: NOx, CO , HAPs PSD True Minor Source NOx, CO, VOC MACT HH Synthetic Minor Source : Toluene , Total HAPs AIRS ID: 045/1046/005 Page 5 of 6 EnCana Oil & Gas (USA) Inc. Permit No. 06GA0851 Issuance 2 Colorado Department of Public Health and Environment Air Po ll ution Control Division I MACT zzzz I Maj o r Source 7) Ful l text of the Title 40 , Protection of Enviro n ment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.g poaccess .gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A-Subpart KKKK NSPS Part 60, Appendixes Append ix 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 M-Subpart DOD 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 8) An Oil and Gas Industry Construction Permit Se lf-Certification Form is included with this permit packet. Please use this form to comp lete the self-certification requ irements as specified in the permit conditions. Further guidance on self-certification can be foun d on our website at: http://www.cdphe.state.co.us/ap/oilgaspermitting.html AIRS ID: 045/1046/005 Page 6 of 6