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Home My WebLink About20130295.tiffMemorandum TO: Tom Parko, Director — Weld County Department of Planning Services FROM: Troy Swain, EH Program Coordinator — Weld County Department of Health & Environment DATE: July 23, 2013 SUBJECT: E-Waste/Recyclables Recovery: USR- 895, Waste Management Company's North Weld Landfill /44 The Department received the attached letter from Waste Management Company after requesting detail regarding any plans they have developed in response to recent state legislation for diverting electronic wastes (e -waste). Historically, the landfill has added services to accept and divert other material subject to disposal bans and also provides on -site recyclables collection. The second paragraph of this letter contains Waste Management's plans for the acceptance of banned electronic waste (e -waste) from users of the landfill. The ban was effective July 1, 2013 as a result of the Electronics Recycling Jobs Act (SB12-133). The third paragraph includes possible future plans to recover recyclable material from the working face. The company is currently piloting this operation at their Denver Arapahoe Disposal facility in the Southeast Denver area. The Weld County Department of Public Health and Environemnt has reviewed these minor operational changes and recommends the following actions regarding this letter: forward as a communication to the governing body having jurisdiction (Weld County Commissioners), adding to this waste facility's operating record, and recording into the Weld County Clerk to the Board document recording system (Tyler). If you have any questions, please contact me at your convenience. CC: Trevor Jiricek, Director — Environmental Health Services Czywn,[,(,vt.tac Cilit\c3 dt13,Oa% 7L0-111 June 12, 2013 Mr. Troy Swain Weld County Department of Public Health and Environment 1555 North 17th Street Greeley, CO 80631 SUBJECT: North Weld Landfill (NWLF) Enhanced Recycling Services and Resource Recovery Dear Mr. Swain: NORTH WELD LANDFILL A WASTE NANACpNNr COMPAAY 40,000 Weld County Road 25 Ault, Colorado 80610-9748 (970) 686-2800 (970) 686-1031 Fax The North Weld Landfill received USR-895 and the associated Certificate of Designation on June 27, 1990. In addition to providing environmentally -sound disposal, our commitment to meet the recycling needs of our community was demonstrated in our original application. Based on our original proposal, development standard #17 provides for recycling receptacles at the landfill gate as an alternative to disposal of certain consumer recyclables. This commitment was further exemplified though our leadership position on The North Front Range Solid Waste Action Plan. One of the premier accomplishments of this was the pilot project that started consumer curbside recycling in Greeley in the early 1990s, and has since spread to most Northern Colorado communities. For this, we received the Governor's Award for Outstanding Efforts in Smart Growth and Development, dated July 19, 1997. We are committed to meeting the changing needs of our community in recycling and resource recovery from the commencement of our operations and into the future. We expanded our consumer recycling drop-off area to include corrugated cardboard (OCC) and converted our consumer recyclables to 'single stream' for better efficiency and consumer ease. Additional consumer recycling commodities have also been added, as markets and consumer needs have changed over the years. We also provide opportunities for our customers to recycle white goods (including our environmentally -sound program of refrigerant gas recovery) and other separated scrap metal. With the changing regulations associated with consumer electronics (often referred to as e -Waste or e - Scrap), prohibiting their disposal after June 30, 2013, we are developing the procedures and location at NWLF to properly accept e -Waste and ensure it is properly transported and recycled in an environmentally sound and compliant manner. We anticipate providing the accumulation area on the west side of the property, within the fenced buffer area north of our scale house. All e -Waste accepted will be maintained orderly, primarily in Gaylord Containers within enclosed metal storage containers, and in compliance with regulations for handling this material. Managing the material through Waste Management Recyde America assures that all material is properly processed through ISO 9001. and 14001 Certified eCyding Plants in the U.S. Other units may be returned to manufacturers, according to their specification for 'take -back' programs (currently including Bose, Zenith, LG, and Goldstar Brands). All material will be handled, transported and processed consistent with Waste Management's high commitment to our communities and the environment. In addition, North Weld Landfill is evaluating the feasibility of mechanical recovery of certain recyclable material contained in the waste stream accepted from our communities and customers. Initially, we are considering a pilot project to recover dean OCC and metal from the landfill working face (disposal area). We anticipate patterning this process from other successful projects at Waste Management facilities across North America, induding our Southeast Denver Metro landfill, Denver Arapahoe Disposal Site (DADS). This will likely be accomplished by an additional operator on an excavator with magnetic and/or mechanical recovery capabilities. Recovered resources will be segregated and processed through established Waste Management facilities, or through contractual commitments with other local businesses that meet our high environmental standards. We believe these activities are consistent and compatible with the existing approvals and operations at the North Weld Landfill. Pursuant to the wording of Development Standard #34, we do not believe this constitutes a "major change from the plans or Development Standards". Accordingly, we anticipate filing this in the office of the Department of Planning Services in compliance with this Development Standard. Respectfully submitted; Bill Hedberg Sr. District Manager, NWLF/ BRLF Tammy Waters From: Troy Swain Sent: Friday, September 06, 2013 12:02 PM To: Tammy Waters Cc: Bill Hedberg; Tom Parko Jr.; Trevor Jiricek Subject: FW: RE: Health memo regarding minor operational changes at North Weld Landfill. Attachments: Health Memo RE NWLF ewaste and recycling recovery 20130612 WMX letter .pdf Tammy, as discussed, please add the attached memo and letter as a communication item for the BOCC and record into Tyler after the agenda date. Thanks, Troy E. Swain EH Program Coordinator. Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. From: Troy Swain Sent: Thursday, September 05, 2013 9:21 AM To: Tom Parko Jr. Cc: Trevor Jiricek; Bill Hedberg Subject: RE: Health memo regarding minor operational changes at North Weld Landfill. RE: Health memo regarding minor operational changes at North Weld Landfill. I spoke with Bill Hedberg of Waste Management today. They are planning on moving equipment to implement these operations and asked if the County had any problem with the addition of the e -waste and working face recycling operations at the North Weld Landfill (see attached June 12, 2013 memo). If you are ok with it I can send it over to the Clerk to the Board to get it added to the consent agenda as a communication item. Let me know. Thanks, Troy E. Swain EH Program Coordinator Weld County Dept. of Public Health & Environment 1555 N. 17th Avenue Greeley, CO 80631 (970) 304-6415, ext. 2219 (970) 673-2218 (cell) (970) 304-6411 (fax) Confidentiality Notice: This electronic transmission and any attached documents or other writings are intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. If you have received this communication in error, please immediately notify sender by return e-mail and destroy the communication. Any disclosure, copying, distribution or the taking of any action concerning the contents of this communication or any attachments by anyone other than the named recipient is strictly prohibited. 2 WASTE MANAGEMENT April 11, 2013 Mr. Jerry Henderson Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division HMWMD-SWIM-B2 4300 Cherry Creek Drive South Denver, CO 80246-1530 Mr. Troy Swain Weld County Department of Public Health and Environment 1555 N. 17th Avenue Greeley, CO 80631 2400 West Union Avenue Englewood, CO 80110 303-914-1445 (Phone) 866-442-0285 (Fax) RECEIVED APP 12 ?013 Weld County Planning Department GREELEY OFFICE SUBJECT: NORTH WELD LANDFILL FIRST QUARTER 2013 LANDFILL GAS (Methane) MONITORING REPORT Dear Mr. Henderson and Mr. Swain: Enclosed for your information is the First Quarter 2013 Gas Monitoring Report for North Weld Landfill (NWLF). AquAeTer performed the monitoring of the subsurface and facility structures for methane migration in accordance with 6 CCR 1007-2 on March 20, 2013. The report contains monitoring results from the Phase 1 and 2 perimeter soil gas probes GP -06, GP -07, GP -10 through GP -20, structure probes GP -01 and GP -02, inside the shop and office, and confined spaces in the vicinity of the western boundary of the site. A map showing the gas probe locations, the scale house and maintenance shop is included as Figure 1. Section 2.3.1 of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part 1 (Regulations) requires that the percent of methane (explosive gas) in air (v/v) shall not exceed (A) 25% of the lower explosive limit (LEL) (i.e., 1.25% methane v/v) within facility structures, and (B) the LEL (i.e., greater than 5% methane v/v) at the facility boundary. During this monitoring event, methane was detected in structure probe GP -01 at 40.3% v/v and perimeter probe GP -10 at 41.8% v/v. In addition, although below regulatory levels, methane was detected in GP -06 at 4.9% v/v and GP -16 at 0.5% v/v. Methane was not detected in any of the other probes, shop, office or confined spaces during this monitoring event. The facility currently operates under an approved gas remediation plan prepared in response to previous elevated methane concentrations in structure probe GP -01 and perimeter probes GP -10 and GP -11. The plan includes monthly monitoring of these probes and utility corridor access points along WCR 25. Beginning in February 2012, the facility also began monthly monitoring of GP -06. Included in Attachment 1 are the January and February 2013 monthly reports. A summary of the monitoring results for these monthly events is provided in the following table. Percent (%) CH4 v/v Monitoring Probe January 2013 February 2013 GP -01 34.5 32.8 GP -06 8.9 1.7 GP -10 10.7 5.0 GP -11 0.0 0.0 913_ D2g5 1.�1�VlYVI+AYt�t CQ�'16V1S � 2-�'-t`'J Letter Jerry Henderson and Troy Swain April 11, 2013 Page 2 Methane was not detected in the utility corridor access points or facility structures during the monthly monitoring. You will note that the special monitoring documentation report for January shows a methane concentration of 0.6% v/v at Sample Point 19 and, for February, a detection of 0.6% v/v at Sample Point 18. The reports show these sample points to be associated with the new scalehouse that was built in 2010. The scalehouse foundation was constructed over a permeable granular base containing perforated pipe that connect to two vertical vent pipes extending along the exterior of the building. The purpose for this design was to allow for passive venting capability beneath the foundation, thereby preventing gas from migrating into the building. Sample Points 18 and 19 are sample ports installed in the two vertical vent pipes. Sample point 17 in the report is the sample location within the gatehouse structure, which shows no methane was detected. The approved remediation plan also included the installation and operation of passive gas vents constructed within waste along the western limit of the disposal area. As stated in the plan, the passive vents, which were installed in December 2009, may require one or more years to show consistent reduction in methane levels at perimeter probes GP -10 and GP -11 and structure probe GP -01. Until methane levels are below the regulatory threshold for three consecutive monthly events, monthly monitoring will continue to be performed. As previously indicated, GP -06 was added to the monthly monitoring program commencing in February 2012. Continuous methane monitors are in operation within the facility maintenance building, office and gatehouse and no methane detections have been observed. We have been evaluating options to augment the performance of the existing in waste passive gas vents in order to increase their radius of influence in the southwest corner of the disposal area. Most recently, we replaced the wind turbines affixed to the top of the passive vents with solar flares; with two being replaced in August 2012 and the remaining five in January 2013. The purpose of the flares was to increase negative pressure at the gas vents, to establish a more consistent inward gradient for landfill gas and better control its movement away from the waste mass. Additionally, we have retained SCS Engineers to evaluate connecting the passive vents to a header pipe equipped with a small blower and venting the collected gas through a carbon canister; the intent being to increase the negative pressure and radius of influence at the vents. We will meet with SCS this month at the site to confirm feasibility and begin preliminary design efforts. We will keep you apprised as the project develops. Please contact me at (303) 914-1445 should you have questions about this report. Sincerely, On behalf of North Weld Landfill Tom Schweitzer Facility Engineer cc: Kim Ogle, WCDPS, w/o enc. Bill Hedberg, NWLF WASTE MAGMAGEME UT April 8, 2013 Mr. Charles Johnson Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 2400 West Union Avenue Englewood, CO 80110 303-914-1445 (Phone) 866-442-0285 (Fax) ECEIVE APR 12?an Weld County Planning Department GREELEY OFFICE Subject: North Weld Landfill (NWLF) Updated Closure and Post -Closure Plan and Financial Assurance Plan Dear Mr. Johnson: Enclosed are updated closure/post-closure and financial assurance plans which have been revised to reflect current operations at NWLF and anticipated closure and post -closure activities. Section 1.8.3 (C) of the Colorado Regulations Pertaining to Solid Waste Disposal Sites and Facilities, 6CCR-1007-2, requires an annual adjustment to the closure and post -closure financial assurance cost estimate by using the implicit price deflator (IPD) for the gross domestic product. The IDP for 2013 is 1.018 as confirmed with CDPHE. The closure and post -closure cost estimates respectively contained in Appendix A and Appendix B of the enclosed financial assurance plan were adjusted using this value. The insurance certificate contained in Appendix C of the financial assurance plan reflects this adjustment to the referenced cost estimates. The insurance certificate and updated plans have been placed in the facility operating record. Please call me at (303) 914-1445 if you have questions about the enclosures. Sincerely, Tom Schweitzer, P.E. Facility Engineer Enclosures cc: Troy Swain, WCDPHE Kim Ogle, WCDPS Douglas Ikenberry, CDPHE Bill Hedberg/NWLF Operating Record Donna Meals, Waste Management, w/o enclosure C:\Users\tschweit\Docmnents\mydata\FinAssurance13\N W LF FinAssur Transmittal Ltr - 04-2013.docx CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL Weld County, Colorado Prepared by: Waste Management Disposal Services of Colorado, Inc. North Weld Landfill 40,000 Weld County Road 25 Ault, Colorado �fl REG/6„'S Reviewed By: ° —h =°s �� a. a�4 Thomas S. SchCeitzer, PL ©� o pf/To °`yam Registered of Colorado Professional En ./ ON A i State ,�N�`��o�� oas License # 24176 Revised March 2013 CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1 1.1 PURPOSE 1 1.2 FACILITY INFORMATION 1 2.0 CLOSURE PLAN 2 2.1 INTRODUCTION 2 2.1.1 Description 2 2.1.2 Regulatory Requirements 2 2.2 CLOSURE ACTIVITIES 3 2.3 MAXIMUM EXTENT OF OPERATIONS 4 2.4 FINAL COVER 4 2.4.1 Final Grades 4 2.4.2 Final Cover Description 4 2.5 CONSTRUCTION 5 2.6 CONSTRUCTION QUALITY ASSURANCE (CQA) 5 2.7 CLOSURE SCHEDULE 6 3.0 POST -CLOSURE PLAN 7 3.1 INTRODUCTION 7 3.1.1 Description 7 3.1.2 End Use 7 3.1.3 Regulatory Requirements 7 3.2 POST -CLOSURE ACTIVITIES 8 3.2.1 Facility Management 8 3.2.2 Post -Closure Activities 8 LIST OF FIGURES Figure 1 Site Location Map 2 Closure Area Map 3 Backfill Area Map 4 Post -Closure Drainage Channel 5 Closure Schedule Closure/Post Closure Plan ii March 2013 North Weld Landfill CLOSURE/POST-CLOSURE PLAN NORTH WELD LANDFILL REVISION LOG DA IL DESCRIPTION OF REVISION BY 4/97 Update Plan originally submitted to CDPHE 10/93, to reflect operational changes TS/AS 3/01 Update Plan to increase estimate of largest area of the landfill ever requiring final cover during the active life TS/AS 4/03 Update Plan to increase estimate of largest area of the landfill ever requiring final cover during the active life TS/AS 3/05 Update Plan to increase estimate of largest area of the landfill ever requiring final cover during the active life and modify text in Sections 2.4, 2.5 and 2.6 to reflect approval of an alternative final cover design TS/AS 3/06 Updated Plan to decrease estimate of largest area of the landfill requiring final cover during the active life. Miscellaneous text changes were also made to the Plan. TS/AS 3/07 Updated Plan to reflect changes to the corresponding Financial Assurance Plan dated March 2007 specifically replacing cost estimates prepared in 2002 with new cost estimates; updated Plan to adjust estimate of largest area of the landfill requiring fmal cover during the active life; update soil backfill quantities. Miscellaneous text changes were also made to the Plan. TS/AS 3/09 Updated Plan to adjust estimate of largest area of the landfill requiring final cover during the active life; update soil backfill quantities; included drawing illustrating surface water control structures that remain to be constructed and areas requiring backfill to achieve 5% slope. TS/AS 3/10 Updated Plan to adjust estimate of largest area of the landfill requiring final cover during the active life; updated soil backfill quantities to achieve 5% slope; updated post -closure acreage. TS 3/11 Updated Plan to adjust estimate of largest area of the landfill requiring final cover during the active life; updated post -closure acreage. TS 3/12 Updated Plan to reflect changes to the corresponding Financial Assurance Plan dated March 2012, specifically replacing cost estimates prepared in 2007 with new cost estimates. Miscellaneous text changes. TS 3/13 Updated Plan to adjust estimate of largest area of the landfill requiring fmal cover during the active life; updated post -closure acreage. TS Closure/Post Closure Plan North Weld Landfill March 2013 LO INTRODUCTION 1.1 PURPOSE This Closure/Post-Closure Plan (Plan) for the North Weld Landfill (NWLF) reflects the facility's present understanding of closure and post -closure care requirements for this solid waste disposal site. It has been prepared to meet the following objectives: 1. Describe the steps necessary to close the site when the cost of closure would be the greatest. 2. Describe the activities to be conducted during the post -closure care period. This Plan has been prepared in accordance with the provisions of the Colorado "Regulations Pertaining to Solid Waste Disposal Sites and Facilities", 6 CCR 1007-2 (Regulations). Sections 2.5 and 3.5 of the Regulations pertain to closure activities and Sections 2.6 and 3.6 pertain to post - closure activities. This Plan is to be used in conjunction with the Financial Assurance Plan for NWLF revised March 2013. Cost estimates are calculated in the Financial Assurance Plan for the closure and post -closure care activities described in this Plan. 1.2 FACILITY INFORMATION NWLF is located approximately six miles west of Highway 85, on Colorado Highway 14, in the southwest quarter of Section 7, Township 7 North, Range 66 West, as shown on Figure 1. The facility is owned and operated by Waste Management Disposal Services of Colorado (WMC). The site consists of 170 acres, about 122 of which are permitted for municipal solid waste disposal, and an approximate disposal capacity of 15 million bank cubic yards. Current operations are in Phase 3A, Module 2. The facility accepts non -hazardous municipal, commercial and industrial solid wastes. NWLF is being developed in four phases: 1, 2, 3A and 3B. The site will be closed and monitored as a single unit. Individual phases will not be closed or monitored separately; therefore, this plan addresses the site as a whole. However, operational factors occurring during the life of the site may necessitate closure or monitoring of portions of the site individually. Closure/Post Closure Plan North Weld Landfill 1 March 2013 2.0 CLOSURE PLAN 2.1 INTRODUCTION 2.1.1 Description This closure plan describes the steps necessary to close the facility at any point during its active life. This plan will be reviewed and updated as needed for changing conditions. 2.1.2 Regulatory Requirements This closure plan is prepared in accordance with Section 2.5, "Closure of Solid Waste Disposal Sites and Facilities" and Section 3.5, "Closure" of the Regulations. This plan will be maintained in the facility operating record. The closure requirements call for a closure plan, a description of the closure activities and the closure certification. The requirements are summarized below: Closure Plan 1. Prepare a closure plan for approval by the CDPHE after consultation with the local governing body having jurisdiction. The plan, at a minimum, must include the following: a. The steps necessary to close the landfill at any point during its active life. b. A description of the final cover system and the methods and procedures to be used to install the cover. c. An estimate of the largest area of the landfill ever requiring a final cover during the active life. d. A schedule for completing closure activities. 2. Maintain a copy of the closure plan in the operating record. Closure Activities 1. Close the site in accordance with the Solid Waste Disposal Sites and Facilities Act and the Regulations. 2. Sixty (60) days prior to closure notify the CDPHE and the local governing body in writing that the facility will be closing. 3. Sixty (60) days prior to closure notify the general public of the facility closure by posting clearly visible signs of suitable size at the site entrance. 4. Enact precautions to prevent further use of the site for unauthorized disposal. Closure/Post Closure Plan North Weld Landfill 2 March 2013 5. Prevent water pollution from occurring at or beyond the point of compliance. 6. Prevent nuisance conditions at or beyond the site boundary. 7. Initiate closure activities within thirty (30) days of reaching final design grades unless an extension is obtained from CDPHE. 8. Complete closure within 180 days after closure initiation, or if necessary, obtain an extension from the CDPHE. Closure Certification 1. Following closure, submit a report certified by a Colorado professional engineer (P.E.) to the CDPHE documenting that closure has been completed in accordance with the closure plan. Place a copy of the report in the facility operating record. 2. Following closure, record a notation on the deed or other title instrument stating that the land was used as a landfill and its use is restricted. Notify the CDPHE and the local governing authority that the notation has been recorded and place a copy of the notation in the operating record. 2.2 CLOSURE ACTIVITIES The following closure activities will be performed when site closure is necessary: 1. Construction Documents — Closure construction plans will be prepared as needed. 2. Regulatory Agency Notification - Sixty (60) days prior to closure of any landfill phase, a notification of the intent to close will be submitted to the CDPHE and the local governing authority and a copy of the notice will be placed in the operating record. 3. Public Notification - Sixty (60) days in advance of closure date, signs will be placed at entrance to the site notifying the general public of the closure date. 4. Final Cover - Final cover will be placed in accordance with the Regulations. The final cover design is discussed in detail in Section 2.3 of this Plan. 5. Completion of Closure - Closure activities will be completed within 180 days following closure. A request for an extension may be submitted to CDPHE if climatic or operational factors dictate that additional time is required for proper closure. 6. Certification/Documentation - Upon completion of construction, a report will be prepared Closure/Post Closure Plan North Weld Landfill 3 March 2013 by a Colorado P.E. certifying that closure was conducted in accordance with the provisions of this plan. The report will be submitted to CDPHE for approval after consultation with the local governing board. The approved report will be placed in the operating record. To complete closure a notation will be made on the title or deed to the land, which notifies prospective buyers that the land was used as a landfill, and that certain land use restrictions apply. Copies of the notation will be submitted to CDPHE and the local governing body and a copy will also be placed in the operating record. 7. Security - During closure activities and after closure, public disposal will be prohibited. Signs will be posted warning of unauthorized entry or waste disposal. The existing fence will be maintained and the front gate will be kept locked when not in use. 2.3 MAXIMUM EXTENT OF OPERATIONS An estimate of the largest area of the landfill currently requiring final cover is about 85 acres in Phases 1, 2 and 3A as shown in Figure 2. The estimated 85 -acre closure area is based on the facility's current disposal activities, less 15 acres of final cover completed in 2006. 2.4 FINAL COVER 2.4.1 Final Grades Final grades have been designed to promote surface water runoff and minimize erosion. Final grade slopes are designed to be a minimum of 5 percent (20 to 1) and a maximum of 25 percent (4 to 1), unless alternative grades have been approved by CDPHE. Prior to placement of final cover, areas of the site that have not been filled to final grades may require placement of backfill to achieve 5% slopes. About 280,000 cubic yards of on - site soils are estimated for achieving minimal slopes prior to placement of final cover. Figure 3 shows the area of backfill needed to achieve 5% slopes. 2.4.2 Final Cover Description NWLF received approval from CDPHE and Weld County Depaitiuent of Public Health and Environment (WCDPHE) for an alternative fmal cover (AFC) design on March 30, 2004 and September 3, 2004 respectively. The AFC components are described below. 1. Alternative Final Cover Layer - The AFC layer will consist of a minimum of 18 inches of slightly compacted soil from on -site sources. AFC thickness on the side slope will be increased to 20 inches in accordance with the AFC design. The AFC components should have no less than 15% fines content and be compacted to between 80% to 90% of maximum density as determined by Standard Proctor (ASTM D 698). Approximately 218,000 cubic yards of soil will be necessary for the AFC layer. This assumes an average 19 -inch AFC layer will be installed over the 85 -acre area. Closure/Post Closure Plan North Weld Landfill 4 March 2013 2. Alternative Final Cover Topsoil Layer — The 6 -inch topsoil layer of the AFC will have no less than 30% fines content and be compacted to between 80% and 90% of maximum density as determined by Standard Proctor (ASTM D698). The 6 -inch topsoil layer of the AFC will be material suitable for sustaining vegetation. AFC seedbed preparation, seed mix and fertilizer requirements are specified in the approved "North Weld Landfill Alternative Final Cover Demonstration" prepared by Golder Associates dated December 30, 2003. Approximately 69,000 cubic yards of soil will be required for the topsoil layer over the 85 -acre area. 2.5 CONSTRUCTION Construction of the final cover system will be performed by using equipment such as scrapers to excavate, haul and place loose soil lifts for the AFC layer. A motor grader, low ground pressure dozer, or other suitable equipment will be used to spread/shape the cover. The topsoil layer will be placed loosely over the AFC layer with scrapers and then shaped with a motor grader, low ground pressure dozer, or other suitable equipment. The topsoil layer will then be prepared in accordance with specifications provided in the above referenced North Weld Landfill Alternative Final Cover Demonstration. 2.6 CONSTRUCTION QUALITY ASSURANCE (CQA) To ensure proper implementation of the AFC design the following CQA requirements apply: ® Performance of grain -size distribution tests every 5,000 cubic yards will be conducted for the AFC layer and the 0.5 foot topsoil layer; ® Performance of Standard Proctor tests every 10,000 cubic yards; a In -situ density testing using a nuclear gauge at a frequency of one test per 1,000 cubic yards; o Oven -dry moisture contents at a frequency of one test every 1,000 cubic yards; ® Verification of proper thickness of cover at a grid spacing of approximately 100 feet on -center. A design drawing showing the area of AFC to be built and a detail of the cover cross-section will be supplied to the CDPHE and WCDPHE prior to construction. Also, an as -built construction drawing will be provided with the certification report that shows the survey points used to verify thickness on the approximately 100 feet on -center grid pattern. Upon completion of construction activities, a Colorado P.E. will sign a certification Closure/Post Closure Plan North Weld Landfill 5 March 2013 document indicating that the final cover was constructed in substantial conformance with the project specifications and approved closure plan. 2.7 CLOSURE SCHEDULE The schedule for closure is weather dependent. Excessive cold or rainy weather can affect placement of cover materials. The typical available construction window for placing cover materials in this climate is from late April through late September. A typical closure schedule is provided in Figure 5. If necessary, a request for an extension will be submitted to CDPHE to ensure that sufficient time is available to complete closure in accordance with the provisions of this closure plan. Closure/Post Closure Plan 6 March 2013 North Weld Landfill 3.0 POST -CLOSURE PLAN 3.1 INTRODUCTION 3.1.1 Description This post -closure plan describes all actions to be taken following closure of the site. Post - closure care begins after the site is closed in accordance with the closure plan. Post -closure care continues for a period of 30 years, unless during the life of the facility or the post - closure period, a demonstration is made to the CDPHE and the local governing body, which shows that a reduced time period is sufficient to protect human health and the environment. If the post -closure period is reduced, this plan will be updated accordingly. 3.1.2 End Use Upon completion of closure, current plans indicate that the site will be zoned for agricultural use. This end use should have minimal impact on the final cover, and the use will not interfere with post -closure monitoring. 3.1.3 Regulatory Requirements This post -closure plan is prepared in accordance with Section 2.6 "Post -Closure Care and Maintenance Standards" and Section 3.6, "Post -Closure Care and Maintenance" of the Regulations. This plan will be maintained in the facility operating record. The regulatory requirements are summarized below: Post -Closure Plan 1. Prepare a post -closure plan for approval by CDPHE in consultation with the local governing body, which includes the provisions to prevent or minimize nuisance conditions, maintain the final cover, monitor groundwater, maintain and monitor the leachate collection system, and monitor landfill gas. 2. Describe the planned end use for the site and identify the name and address of a contact person who is responsible for the facility. 3. Maintain a copy of the post -closure plan in the site's operating record. Post -Closure Activities 1. The post -closure period shall be at least 30 years unless a demonstration is made to CDPHE and the local governing body that a shorter time period is sufficient to protect human health and the environment. 2. Permanent surface water structures remaining after closure shall be designed to manage run-on and run-off from a 100 year, 24 -hour storm event. Figure 4 shows the general location of permanent stormwater channels anticipated to be Closure/Post Closure Plan North Weld Landfill 7 March 2013 constructed as part of closure activities. 3. Enact precautions to prevent water pollution at the point of compliance after closure. 4. Enact precautions to prevent nuisance conditions at or beyond the site boundary after closure. 5. Post -closure monitoring shall be conducted in accordance with the approved post -closure monitoring plan. 6. At the completion of the post -closure care period, a notification will be submitted to CDPHE with a certification signed by an independent Colorado Registered Professional Engineer or approved by the CDPHE and the local governing body having jurisdiction verifying that post -closure care has been completed in accordance with the post -closure plan. The notification will be placed in the operating record. 3.2 POST -CLOSURE ACTIVITIES 3.2.1 Facility Management During the post -closure period, a facility manager will be named and a phone number and address for the manager will be incorporated into this plan. The manager currently responsible for the facility is: Mr. William Hedberg North Weld Sanitary Landfill 40,000 WCR 25 Ault, Colorado (970) 686-2800 3.2.2 Post -Closure Activities The following post -closure activities provide for inspection, maintenance, and monitoring of the design features of the facility during the post -closure period: 1. Inspections - Inspections of the site will be conducted quarterly for the first two years after closure and semi-annually thereafter. The inspector will assess the conditions of the site and recommend corrective actions for any items needing attention. Items to be inspected are further described in the following line items and include nuisance conditions, the final cover system, groundwater monitoring points, leachate monitoring system, gas monitoring system, surface water management system, and security. Closure/Post Closure Plan North Weld Landfill 8 March 2013 2. Prevent Nuisance Conditions - The placement of final cover provides a barrier between the refuse and the environment. Construction of the final cover in substantial conformance with the project specifications should prevent disease vectors, deter birds, minimize odors, reduce blowing litter, and minimize air and water pollution as direct contact with refuse is prevented. Inspections and continued maintenance of the final cover system will ensure the integrity of the final cover so nuisance conditions are prevented throughout the post -closure period. The potential for on -site litter, traffic congestion, and noise pollution will be eliminated once the closure of the facility is complete since refuse will no longer be accepted for disposal and heavy equipment will no longer be operating. 3. Final Cover System - The maintenance of the final cover may involve repair of the AFC layer, the erosion layer and vegetation. It is estimated that 5% of the site per year will require cover maintenance, reseeding and fertilizer. An additional 5% is estimated, which will allow for 10% of the site for the first 2 years of post -closure for cover maintenance, reseeding and fertilizer. Additionally, NWLF will conduct a qualitative vegetation assessment annually during post -closure to ensure the vegetative cover is established and assist in identifying any areas that may require attention. 4. Groundwater Monitoring - The current groundwater monitoring program consists of 5 wells, which will be monitored in accordance with the Site Specific Groundwater Monitoring Plan (GWMP). Depending on the monitoring analytical data obtained during the site operating period, the number of wells and the monitoring frequency may be reduced during the post -closure care period with concurrence by CDPHE and the local governing authority. For this plan it is estimated that groundwater monitoring will be performed semi-annually. Samples will be analyzed for the constituents listed in the Groundwater Management Plan. The results of all analysis will be placed in the site's operating record. Monitoring results will be reviewed and a statistical evaluation performed comparing each event's results to background levels. Detection monitoring will continue as long as results remain below specified levels for each constituent. If the statistical evaluation shows that background levels are exceeded, confirmation sampling, and if necessary, corrective action will be performed in accordance with the GWMP and this plan will be updated as necessary. In addition to sampling, it is estimated that one well will require repair each year and a new pump will be required every five years. The integrity of the monitoring well system will be inspected during the monitoring events or during the annual site inspections. Any required repairs will be corrected. 5. Leachate Monitoring - The liquid elevation in the leachate collection sumps will Closure/Post Closure Plan North Weld Landfill 9 March 2013 be monitored semi-annually to verify the levels are 1 ft or less above the base liner. The measurements will be taken concurrent with semi-annual groundwater monitoring or site inspection activities. Leachate samples from the sumps will be taken annually for analysis, if leachate is present. Although leachate is not expected during post -closure, in the event that leachate is removed from a sump, it will be managed in accordance with the analytical data and approved leachate management procedures. Information related to the number of gallons removed, date, time, and location of leachate removal, and the disposal method will be maintained in the facility operating record. Due to the arid climate leachate generation is not expected at closure. Nevertheless, during the post -closure period, an allowance for leachate management is provided for the first 5 years of post -closure in the event of premature closure. A demonstration may be made to the CDPHE showing that the leachate no longer poses a threat to human health and the environment and that monitoring can cease. 6. Gas Monitoring - The facility will continue to monitor gas at the site quarterly in accordance with the Landfill Gas Migration Monitoring Plan (LGMMP). The post - closure cost estimate assumes the 15 gas monitoring probes (currently in the program) will be monitored during post -closure. Based on the monitoring data obtained during the site operating period, the number of probes and the frequency of monitoring may be reduced during the post -closure care period with concurrence by CDPHE and the local governing authority. Results from each gas monitoring event will be placed in the site's operating record. If monitoring results indicate that methane gas is present above the permissible regulatory limits, measures will be taken in accordance with Section 2.3.3 of the Regulations. 7. Surface Water Management System - Maintenance of the surface water management system is expected to be required during the post -closure period. This maintenance consists of regrading or desilting channels and ponds. In addition, semi-annual inspections of the stormwater system will be performed. Inspections of permanent stormwater management structures will be performed following storm events exceeding the 100 year, 24 hour storm event. 8. Waste Disposal - Off -site refuse will not be accepted during the post -closure period. However, if during post -closure repairs, previously placed refuse is excavated for construction activities, the refuse will be placed within the permitted fill area and final cover will be applied. 9. Security- During post -closure, the perimeter fence will remain in place and the front gate locked when not in use. Signs will be posted warning of unauthorized entry. Closure/Post Closure Plan North Weld Landfill 10 March 2013 The integrity of the fence will be monitored and maintenance performed as necessary. 10. Certification - At the completion of the post -closure care period, a notification will be submitted to CDPHE with a certification signed by an independent Colorado Registered Professional Engineer or approved by the CDPHE and the local governing body having jurisdiction verifying that post -closure care has been completed in accordance with the post -closure plan. The notification will be placed in the operating record. Closure/Post Closure Plan North Weld Landfill 11 March 2013 FIGURES z acc zo0 N np C IOC/efl 31VO loud uOp'8060CIOt so?,V o!^ 0ID 100id ['IOC VIaMN ;31I3 0010000 � S Z s � a a t t 1 000857 N 000LS, u6P•B01OC IOL luao uad c yogi asap t IBLUBI$ •31YO 101d W a,nso l7 la!i [IOL P I•YN;31IJ DRAMA w -I =CO LU 0 0 U U y w U 4 D Z s i5 z 1/ "7:7%c-- sTJ3-' ll re,/ 11 Cj, Ih} ii; y !,Ip C 102/8/t a1V0 bola u6p'00'0C too aanao to 20l EEO' l!0 a6 In -10 0102 POMX;3ll3 0MMVC J CC 0 LL 0 z (7 W = o H W w cc Z co O J U Month 12 Closure acitivities to begin after 60 Notification Period V. L C 0 5 Month 10 Month 9 Month 8 1 Month 7 CO s 2 Month 5 \ \ \ Month 4 \ \ Month 3 Month 2 t C o 2 i- Tasks Contract Preparation Regulatory Agency Notification Public Notification Premature Closure Contractor Mob/Demob Backfill to 5% AFC/Infiltration Layer Placement Erosion Layer Placement Vegetation Completion of Closure Activities QA/QC Certification Security FINANCIAL ASSURANCE PLAN NORTH WELD LANDFILL Weld County, Colorado Prepared by: Waste Management Disposal Services of Colorado, Inc. North Weld Landfill 40,000 Weld County Road 25 Ault, Colorado Revised March 2013 FINANCIAL ASSURANCE PLAN NORTH WELD LANDFILL TABLE OF CONTENTS Section Page 1.0 INTRODUCTION 1 2.0 REGULATORY REQUIREMENTS 1 2.1 Cost Estimates 1 2.2 Financial Assurance Activities 1 2.3 Financial Assurance Mechanisms 2 3.0 CLOSURE AND POST -CLOSURE COSTS 2 4.0 FINANCIAL ASSURANCE MECHANISM 2 LIST OF APPENDICES Appendix A Closure Costs B Post -Closure Care Costs C Insurance Certificate for Closure and Post -Closure Care Costs Financial Assurance Plan i March 2013 North Weld Landfill FINANCIAL ASSURANCE PLAN NORTH WELD LANDFILL REVISION LOG DATE DESCRIPTION OF REVISION BY 4/99 Replaced letter of credit with insurance certificate. TS 3/01 Revise financial assurance costs based on the revised closure and post- closure plan dated March 2001. TS/AS 5/02 Replace original engineering cost estimates of closure and post -closure based on 2002 CDPHE guidance or determined by NWSL TS/AS 4/03 Revise financial assurance costs based on the revised closure and post- closure plan dated April 2003. TS/AS 3/05 Revise financial assurance costs based on the revised closure and post- closure plan dated March 2005 TS/AS 3/06 Revised financial assurance costs based on the revised closure and post- closure plan dated March 2006. TS/AS 3/07 Replace cost estimates of closure and post -closure prepared in 2002 with new cost estimates in accordance with Section 1.8.3 of the Solid Waste Regulations. Miscellaneous text changes were also made to the Plan. TS/AS 3/09 Revised financial assurance costs based on the revised closure and post- closure plan dated March 2009. TS/AS 3/10 Revised financial assurance costs based on the revised closure and post- closure plan dated March 2010. TS 3/11 Revised financial assurance costs based on the revised closure and post- closure plan dated March 2011. TS 3/12 Replaced cost estimates of closure and post -closure prepared in 2007 with new cost estimates in accordance with Section 1.8.3 of the Solid Waste Regulations. Miscellaneous text changes were also made to the Plan. TS 3/13 Revised financial assurance costs based on the revised closure and post- closure plan dated March 2013. TS Financial Assurance Plan North Weld Landfill ii March 2013 1.0 INTRODUCTION This Financial Assurance Plan (Plan) has been prepared in accordance with Section 1.8 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities, 6 CCR 1007-2, (Regulations), and sets forth the closure and post -closure care costs for North Weld Landfill (NWLF) in Ault, Colorado. This Plan includes, in Appendices A and B, closure and post -closure cost estimates, adjusted to 2013 dollars, which replace all previous estimates. The Regulations require that cost estimates be replaced every five (5) years or as otherwise required by the Colorado Department of Public Health and Environment (CDPHE) and costs were last replaced in 2012. The next replacement of cost estimates is scheduled for 2017. This Plan also describes the financial assurance mechanism in place to ensure payment of all associated closure and post -closure costs. This Plan is to be used in conjunction with the NWLF Closure/Post Closure Plan dated March 2013. 2.0 REGULATORY REQUIREMENTS 2.1 Cost Estimates Sections 1.8 of the Regulations list the specific financial assurance requirements for solid waste disposal sites. These requirements are described below: 1. Maintain cost estimates, in current dollars, for hiring a third party to close the largest area of the facility requiring closure during the active life of the site. The cost estimate must also include costs associated with conducting post -closure care. 2. The facility must establish financial assurance sufficient to ensure payment of the closure and post -closure care costs. 2.2 Financial Assurance Activities The following are the requirements for financial assurance activities as described in Section 1.8 of the Regulations: 1. Notify CDPHE when the required cost estimates have been placed in the operating record; 2. Annually adjust cost estimates to account for inflation using the method prescribed by CDPHE; 3. Replace original cost estimates with new cost estimates every five (5) years, unless otherwise required by CDPHE; 4. Costs associated with closure, post -closure and corrective actions may be adjusted, after approval by CDPHE and the local governing authority; Financial Assurance Plan North Weld Landfill 1 March 2013 5. Financial assurance must be provided continuously unless a release is granted by CDPHE. 2.3 Financial Assurance Mechanisms Several financial assurance mechanisms are available, and more than one mechanism may be used. For corporate entities, these mechanisms include a trust fund, letter of credit, surety bond and insurance. Waste Management Disposal Services of Colorado, Inc. (WMC) has chosen to use insurance to meet the financial assurance requirements. The insurance certificate was prepared in accordance with the requirements set forth in Section 1.8.9 of the Regulations. 3.0 CLOSURE AND POST -CLOSURE COSTS Closure and post -closure costs are those costs associated with closing the facility and conducting post -closure care activities. These costs are determined by calculating the cost to complete all of the actions in the Closure/Post Closure Plan. The unit cost values for closure and post -closure activities were determined by WMC. Costs for items including earthwork, excavation and soil placement, were taken from recent bids for similar work completed at Waste Management construction projects. The closure costs are provided in Appendix A, and the post -closure costs are provided in Appendix B. These costs are based on the 2012 cost estimates and an inflation adjustment factor for 2013. 4.0 FINANCIAL ASSURANCE MECHANISM WMC has established insurance coverage to assure adequate funds are available for all closure and post closure care costs determined in the Closure/Post-Closure Plan. The insurance meets all requirements set forth in Section 1.8.9 of the Regulations, "Insurance for Closure and Post - Closure". The insurance certificate is provided in Appendix C. Financial Assurance Plan North Weld Landfill 2 March 2013 APPENDIX A CLOSURE COSTS TABLE 1 - CLOSURE COST ESTIMATE Site: NORTH WELD LANDFILL Date: March -13 Page: 1 Item Description Units Quantity Unit Cost (Note 1) Extended COSt Category COSt 1 Foundation Layer a Backfill of intermediate grades to achieve minimum 5% slope (on -site source) CY 280,000 1.85 518,000 b Other Foundation Layer Closure Costs 0 Foundation Layer Total Cost 518,000 2 Final Cover Section Closure Area: 85.0 Acres a Compacted Clay Layer (on -site source) CY 0 b Alternative Final Cover (on -site source) CY 218,000 1.85 403,300 c Topsoil (on -site source) CY 69,000 1.85 127,650 d Fertilizer/Soil Amendements/material hauling Acre 85.0 834.00 70,890 e Seeding Acre 85.0 620.00 52,700 f Other Final Cover Closure -Related Costs Acre 0 Final Cover Total Cost 654,540 3 Surface Water Controls a Drainage Swales/Berms/Channels LF 3,855 20.48 78,950 b Culverts LF 210 104.00 21,840 c Sedimentation/Surface Wtr Control Ponds 0 d Erosion Control 0 e Other Surface Water Closure -Related Costs 0 Surface Water Total Cost 100,790 4 Environmental Monitoring Installations a Grndwtr Mntg Wells w/dedicated pumps EA 0 b Gas Monitoring Probes EA 0 c Other Env. Monitoring Closure Costs 0 Environmental Monitoring Total Cost 0 5 Gas Collection and Control System (GCCS) a Extraction Well Installation 0 b Extraction Well - Well Head Assembly 0 c Extraction Well - Lateral Pipe 0 d GasNapor Collection - Header Pipe 0 e GasNapor Collection - Header Drain 0 f Blower 0 g Blower Enclosure/Building 0 h Flare 0 i Other GCCS Closure -Related Items 0 GCCS Total Cost 0 TABLE 1 - CLOSURE COST ESTIMATE (Continued) Site: NORTH WELD LANDFILL Date: March -13 Page: 2 Item Description Units Quantity Unit Cost (Note 1) Extended Cost Category Cost 6 7 8 9 10 11 12 13 14 Miscellaneous Closure Activities a Access Road Construction 0 b Fencing 0 c Signs EA 2 150.00 300 d Other Miscellaneous Closure -Related Items 0 Miscellaneous Total Cost 300 CLOSURE COST ESTIMATE SUBTOTAL 1,273,630 Engineering & Project Management a Design & Bid Documents (% of Subtotal) 3% 38,209 b CQA, Surveys & Reports (% of Subtotal) 10% 127,363 c Project Mgmt & Admin (% of Subtotal) 2% 25,473 Engineering & Project Mqmt Total Cost 191,045 Contingency (% of Subtotal) 10% 127,363 CLOSURE COST ESTIMATE TOTAL (in 2012 dollars) $1,592,038 Inflation Adjustment Factor for 2013 1.018 Inflation Adjustment Factor for 2014 Inflation Adjustment Factor for 2015 Inflation Adjustment Factor for 2016 Total Closure Cost (adjusted to 2013 dollars - Line 10 x Line 11) $1,620,695 Notes: 1 All costs include material and installation unless noted otherwise. APPENDIX B POST-CLOSUCARE COSTS TABLE 2 - POST -CLOSURE COST ESTIMATE Site: NORTH WELD LANDFILL Date: March -13 Acres at Closure: 100 Item Description Units Unit Quantity Unit Cost Quantity per Year Cost per Year 1a Facility Inspections & Reporting - 2 per year EA 1 1,150 2 2,300 1b Facility Inspections & Reporting - 2 addt'l events to allow for qtrly inspections first 2 yrs of post -closure. Annual cost fore addt'I events= 2,300 Total Item cost for 2-yr period = 4,600 Total Item cost annualized over 30 yr PC period = 153 2 Qualitative Vegetative Assessement - annual EA 1 3,600 1 3,600 3a Cover Maintenance, Reseeding & Fertilizing - 5% of site per year (Note 1) AC 5% 2,181 5.0 10,905 3b Cover Maintenance, Reseeding & Fertilizing - addt'l 5% per year to allow for 10% of the site first 2 yrs of post -closure Annual cost for addt'l 5% = 10,905 Total Item cost for 2-yr period = 21,810 Total item cost annualized over 30 yr PC period = 727 4 Surface Water Controls - Maintenance LS 1,000 1 1,000 5 Fence Repair LS 500 1 500 6 Mowing - Assume annual mowing for first 10 years of post -closure AC 1 40 100 1,333 Annual mowing cost= 4,000 Cost for 10 mowing events = 40,000 Total Item cost annualized over 30 yr PC period = 7 Groundwater Monitoring - Semi-annual events EA 5 1,723 2 17,230 8 Groundwater Well Pump Repair / Maintenance LS 300 1 300 9 Gas Probe Monitoring, Maintenance and Reporting - 4 Events per Year EA 15 87 4 5,220 10 Leachate Monitoring -Annual EA 3 461 1 1,383 11 Leachate Depth Measurement - Semi-annual EA 3 554 2 3,324 12 Leachate Management - First 5 years of post- closure (managed on -site) (Note 2) Annual cost for leachate mgmt = 5,000 Total Item cost for 5-yr period = 25,000 Total Item cost annualized over 30 yr PC period = 833 13 Gas Collection and Control Syst Maint LS 0 14 Gas Condensate Disposal GAL 0 15 Subtotal - Items 1 through 14 48,809 16 Administrative Costs (% of Subtotal) Contingency (% of Subtotal) 5% 2,440 17 10% 4,881 18 Total Cost per Year 56,130 19 Post -Closure Care Period: 30 Years 20 Total Post -Closure Cost (in 2012 dollars) $1,683,911 21 Inflation Adjustment Factor for 2013 1.018 22 Inflation Adjustment Factor for 2014 23 Inflation Adjustment Factor for 2015 24 Inflation Adjustment Factor for 2016 Total Post -Closure Cost (adjusted to 2013 dollars - Line 20 x Line 21) $1,714,221 Notes: 1 Unit cost for Item 3 is based on the Fertilizer, Soil Amendment and Seeding costs of the Closure Cost Estimate (Table 1) increased by a factor of 1.5 to provide an allowance for cover maintenace in addition to seeding, fertilizer and amendments. 2 Due to arid climate, leachate generation is not expected at closure. However, an annual allowance for leachate management is provided for the first 5 years of post -closure in the event of premature closure. Basis for Costs Line is $1,150 based on 9 hrs for site inspector @ $70/hr and 3 hrs for report preparation @ $120/hr plus clerical to write report 2 $3,212 vegetation assessement based on actual CSLF 3rd party costs for this service 3a $2,181 based on Table 1, Line 2d and 2e values increased by a factor of 1.5 4 & 5 Estimated values 6 $40/acre mowing cost based on 3rd party bid submitted to DADS 7 Based on actual 3rd party sampling and lab costs 8 Estimated value 9 Based on representative 3rd party costs from other Colorado WM landfills 10 Based on actual 3rd party sampling costs 11 Based on actual 3rd party costs APPENDIX C INSU NCE CERTIFICATE FOR CLOSURE AND POST -CLOSURE CARE COSTS 2013 CLOSURE AND POST -CLOSURE COST ESTIMATES The NWSL Financial Assuarance Plan as revised March 2013 includes a closure cost estimate of $1,620,695 (Appendix A) and a post -closure cost estimate of $1,714,221 (Appendix B) for a combined total estimate of $3,334,916. These estimates are based on the site Closure and Post - Closure Plan dated March 2013. The accompanying insurance certificate reflects this adjusted amount. A �O `JH 7�VTM CERTIFICATE LIABILITY INSURANCE CORD DATE )MMIOD/YYYY)03/20/2013 PRODUCER National Guaranty Insurance Company of Vermont 100 Bank Street, Suite 610 Burlington, Vermont 05401 (802) 864-1715 THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. INSURERS AFFORDING COVERAGE NAIC # INSURED Waste Management Disposal Services of Colorado, Inc. 5500 South Quebec Street, Suite 250 Greenwood Village, Colorado 80111 INSURER A: National Guaranty Insurance Company INSURER B. of Vermont INSURER C: INSURER D: INSURER E: c;vvttu►LFItb THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. AGGREGATE LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. ILTRJ LTR NSRO GENERAL TYPJ=Q�pjSURANCE POLICY NUMBER DATEYfMMFDD/I f) TIVE PDATEILICY MM(DD/YYIN LIMITS EACH OCCURRENCE $ LIABILITY COMMERCIAL GENERAL LIABILITY DAMAGEToiTENTED PREMISES(Eaoccurence) $ MED EXP (Anyone person) $. CLAIMS MADE P1 OCCUR PERSONAL & ADV INJURY $ GENERAL AGGREGATE S GEH'L AGGREGATE LIMIT APPLIES PER: POLICY PRO- JECT PRODUCTS - COMP/OP AGG $ AUTOMOBILE LIABILITY ANY AUTO ALL OWNED AUTOS COMBINED SINGLE LIMIT (Ea accident) BODILY INJURY (Per person) BODILY INJURY (Per accident) PROPERTY DAMAGE (Per accident) ---- GARAGE LIABILITY ANY AUTO AUTO ONLY -EAACCIDENT $ EA ACC. THAN S OTHER AUTO ONLY: AGG 5 EXCESS(UMBRELLA 7 LIABILITY OCCUR CLAIMS MADE DEDUCTIBLE RETENTION S EACH OCCURRENCE S AGGREGATE $ $ S $ I WORKERSCOMPENSATIONAND EMPLOYERS' LIABILITY ANY PROPRIETOR/PARTNER/EXECUTIVE OFFICER/MEMBER EXCLUDED? If yes. describe under SPECIAL PROVISIONS below WCSTATU- OTH- „__1 CSfAUTER_ E.L. EACH ACCIDENT $ E.L. DISEASE - EA EMPLOYEE $ E.L. DISEASE POLICY LIMIT $ A OTHER Closure Post -Closure CPCS99-0013 4/9/1999 4/9/2014 $1,620,695.00 $1,714,221.00 DESCRIPTION North This with Waste OF OPERATIONS! LOCATIONS /VEHICLES (EXCLUSIONS ADDED BY ENDORSEMENT! SPECIAL PROVISIONS Weld Sanitary Landfill, 40000 Weld County Road 25, Ault, CO 80610 certificate certifies that the policy to which this certificate applies provides closure and/or post -closure care in connection the Insured's obligation to demonstrate financial responsibility under Section 1.8.9 of the regulations pertaining to Solid Disposal Sites and Facilities 6 CCR 1007-2, as amended. CERTIFICATE HOLDER Director Colorado Department of Public Health and Environment Hazardous Materials/Waste Management Division 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION THEREOF. THE ISSUING INSURER WILLXNAla9IGFICSB MAIL 120 DAYS WRITTEN DATE NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEF-Det 0(l@1dX99n(RCi3i$JiHCX dd oi_ xat t� )Exf(Mn Nfl * NI ) kx�nk > ft4iht34 NCI__ " i 4 a AUTHORIZED REPRESENTATIVE Donna L. Meals, Vice President and Secretary n ernRn (_ORPORATION 1988 ACORD 25 (2001/08) wu� WASTE MANAGEMENT February 7, 2013 RECEIVER FEB 13AI WELD COUNTY COMMISSIONER.. Ms. Dana Podell Air Pollution Control Division (APCD-SS-B I) Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 RE: ANNUAL NMOC EMISSION RATE REPORT NORTH WELD LANDFILL AIRS ID: 123/209/1 Dear Ms. Podell, 2400 West Union Avenue Englewood, CO 80110 303-914-1445 (Phone) 866-442.0285 (Fax) RECE VED FFR 1 2013 Weld County 'L:i,ning Department GREEL E'! OFFICE SENT BY UPS OVERNIGHT As required under the State Emissions Guideline Program for municipal solid waste landfills, enclosed is the 2012 Annual NMOC Emission Rate Report for North Weld Landfill (NWLF) located at 40,000 County Road 25, Ault, Colorado. A Tier 2 investigation was conducted at the site in 2012 and the report is currently undergoing review by APCD. Following APCD's approval of the report, the NMOC concentration obtained in 2012 will be used in future NMOC reports. Should you have any questions regarding the information contained in the enclosed report, please contact me at 303-914-1445. Sincerely, TorrrSchweitzer Facility Engineer Enclosure cc: Troy Swain, WCDPHE Kim Ogle, WCDPS Jerry Henderson, CDPHE Bill Hedberg, NWLF Bruce Clabaugh, Waste Management alintinGuAkCigijoYt5 a-9-0-13 2013- 0°1'15 WANTS MANAOUM Tfl WASTE MANAGEMENT CERTIFICATION STATEMENT NOTE: This Certification must be completed by a responsible official for any application, report, document, or compliance certification submitted to the Air Pollution Control Division pursuant to Colorado Regulation No. 3 and General Conditions of the Operating Permit. A Certification Statement must be kept with each associated report or document submittal. OPERATING PERMIT NUMBER: COMPANY NAME: FACILITY NAME: FACILITY ADDRESS: Purpose of Certification: AIRS ID 123/209/1 Waste Management Disposal Services of Colorado, Inc. North Weld Landfill 40000 County Road 25, Ault, Colorado 80610 2012 Annual NMOC Report "I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualed personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations." Bruce Clabaugh Environmental Protection Manager Print Name Title / i7 Signature Date ` 2012 Tier 2 NMOC Emission Rate Report North Weld Landfill Prior to scale installation on February 1, 2010, volume of waste accepted was estimated based on container size of incoming waste. Therefore, because the actual year-to-year solid waste acceptance rate is estimated, the equation found in 40 CFR 60.754(a)(ii) was used to determine NMOC emission rates for this time period. MNMoc=2LoR(e*e-e kl)(CNMoc)(3.6 x 10') NMOC Emission Rate for Years with Estimated Waste Acceptance Rates MNMOC Lo R k c CNMOC Mass emission rate of NMOC, Mg/yr = Refuse methane generation potential, m3/Mg Average annual acceptance rate, Mg/yr = Methane generation rate constant, 1/yr = Years since closure, yrs (c = 0 for active and/or new landfills) = Age of landfill, yrs = Concentration of NMOC, ppm as hexane Conversion factor MNMoc=2(Lo)(R)(eikllcl-e"("I1)(Cnmoc)(3.6 x104) 170.00 2 122,534.25 1 0.02 3 0.00 ° 20.91 153.00 2 3.6 x 10s 7.84 Mg/yr 1 Information used to determine annual average acceptance rate The average annual acceptance rate (R) is determined by taking the total waste received between the approximate opening date of February 3, 1992 and January 31, 2010 divided by the number of years for this period. Total tons received as of 01/31/10 4,584,717.63 Total tons converted to Mg5 4,159,228.55 Percent inert (including soil) 0.47 Total Mg less inert wastes 2,204,391.13 Age of site as of 01/31/10 17.99 Annual average acceptance rate (Mg/yr) 122,534.25 2 For regula ory purposes, the EPA default values for Lo and CNMOC must be used to calculate Tier 1 NMOC emission rates unless actual values have been obtained during Tier 2 sampling. NWLF conducted Tier 2 site specific sampling for CNMOC in 2008 (using Method 25C) with a resulting concentration of 153 ppmV as hexane. 3 For landfills in areas with a thirty year annual average precipitation of less than 25 inches, a k value of 0.02 is to be used. Annual precipitation in the area of North Weld Landfill is about 13 inches, therefore a k value of 0.02 has been used in the NMOC emission rate calculation. Gas generation from waste accepted after January 31, 2010 is calculated with "Known Waste Acceptance Rate" NSPS equation. 5 Conversion Used: Tons to Mg - Divide tons by 1.1023 6 Inert material includes inert wastes that are disposed in the landfill as well as intermediate and final cover soil used as part of routine landfill cell development. NOTE. These calculations are made for NSPS purposes only. EPA has specifically stated as follows "II Is recommended that these default values not be used for estimating landfill emissions for purposes other than NSPS and ES" (61 FR 9905, 9912, March 12, 1996). Consequently, these emission calculations grossly overestimate actual and potential emissions and reviewers of this document are specifically cautioned against improper and irresonsible uses of these calculations. Page 1 of 2 NWLF NMOC Tier 2 Report 2012.xls 2012 Tier 2 NMOC Emission Rate Report North Weld Landfill 40 CFR 60.754(a) provides two equations for determining NMOC emission rates; one for sites with known solid waste acceptance rates and another for sites with unknown (i.e. estimated) waste acceptance rates. For sites that include time periods with both known and unknown acceptance rates, the Regulation indicates that both equations should be used. North Weld Landfill is such a facility. Accordingly, this Emission Rate Report applies both equations for calculating the facility's 2012 Tier 2 NMOC emission rate. NMOC Emission Rate Calculations for Years with Known Waste Acceptance Rates The site installed scales on February 1, 2010. Therefore, the equation found in 40 CFR 60.754(a)(1)(I) for known waste acceptance was used to determine NMOC emission rates for this time period. The equation is provided below: MNMoc = Summation of [2kLOMi(e 5,)(CNMoc)(3.6 x 10'9)1 for each year with a known waste acceptance rate MNMOC k Lo Mi ti CNMOC = Mass emission rate of NMOC, Mg/yr = Methane generation rate constant, 1/yr = Refuse methane generation potential, m'/Mg = Mass of solid waste received for given year, Mg = Age of the i n section, Years = Concentration of NMOC, ppm as hexane Conversion factor 0.02 1 = 170.00 2 = Varies per year (see table below) = current year minus year of waste placement = 153.00 2 3.6 x 10-9 NMOC Emission Rate Calculation Summary (for years with known waste acceptance rates) Tons Tons Less Year Received Inert Waste' Mi* tl MNMoc 02/01-10/31/2010 11/01-12/31/2010 2011 2012 2013 578,688 71,125 477,545 492,283 306,704 278,240 2 1.00 37,696 34,198 2 0.12 345,463 313,402 1 1.15 362,419 328,784 0 1.23 Totals 1,619,641 1,052,282 954,624 3.51 Mglyr `Conversion Used: tons to Mg - divide tons by 1.1023 1 For landfills in areas with a thirty year annual average precipitation of less than 25 inches, a k value of 0.02 is to be used. Annual precipitation in the area of North Weld Landfill is about 13 inches, therefore a k value of 0.02 has been used in the NMOC emission rate calculation. 2 For regulatory purposes, the EPA default values for Lo and CNMOC must be used to calculate Tier 1 NMOC emission rates unless actual values have been obtained during Tier 2 sampling. NWLF conducted Tier 2 site specific sampling for CNMOC in 2008 (using Method 25C) with a resulting concentration of 153 ppmV as hexane. ' Inert material includes inert wastes that are disposed in the landfill. 40 CFR 60.754(a) allows the mass of nondegradable material to be subtracted from the total mass of solid waste when calculating the value of M,. NOTE. These calculations are made for NSP5 purposes only. EPA has specifically stated as follows "It is recommended that these default values not be used for estimating landfill emissions for purposes other than NSPG and EG" (61 FR 9905. 9912, March 12, 1996). Consequently, these emission calculations grossly overestimate actual and potential emissions and reviewers of this document are specifically cautioned against improper and irresponsible uses of these calculations. TOTAL NMOC EMISSION RATE: NMOC rate for years with known waste acceptance rates: NMOC rate for years with estimated waste acceptance rates: Combined NMOC Emission Rate: 3.51 7.84 11.35 Mg/yr Page 2 of 2 STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us January 31, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Mr. Louis Bull Waste Management 2400 West Union Avenue Englewood, Colorado 80110 rr 0n 2013 Weld County .,epartmeni GREELEY JFHCE Re: Approval: Alternative Source Demonstration MW -4 Alkalinity, Request for Background Update North Weld Landfill 40000 WCR 25, Ault, Colorado 80610 SW/WLD/NWC 4.4 Mr. Bull, RECEIVED Colorado Department of Public Health and Environment The Colorado Department of Public Health and the Environment (the "Department") Hazardous Materials and Waste Management Division (the "Division") received the following Alternative Source Demonstration (ASD) letter report addressing a confirmed CUSUM exceedance for alkalinity in groundwater monitoring well MW -4 at the North Weld Landfill (the "Facility"): North Weld Landfill, Ault, Colorado — Second Half 2012 Groundwater Monitoring 14 -day Notification of Statistically Significant Increase Above Background (SSI) — Alkanlinity at MW -4. Prepared by: AquAeTer, Inc. Dated: November 26, 2012. Received: November 28, 2012. The Division thanks the Facility for this extremely well prepared and presented letter report. We agree with the conclusion that the statistical database for alkalinity at MW -4 should update the background dataset. Based on the data presented in the letter report the Division approves this alternative source demonstration. The Division is currently converting all files to an electronic format. This effort is designed to make public information, such as facility reports, available through the internet. Based on this effort the Solid Waste Unit is asking that deliverables are submitted electronically. Information regarding this electronic submittal policy change is included on the notification enclosed. Note that the Department is authorized to bill for its review and response of technical submittals including these meeting minutes pursuant to Section 1.7 of the Regulations Pertaining to Solid Waste env\✓ALlkytl (cd1 S c2 -b (3 Mr. Louis Bull Waste Connections January 31, 2013 Page 2 of 2 Sites and Facilities (6 CCR 1007-2). An invoice for the Division's review of the above referenced documents will be transmitted under separate cover. Our fees and billing ceilings may be viewed online at http://www.cdphe.state.co.us/regulations/solidwaste/100702partlSWRegs.pdf. Thank you for your continued diligence in meeting our objectives of ensuring the health of the public and protection of the environment through compliance with applicable state and federal regulation. Should you have any questions or concerns, please do not hesitate to contact Doug Ikenberry at 303- 692-3389 (doug.ikenberry@state.co.us) or Eric Jacobs at 303-692-3430 (eric.jacobs@state.co.us). Sincerely, 2 c - Eric K. Jacobs P.G. Solid Waste Permitting Unit Solid Waste and Materials Management Program Hazardous Materials and Waste Management Division cc: ec: Mr. Tom Schweitzer, Waste Management Mr. Brad Pollock, Waste Management Mr. Bill Hedberg, Waste Management Ms. Kim Ogle, WCDPS Mr. Troy Swain, Weld County Dept. of Public Health Ms. Cathryn Stewart, AquAeTer, Inc. Mr. Stephen Wampler, AquAeTer, Inc. Jerry Henderson, HMWMD Doug Ikenberry, HMWMD CADocuments and Settings\ejacobs\My Documents\Working File\Projects\County Weld\North Weld County\Correspondence\130131 NWL ASD MW -4 Alkalinity Update Approval FINAL.doc STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us February 5, 2013 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Weld County Clerk & Recorder 1402 N 17th Ave Greeley, CO 80631 Dear Sir or Madam: Colorado Department of Public Health and Environment On February 9, 2013, the Air Pollution Control Division will publish a public notice for DCP Midstream, LP — Lucerne Gas Processing Plant, in the The Greeley Tribune. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Ellen Evans Regards, Ellen Evans Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT Website Title: DCP Midstream, LP — Lucerne Gas Processing Plant — Weld County NOTICE is hereby given that an Operating Permit application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80205 Facility: Lucerne Gas Processing Plant 31495 WCR 43 Lucerne, CO 80646 DCP Midstream, LP has applied for a Renewal Operating Permit for the Lucerne Gas Processing Plant in Weld County, CO. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 95OPWE100 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at www.colorado.qov/cdphe/AirPublicNotices. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Bailey Kai Smith of the Division at 303-691-4961 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. RELEASED TO: The Greeley Tribune on PUBLISHED: February 9, 2013 February 5, 2013 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 95OPWE100 AIRS ID #: 1230107 DATE: January 18, 2013 APPLICANT: DCP Midstream, LP — Lucerne Gas Processing Plant REVIEW ENGINEER: Bailey Kai Smith SOURCE DESCRIPTION DCP Midstream, LP has applied for renewal of their Operating Permit issued for the Lucerne Gas Processing Plant located in Lucerne, Weld County. The Lucerne Plant is a natural gas processing plant classified under SIC 1321. The process uses nine reciprocating internal combustion engines, two natural gas processing skids, an amine unit, and an amine reboiler. Fugitive emissions from equipment leaks are also present at this facility. This facility is located in an Area classified as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. Wyoming is an affected state within 50 miles of the plant. The following Federal Class I designated areas are within 100 kilometers of the plant: Rocky Mountain National Park. This facility is categorized as a NANSR major stationary source and as a PSD minor stationary source. The emission units covered under this permit are subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. In addition, pre -controlled NOx and CO emissions from each of the nine Waukesha engines and VOC emissions from the amine unit are above the major source level. The control devices on the units are used to meet their emission limitations and therefore are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64. FACILITY EMISSION SUMMARY Pollutants Potential Emissions (tons/yr) NOx 192.2 CO 233.9 VOC 121.8 SO2 12.3 PM/PM10/PM25 8.2 Individual HAP 4.6 Total HAP 8.6 EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. Engines — A new engine was added to the operating permit. The Reg 7 requirement to install control equipment was included in the permit. The requirements from NESHAP Subpart 7777 were also added to the permit. The serial numbers were corrected to account for AOS executions. Amine Unit — The requirements from the most recent permit issued for the amine unit and corresponding rebuilder were added to the permit. A CAM plan for the amine unit was added to Appendix G. Fugitive Emissions — The emission limitation was increased in accordance with the information submitted with the renewal application. The most recent hard component count was included in the permit. Requirements for the flare used to control emissions in accordance with NSPS Subpart KKK were added to the operating permit. ALTERNATIVE OPERATING SCENARIOS The most recent version of the alternative operations scenarios for engine replacement was included in the permit. INSIGNIFICANT ACTIVITIES An updated list of insignificant activities was included in the permit. PERMIT SHIELD Applicable requirements were removed from the permit shield. TECHNICAL REVIEW DOCUMENT For RENEWAL OF OPERATING PERMIT 95OPWE100 DCP Midstream, LP — Lucerne Natural Gas Processing Plant Weld County Source ID 1230107 October - November 2012 Operating Permit Engineer: Operating Permit Supervisor review: Field Services Oil & Gas Unit review: I. Purpose Bailey Kai Smith Matthew S. Burgett Jen Mattox This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for the Lucerne Natural Gas Processing Plant. The previous Operating Permit for this facility was issued on November 1, 1998, was renewed on April 1, 2008, was last revised on April 1, 2010 and expired on April 1, 2013. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on March 30, 2012, comments on the draft permit submitted on [date], previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at http://www.colorado.gov/cs/Satellite/CDPHE- AP/CBON/1251596446069. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. 123/0107 Page 1 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit II. Description of Source The Lucerne Gas Processing Plant is a natural gas processing plant. Natural gas is delivered to the plant by pipeline. Field gas is first charged to a separator where liquids formed during transport to the plant are separated from the gas stream. The gas stream discharged from the separator is processed through an amine unit to remove CO2 and then a molecular sieve contact tower, where moisture contained in the gas stream is absorbed. After the molecular sieve has removed the moisture in the gas, the gas stream is fed to the processing plant, where it is chilled by a propane refrigeration system. Natural gas liquids formed during this process are transported offsite by truck. The process uses nine reciprocating internal combustion engines, two natural gas processing skids, an amine unit, and an amine reboiler. Fugitive emissions from equipment leaks are also present at this facility. The plant is located near Lucerne in Weld County, Colorado. The area in which the plant operates is classified as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.16. Wyoming is an affected state within 50 miles of the plant. Rocky Mountain National Park is a Federal Class I designated areas within 100 kilometers of the plant. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which is major by itself (i.e. a Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Emissions at the facility are as follows: Pollutants Potential Emissions (tons/yr) NOx 192.2 CO 233.9 VOC 121.8 SO2 12.3 PM/PM10/PM2.5 8.2 Individual HAP 4.6 Total HAP 8.6 123/0107 Page 2 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit Ill. Applicable Requirements Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the rule. The facility is subject to the provisions of Section 112(r) of the Federal Clean Air Act. 112(r) requires the submittal of a risk management plan (RMP) by June 20, 1999 and DCP did submit an RMP by the June 20, 1999 deadline. Compliance Assurance Monitoring (CAM) The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: C-105, C-106, C-107, C-108, C-109, C-110, C-112, C-113: Waukesha Model L-7042 GSI ICE and C-115 (C-178): Waukesha Model L-5794GS1 ICE for NOX and CO. AU01 - 40 MMscfd Amine Unit for VOC. NSPS Subpart LLL The amine sweetening unit at this facility is subject to the provisions of 40 CFR Part 60 Subpart LLL for SO2 emissions from Onshore Natural Gas Processing. This unit is exempt under the rule since emissions are less than the two long tons per day of H2S, expressed as sulfur, threshold. NSPS Subpart JJJJ Applicability of 40 CFR Part 60 Subpart JJJJ for spark -ignition engines is based on the construction date, date of manufacture, and power rating. For the purposes of determining applicability to the provisions of Subpart JJJJ, the date that construction commences is the date the engine is ordered. The rule specifies that for rich burn engines above 500 HP, requirements apply to units both ordered after June 12, 2006 and manufactured after July 1, 2007. All engines at this facility with the exception of engine C-115 were constructed and manufactured prior to the applicability dates and are not subject to the requirements of NSPS Subpart JJJJ. Engine C-115 (previously C-178) was manufactured on July 31, 2007 and is subject to emissions standards under Subpart JJJJ. 123/0107 Page 3 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit NSPS Subpart OOOO The final rule for 40 CFR Part 60 Subpart OOOO was published in the Federal Register August 16, 2012. These requirements apply to affected facilities that commenced construction, modification, or reconstruction after August 23, 2011. Facilities potentially affected by the Subpart OOOO requirements at natural gas gathering stations are: reciprocating compressors; continuous bleed natural-gas driven pneumatic controllers with a natural gas bleed rate greater than 6 standard cubic feet per hour (scfh); and storage vessels. There are no reciprocating compressors at Lucerne which commenced construction after August 23, 2011. If, in accordance with the engine replacement AOS, a compressor package is swapped concurrently with an engine replacement, the facility will be subject to the requirements of Subpart OOOO and must submit an operating permit modification application accordingly. The Lucerne facility does not operate any pneumatic controllers with a natural gas bleed rate greater than 6 scfh. Additionally, none of the storage tanks onsite commenced construction after August 23, 2011. Therefore, at this time, the source is not subject to any of the provision of Subpart OOOO. NESHAP Subpart ZZZZ 40 CFR Part 63 Subpart ZZZZ, also known as the RICE MACT, applies to both new and existing engines of all sizes located at area sources of HAPs. Under the rule, engines located at area sources are considered existing if construction commenced prior to June 12, 2006. All engines at this facility with the exemption of engine C-115 are considered existing engines and must comply with the requirements of the subpart, which include formaldehyde emissions standards, by October 19, 2013. Engine C-115 is considered a new engine under the rule. As specified in §63.6590(c), new or reconstructed RICE located at area sources must meet the requirements of Subpart ZZZZ by meeting the requirements in 40 CFR Part 60 Subpart JJJJ and no further requirements apply under 40 CFR Part 63 Subpart ZZZZ. Colorado Regulation No. 7 The Lucerne facility is located in an area designated as nonattainment for ozone and is subject to the nonattainment area rules in Colorado Regulation No. 7, Section XVI accordingly. All engines at the facility are subject to Section XVI.B.2, which requires the installation of an oxidation catalyst. Engines C-105 through C-109 are subject to the catalytic control requirements of Colorado Regulation No. 7, Section XVII.E.3 for existing engines. Engines C-110, C- 112, C-113, and C-115, since located in Colorado after the applicability date, are subject to the emission standards for new engines in Section XVII.E.2. While Reg 7 Section XVII.B.4 exempts units that are subject to NSPS or MACT control requirements from the provisions of Section XVII.E, all engines, except C-115, which are subject to control requirements under the reciprocating internal combustion engine NESHAP Subpart ZZZZ are not required to comply with these limitations until October 19, 2013. Until the MACT requirements become effective, those engines are subject 123/0107 Page 4 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit to the requirements in Reg 7, Section XVII.E.3.b.(i) to install and operate an oxidation catalyst. Engine C-115 is presently exempt from the requirements since it is currently subject to the requirements from NSPS Subpart JJJJ. The condensate storage tanks at this facility are potentially subject to the requirements in Section XVII.C. The control requirements will apply if uncontrolled actual VOC emissions from the tanks should exceed 20 tons per year. Greenhouse Gases The potential -to -emit of greenhouse gas (GHG) emissions from this facility is less than 100,000 TPY CO2e. Future modifications greater than 100,000 TPY CO2e may be subject to regulation (Regulation No. 3, Part A, 1.6.44). Source Determination With this permit action, the Division revisited the source determination in regards to the natural gas operations in the area surrounding the Lucerne processing plant to verify that the proper pollutant emitting activities are included in this permit as part of the Lucerne processing plant. The applicant did not identify any other pollutant emitting activities in the vicinity of Lucerne that are dependent upon the facility to maintain operations. The Division considers the current determination for this facility to be accurate, and the proper pollutant emitting activities are included in this permit. IV. Modifications Requested by the Source The renewal application received on March 30, 2012 requested the following: • Incorporate the most recent issuance of the construction permits 96WE905, for the fugitive emissions and engines, and 08WE0920 and 08WE0921, for the amine sweetening unit and the associated reboiler. • Correct errors as identified on the self certification for the permits listed above, as submitted on May 12, 2011. The self certification requested corrections to the engine emission limitations listed, the applicability of NESHAP Subpart ZZZZ, and the removal of outdated NSPS Subpart KKK conditions. The self certification also requested a modification to permit 08WE0920 to reflect the actual configuration of the amine system as well as the use of a proprietary amine solution rather than DGA. The change to the amine unit was incorporated into the most recent issuance of construction permit 08WE0920 on August 30, 2011. • Remove engine C-244 from the permit. This engine was never constructed. • Rename the engine C-178. The engine is more commonly identified as C-115. • Several engines were replaced under the provisions of the AOS. APENs were submitted to the Division for each of these replacements. • Include the applicable provisions for the emergency flare. 123/0107 Page 5 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit The source's requested modifications were addressed as follows: Section I — General Activities and Summary • The description of permitted activities in Condition 1.1 and the summary table in Condition 6.1 were revised to account for the new equipment. Section II — Specific Permit Terms • The initial reporting requirements from NSPS Subpart KKK have been removed from the specific conditions for fugitive emissions from equipment leaks. This one-time requirement has already been fulfilled. • Facility -wide annual HAP emission limitations were included in the permit. A specific condition was included for each unit with potential HAP emissions above reportable levels. • The appropriate applicable requirements from the initial approval of modification 1 to construction permit 96WE905, issued February 3, 2010, have been incorporated into the operating permit. According to the Division's database, self -certification for this permit was received on May 12, 2011. The source has demonstrated compliance under the provisions of Regulation No. 3, Part B, Section III.G.2 for initial approval construction permit 96WE905 but has not yet received a final approval construction permit. Under the provisions of Regulation No. 3, Part C, Section V.A.3, the Division will not issue a final approval construction permit and is allowing the initial approval construction permit to continue in full force and effect. The provision have been included with the following changes: o Conditions 1 through 4 were not included in the operating permit, as the requirements in these conditions have already been fulfilled. o The annual emission limitation for insignificant activity in Condition 5 was not included in the operating permit. The intent of this condition is to assure that the major stationary source threshold has not been exceeded. Since this determination is based on potential emissions, and not actual emissions, the tracking of actual emission from insignificant activity is not necessary. At the time of operating permit issuance, the facility wide potential emissions, including those from insignificant activities, were below the PSD major stationary source threshold of 250 tons per year for CO. The facility is already considered a major stationary source for nonattainment NSR for NOx and VOC, since potential emissions exceed the 100 tons per year threshold. To fulfill the intent of this condition, a requirement was added to the operating permit requiring the source to recalculate the facility wide potential to emit, including insignificant activities, with each addition (or modification) of an insignificant emission unit. 123/0107 Page 6 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit • The appropriate applicable requirements from the final approval construction permit 08WE0920, issued August 30, 2011, for the amine sweetening unit, have been incorporated into the operating permit with the following changes: o Condition 2: The annual emission limitation for NOx was removed. The uncontrolled potential emissions of NOx are below the APEN permitting threshold. o Condition 4: The requirement to install controls to meet the emission limits was not included. A description of the control system was included in the summary of emission units in Section I, Condition 6.1. The annual emission limitations incorporate the use of the control equipment described in the construction permit. o Condition 7: This is a construction permit only requirement and has already been fulfilled and was not included in the operating permit. o Condition 8: The thermal oxidizer is subject to the flare opacity requirement in Reg. 1, which was included in the operating permit. o Condition 11: The requirement to maintain an external O&M plan was removed. The Promax parameter monitoring requirements were included directly in the operating permit. • CAM requirements were added for the amine unit, which is controlled by a thermal oxidizer. The requirements for monitoring design criteria in 40 CFR Part 64.3(b)(4)(iii) specify that for a small pollutant specific emission unit, only one indicator is needed recording data at a minimum of once daily. The Division chose combustion chamber temperature as an indicator. A minimum temperature threshold of 1400°F, as was required by the Division -approved O&M plan, will be used to monitor the performance of the thermal oxidizer. • Initial approval of construction permit 08WE0921 was issued February 3, 2010. According to the Division's database, self -certification for this permit was received on May 12, 2011. The source has demonstrated compliance under the provisions of Regulation No. 3, Part B, Section III.G.2 for initial approval construction permit 08WE0921 but has not yet received a final approval construction permit. Under the provisions of Regulation No. 3, Part C, Section V.A.3, the Division will not issue a final approval construction permit and is allowing the initial approval construction permit to continue in full force and effect. The appropriate applicable requirements from the initial approval construction permit have been incorporated into the renewal operating permit with the following changes: o Conditions 1 — 5: These conditions have already been fulfilled or, in the case of the requirement to self -certify, will be fulfilled through the Title V process, as mentioned above. As such, these conditions were not included in the operating permit. 123/0107 Page 7 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit o Condition 6: The annual VOC emission limitation was not included in the operating permit as uncontrolled potential emissions are below the reporting threshold in Regulation No. 3, Part A. o Condition 11: The particulate matter emission standard from Regulation No. 6, Part B, Section II.C.2 was streamlined from the permit and the more stringent requirement from Regulation No. 1, Section III.A.1 was included in the specific conditions of the operating permit. o Condition 12: The requirement to operate low NOx burners to meet the emission limits was not included. A description was included in the summary of emission units in Section I, Condition 6.1. The annual emission limitations incorporate the use of the equipment described in the construction permit. • The emergency flare is subject to the requirements of NSPS Subpart A, as it controls emissions from fugitive leaks as required by NSPS Subpart KKK. The appropriate applicable requirements were included in the body of the permit, as requested by the applicant. The flare is to be considered part of the fugitive emissions point and will not require its own APEN. Appendices • The CAM plan for the amine unit was added to Appendix G. V. Other Modifications In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows: • Throughout the permit the specific conditions were restructured and reworded to more closely agree with recently issued DCP operating permits. Page Following Cover Page • It should be noted that the monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). Section I — General Activities and Summary 123/0107 Page 8 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit • Revised the language in Condition 1.4 include current conditions that are state - only enforceable. • Updated the alternative operating scenarios in Condition 2 to the most current version (10/12/2012). Section II — Specific Permit Terms • The duplicative requirement to conduct physical component counts has been removed in Condition 1.1. • Updated the portable monitoring language to the current version (10/12/2012) which includes a new link to the CDPHE website. • The serial number reporting requirement for engine C-115 (nee C-178) was removed as this one-time requirement has already been fulfilled. • The initial compliance testing requirements for the engines have been removed as the testing has already been conducted. • The requirement to follow an external operating and maintenance plan was removed from the permit. The specific conditions applicable to the equipment were added directly to the operating permit. o The previous operating and maintenance requirements for the engines at this facility required the pressure drop across the catalyst to be kept within 3 inches water column from the baseline. The engines are subject to the requirements of Subpart ZZZZ which requires a range of 2 inches. For consistency, the Division will also require this range, since the MACT monitoring is presumptively acceptable. Additionally, the newest version of the Division's O&M plans specify 2 inches. • The calculations condition was removed from the permit and the specific calculation methodology was included under the specific conditions for each emission unit. Section III — Permit Shield • Several specific non -applicable conditions were removed from the permit shield. Conditions removed either were applicable to the facility or unrelated to the operation of the facility. • The less stringent state -only requirements applicable to the engines from Regulation No. 7, Section XVII were streamlined from the permit. Section IV — General Permit Conditions • Updated the general permit conditions to the current version (5/22/2012) Appendices 123/0107 Page 9 of 10 DCP Midstream, LP — Lucerne Gas Processing Plant Operating Permit No. 95OPWE100 Technical Review Document — Renewal Operating Permit • Cleared the list of modifications from Appendix F related to the previous issuance. 123/0107 Page 10 of 10 Colorado Department of Public Health and Environment OPERATING PERMIT DCP Midstream, LP Lucerne Gas Processing Plant Issued: November 1, 1998 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: FACILITY ID: RENEWAL DATE: EXPIRATION: MODIFICATIONS: Lucerne Gas Processing Plant 1230107 DRAFT DRAFT See Appendix F of Permit OPERATING PERMIT NUMBER 95OPWE100 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq and applicable rules and regulations. ISSUED TO: DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80202 INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: PLANT SITE LOCATION: 31495 Weld County Road 43 Lucerne, CO Weld County March 30, 2012 Nature of Business: Natural Gas Liquids Processing and Gathering Primary SIC: 1321 RESPONSIBLE OFFICIAL Name: Joseph Kuchinski Title: VP Arca Operations North Phone: (970) 378-6345 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: Semi -Annual Monitoring Report: Annual Compliance Period: Annual Compliance Certification: Note that the Semi -Annual Monitoring reports and the Annual Compliance report must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports, FACILITY CONTACT PERSON Name: Brian S. Taylor Title: Rockies Air Permitting Manager Phone: (303) 605-2185 January 1 June 30, July 1 December 31 August 1, 2010 & February 1, 2011 and subsequent years January 1 — December 31 February I, 2011 and subsequent years Table of Contents SECTION I - General Activities and Summary I. Permitted Activities 2. Alternative Operating Scenarios (ver 10/12/2012) 2 3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 8 4. Accidental Release Program (112(r)) 9 5. Compliance Assurance Monitoring (CAM) 9 6. Summary of Emission Units 10 SECTION II - Specific Permit Terms 11 1. P007 - Fugitive VOC Emissions from Equipment Leaks 11 2. C-106, C -I 10, C-107, C-109, C -I 12, C-113, C-108 - Waukesha 1,232 HP Natural Gas -Fired Internal Combustion Engines equipped with NSCR 13 C-105 Waukesha 1,478 HP Compressor Engine equipped with NSCR 15 3. C -I 15 — Waukesha 1,380 11P Compressor Engine with NSCR 22 4. AUOI -- Exterran Amine Sweetening Unit with VRU and Thermal Oxidizer 28 5. HTOI — 16 MMBtu/hr Natural Gas Fired Amine Regeneration Heater 31 6. H001 - 6 MMBtu/Hr Natural Gas Fired Regeneration Heater 34 7. Facility Wide 35 8. Portable Monitoring (ver 10/12/2012) 37 9. Compliance Assurance Monitoring 38 SECTION III - Permit Shield 44 1. Specific Non -Applicable Requirements 44 2. General Conditions 44 3. Stream -lined Conditions 45 SECTION IV - General Permit Conditions (ver 5/22/2012) 1 1. Administrative Changes 2. Certification Requirements 1 3. Common Provisions 1 4. Compliance Requirements 5 5. Emergency Provisions 6 6. Emission Controls for Asbestos 6 7. Emissions Trading, Marketable Permits, Economic Incentives 6 8. Fee Payment 6 9. Fugitive Particulate Emissions 7 10. Inspection and Entry 7 11. Minor Permit Modifications 7 12. New Source Review 7 13. No Property Rights Conveyed 7 14. Odor 7 15. Off -Permit Changes to the Source 8 16. Opacity 8 17. Open Burning 8 18. Ozone Depleting Compounds 8 19. Permit Expiration and Renewal 8 20. Portable Sources 8 Table of Contents 21. Prompt Deviation Reporting 8 22. Record Keeping and Reporting Requirements 9 23. Reopcnings for Cause 10 24. Section 502(6)(10) Changes 10 25. Severability Clause 10 26. Significant Permit Modifications I I 27. Special Provisions Concerning the Acid Rain Program 11 28. Transfer or Assignment of Ownership II 29. Volatile Organic Compounds I I 30. Wood Stoves and Wood burning Appliances 12 APPENDIX A - Inspection Information 1 Directions to Plant : 1 Safety Equipment Required : 1 Plant Plot Plan • I List of Insignificant Activities • I APPENDIX B Reporting Requirements and Definitions Monitoring and Permit Deviation Report - Part I 5 Monitoring and Permit Deviation Report - Part II 7 Monitoring and Permit Deviation Report - Part III 9 APPENDIX C I Required Format for Annual Compliance Certification Report (ver 2/20/07) 1 APPENDIX D Notification Addresses APPENDIX E Permit Acronyms APPENDIX F Permit Modifications APPENDIX G I Compliance Assurance Monitoring Plan - Engines 1 Compliance Assurance Monitoring Plan Amine Sweetening Unit and Glycol Dehydrator 4 APPENDIX H I Applicability Reports 1 Air Pollution Control Division Colorado Operating Permit Permit H 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page I SECTION I - General Activities and Summary 1. Permitted Activities The Lucerne Gas Processing Plant is a natural gas processing plant. Natural gas is delivered to the plant by pipeline. Field gas is first charged to a separator where liquids formed during transport to the plant are separated from the gas stream. The gas stream discharged from the separator is processed through an amine unit to remove CO2 and then a molecular sieve contact tower, where moisture contained in the gas stream is absorbed. After the molecular sieve has removed the moisture in the gas, the gas stream is fed to the processing plant, where it is chilled by a propane refrigeration system. Natural gas liquids formed during this process are transported offsite by truck. The process uses nine reciprocating internal combustion engines, two natural gas processing skids, an amine unit, and an amine reboiler. Fugitive emissions from equipment leaks are also present at this facility. The plant is located near Lucerne in Weld County, Colorado. The area in which the plant operates is classified as attainment for all pollutants except ozone. It is classified as non - attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.16. Wyoming is an affected state within 50 miles of the plant. Rocky Mountain National Park is a Federal Class I designated areas within 100 kilometers of the plant. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this plant in accordance with the requirements, limitations, and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section I1) from the following Colorado Construction Permit(s): 96WE905, 04WE1301, 04WE1302, 05WE0958, 07WE0021, 07WE0979, 08WE0920, 08WE0921. 1.4 All conditions in this permit are enforceable by the US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Section IV, 3.g (last paragraph), 14 and 18 (as noted). Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records arc acceptable. 2. Alternative Operating Scenarios (ver 10/12/2012) 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. 2.1 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 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 arc subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit. 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 2.1.2 and make them available to the Division upon request. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit 4 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 3 2.1.1 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 temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of NO, and CO from the temporary replacement engine must be less than or equal to the potential annual emissions of NO„ and CO from the original grandfathered or permit exempt engine or for the engine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP -42 or manufacturer's emission factors). 2.1.2 The permittee may permanently replace the existing compressor engine for the emission points specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table I without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. 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. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non -Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found in Appendix A. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEl00 DCP Midstream, LP Lucerne Gas Processing Plant Page 4 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. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacemcnt(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements, 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website: htgi: www,Colorado. 0 csSatellite 'CDPIIF.-AP CRON 1251596520271). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/MMBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) 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 Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OP W E 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 5 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 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.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 PMi0 attainment/maintenance area, RACT applies to PMio at any level of emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural- gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOx: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM lo 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. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and X V I I. E (State -Only conditions). Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 6 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. 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 copies of the relevant Applicability Reports required under Condition 2.1.2. 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 HP Construction or Relocation Date Emission Standards in 6/hp-hr NOx CO VOC 100<Hp<500 January I, 2008 2.0 4.0 1.0 January 1, 201 1 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July I, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 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 bum engines greater than or equal to 500 hp and less than 1,350 hp arc subject to the requirements of 40 CFR Part 60, Subpart JJJJ. Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 7 An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. 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 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 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 October 1, 2011 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, ,$1.5 (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. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. 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 2.1.2. 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 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.3.5 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. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OP WE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 8 Table I Internal Combustion Engine Information For AOS Emission Point Replacement Engine Periodic Monitoring Subject to CAM? C -I 05 Waukesha, Model L-7042GSI, 4 -Cycle Rich Burn Internal Combustion Engine, Rated at 1,478 HP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C -I06 Waukesha, Model L-7042GSI, 4 -Cycle Rich Burn Internal Combustion Engine, Rated at 1232 IIP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C-107 Waukesha, Model L-7042GSI, 4 -Cycle Rich Burn Internal Combustion Engine, Rated at 1.232 IIP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C -I 08 Waukesha, Model L -7042G51, 4 -Cycle Rich Burn Internal Combustion Engine. Rated at 1.232 HP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C-109 Waukesha, Model L -7042G51, 4 -Cycle Rich Bum Internal Combustion Engine. Rated at 1,232 IIP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C -I10 Waukesha. Model I.,7042GSI, 4 -Cycle Rich Burn Internal Combustion Engine, Rated at 1,232 HP (Site). Natural Gas Fired. Equipped with NSCR and APR. Portable Monitoring Quarterly Yes C -I12 Waukesha. Model L-7042GSI. 4 -Cycle Rich Burn Internal Combustion Engine. Rated at 1232 HP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes C -I13 Waukesha, Model L-7042GS1, 4 -Cycle Rich Burn Internal Combustion Engine. Rated at 1232 IIP (Site). Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yea C -I 15 Waukesha. Model l.5794GSI. 4 -Cycle Rich Burn Internal Combustion Engine, Rated at 1.38(1 HP (Site) Natural Gas Fired. Equipped with NSCR and AFR. Portable Monitoring Quarterly Yes 3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which is major by itself (i.e. a Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. 3.2 Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit Any future modification which is Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 9 major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.3 There arc no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. 4. Accidental Release Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). 4.2 The Risk Management Plan required by the Act was submitted to the appropriate authority and/or a designated central location by June 20, 1999. 4.3 The source shall certify to the Division in writing that the source is in compliance with all requirements of 112(r) and that the Risk Management Plan has been submitted to the appropriate authority and/or a designated central location. Such certification shall be signed by the Responsible Official. 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: C-105, C-106, C-107, C-108, C-109, C-110, C -I 12, C -I 13 - Waukesha Model L-7042GSI ICE C-115 - Waukesha Model L-5794 GSI ICE AU01 - 40 MMscfd Amine Unit Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 10 6. Summary of Emission Units 6.1 The emissions units regulated by this permit arc the following: AIRS Stack Number Plant Identifier Description Pollution Control Device Construction Permit 014 P007 Gas Plant Fugitive Emissions LDAR 96WE905 015 C-106 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Bum w/ air/fuel ratio controller, Serial No. 266454; powering an inlet natural gas compressor, 1232 HP Non -Selective Catalytic Reduction 96WE905 017 C -I 10 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Bum w/ air/fuel ratio controller, Serial No. 360657; powering a residual natural gas compressor, 1232 HP Non -Selective Catalytic Reduction 96WE905 018 C-107 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. 327597; powering an inlet natural gas compressor, 1232 HP Non -Selective Catalytic Reduction y 96W 19115 019 C-109 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. 263183; powering a residual natural gas compressor, 1232 IIP Non -Selective Catalytic Reduction y 96W F.905 024 C -I 12 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. 380839; powering an inlet natural gas compressor, 1232 HP Non -Selective Catalytic Reduction 04WEI301 025 C -I 13 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. 176330; powering an inlet natural gas compressor, 1232 HP Non -Selective Catalytic Reduction y 04WP.1302 029 C -I08 Waukesha Model 1.-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. 240602; powering a residual natural gas compressor, 1232 HP Non Selective Catalytic Reduction 05WE0958 032 C -I05 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. C -17495-I; powering a refrigeration unit, 1478 HI' Non -Selective Catalytic Reduction 07WL'002I 033 C-115 Waukesha Model L-5794 GSI Natural Gas Fired Internal Combustion Engine, 4 -cycle, Standard Rich Burn w/ air/fuel ratio controller, Serial No. C-17419-1; powering an inlet gas compressor, 1380 HP Non -Selective Catalytic Reduction 07WE0979 042 AU01 Exterran Item 4103,15 amine natural gas sweetening system for acid gas, 40 MMscf per day capacity. This system includes a 175 gpm amine pump, natural gas/amine contactor, a flash tank, and an amine rwlaimcr. Flash Tank: VRU, Thermal Oxidizer as Backup Still Vent: Thermal Oxidizer 08WE0920 043 HT01 Amine regeneration heater equipped with low NOx burners, rated at 16 MMBtWhr 08 W F11921 030 H-101 Regeneration boiler, rated at 6 MMBtu/Ilr 05WE0959.xp xp Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 11 SECTION II - Specific Permit Terms 1. P007 - Fugitive VOC Emissions from Equipment Leaks Parameter Permit Condition Number Limitations Emission Factor Monitoring Method Interval VOC I. 13.78 tons/yr By Component -EPA Protocol for Equipment Leak Estimates Rccordkeeping and calculation Semi - Annually Gas Analysis EPA/Division Approved Methods Annually Leak Detection and Repair 1.2 As defined by approved plan per Subpart KKK NSPS General Provisions 1.3 See Condition 1.3 1.1 VOC emissions shall not exceed the limitations above (Colorado Construction Permit 96WE905). Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lb/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA -453/R-95-017 . These emission factors are fixed until changed by established permit modification procedures. Component Emission Factors (lb/component-hr) Gas Service Light Liquid Valves 9.92 x 103 5.51 x 10-3 Connectors 4.41 x 104 4.63 x 10' Flanges 8.60 x 1014 2.43 x l0-° Pump Seals 5.29 x 103 2.87 x l0' Other* 1.94 x 10-2 1.65 x 10-2 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods, and vents. Calculation of annual emissions of VOC per component: Component count X 8760 hrs/year X Weight %VOC X Emission Factor X (I - Control Factor) The total fugitive VOC emissions shall be the sum of the emissions from each type of component. For determining compliance the Division accepted the use of a 75 percent (%) control factor for all components except the flanges/connectors. For the flanges/connectors the Division accepted the use of a 30 percent (%) control factor. These control factors may be used when estimating emissions for P007. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 12 1.1.1 A plant inlet gas analysis shall be performed according to appropriate ASTM or EPA approved methods at least once per calendar year. The dates of the annual inlet gas analyses shall be separated by at least two (2) calendar months. The most recent inlet gas analysis shall be used to determine the appropriate Weight %VOC to use in the above equation. 1.1.2 The annual emission limit was based on the following component count, which includes a 10% buffer: Component Component Count Gas Service Liquid Service Valves 1597 741 Connectors 1718 1084 Flanges 692 359 Pump Seals 12 Other* 88 12 VOC Content (wt%) 30 100 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms. drains, dump arms, hatches, instrument meters, polish rods, and vents. 1.1.3 Records shall be kept of all component additions and deletions and running tally maintained and made available to the Division upon request. An actual physical hard count of the existing components shall be performed at least once every five years. 1.2 This source is subject to 40 CFR Part 60 Section 60.630, Subpart KKK, New Source Performance Standards (NSPS) (Adopted into Colorado Regulation No. 6, Subpart KKK): "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants". The following items apply: 1.2.1 Inspection and maintenance requirements as stated in Federal NSPS 40 CFR Part 60 §60.632, §60.633, and §60.634. 1.2.2 Record keeping requirements as stated in Federal NSPS 40 CFR Part 60 §60.635. 1.2.3 Reporting requirements as stated in Federal NSPS 40 CFR Part 60 §60.636. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. 1.3 Regulation No. 6, Part A, General Provisions applies as follows: 1.3.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 13 opacity standard or with a standard which is based on the concentrations of a pollutant in the gasses discharged to the atmosphere (40 CFR Part 60 §60.12) 1.3.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR Part 60 §60.7. 2. C-106, C-107, C-109, C-108 - Waukesha 1,232 HP Natural Gas -Fired Internal Combustion Engines equipped with NSCR NOTE: The followine terms and conditions aanly to each engine senaratel Parameter Permit Condition Number Limitations emission Factor (Ib/MMBtu) Monitoring Method Interval NON 2.1 23.79 tons/year 0.577 Recordkeeping and Calculation 12 month rolling total Month4 CO 23.79 tons/year 0.577 VOC 2.2 11.90 tons/year 0.289 HAP 2.3 Single: 8 tons/year Combined: 20 tonslycar AP -42 Portable Monitoring 2.1.3 Flue Gas Analyzer Quarterly Natural Gas Consumption 2.4 79.18 MMscflycar Plant Fuel Meter 12 month rolling total Monthly Btu Heat Content 2.5 ASTM or other Division - Approved Method Semi -Annually Operating Flours 2.6 Rccordkeeping Monthly Opacity 2.7 Except as provided below, not to exceed 20% Fuel Restriction Only Natural Gas is Used as Fuel During startup, not to exceed 30% Control Device 2.8 Sec Condition 2.8 See Condition 2.8 NESHAP Subpart ZZZZ 2.9 I.imit Formaldehyde concentrations to 2.7 ppmvd (41 15% O2 or Reduce Formaldehyde by 76% Scc Condition 2.9 NESHAP 2.10 Subpart A See Condition 2.10 Compliance , 2.11 Assurance Monitoring See Condition l0 Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE10O DCP Midstream, LP Lucerne Gas Processing Plant Page 14 C-110, C-112 and C-113 - Waukesha 1,232 HP Natural Gas -Fired Internal Combustion Engines equipped with NSCR NOTE: The following terms and conditions apply to each engine separated Parameter Permit Condition Number Limitations Emission Factor (Ib/MMBtu) Monitoring Method Interval NOx 2.1 11.90 tons/year 0.289 Rccordkecping and Calculation 12 month rolling total Monthly CO 8.33 tons/year 0.202 VOC 2.2 11.90 tons/year 0.289 HAP 2.3 Single: 8 tons/year Combined: 20 tons/year AP -42 Portable Monitoring 2.1.3 Flue Gas Analyzer Quarterly Natural Gas Consumption 2.4 79,18 MMsct year Plant Fuel Mctcr 12 month rolling total Monthly Btu Heat Content 2.5 ASTM or other Division - Approved Mcthod Semi -Annually Operating Hours 2.6 Recordkecping Monthly Opacity 2.7 Except as provided below, not to exceed 20% Fuel Restriction Only Natural Gas is Used as Fuel During startup, not to exceed 30% Control Device 2.8 See Condition 2.8 Sec Condition 2.8 NESHAP Subpart ZZZZ 2.9 Limit Formaldehyde concentrations to 2.7 ppmvd fii 15% O. or Reduce Formaldehyde by 76% Sec Condition 2.9 NESHAP Subpart A 2.10 Sec Condition 2.10 Compliance Assurance Monitoring 2 I 1 Sec Condition 10 Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 15 C-105 — Waukesha 1,478 HP Compressor Engine equipped with NSCR Parameter Permit Condition Number Limitations Emission Factor (lb/MMBtu) Monitoring Method Interval NOx 2.1 28.54 tons/year 0.565 Recordkccping and Calculation 12 month rolling total Monthly CO 28.54 tons/year 0.565 VOC 2.2 14.27 tons/year 0.282 HAP 2.3 Single: 8 tons/year Combined: 20 tons/ycar AP -42 Portable Monitoring 2.1.2 Flue Gas Analyzer Quarterly Natural Gas Consumption 2.4 97.10 MMscPycar Plant Fuel Meter 12 month rolling total Monthly Btu Heat Content 2.5 ASTM or other Division - Approved Method Semi -Annually Operating Hours 2.6 Recordkceping Monthly Opacity Except as provided below, not to exceed 20% Fuel Restriction Only Natural Gas is Used as Fuel During startup, not to exceed 30%% Control Device 2.8 Sec Condition 2.8 See Condition 2.8 NESHAP Subpart ZLZL 2.9 limit Formaldehyde concentrations to 2.7 ppmvd (ai 15% O. or Reduce Formaldehyde by 76% See Condition 2.9 NESHAP Subpart A 2.10 Sec Condition 2.10 Compliance Assurance Monitoring 2.11 Sec Condition 10 2.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations stated in the tables above (Colorado Construction Permits 96WE905, 04WE1301, 04WEI302, 05WE0958, and 07WE0021). Except as provided below, the emission factors listed above have been approved by the Division and shall be used to calculate emissions from these engines. Compliance with the emission limitations shall be monitored as follows: 2.1.1 Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the natural gas consumption (as required by Condition 2.4) and Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 16 the Btu content of the natural gas (as required by Condition 2.5) in the following equation: tons/mo — JEF (lbs/MMBtu) x natural gas consumption (MMscf/year) x heat content of fuel (Btu/sell( 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.1.2 If the results of the portable analyzer testing conducted under the provisions of Condition 2.1.3 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 2.1.3 Portable monitoring shall be conducted quarterly as required by Condition 9 2.2 Emissions of Volatile Organic Compounds (VOC) from each engine shall not exceed the annual emission limitation stated in the tables above (Colorado Construction Permits 96WE905, 04WE1301, 04WE1302, 05WE0958, and 07WE0021). Monthly emissions shall be calculated by the end of the subsequent month using the VOC emission factor in the table above, the monthly natural gas consumption (as required by Condition 2.4) and the Btu content of the natural gas (as required by Condition 2.5) in the following equation: tons/mo = f EF (lbs/MMBtu) x natural gas consumption (MMsct1year) x heat content of fueljBtu/scf)j 2000 Ib/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.3 Facility wide emissions of Hazardous Air Pollutants (HAP) shall not exceed the above limitations. Compliance with the facility wide HAP limits shall be monitored by calculating monthly emissions of individual HAP above the de minimis reporting level by the end of the subsequent month. Emissions of individual HAP from each engine shall be calculated using AP -42 emission factors (AP -42, Section 3.2, dated 7/00, Table 3.2-2), the monthly natural gas consumption (as required by Condition 2.4), the Btu content of the natural gas (as required by Condition 2.5) and an assumed 50% control efficiency in the equation below: tons/mo = JEF (Ib/MMBtu) x fuel use (MMscf/mo) x Btu consent of gas (MMBtu/mo) x (0.5)] 2000 lb/ton Monthly HAP (individual HAP and total HAP) emissions from each engine shall be used in a twelve month rolling total of facility wide emissions as specified in Condition 8.1. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 17 2.4 Natural gas consumption from each engine shall not exceed the limitation in the tables above (Colorado Construction Permits 96WE905, 04WE1301, 04WE1302, 05WE0958, and 07WE0021). Facility -wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured on the same day that run time hours have been recorded in accordance with Condition 2.6. Allocation of natural gas to each engine will be calculated using the following calculation: Fuel Consumption (Design Heat Rate (hp -hr) Hours of Operation (—hr) Site Rated ❑ w Btu orsepoer (hp)) 7(nesign Iteat Rate ( r) A I lours of Operation (—hr) Site Rated I iorsepower(hp) Btumo + (Design Ilea) Rate (NI Mnmj flours of Operation (mn)) lb h alo Total Facility Fuel Use Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly natural gas consumption from each engine shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 2.5 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually, or once every six months, using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 2.6 Hours of operation of each engine shall be recorded for each calendar month. Records shall be made available for Division review upon request. 2.7 Visible emissions shall not exceed 20% opacity (Colorado Regulation No. 1, Section II.A.1) except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each engine. In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for these engines. 2.8 Each engine shall be equipped with both a non -selective catalytic reduction system and an air fuel controller (Colorado Regulation No. 7 Section XVI.B. I). Parameters associated with the air -to -fuel ratio controller (AFR) and non -selective catalyst reduction unit shall be monitored as follows: 2.8.1 The pressure drop across the catalyst shall be monitored and recorded monthly. The pressure drop shall not exceed 2 inches of water column from the baseline value established by the source when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during each initial compliance and portable analyzer test, and as noted below. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page I S If the pressure is outside this range then the appropriate maintenance shall be performed to bring the pressure back into range. In lieu of maintenance the source may choose to perform a portable analyzer test of the engine to establish a new pressure drop value. If the test demonstrates that the engine is in compliance with its emission limits, the pressure drop value at which the engine is tested shall become the new baseline. The catalyst will be cleaned, reconditioned and replaced per the manufacturer's recommended schedule and a copy of maintenance reports shall be kept for Division review upon request. For new, cleaned or reconditioned catalyst: the new pressure drop baseline must be established by the operator within the first 7 days of engine/catalyst operation and re-established during the next regularly scheduled emission test. 2.8.2 The catalyst inlet temperature shall be monitored and recorded daily and kept between 750°F and 1250°F. If the temperature is outside of this range then appropriate maintenance activities shall be performed. 2.8.3 Upon compliance with the requirements in Condition 2.9, the monitoring requirements in Conditions 2.8. I and 2.8.2 shall no longer apply. 2.8.4 When portable monitoring is scheduled, the parameters above in Conditions 2.8.1 and 2.8.2 shall be recorded during the portable monitoring event. 2.8.5 The millivolt reading (AFR) for each engine will be monitored and recorded weekly to assess the air to fuel ratio controller operating condition. During those weeks when portable monitoring is scheduled the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFR controlled is operated in accordance with the manufacturer's recommendations. 2.9 [Federal -Only] These engines arc subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: Note that as of the issuance date of this permit [DATE], the provisions in 40 CFR Part 63 Subpart ZZZZ (those provisions published in the August 20, 2010 Federal Register) have not been adopted in Colorado Regulation No. 6, Part A and Colorado Regulation No. 8, Part E and are therefore not state enforceable. Note: If there is a change in federal law which renders ineffective or alters the applicable requirements of this Subpart ZZZZ, the source shall follow the effective federal rules. 2.9.1 This facility must comply with the applicable limitations no later than October 19, 2013. (§63.6595(a)(1)) 2.9.2 Formaldehyde emission from these engines shall be limited to 2.7 ppmvd at 15% O2 or reduced by 76 percent or more (Table 2d of Subpart ZZZZ, Item 10). Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE I00 DCP Midstream, LP Lucerne Gas Processing Plant Page 19 2.9.3 For the non -selective catalytic reduction device installed to meet the requirement in Condition 2.9.2, the following operating requirements shall apply: (Table 1b of Subpart ZZZZ, Item I) 2.9.3.1 Maintain each 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 measured during the initial performance test and 2.9.3.2 Maintain the temperature of each engine's exhaust so the catalyst inlet temperature is greater than or equal to 750°F and less than or equal to 1250°F. Performance Tests 2.9.4 Initial performance tests must be conducted within 180 days after the compliance date specified in Condition 2.9.1 according to the provisions of §63.7(a)(2). (§63.6612(a)) 2.9.4.1 An initial performance test is not required on a unit which a performance test has previously been conducted, provided the test meets the conditions described in §63.6612(b)(1) through (4).(§63.6612(6)) 2.9.5 Performance tests must be conducted using the appropriate ASTM methods or equivalent, if approved in advance by the EPA, as described in Table 4 to Subpart ZZZZ, according to the following protocol: 2.9.5.1 Select the sampling port location and the number of traverse points a. Sampling sites must be located at the inlet and outlet of the control device 2.9.5.2 Measure O, at the inlet and outlet of the control device a. Measurements to determine O2 concentration must be made at the same time as the measurements for formaldehyde concentration 2.9.5.3 Measure moisture content at the inlet and outlet of the control device a. Measurements to determine moisture content must be made at the same time and location as the measurements for formaldehyde concentration 2.9.5.4 Measure formaldehyde at the inlet and the outlet of the control device a. Formaldehyde concentration must be at 15 percent O,, dry basis. Results of this test consist of the average of the three 1 -hour or longer runs Demonstrating Compliance 2.9.6 Initial compliance with the requirement to limit concentration or reduce formaldehyde emissions in Condition 2.9.2 is demonstrated by achieving the following: 2.9.6.1 The average reduction of emissions of formaldehyde determined from the initial performance test is equal to or greater than the required formaldehyde percent Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 20 reduction or the average formaldehyde concentration, corrected to 15% O2, dry basis, from the initial performance test is less than or equal to the emission limitation; (Table 5 of Subpart ZZZZ, Item 7.a.i or 10.a.i) and 2.9.6.2 A CPMS has been installed to continuously monitor catalyst inlet temperature according to the requirements in §63.6625(b); (Table 5 of Subpart ZZZZ, Item 7.a.ii or 10.a.ii) and 2.9.6.3 The catalyst pressure drop and catalyst inlet temperature have been recorded during the initial performance test. (Table 5 of Subpart ZZZZ, Item 7.a.iii or 10.a.iii) 2.9.7 Demonstrate continuous compliance with the limitations in Condition 2.9.2 using the following methods described in Table 6 of Subpart ZZZZ. (§63.6640(a)): 2.9.7.1 Conduct performance tests according to Condition 2.9.5 every 8,760 hours or 3 years, whichever comes first, to demonstrate that the required formaldehyde concentration or percent reduction is achieved; (Table 6 of Subpart ZZZZ, Item 10.a.i) and 2.9.7.2 Collect the catalyst inlet temperature data according to §63.6625(b); (Table 6 of Subpart ZZZZ, Item 10.a.ii) and 2.9.7.3 Reduce these data to 4 -hour rolling averages; (Table 6 of Subpart ZZZZ, Item 10.a.iii) and 2.9.7.4 Maintain the 4 -hour rolling averages within the operating limitations for the catalyst inlet temperature; (Table 6 of Subpart ZZZZ, Item I0.a.iv) and 2.9.7.5 Measure the pressure drop across the catalyst once per month and demonstrating that the pressure drop across the catalyst is within the operating limitation established during the performance test. (Table 6 of Subpart ZZZZ, Item 10.a.v) Notification and Reporting Requirements 2.9.8 Submit compliance reports semiannually according to the requirements in §63.6650(b). The report must contain the following: 2.9.8.1 If there are no deviations from any emission limitations or operating limitations, include a statement that there were no deviations from the emission limitations or operating limitations during the reporting period. If there were no periods during which the CMS, including CEMS and CPMS, was out -of -control, as specified in §63.8(c)(7), include a statement that there were not periods during which the CMS was out -of -control during the reporting period. (Table 7 of Subpart ZZZZ, Item 1.a) 2.9.8.2 If there is a deviation from any emission limitation or operating limitation during the reporting period, include the information in §63.6650(d). If there were periods during which the CMS, including CEMS and CPMS, was out -of -control, as specified in §63.8(c)(7), include the information in §63.6650(e). (Table 7 of Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 21 Subpart ZZZZ, Item 1.6) 2.9.8.3 If there was a malfunction during the reporting period, include the information in §63.6650(c)(4). (Table 7, Item I.c) 2.9.9 Submit a Notification of Compliance Status according to §63.6645(h). 2.9.10 Submit all notifications that are applicable in §§63.7(b) and (c), 63.8(c), (f)(4) and (t)(6), 63.9(b) through (e), (g) and (h). (§63.6645(a)) 2.9.1 l Keep records of the maintenance conducted on the engine in order to demonstrate that the engine was operated and maintained according to the maintenance plan. (§66.6655(e)). General Requirements 2.9.12 Compliance with the emission limitations and operating limitations in this subpart must be achieved at all times. (§63.6605(a)) 2.9.13 At all times the engines must be operated and maintained in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§63.6605(b)) Maintenance Requirements 2.9.14 Comply with the monitoring, installation, collection, and maintenance requirements in §63.6625. 2.9.15 Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes. (§63.6625(h)) 2.10 [Federal -Only] These engines arc subject to the requirements in 40 CFR Part 63 Subpart A a "General Provisions", Section I as specified in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following: 2.10.1 Prohibited activities and circumvention in § 63.4. 2.10.2 Performance testing in§63.7. 2.10.3 Monitoring in §63.8. 2.10.4 Notification in §63.9. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE1O0 DCP Midstream, LP Lucerne Gas Processing Plant Page 22 2.10.5 Recordkccping and reporting in §63.10. 2.11 The source shall follow the Compliance Assurance Monitoring (CAM) requirements for the engines as outlined in Section II, Condition 10 of this permit. 3. C-115 — Waukesha 1,380 HP Compressor Engine with NSCR Parameter Permit Condition Number Limitations Emission Factor (16/MMBtu) Monitoring Method Interval NOx 3 1 26.70 tons/year 0.578 Rccordkceping and Calculation 12 month rolling total Monthly CO 26,70 tonslycar 0.578 VOC 3.2 13.33 tonslycar 0.288 HAP 3.3 Single: 8 tonsycar Combined: 20 tons/year AP -42 Portable Monitoring 3.1.3 Flue Gas Analyzer Quarterly Natural Gas Consumption 3.4 88.90 MMSct7ycar Plant Fuel Mctcr 12 month rolling total Monthly Btu Heat Content 3.5 ASTM or other Division -Approved Method Semi -Annually Operating Hours 3.6 Recordkceping Monthly Opacity 3,7 Except as provided below, not to exceed 20% Fuel Restriction _ Only Natural Gas is Used as Fuel 3.8 During startup, not to exceed 30% Control Device 3.8 Sec Condition 3.8 Sec Condition NSPS Subpart 1.1.1.1 3.9 NOx: 2.0 gthp-hr CO: 4.0 g -hp -hr VOC :1.0 g//hp-hr Certified Engine or Performance Test 8,670 hours or 3 years, whichever comes first NSPS Subpart A 3.10 Sec Condition 3.10 NFSHAP Subpart ZZZZ 3.11 Compliance with MACT met by complying with NSPS Subpart JJ1J See Condition 3.11 e Compliance Assurance Monitoring 3.12 Sec Condition 10 3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations stated in the table above (Colorado Construction Permit 07WE0979). Except as provided below, the emission factors listed above have been approved by the Division and shall be used to calculate emissions from these engines. Compliance with the emission limitations shall be monitored as follows: Operating Permit Number: 95OP WE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 23 3.1.1 Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the natural gas consumption (as required by Condition 3.4) and the Btu content of the natural gas (as required by Condition 3.5) in the following equation: tons/too=1EF (Ibs/MMBtu) x natural Ras consumption (MMscf/mo) x heat content of fuel (Btu/sclll 2000 Ib/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.1.2 If the results of the portable analyzer testing conducted under the provisions of Condition 3.1.3 show that either the NOx or CO emission rates/factors arc greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 3.1.3 Portable monitoring shall be conducted quarterly as required by Condition 9. 3.2 Emissions of Volatile Organic Compounds (VOC) shall not exceed the annual emission limitation stated in the tables above (Colorado Construction Permit 07WE0979). Monthly emissions shall be calculated by the end of the subsequent month using the VOC emission factor in the table above, the monthly natural gas consumption (as required by Condition 3.4) and the Btu content of the natural gas (as required by Condition 3.5) in the following equation: tons/too = J EF (Ibs/MMBtu) x natural gas consumption (MMsctimo) x heat content of fuel (Btu/sc(ll 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.3 Facility wide emissions of Hazardous Air Pollutants (HAP) shall not exceed the above limitations. Compliance with the facility wide HAP limits shall be monitored by calculating monthly emissions of individual HAP above the de minimis reporting level by the end of the subsequent month. Emissions of individual HAP from the engine shall be calculated using AP - 42 emission factors (AP -42, Section 3.2, dated 7/00, Table 3.2-2), the monthly natural gas consumption (as required by Condition 3.4), the Btu content of the natural gas (as required by Condition 3.5) and an assumed 50% control efficiency in the equation below: tons/mo !FY (Ib/MMBtu) x fuel use (MMscf/mo) x Btu content of gas (MMBtu/mo) x (0.5)1 2000 lb/ton Monthly HAP (individual HAP and total HAP) emissions shall be used in a twelve month rolling total of facility wide emissions as specified in Condition 8.1. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit 4 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 24 3.4 Natural gas consumption shall not exceed the limitation in the table above (Colorado Construction Permit 07WE0979). Facility -wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured on the same day that run time hours have been recorded in accordance with Condition 3.6. Allocation of natural gas to the engine will be calculated using the following calculation: (Design heat Rate �Btu h hr/ x (lours of Operation (mro) x site Rated horsepower (hp)) P- i'dnia.i."ai" Fuel Consumption - \ Total Facility Fuel Use (Design Heat Rate (hpntu hr) I lours of Operation ( hro) x Site Rated Horsepower (hp)) + (Design I teat Rate GM,lb hr MHtu) I lours of Operat ion (m)) Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 3.5 The Btu content of the natural gas used to fuel this engine shall be verified semi-annually, or once every six months, using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 3.6 Hours of operation shall be recorded for each calendar month. Records shall he made available for Division review upon request. 3.7 Visible emissions shall not exceed 20% opacity (Colorado Regulation No. I, Section II.A.I) except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for these engines. 3.8 This engine shall be equipped with both a non -selective catalytic reduction system and an air fuel controller (Colorado Regulation No. 7 Section XVI.B.I). Parameters associated with the air -to - fuel ratio controller (AFR) and non -selective catalyst reduction unit shall be monitored as follows: 3.8.1 The pressure drop across the catalyst shall be monitored and recorded monthly. The pressure drop shall not exceed 2 inches of water column from the baseline value established by the source when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during each initial compliance and portable analyzer test, and as noted below. If the pressure is outside this range then the appropriate maintenance shall be performed to bring the pressure back into range. In lieu of maintenance the source may choose to Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 25 perform a portable analyzer test of the engine to establish a new pressure drop value. If the test demonstrates that the engine is in compliance with its emission limits, the pressure drop value at which the engine is tested shall become the new baseline. The catalyst will be cleaned, reconditioned and replaced per the manufacturer's recommended schedule and a copy of maintenance reports shall be kept for Division review upon request. For new, cleaned or reconditioned catalyst: the new pressure drop baseline must be established by the operator within the first 7 days of engine/catalyst operation and re-established during the next regularly scheduled emission test. 3.8.2 The catalyst inlet temperature shall be monitored and recorded daily and kept between 750°F and 1250°F. If the temperature is outside of this range then appropriate maintenance activities shall be performed. 3.8.3 When portable monitoring is scheduled, the parameters above in Conditions 3.8.1 and 3.8.2 shall be recorded during the portable monitoring event. 3.8.4 The millivolt reading (AFR) will be monitored and recorded weekly to assess the air to fuel ratio controller operating condition. During those weeks when portable monitoring is scheduled the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFR controlled is operated in accordance with the manufacturer's recommendations. 3.9 [Federal -Only] This engine is subject to the requirements of 40 CFR Part 60 Subpart JJJJ "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", including but not limited to the following requirements: Note that as of the date of revised permit issuance [DATE], the requirements in 40 CFR Part 60 Subpart JJJJ have not been adopted into Colorado Regulation No. 6, Part A by the Division and are therefore not state -enforceable. In the event that the Division adopts these requirements, these requirements will become both state and federally enforceable. 3.9.1 This engine must comply with the specific emission limitations shown in the table below: (Table 1 of Subpart JJJJ) Engine Type and Fuel: Non -Emergency SI Natural Gas and LPG Maximum Engine Power: HP ≥ 500 Manufacturer Date: After July 1, 2007 Emission Standards (g/hp-hr) Emission Standards (ppmvd at 15% O2) NOx CO VOC NOx CO VOC 2.0 4.0 1.0 160 540 86 3.9.1.1 For engines manufactured prior to January 1, 2011 that were certified to the certification emission standards in 40 CFR part 1048 applicable to engines that arc not severe duty engines, if such stationary SI ICE was certified to a carbon monoxide (CO) standard above the standard in Condition 3.9.1 above, then the Operating Permit Number: 95OP W E 100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 26 source may meet the CO certification (not field testing) standard for which the engine was certified. (§ 60.4233(e)) Compliance Requirements 3.9.2 This facility may operate an engine certified to the emission standards listed above. The facility shall operate and maintain the certified engine and control device according to the manufacturer's emission -related written instructions and keep records of conducted maintenance to demonstrate compliance. The engine must also meet the requirements as specified in 40 CFR part 1068, subparts A through D, as they apply. If the engine settings are adjusted according to and consistent with the manufacturer's instructions, the engine will not be considered out of compliance. (§60.4243(b)(1)) 3.9.2.1 If the engine is not a certified engine or was not operated and maintained according to the manufacturer's emission -related written instructions, the facility shall keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the source must conduct an initial performance test and conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first, thereafter, in accordance with §60.4244, to demonstrate compliance. (§§60.4243(a)(2)(iii) & (b)(2)(ii)) Notification, Reporting, and Recordkceping Requirements 3.9.3 The facility must keep records of the following information: 3.9.3.1 All notifications submitted to comply with this subpart and all documentation supporting any notification. (§ 60.4245(a)(l)) 3.9.3.2 Maintenance conducted on the engine. (§ 60.4245(a)(2)) 3.9.3.3 If the stationary SI internal combustion engine is a certified engine, documentation from the manufacturer that the engine is certified to meet the emission standards and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as applicable. (§ 60.4245(a)(3)) 3.9.3.4 If the engine is not a certified engine or is a certified engine operating in a non - certified manner and subject to §60.4243(a)(2), documentation that the engine meets the emission standards. (§ 60.4245(a)(4)) 3.9.4 The source must submit a copy of each performance test as conducted in §60.4244 within 60 days after the test has been completed. (§ 60.4245(d)) 3.10 [Federal -Only] This engine is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions". These requirements include, but are not limited to the following: Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 27 3.10.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR 60 Subpart A § 60.12, as adopted by reference in Colorado Regulation No. 6, Part A). 3.10.2 Performance tests shall be conducted in accordance with the requirements in 40 CFR Part 60 Subpart A § 60.8. 3.11 [Federal -Only] These engines are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", as follows: Note that as of the issuance date of this permit [DATE], the provisions in 40 CFR Part 63 Subpart ZZZZ (those provisions published in the August 20, 2010 Federal Register) have not been adopted in Colorado Regulation No. 6, Part A and Colorado Regulation No. 8, Part E by the Division and are therefore not state -enforceable. In the event that the Division adopts these requirements, these requirements will become both state and federally enforceable. If there is a change in federal law which renders ineffective or alters the applicable requirements of this Subpart ZZZZ, the source shall follow the effective federal rules. An affected source that is a new or reconstructed stationary RICE located at an area source must meet the requirements of this part by meeting the requirements of 40 CFR Part 60 Subpart JJJJ in Condition 3.9. No further requirements apply for such engines under this part. (§ 63.6590(c)) 3.12 The source shall follow the Compliance Assurance Monitoring (CAM) requirements for the engines as outlined in Section II, Condition 10 of this permit. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEl00 DCP Midstream, LP Lucerne Gas Processing Plant Page 28 4. AU01 — Exterran Amine Sweetening Unit with VRU and Thermal Oxidizer Parameter Permit Condition Number Compliance Limits Emission Factor (Ib/MMBtu) Monitoring Method Interval CO 4.1 4.31 tons/year 0.37 Recordkccping and Calculation 12 month rolling total Monthly SO2 4.2 12.32 tons/year Mass Balance VOC 4.3 5.70 tons/year I'roMax HAP Single: 8 tons/year Combined: 20 tons/year Natural Gas Processing 44 14,600 MMscf year ProMax Input Parameters 4.5 Recordkeeping and Gas Analysis See Condition 4.5 Lean Amine Recirculation Rate 4.6 ≤ 175 gallons/min Recordkeeping Daily NSPS Subpart LLL 4.7 H25 <2 long tons/day Gas Analysis Annually Opacity 4.8 Not to exceed 30% EPA Method 22 Daily Thermal Oxidizer Requirements 4.9 See Condition 4.9 See Condition 4.9 Compliance Assurance Monitoring 4.10 See Condition 10 4.1 Emissions of Carbon Monoxide (CO) from the thermal oxidizer controlling the amine unit shall not exceed the annual emission limitation stated in the table above (Colorado Construction Permit 08WE0920). Monthly emissions shall be calculated by the end of the subsequent month using the emission factor in the table above, the quantity of gas sent to the thermal oxidizer, estimated from the output of the monthly ProMax run, and the Btu content of the combusted gas as determined from the output of the monthly ProMax run, in the following equation: tons/mo = 1EF (Ib/MMBtu) x quantity of combusted gas (MMsef/mo) x heat content of combusted gas(Htu/selll 2000 Ib/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.2 Emissions of Sulfur Dioxide (5O2) from the amine unit shall not exceed the annual emission limitation stated in the table above (Colorado Construction Permit 08WE0920). Monthly emissions shall be calculated by the end of the subsequent month with a mass balance approach using the H2S concentration from the results of the most recent extended gas analysis, as required by Condition 4.5.4, assuming 100% conversion of H2S to SO2. Operating Permit Number: 95OPWE 100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 29 Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.3 Emissions of Volatile Organic Compounds (VOC) and facility -wide Hazardous Air Pollutants (HAP) shall not exceed the annual emission limitation stated above (Colorado Construction Permit 08WE0920). Monthly emission shall be calculated by the end of the subsequent month using ProMax software or a Division -approved alternative. Input parameters to the ProMax model shall be the monthly average of parameters monitored in accordance with Condition 4.5. Monthly emissions shall be used in a twelve-month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. Monthly HAP (individual HAP and total HAP) emissions shall be used in a twelve month rolling total of facility wide emissions as specified in Condition 8.1. 4.4 Natural gas processing at this unit shall not exceed the above limitation (Colorado Construction Permit 08WE0920). The quantity of natural gas processed in the amine unit shall be monitored and recorded monthly and used to calculate emission as required by Conditions 4.1, 4.2, and 4.3. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 4.5 The input parameters to ProMax shall be monitored as follows: 4.5.1 Monthly averages of the following monitored values shall be determined for use as inputs to the ProMax model. Monthly average values shall be representative of the unit's operation during the month: Parameter Monitoring Frequency Lean Amine Circulation Rate Daily Inlet Gas Temperature Weekly Inlet Gas Pressure Weekly 4:5.2 Records of the time and duration of all VRU downtime experienced shall be kept and available for Division review upon request. 4.5.3 An extended sour gas analysis of the inlet gas to the amine unit shall be performed annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division. Copies of the extended gas analyses shall be kept on -site and available for Division review upon request. 4.5.4 An analysis of the plant inlet gas to determine the Hydrogen Sulfide (H2S) concentration shall be performed annually according to appropriate ASTM methods, or equivalent, if Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEI00 DCP Midstream, LP Lucerne Gas Processing Plant Page 30 approved in advance by the Division. Copies of the extended gas analyses shall he kept on -site and available for Division review upon request. 4.6 The lean amine recirculation pump rate shall not exceed 175 gallons per minute (Colorado Construction Permit 08WE0920). The lean amine recirculation rate shall be recorded daily and made available for Division review upon request. 4.7 This amine unit is subject to the requirements of 40 CFR Part 60 Subpart LLL "Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011" including, but not limited to, the following: 4.7.1 The source shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. (§60.647(c)) 4.7.2 The concentration of Hydrogen Sulfide (PI'S) in the gas stream, as determined from the extended gas analysis required in Condition 4.5.3, shall be used to monitor the exemption qualification. (§60.640(b)) 4.8 Visible emission shall not exceed 30% opacity for a period or periods aggregating six minutes in any sixty consecutive minutes (Colorado Regulation No. I, Section II.A.5). Compliance shall be monitored by conducting EPA Method 22 observations for one minute daily. If visible are observed, an EPA Reference Method 9 opacity observation shall be performed to monitor compliance with the opacity standard. The result(s) of the visual observations and the Method 9 observations shall be kept on file and made available for Division review upon request. The EPA Reference Method 9 opacity observations shall be performed by an observer with a current and valid Method 9 certification. A clear and readable copy of the observer's certificate and any opacity observations shall be kept on file and made available to the Division for review upon request. Subject to the provisions of §25-7-123.1, C.R.S., and in the absence of credible evidence to the contrary, exceedance of the opacity limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedancc of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 4.9 The following requirements apply to the operation of the thermal oxidizer: 4.9.1 The thermal oxidizer shall be operated at all times when emissions are routed to it. 4.9.2 The thermal oxidizer shall be operated with a pilot flame present at all times. The presence of a pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. The device shall be equipped with an alarm to indicate no ignition of the pilot flame. Records of the times and duration of all periods of pilot flame outages, and estimated emissions shall be maintained and made available to the Division upon request. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 31 4.9.3 The thermal oxidizer shall be operated with a minimum combustion chamber temperature of 1400°F. The combustion chamber temperature shall be recorded daily. Records of the combustion chamber temperature reading shall be maintained and made available to the Division upon request. 4.10 The source shall follow the Compliance Assurance Monitoring (CAM) requirements as outlined in Section II, Condition 10 of this permit. 5. HT01 — 16 MMBtu/hr Natural Gas Fired Amine Regeneration Heater Parameter Permit Condition Number Compliance Limits Emission Factor (Ib/MMscf) Monitoring Method Interval NOx 5.1 2.59 tons/year 88.24 Reeordkeeping and calculation 12 month rolling total Monthly CO 5.05 tons/year 74.12 HAP 5.2 Single: 8 tons/year Combined: 20 tons/year PM 5.3 0.243 Ib/MMtu Fuel Restriction Only Natural Gas is Used as Fuel Natural Gas Consumption 5.4 134.77 MMscl/year Reeordkeeping and calculation 12 month rolling total Monthly Operating Hours 5.5 Reeordkeeping Monthly Opacity 5.6 Not to Exceed 20% Except as Provided for Below Fuel Restriction Only Natural Gas is Used a Fuel For Startup - Not to Exceed 30%, for a Period or Periods Aggregating More than Six (6) Minutes in any 60 Consecutive Minutes NSPS General Provisions 5.7 See Condition 5.7 As Required by NSPS General Provisions 5.1 Emissions of N trogen Oxides (NOx) and Carbon Monoxide (CO) from the heater shall not exceed the annual emission limitation stated above (Colorado Construction Permits 08WE0921). Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor and the monthly natural gas consumption (as required by Condition 5.4) in the equation below: tons/mo = JEF (Ibs/MMsel) x natural gas usage (MMsellmo)l 2000 lb/ton Monthly emissions shall be used in a twelve-month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 32 5.2 Facility wide emissions of Hazardous Air Pollutants (HAP) shall not exceed the above limitations. Compliance with the facility wide HAP limits shall be monitored by calculating monthly emissions of individual HAP above the de minimis reporting level by the end of the subsequent month. Emissions of individual HAP shall be calculated using AP -42 emission factors (AP -42, Section 1.4, dated 7/98) and the monthly natural gas consumption (as required by Condition 5.4) in the equation below: tons/mo = f EE (lb/MMsef) x fuel use (MMscf/mo)] 2000 lb/ton Monthly HAP (individual HAP and total HAP) emissions shall be used in a twelve month rolling total of facility wide emissions as specified in Condition 8.1. 5.3 Particulate Matter (PM) emissions shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). The numeric PM standards were determined using the design heat input for the heater in the following equation PE = 0.5 x (FIE° 26' where'. PE — particulate standard in Ib/MMBtu PI — fuel input in MMtu/hr In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only natural gas is permitted to be used as fuel for these heaters. 5.4 Natural gas consumption shall not exceed the above limitation (Colorado Construction Permits 08WE0921). Facility -wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured on the same day that run time hours have been recorded in accordance with Condition 5.5. Allocation of natural gas to the heater will be calculated using the following calculation: Fuel Consumption = (Design Ilea) Rate (MMBtu) Hours of Operation (mo)) individual hearer Total Facility Fuel Use E (Design Heat Rate (hllthr) a Ilours of Operation o) = Site Rated Ilorscpower (hp)) P .aan awls + (Design Heat Rate (MMRtu) Hours of Operation (mo)) endi The facility shall record and maintain records of the amount of fuel combusted during each month (40 CFR Part 60 Subpart Dc, §60.48c(g)). Records shall be maintained for a period of two years following the date of such record and made available for Division review upon request (40 CFR Part 60, Subpart Dc, §60.48c(i)). Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 5.5 Hours of operation shall be recorded for each calendar month. Records shall be made available for Division review upon request. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 33 5.6 Visible emissions shall not exceed 20% opacity (Colorado Construction Permit 08WE0921 and Colorado Regulation No. 1, Section ILA.1) except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section I1.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for this heater. 5.7 These heaters are subject to the requirements in 40 CFR Part 60 Subpart A, "General Provisions", including the following: 5.7.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard, Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (§60.12). 5.7.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (§60.11(d)). 5.7.3 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (§60.7(b)). Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEI00 DCP Midstream, LP Lucerne Gas Processing Plant Page 34 6. H001 - 6 MMBtu/Hr Natural Gas Fired Regeneration Heater Parameter Permit Condition Number Limitations Compliance Emission Factor (lb/MMscl) Monitoring Method Interval Emission Limits 6_I NO,: 100 CO'. 54 PM/PM„,: 7.6 VOC: 5.5 Recordkeeping and Calculation Annual Natural Gas Consumption 6.2 50.54 MMscf/year Operating Hours 6.3 Opacity 6.4 Not to Exceed 20% Except as Provided for Below Fuel Restriction Only Natural Gas is Used as Fuel For Startup - Not to Exceed 30%, for a Period or Periods Aggregating More than Six (6) Minutes in any 60 Consecutive Minutes 6.1 For APEN reporting and fee purposes, emissions from the heater shall be calculated annually using the above emission factors and the annual natural gas consumption (as required by Condition 6.2) in the equation below: tonsiyr= IF:F(Ibs/MMscf) x natural gas usage (MMscl7yr)I 2000 Ib/ton 6.2 Natural gas consumption shall not exceed the above limitation. Natural gas consumption shall be determined using the facility -wide fuel meter and allocated using the annual hours of operation of the heater, as required by Condition 6.3, and the design heat rate. Records of calculations shall be kept in a log to be made available to the Division upon request. 6.3 Hours of operation shall be recorded annually. Records shall be made available for Division review upon request. 6.4 Visible emissions shall not exceed 20% opacity (Colorado Construction Permit 08WE0921 and Colorado Regulation No. 1, Section ILA. I) except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. I, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for this heater. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 35 7. Emergency Flare Parameter Permit Condition Number Limitations Emission Factor Monitoring Method Interval Flare Requirements 7.1 Visible Emissions/Opacity Requirements Visible Emissions Observations Monthly A Flame Shall be Present at all times that the Flare is Operated Temperature Sensor or Flame Detection Device with Alarm Continuously Flare Specifications Btu Content of Gas and Velocity Performance Test, One Time Flare Shall be Operating at all Times that the Emission arc Routed To It Certification Annually 7.1 The flare is subject to the following requirements from 40 CFR Part 60 Subpart A § 60.18(6): 7.1.1 Owners or operators using flares to comply with the provisions of this part shall monitor these control devices to assure that they are operated and maintained in conformance with their designs (40 CFR Part 60 Subpart A § 60.18(d)). 7.1.2 Flares shall be steam -assisted, air -assisted, or non -assisted (40 CFR Part 60 Subpart A § 60. I 8(c)(6)). 7.1.3 Flares shall be operated at all times when emissions maybe vented to them (40 CFR Part 60 Subpart A § 60.18(c)). 7.1.4 Flares shall be designed for and operated with no visible emissions, except for periods not to exceed a total of 5 minutes during any 2 consecutive hours. Test Method 22 in 40 CFR Part 60 Appendix A shall be used to determine the compliance of flares with the visible emission provisions of this part. The observation period is 2 hours and shall be used according to Method 22. (40 CFR Part 60 Subpart A § 60.18(c)(1)) Compliance with the visible emission requirements shall be monitored by conducting a visible emission observation monthly when the flare is operating. Monthly observations shall last a minimum of five minutes. If no visible emissions are present during this observation, in the absence of credible evidence to the contrary, the flare will be considered in compliance with the above visible emissions requirement. If visible emissions are present during the monthly reading, a two (2) hour observation shall be conducted in accordance with Method 22 to determine if the flare is in compliance with the above visible emissions requirement. If visible emissions are present for five minutes or less (total) during the two-hour observation, then the flare shall be deemed in compliance. If visible emissions are present for more than five minutes (total) during the two-hour observation, then the flare shall be deemed out of compliance with the above Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 36 visible emissions requirement. Subject to the provisions of C.R.S. § 25-7-123.1 and in the absence of credible evidence to the contrary, excecdance of the visible emission requirement shall be considered to exist from the time a Method 22 reading is taken that shows the flare is out of compliance (as defined above) until a Method 22 reading is taken that shows the flare is in compliance (as defined above). 7.1.5 Flares shall be operated with a flame present at all times. The presence of a flare pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame (40 CFR Part 60 Subpart A § 60.18(b)(2))). Records of the times and duration of all periods of pilot flame outages, and estimated emissions shall be maintained and made available to the Division upon request. 7.1.6 Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam -assisted or air -assisted; or with the net heating value of the gas being combusted being 7.45 MJ/scm (200 Btu/scf) or greater if the flare is nonassisted (40 CFR Part 60 Subpart A § 60.18(c)(3)(ii)). The net heating value of the gas being combusted shall be calculated using the equation specified in 40 CFR Part 60 Subpart A § 60.18(O(3). 7.1.7 The actual exit velocity of a flare shall be determined by dividing by the volumetric flow rate of gas being combusted (in units of emission standard temperature and pressure), as determined by Test Method 2, 2A, 2C, or 2D in 40 CFR Part 60 Appendix A, as appropriate, by the unobstructed (free) cross-sectional area of the flare tip (40 CFR Part 60 Subpart A § 60.18(O(4)). 7.1.7.1 Air -assisted flares shall be designed and operated with an exit velocity less than the velocity, Vmax, as determined by 40 CFR Part 60 Subpart A § 60.18(O(6) (40 CFR Part 60 Subpart A § 60.18(c)(5)). 7.1.7.2 Steam -assisted and nonassisted flares shall he designed for and operated with an exit velocity less than 18.3 m/sec (60 ft/sec), except as provided in Conditions 7.2.7.3 and 7.2.7.4 below. (40 CFR Part 60 Subpart A § 60.18(c)(4)(i)). 7.1.7.3 Steam -assisted and nonassisted flares designed for and operated with an exit velocity equal to or greater than 18.3 m/sec (60 ft/sec) but less than 122 m/sec (400 ft/sec) are allowed if the net heating value of the gas being combusted is greater than 37.3 MJ/scm (1,000 Btu/scf). (40 CFR Part 60 Subpart A § 60.18(c)(4)(ii)). 7.1.7.4 Steam -assisted and nonassisted flares designed for and operated with an exit velocity Vmax, as determined by the method specified in 40 CFR Part 60 Subpart A §60.18(f)(5), and less than 122 m/sec (400 ft/sec) are allowed (40 CFR Part 60 Subpart A § 60.18(c)(4)(iii)). Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit kt 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 37 8. Facility Wide Parameter Permit Condition Number Limitations Emission Factor Monitoring Method Interval HAP 8.1 Single'. 8 tons/year Combined. 20 tons/year Rccordkccping and Calculation Monthly Insignificant Activity Tracking 82 Sec Condition 8.2 Sec Condition 8.2 Operation 8.3 8.1 Facility -wide emissions of Hazardous Air Po lutants (HAP) shall not exceed limitation above. HAP calculated in accordance with Conditions 2.3, 3.3, 4.3, and 5.2 shall be summed and used in a twelve month rolling total to monitor comp iance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months' data. 8.2 An analysis of the facility's potential -to -emit shall be performed for each addition of, or modification to, an insignificant activity to monitor PSD status. Records of this analysis shall be kept and made available for Division review upon request. 8.3 At all times, including periods of start-up, shutdown, and malfunction, the plant and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution prevention and control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. 9. Portable Monitoring (ver 10/12/2012) Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted quarterly using a portable flue gas analyzer on each individual engine. At least one calendar month shall separate the quarterly tests. Note that if any individual engine is operated for less than 100 hrs in any quarterly period, then the portable monitoring requirements do not apply for that engine only. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's websitc at: hit"):- WWvv,.coloraclo.gov cs`Satellito%(DPI I NAP/C13ON, I25159652O27 Results of the portable analyzer tests shall be used to monitor the compliance status of these units. For comparison with an annual or short term emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 38 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 engines are 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, that individual engine(s) 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. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request. 9.1 The outlet oxygen content of the exhaust stream from each individual engine shall be measured during portable monitoring when measurement of the outlet CO content is being conducted. 10. Compliance Assurance Monitoring 10.1 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to the seven (7) Waukesha Model L-7042 GSI (1,232 HP), the one Waukesha Model L-7042 GSI engine (1,478 HP), and the one Waukesha Model L-5794 GS] engine (1,380 HP) with respect to the NOx and CO limitations identified in Section II, Condition 2.1 and 3.1, and the Exterran amine sweetening unit (AU01) with respect to the VOC identified in Section II, Condition 4.1, as follows: 10.1.1 The permittee shall follow the CAM Plan provided in Appendix G of this permit. 10.1.1.1 For the engines, excursions, for purposes of reporting, are any time the thermocouple temperature indicates a temperature less than 750° F or greater than 1250° F, or a pressure drop across the catalyst of more than 2 inches of water from the pressure drop measured during the performance test. 10.1.1.2 For the amine unit, excursions, for purposes of reporting, shall be any combustion chamber temperature reading below 1400°F. Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 39 10.1.2 Operation of Approved Monitoring 10.1.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(6), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.2.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant -specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that arc caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.2.3 Response to excursions or exccedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant -specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 95OPWEl00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 40 b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedancc will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.2.4 After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and, if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3 Quality Improvement Plan (QIP) Requirements 10.1.3.1 Based on the results of a determination made under the provisions of Condition I0.1.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEI00 DCP Midstream, LP Lucerne Gas Processing Plant Page 41 c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 6.1.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 10.1.2.3.6, the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.4 Reporting and Recordkeeping Requirements 10.1.4.1 Reporting Requirements: The reports required by Section IV, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 42 a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 10.1.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Pan C, Section XIV). 10.1.4.2 General Rccordkeeping Requirements: In addition to the recordkeeping requirements in Section IV, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 10.1.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(6)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.5 Savings Provisions 10.1.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 43 authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(I), as adopted by reference in Colorado Regulation No. 3, Pan C, Section XIV). 10.1.5.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 10.1.5.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV) Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OP WE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 44 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; @ 25-7-I 14.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modifications or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description & Number Applicable Requirement Justification C-106, C -I 10, C-107, C-109, CI 12. C -I 13, C108, C105 Waukesha L-7042 G511232 HP C-115 Waukesha 1:5794 GSI 1380 HP Reg I_III A.I .b - Particulate emissions from fuel -burning equipment Reg I.VLB.5-a- Sulfur dioxide emissions from fuel - burning equipment Internal combustion engines arc not considered fuel burning equipment for the applicable requirements of Regulation I. Plant -wide Reg 4 Wood Burning Stoves This plant does not include any wood burning stoves or wood burning appliances, or advertise, or sell such devices. Reg 7 VIB. I Reg 7 VIB.2 Storage of Petroleum Distillates These provisions apply to the storage of petroleum liquids in tanks with greater than 40,000 gallons capacity. Rug 7 VILC - Crude Oil Storage These provision apply to the storage of crude oil in tanks with greater than 40,000 gallons capacity. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance. 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWEI00 DCP Midstream, LP Lucerne Gas Processing Plant Page 45 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(1), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Stream -lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition Streamlined (Subsumed) Requirements Section II, Conditions 2.1 and 2.2 C-110 C-112, C -Ill Colorado Regulation No. 7, Section XVII.E.3.a.(i) [control requirements] — State -only Upon compliance with Section I[, Condition 2.9, the engines are no longer subject to this requirement. Section II, Condition 2.8 C-105, C-106, C -I07, C-108, C-109: Colorado Regulation No. 7, Section XVII.E.2.b [control requirements] — State -only Upon compliance with Section II Condition 2.9, the engines are no longer subject to this requirement. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page I SECTION IV - General Permit Conditions (ver 5/22/2012) I. Administrative Changes Regulation No. 3, 5 CCR 1001-5, Part A, § III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § I.B.I. The permittce may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, §§ lll.B.9., V.C.16.a.& e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of'such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document arc true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (t) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s) used for determining the compliance status of the source, currently and over the reporting period; and such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. (v) d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition, 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 §S ILA., ILB., ILC, ILG, II.F., 11.1, and Ili a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit #t 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 2 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference lest methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 3 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (I) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no cxceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 4 e. Circumvention Clause g A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day. and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 5 The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5, Part C, $t III.C.9., V.C.11. & 16.d. and § 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit maybe modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No. 3, Part C. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 6 g (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, $ VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Par B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S SO 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114,7. A I% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91 st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. Operating Permit Number: 95OPWF.I00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 7 b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. § 25-7-114.1(6) for each ANN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. I, 5 CCR 1001-3, § III.D.I. The permittee shall employ such control measures and operating procedures as arc necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. I, § IILD.I. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C. I 6.b. Upon presentation of credentials and other documents as may be required by law, the pennittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. I. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §5 X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, 0 V.C.I I .d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2, 5 CCR 1001-4, Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OP WE 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 8 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, S XII.B. The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, 88 I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II. 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I., Il.C., II.D., Ill. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3, 5 CCR 1001-5, Part C, §8 ll I.B.6., I V.C., V.C.2. a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates the pennittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, § II.D. Portable Source pennittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3, 5 CCR l001-5, Part C, § V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 9 a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: 0) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. If any of the conditions in paragraphs b.i or b.ii above arc met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note. Notification by telephone or facsimile must specify that this notification is a deviation report %or an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 -month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, 5 II,; Part C, 88 V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following inl'onnation: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE100 DCP Midstream, LP Lucerne Gas Processing Plant Page 10 d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No, 3, Part A, § II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of live years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the live -year term expires. Pennitteess submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be tiled along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No, 3, 5 CCR 1001-5, Part C, & XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the pennit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(6)(10) Changes Regulation No. 3, 5 CCR 1001-5, Part C, $ XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The pennittee shall attach a copy of each such notice given to its Operating Permit, 25. Severability Clause Regulation No, 3, 5 CCR 1001-5, Part C, 6 V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 95OPWE E 100 DCP Midstream, LP Lucerne Gas Processing Plant Page 11 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, 6 lI1.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. Ifthe permitter chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3 5 CCR 1001-5, Part C., § , V.C.I.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5, Part C, S II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7 5 CCR 1001-9, 56 Ill & V. The requirements in paragraphs a, b and c apply to sources located in an ozone non -attainment area or the Denver I -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No.7, Section VIII.C.3. b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be transferred using submerged or bottom tilling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations. the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RAC'f) is utilized. Operating Permit Number: 95OPWEl00 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit A 95OPWE I00 DCP Midstream, LP Lucerne Gas Processing Plant Page 12 d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in opcn containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No. 4, 5 CCR 1001-6 The pennittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - COMPLIANCE MONITORING REPORT FORMAT C - COMPLIANCE CERTIFICATION REPORT FORMAT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS & ABBREVIATIONS F - PERMIT MODIFICATIONS G - COMPLIANCE ASSURANCE MONITORING H - AOS APPLICABILITY REPORTS DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise stated in this permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page I APPENDIX A - Inspection Information Directions to Plant : The plant is in Section 28, Township 6 North, Range 65 West. The plant address is 31495 Weld County Road 43. The plant is bounded by Weld County Road No. 43 on the East and Weld County Road No. 66 of the North. Safety Equipment Required : Itard Hat Safety Shoes Ear Protection Eye Protection Fire Retardant Clothing Plant Plot Plan : The figure on the following page shows the plot plan as submitted on March 30, 2012. List of Insignificant Activities : The following generic list of insignificant activities was provided: • Nine (9) Engine Blowdown Vents • Methanol Tank, 4,200 gallons • Methanol Tank, 1,000 gallons • Methanol Tank, 300 gallons • Amine Tank, 200 bbl • Reclaim Amine Tank, 200 bbl • Two (2) Coolant Tanks, 100 bbl • Lube Oil Tank, 210 bbl • Lube Oil Tank, 55 gallons • Lube Oil Tank, 30 bbl • Used Oil Tank, 10 bbl • Used Oil Tank, 100 bbl • Kersone Tank, 500 gallons • Slop Oil Tank, 220 gallons • Six (6) Slop Oil Tanks, 80 bbl each • Two (2) Slop Oil Tank, 10 bbl each • Refrig Lube Oil, 55 gallons • Expander Lube Oil, 55 gallons • Hot Oil Tank, 3360 gallons • Produced Water Tank, 80 bbl • Waste Water Tank, 200 bbl • Pressurized Truck Condensate Loadout • Pressurized Truck Y Grade Loadout • Pressurized Propane Loadout Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 2 • #: kn'T t= 1�. '1) 1_ 72.17:M I }• w13ri r,• "It;r1,: ': ijt .pdE• ft, 1 _ E a Operating Permit Number: 95OP WE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page I APPENDIX B Reporting Requirements and Definitions with codes ver 2/20/07 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either tiled or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 2 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit arc required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifics a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. I, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (I) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2 = Process: When the requirement is a production/process limit 3 = Monitor: When the requirement is monitoring 4 = Test: When the requirement is testing 5 = Maintenance: When required maintenance is not performed 6 = Record: When the requirement is recordkeeping 7 = Report: When the requirement is reporting 8 = CAM: A situation in which an excursion or cxceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9 =Other: When the deviation is not covered by any of the above categories Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 3 Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: 1.1 The identification of each term or condition of the permit that is the basis of the certification; 1.2 Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; 1.3 The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations. 1.4 Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports. including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 4 Startup, Shutdown, Malfunctions and Emergencies, Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that arc caused in part by poor maintenance or careless operation arc not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 5 Monitoring and Permit Deviation Report - Part I I. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division on a semi-annual basis unless otherwise noted in the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: DCP Midstream, LP - Lucerne Gas Processing Plant OPERATING PERMIT NO: 95OPWE100 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Unit ID Unit Description Deviations noted During 'eriod?' Deviation Code2 Malfunction/Emergency Condition Reported During Period? YES NO vEs NO P007 Equipment leak fugitive VOC emissions C-106 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C -I 10 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-107 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-109 Waukesha Model L-7042 GSI Compressor Engine, 1232 HI' C -I 12 Waukesha Model L-7042 O51 Compressor Engine, 1232 HI' C-113 Waukesha Model L-7042 O51 Compressor Engine, 1232 HP C-I0S Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-105 Waukesha Model I.-7042 GSI Compressor Engine, 1478 HP C -I 15 Waukesha Model L-5794 GSI Compressor Engine, 1380 HP, AUDI Exterran amine natural gas sweetening system HT0 I 16 MMBtu/hr amine regeneration heater H -I01 6 MMBtu/hr regeneration boiler Emergency Flare General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of wh ther or not a deviation has occurred 'hall be based on a reasonable inquiry using readily available information. Use the following entries, as appropriate: 1 = Standard: 2 = Process: 3 = Monitor: 4=Test: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing Operating Permit Number: 95OP WE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 6 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 — Other: When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 7 FACILITY NAME: OPERATING PERMIT NO: REPORTING PERIOD: Monitoring and Permit Deviation Report - Part II DCP Midstream, LP — Lucerne Gas Processing Plant 95OPWE100 Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: Shutdown Malfunction Normal Operation SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 95OPWEI00 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 8 FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: EXAMPLE Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Linc Feed Plugged Duration START- 17304/10/06 END- 18004/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Shutdown Malfunction Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 9 Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: DCP Midstream, LP - Lucerne Gas Processing Plant FACILITY IDENTIFICATION NUMBER: 123/0107 PERMIT NUMBER: 95OPWE100 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official. The responsible official signing this certification must be pre -approved by the Division in accordance with Colorado Regulation No. 3, Part A, Section I.B.54. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that 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 Sub -Section I8- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Required Format for Annual Compliance Certification Report APPENDIX C Appendix C Page I Required Format for Annual Compliance Certification Report (ver 2/20/07) Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: DCP Midstream, LP - Lucerne Gas Processing Plant OPERATING PERMIT NO: 95OP WE 100 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/arc the method(s) specified in the Permit. _ With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Unit ID Unit Description Deviatons Reported' Monitoring Method per Permit^2 Was complian c continuous or intermittent"' Previous Current YES NO Continuous Intermittent P007 Equipment leak fugitive VOC emissions C-106 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C -I 10 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-107 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-109 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C- 112 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-113 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-108 Waukesha Model L-7042 GSI Compressor Engine, 1232 HP C-105 Waukesha Model L-7042 GSI Compressor Engine, 1478 HP, Serial No. C-10731-1 C- 115 Waukesha Model L-5794 (181 Compressor Engine, 1380 HP AU01 Exterran amine natural gas sweetening system HTOI 16 MMBtu/hr amine regeneration healer H-101 6 MMBIWhr regeneration boiler Emergency Flare General Conditions Insignificant Activities° If deviations were noted in the previous deviation report (i.e., for the firs six months of the annual reporting period), put an "X" under "previous". If deviations were noted in the current deviation report (i.e., for the last six months of the annual reporting period) put an "X" under "current". Mark both columns if both apply. e Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. Operating Permit Number: 95OP WE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Required Format for Annual Compliance Certification Report Appendix C Page 2 Note whether the compliance status with of each term and condition provided was continuous or intermittent "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE. The Periodic Monitoring requirements of the Operating Permit program rule arc intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source 1) conducts all of the monitoring and reeordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non- compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. 11. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification 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 certification in this document 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 Title Signature of Responsible Official Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page I APPENDIX D Notification Addresses I. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B I 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Stop 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 1 Listed Alphabetically: AIRS - AP -42 - APEN - APCD - ASTM - BACT - BTU CAA CCR CEM CF CFR CO COM CRS EPA FR G Gal HAPs HP HP -HR LAER - LBS M MM MMscf MMscfd N/A or NA - NOx NESHAP NSPS PMip PSD PTE RACT - SCC SIC SO, TPY TSP VOC APPENDIX E Permit Acronyms Aerometric Information Retrieval System EPA Document Compiling Air Pollutant Emission Factors Air Pollution Emission Notice (State of Colorado) Air Pollution Control Division (State of Colorado) American Society for Testing and Materials Best Available Control Technology British Thermal Unit Clean Air Act (CAAA = Clean Air Act Amendments) Colorado Code of Regulations Continuous Emissions Monitor Cubic Feet (scf = Standard Cubic Feet) Code of Federal Regulations Carbon Monoxide Continuous Opacity Monitor Colorado Revised Statute Environmental Protection Agency Federal Register Grams Gallon Hazardous Air Pollutants Horsepower Horsepower Hour (G/HP-HR — Grams per Horsepower Hour) Lowest Achievable Emission Rate Pounds Thousand Million Million Standard Cubic Feet Million Standard Cubic Feet per Day Not Applicable Nitrogen Oxides National Emission Standards for Hazardous Air Pollutants New Source Performance Standards Particulate Matter Under 10 Microns Potential for Significant Deterioration Potential To Emit Reasonably Available Control Technology Source Classification Code Standard Industrial Code Sulfur Dioxide Tons Per Year Total Suspended Particulate Volatile Organic Compounds Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Pcrmit Permit Modifications Appendix F Page 1 APPENDIX F Permit Modifications DATE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 95OPWE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix G Page I APPENDIX G Compliance Assurance Monitoring Plan - Engines Background a. Emission Unit Description: Seven Waukesha Model L-7042 GSI Internal Combustion Engines, 1232 HP each One Waukesha Model L-7042 GSI Internal Combustion Engine, 1478 HP One Waukesha Model L-5794 GSI Internal Combustion Engine, 1380 HP b. Applicable Regulation, Emission Limit, Monitoring Requirements: Regulations: Operating Permit Section II, Condition 2.1 & 3.1 Emission Limitations: 2.1 - CO 23.79 tons/yr C-106, C-107, C-109, C-108: NOx 23.79 tons/yr C-110, C-112, and C-113: NOx 11.90 tons/yr 3.1 - NOx 28.54 tons/yr CO 28.54 tons/yr c. Control Technology: Non -Selective Catalytic Reduction Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix G Page 2 It. Monitoring Approach Indicator No. I Indicator No. 2 I. Indicator Measurement Approach Temperature of exhaust gas into catalyst Pressure drop across the catalyst Thermocouple Measured in inches of water II. Indicator Range The indicator range is a temperature between 750" F and 1250° F. Excursions above 1250" F trigger engine shutdown. Excursions below 750° F. trigger notification of excursion. Excursions trigger the permittee to investigate the engine performance and make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded in a log, to be made available to the Division upon request. The indicator range is a pressure drop across the catalyst that is within two inches of water from the baseline value established when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during each initial compliance and portable analyzer test, and as noted below. Excursions trigger the permittee to investigate the catalyst performance and make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded in a log, to be made available to the Division upon request. In lieu of maintenance the source may choose to perform a portable analyzer test of the engine to establish a new pressure drop value. If the test demonstrates that the engine is in compliance with its emission limits, the pressure drop value at which the engine is tested shall become the new baseline. III. Performance Criteria a. Data Representativeness Temperature is measured at the inlet to the catalyst. The minimum accuracy is t-1- 5°F. Pressure drop is measured across the catalyst while the engine is operating. b. Verification of Operational Status Thermocouple manufacturer guarantee. Manometer manufacturer guarantee. c. QA/QC Practices/Criteria Verification or replacement annually. Per manufacturer's recommendation. d. Monitoring Frequency Daily. Monthly I Data Collection Procedures Temperature data will be automatically or manually recorded on days that the engine is operating. Pressure drop will be recorded once per month. e. Averaging Time None None. III. Justification a. Background: The pollutant specific emission units arc nine (9) internal combustion engines. Each engine is equipped with a non -selective catalytic reduction unit to control NOx and CO emissions. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix G Page 3 b. Rational for Selection of Performance Indicators: The Division selected the pressure drop across the catalyst as it is an indicator of the catalyst performance. A change in the pressure drop across the catalyst can indicate if the catalyst is damaged or fouled, which would decrease catalyst performance. The inlet temperature to the catalyst was approved as an indicator since the temperature is important for the proper activation of the catalyst. The final RICE MACT requires monitoring of inlet temperature to the catalyst and the pressure drop across the catalyst. The CAM rule specifies that monitoring required for a MACT standard is presumptively acceptable monitoring, provided the monitoring is applicable to the performance of the control device (40 CFR Part 64 § 64.4(b)(4)). Since the MACT monitoring is for the same control device, the Division considers that the indicators are presumptively acceptable. c. Rational for Selection of Indicator Ranges: The indicator range for the catalyst inlet temperature and the pressure drop cross the catalyst are the same ranges as specified in the final RICE MACT, therefore the Division considers that the indicator range is also presumptively acceptable. Operating Permit Number: 95OPWEI00 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix Ci Page 4 Compliance Assurance Monitoring Plan - Amine Sweetening Unit 1. Background a. Emission Unit Description: The still vent emissions from the amine sweetening unit arc controlled with a thermal oxidizer. The pre -control potential VOC emissions from the unit are above the major source threshold. b. Applicable Regulation, Emission Limit, Monitoring Requirements: Amine Unit (AU01): Regulations: Operating Permit Condition 4.3 Emission Limitations: VOC 5.70 tons/yr c. Control Technology: Thermal Oxidizer 11. Monitoring Approach I. Indicator Measurement Approach Combustion Chamber Temperature The outlet temperature is measured with a thermocouple. II. Indicator Range An excursion is any temperature reading below 1400°F, Excursions trigger an inspection and corrective action. III. Performance Criteria a. Data Representativeness Temperature is measured at the outlet of the combustion chamber. The minimum accuracy is +/- 5 °F. b. Verification of Operational Status Thermocouple manufacturer guarantee. c. QA/QC Practices/Criteria Annual verification or replacement. d. Monitoring Frequency Daily. c. Data Collection Procedures Temperature automatically or manually recorded daily if operating. F Averaging Time None Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix G Page 5 III. Justification a. Background: The pollutant specific emission unit is an amine unit, which functions to remove CO2 and H2S from the gas stream. Flash emissions from are routed to a vapor recovery unit and the still vent emissions are routed to the thermal oxidizer. b. Rational for Selection of Performance Indicators and Indicator Ranges: The destruction of VOC is dependent upon combustion. The combustion chamber of the thermal oxidizer must meet a minimum temperature in order to achieve optimal combustion. The Division has approved the use of 1400°F as a minimum combustion chamber temperature to monitor thermal oxidizer performance. The Division has found that operating the oxidizer above this temperature results in efficient destruction of VOC. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix II Page 1 APPENDIX H Applicability Reports ver 10/12/12 Note: A MS Word version of this Appendix can be found at: http://www.colorado.gov/cs/Satellite/CDPI" E-AP/CIION/ 1251597655816 DISCLAIMER: These are only example reports and do not cover all possible requirements. Operating Permit Number: 95OPWEI00 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 2 Engine AOS Applicability Report Certification Language All information for the Applicability Reports must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section 1.8.38. or 2) for Construction and General Permits, the person legally authorized to act on behalf of the source. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s) shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, section 1.8.9., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s) referenced in the Report(s) until such time as the Permit is revised to reflect the new requirements. 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 certification in this document 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 Title Signature Date Signed Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 3 Colorado Regulation No. 7 Sections XVI and XVII.E DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Source ID: Permit #: Date: Acme Gas Processing 999/1234/001 93OPXX999 October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: Model: Nameplate HP: Construction date: RestEngineCompany 777 LowNox 1340 July 1, 2007 Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, § XVI Li Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, § XVII.E Does not apply to this engine. Engine does not have a maximum horsepower greater than 100 or the construction or relocation date precedes the applicability dates. ❑ Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): CO (g/hp-hr): VOC (g/hp-hr): 2.0 4.0 1.0 Max Engine HP Construction or Relocation Date Emission Standards in g/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January I, 2011 1.0 2.0 0.7 500≤Hp July I, 2007 2.0 4.0 1.0 Jul 1, 2010 1.0 2.0 0.7 Operating Permit Number: 95OP WE 100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 4 NSPS JJJJ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible JJJJ requirements. Note that as of September I, 2008 that 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, § I.B (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. NSPS Subpart JJJJ: Standards of Engines Company: Source ID: Permit It: Date: Manufacturer: Model: Nameplate HP: Engine Type: Manufacture Date: Performance for Stationary Spark Ignition Internal Combustion Acme Gas Processing 999/1234/001 93OPXX999 October I, 2008 BestEngineCompany 777 LowNox 1340 2 Stroke Rich Bum July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. H NSPS JJJJ does not apply to this engine. H NSPS JJJJ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the NSPS JJJJ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical engine that is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 5 Determination of NSPS JJJJ requirements: 60.4230 Applicability (a)(4)(i) Applies to this engine since it is a rich burn engine, greater than 500 HP, with a manufacture date after July I, 2007. 60.4233 Emission Standards for Owners and Operators (e) Owners and operators of stationary SI ICE with a maximum engine power greater than 100 HP must comply with the standards in Table I. Non -Emergency SI, Natural Gas, HP>500, Manufactured after 7/1/2007 NO, 2.0 g/HP-hr or 160 ppmvd(d;15% O2 CO 4.0 g/HP-hr or 540 ppmvd@15% O2 VOC 1.0 g/HP-hr or 86 ppmvd@15% O2 Other Requirements for Owners and Operators 60.4234 Emission standards must be met for the lifetime of the engine. 60.4235 N/A - Sulfur content of gasoline. 60.4236 N/A (for now) - After July 1, 2009 owners and operators may not install engines with a power rating ≥ 500HP that do not meet the emissions standards in 60.4230. 60.4237 N/A - Emergency Engines. 60.4238 - 60.4242 Compliance Requirements for Manufacturers — (Not Applicable) 60.4243 Compliance Requirements for Owners and Operators (b)(2)(ii) To maintain compliance with the emission limits in 60.4233, owners of SI ICE ≥ 500HP must: • Keep a maintenance plan; • Keep records of conducted maintenance; • Maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions; • Conduct an initial performance test; and • Conduct subsequent performance tests every 8,760 hours or every three years, which ever comes first, in order to demonstrate compliance with the emission limits. (g) Air to fuel ratio controllers (AFRCs) must be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. 60.4244 Testing Requirements for Owners and Operators (a) Each performance test must be conducted within 10% of the highest achievable load and must comply with the testing requirements listed in 60.8 and Table 2 of NSPS JJJJ. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 6 (b) Performance tests may not be conducted during periods of startup, shutdown, or malfunction, as specified in 60.8(c). If the engine is non -operational when a performance test is due, the engine does not need to be started up just to test it, but will need to be tested immediately upon startup. (c) Three separate test runs must be conducted for each performance test as specified by 60.8(f). Each run must be within 10% of max load and be at least 1 hour in duration. (d) To determine compliance with the NOR, CO, and VOC mass per unit output emission limitations, the measured concentration must be converted using the equations outlined in this section of NSPS JJJJ. 60.4245 Notification, Reports, and Records for Owners and Operators (a) Owners of all stationary SI ICE must keep records of the following: (1) All notifications submitted to comply with this subpart; (2) Maintenance conducted on the engine; (3) N/A - Manufacturer information for certified engines, and (4) Documentation that shows non -certified engines are in compliance with the emission standards. (b) N/A For emergency engines only. (c) Owners of non -certified engines ≥ 500HP must submit an initial notification as required in 60.7(a)(I) which includes the following information: (1) Name and address of the owner or operator; (2) The address of the affected source; (3) Engine information including make, model, engine family, serial number, model year, maximum engine power, and engine displacement; (4) Emission control equipment; and (5) Fuel used. CONCLUSION OF FINDINGS (EXAMPLE ONLY) In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non -selective catalytic converter (NSCR). These emission rates will be met throughout the life of the engine. A maintenance plan will be kept and all maintenance activities will be recorded. Compliance with the emission limits will be confirmed by the initial performance tests, which shall be conducted following the procedures outlined in 60.4244. Copies of performance test results will be submitted within 60 days of the completion of each test. Since this is an uncertified engine, an initial notification will be submitted including all of the requested information in 40.4245 within 30 days of startup. ACME will keep records of all compliance related materials. Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT ' Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page I MACT ZZZZ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 999/1234/001 Permit #: 93OPXX999 Date: October I, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. MACT ZZZZ does not apply to this engine. H MACT ZZZZ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the major source MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at a major source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at a major source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? This subpart covers Acme's new stationary reciprocating internal combustion engine. 63.6595 When do I have to comply with this Subpart? (a)(5) The engine must comply with the applicable emission limitations and operating limitations upon startup. 63.6600 Emission and operating limitations for RICE site rated at more than 500 hp Operating Permit Number: 95OPWE100 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports (a) Appendix H Page 2 The engine is subject to the emission limits in table la and the operating limits in table lb. ACME will meet the emission limitations by reducing formaldehyde emissions by 76 percent and will maintain the catalyst such that the pressure drop does not change by more than 2 inches of H2O at 100 % load plus or minus 10 percent from the pressure drop measured during the initial performance test and will maintain the temperature of the engine exhaust so that the catalyst inlet temperature is greater than or equal to 750 " F and less than or equal to 1250 " F. The engine will be equipped with non -selective catalytic reduction and an air fuel controller to meet the emission limitations. 63.6601 & 63.6611 Requirements for 4SLB engines between 250 and 200 hp These requirements do not apply. 63.6605 General Requirements (a) The engine will comply with the emission and operating limitations at all times, except during periods of startup, shutdown and malfunction (SSM) (b) The engine, including air pollution control and monitoring equipment shall be operating in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during SSM. 63.6610 Initial performance test (a) the performance tests specified in Table 4 (select sampling port and measure O,, moisture and formaldehyde at inlet and outlet of the control device) shall be conducted within 180 days of startup. (b) & (c) not applicable construction did not commence between 12/19/02 and 6/15/04. (d) previous performance tests have not been conducted on this unit within two years, therefore, this provision does not apply. 63.6615 Subsequent performance tests Subsequent tests will be conducted as specified in Table 3. No additional testing is required for 4SRB engines meeting the formaldehyde percent reduction requirements. 63.6620 Performance test procedures (b) tests must be conducted at 100 % load plus or minus 10% (c) tests may not be conducted during periods of SSM. (d) must conduct three 1 -hr test runs (e) equation (e)(1) shall be used to determine compliance with the percent reduction requirement. (f), (g) & (h) Not applicable (i) engine load during test shall be determined as specified in this paragraph. 63.6625 Monitoring, installation, operation and maintenance requirements (a), (c) & (d) Not applicable Operating Permit Number: 95OPWEI00 ISSUED: November I, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix I -I Page 3 (b) a continuous parameter monitoring system (CPMS) shall be installed to measure the catalyst inlet temperature. The CPMS will meet the requirements in § 63.8 63.6630 Demonstrating initial compliance (a) initial compliance shall be determined in accordance with table 5 (initial performance test must indicate formaldehyde reduction of 76 percent or more, a CPMS must be installed to measure inlet temperature of the catalyst and the pressure drop and catalyst inlet temperature must be recorded during the initial performance test). (b) pressure differential will be established during the initial performance test. (c) Notification of compliance status will be submitted and will contain the results of the initial compliance demonstration. 63.6635 Monitoring to demonstrate continuous compliance (b) except for monitor malfunctions, associated repairs, and required QA/QC activities monitoring must be continuous at all time the engine is operating. (e) data recorded during monitoring malfunctions, associated repairs and required QA/QC activities must not be used in data averages and calculations to report operating levels, however, all the valid data collected during other periods shall be used. 63.6640 Demonstrating continuous compliance (a) continuous compliance will be demonstrated as specified in table 6 (collect catalyst inlet temperature data, reduce that data to 4 -hr rolling average and maintain the 4 -hr rolling averages to within the operating limitation and measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop meets the operating limitation. (b) deviations from the emission and operating limitations must be reported per § 63.6550. If catalyst is changed the operating parameters established during the initial performance test must be re-established. When operating parameters re-established a performance test must also be conducted. 63.6645 Notifications (a) Submit notifications in §§ 63.7(b) & (e), 63.8(e), (f)(4) and (f)(6), 63.9(b) thru (c) & (g) & (h) that apply by dates specified. (b) Not applicable. Acme unit started after effective dated for Subpart ZZZZ. (c) Submit initial notification within 120 days after becoming subject to Subpart ZZZZ. (d) thru (t) Not applicable. Acme engine greater than 500 hp and subject to requirements in Subpart ZZZZ. (g) & (h) Submit notification of intent to conduct performance test and notification of compliance status. 63.6650 Reports (a) Submit reports required by table 7 (compliance report and SSM reports (if actions inconsistent with SSM plan) (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with title v reports Operating Permit Number: 95OPWE100 ISSUED: November 1, 1998 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Applicability Reports Appendix H Page 4 (c) Compliance reports to contain the following information: company name and address, statement by responsible official certifying accuracy, date of report and beginning and end of reporting period, if SSM the information in 63.10(d)(5)(i), if no deviations a statement saying that, if no periods when CPMS out of control a statement saying that. (d) Not applicable, using CPMS (e) For each deviation the information in (e)(l) thru (e)(12) shall be provided. (f) Applicable. Compliance reports are submitted with title v reports. Compliance reports under Subpart ZZZZ include all necessary info for title v deviation report with respect to Subpart ZZZZ requirements. (g) Not applicable. Acme engine not firing landfill or digester gas. 63.6655 Recordkeeping (a) Retain records as follows: copy of each notification and report (including all documentation supporting any initial notification or notification of compliance status), records in 63.6(e)(iii) thru (v) related to SSM, and records of performance tests and evaluations. (b) CPMS records including records in 63.10(b)(2)(vi) thru (xi), previous versions of the performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the relative accuracy test for CPMS as required by 63.8(0(6)0). (c) Not applicable. Acme engine not firing landfill or digester gas. (d) Will keep records required in Table 6 (monthly pressure drop readings, 4 -hr averages of catalyst inlet temperature) to show continuous compliance with emission and operating limits. 63.6660 Form and length of records (a) records must be in a form suitable and readily available for expeditions review (b) records must be retained for five years (c) records must be retained on -site for first 2 years, may be retained off -site for the remaining 3 years 63.6665 General Provisions This engine must comply with the general provisions as indicated in Table 8. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to the requirements of MACE Subpart ZZZZ. The engine will be installed with a non -selective catalyst to meet the formaldehyde reduction requirement of 76% or more. An initial performance test will be conducted within 180 days of startup to demonstrate compliance with the formaldehyde percent reduction requirement. During the initial performance test, the pressure drop across the catalyst will be measured. A CPMS will be installed to measure the catalyst inlet temperature. Continuous compliance will be demonstrated by keeping the 4 -hr rolling averages of catalyst inlet temperature within the operating limitations and recording the pressure drop across the catalyst monthly and demonstrating that the pressure drop is within the operating limitation. Records, notifications and reports will be submitted as required. To that end required reports and notifications include initial notification, notice of intent to conduct performance test, notification of compliance status, SSM reports (if required) and semi-annual compliance reports. Operating Permit Number: 95OPWEI00 ISSUED: November I, 1998 RENEWED: DRAFT dcp Midstream. March 30, 2012 Sent Via UPS Tracking Number 1Z F46 915 01 9235 0539 Ms. Bailey Smith Operating Permit Engineer Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Re: Lucerne Natural Gas Processing Plant Operating Permit 95OPWE100 Title V Permit Renewal Application Dear Ms. Smith: DCP Midstream 370 17th Street, Suite 2500 Denver, CO 80202 303-595-3331 DCP Midstream, LP (DCP) is submitting the attached Title V Operating Permit renewal application for the Lucerne Natural Gas Processing Plant (Lucerne) located at 31495 Weld County Road 43 in Weld County. The current Operating Permit 95OPWE100 was originally issued by the Colorado Department of Public Health and Environment, (CDPHE), Air Pollution Control Division on November 1, 1998, most recently reissued on April 1, 2008, and updated on April 1, 2010. Lucerne is classified as a natural gas processing plant as set forth under Standard Industrial Classification Code 1321. Natural gas is delivered to the plant by pipeline. Field gas is first charged to a separator where liquids formed during transport to the plant are separated from the gas stream. The gas stream discharged from the separator is processed through an amine unit to remove CO2 and then a molecular sieve contact tower, where moisture contained in the gas stream is absorbed After the molecular sieve has removed the moisture in the gas, the gas stream is fed to the processing plant, where it is chilled by a propane refrigeration system. Natural gas liquids formed during this process are transported offsite via pipeline and truck. The process uses nine (9) reciprocating internal combustion (IC) engines, two (2) natural gas processing skids, a 40 MMSCFD amine unit, a 6 MMBtu/hr heater, and a 16 MMBtu/hr regeneration heater. Please update the process description in the Operating Permit with this information. The Lucerne facility is an existing major source with respect to Nonattainment New Source Review for NOx and VOC. Lucerne is a synthetic minor source with respect to all other pollutants for Prevention of Significant Deterioration (PSD). The facility is located near the town of Lucerne, in Weld County, Colorado. Since the last issuance of Operating Permit 95OPWE100, there have been a few small changes to the facility. The dates and documents are listed below. Per your request, we have not attached these files to the renewal application. However, to facilitate your review, we will follow up with an email containing some of the important documents for you. March 30, 2012 Page 2 of 3 • February 2, 2010 - Issuance of permits 08WE0920 (40 MMSCFD amine unit), 08WE0921 (16 MMBT/hr reboiler), and 96WE905 (revised permit for P007, C-106, C-110, C107, C-109). • May 11, 2011 — Self Certification for permits 08WE0920, 08WE0921, and 96WE905. This was also a request to roll the permits into the Title V Permit. Please note that there are several errors which are currently in the Operating Permit that are corrected in this submittal. Also, permits 08WE0920 and 08WE0921 list new emission units that need to be rolled into the Operating Permit. A copy of the cover letter and TV forms from this submittal are attached as you will need these for your review. • June 16, 2010 — Engine C107 AOS was submitted. A revision to this AOS submittal was sent to the Division on October 22, 2010 to correct the emissions on the MEN. There are no changes from the current construction permit limits. This replacement engine was from out of state but met the Regulation Number 7 emission limits at the time of the AOS. • November 30, 2010 — MEN update submitted for the amine unit to correct the control configuration. The flash tank vapors are captured with a VRU and recycled to the plant inlet. The still vent vapors are sent to a regenerative thermal oxidizer. The overall control efficiency is 99%. • April 18, 2011 — Engine C113 AOS was submitted. The replacement engine was from out of state and the APEN denotes that the engine will meet the current Regulation Number 7 emission limits. Please revise the permit to reflect this change. • June 22, 2011 — Engine C112 AOS was submitted. The replacement engine was from out of state and the APEN denotes that the engine will meet the current Regulation Number 7 emission limits. Please revise the permit to reflect this change. • August 30, 2011 - Issuance 1 of permit 08WE0920 was issued to reflect that the emissions from the amine flash tank stream were routed to the VRU. Please note that the self certification for this permit (5/11/2011) requested that DGA be replaced with amine solution since we use a proprietary blend that DCP purchases from the amine vendor. • Engine C-244 was never constructed. Please remove that from the permit. • Engine C-178 is more commonly known by DCP Operations Staff as C-115. Please rename this unit to avoid confusion. We have denoted in in the application materials as C -115(C-178). That is AIRS point 033. Since the last issuance of Operating Permit 95OPWE100, the Green House Gas (GHG) Tailoring Rule has been passed which sets the major source threshold for GHG emissions at 100,000 tpy CO2e. GHG emissions from Lucerne were estimated to be approximately 83,047 CO2e. GHG emission calculations can be found in Appendix B of the renewal application. www.dcpmidstream.com March 30, 2012 Page 3 of 3 The following summarizes the enclosed attachments and their location within the renewal application: • Appendix A Operating Permit Application Forms • Appendix B Equipment and Emission Information o Facility Wide Emissions Inventory o Emission Calculations and Backup o Insignificant List o GHG Emissions • Appendix C Plot Plan • Appendix D AOS Table with current engine serial numbers • Appendix E Back-up information o Email list of required documents o Copy of May 2011 Self Certification letter and forms If you have any questions or require any additional information about the project, please feel free to contact me at (303) 605-1716 orWDHill@dcpmidstream.com. Also, since so many changes are being made to this permit, DCP would like to review the permit before it is sent out for EPA review. Sincerely, DCP Midstream, LP Wesley Hill Senior Environmental Specialist Enclosures Original plus 3 Copies www.dcpmidstream.com Appendix A Operating Permit Application Forms Operating Permit Application FACILITY IDENTIFICATION Colorado Department of Public Health and Environment Air Pollution Control Division 1. Facility name and mailing address Name SEE INSTRUCTIONS ON REVERSE SIDE Lucerne Natural Gas Processing Plant Street or Route City, State, Zip Code FORM 2000-100 Rev 06-95 370 17t" Street, Suite 2500 Denver, CO 80202 2. Facility location (No P.O. Box) Street Address City,County, Zip Code 31495 Weld County Road 43 Lucerne, Weld County 3. Parent corporation Name Street or Route City, State, Zip Code Country (if not U.S.) DCP Midstream, LP 370 17t" Street, Suite 2500 Denver, CO 80202 4. Responsible official Name Title Telephone Joseph Kuchinski V.P. Area Operations North 970-378-6345 5. Permit contact person (If Different than 4) Name Title Telephone Wesley Hill Senior Environmental Specialist 303-605-1716 6. Facility SIC code: 1321 7. Facility identification code: CO 1230107 8. Federal Tax I. D. Number: 841041166 9. Primary activity of the operating establishment: Process Natural Gas 10. Type of operating permit ❑ New ❑ Modified X Renewal 11. Is the facility located in a "nonattainment" area: X Yes ❑ No If "Yes", check the designated "non -attainment" pollutant(s): O Carbon Monoxide x Ozone ❑ PM10 ❑ Other (specify) 12. List all (Federal and State) air pollution permits (including grandfathered units), plan approvals and exemptions issued to this facility. List the number, date and what unit/process is covered by each permit. For a Modified Operating Permit, do not complete this item. Operating Permit No. 95OPWE100 Construction Permit No. 96WE905 - Construction Permit No. 04WE1301 Construction Permit No. 04WE1302 Construction Permit No. 05WE0958 Construction Permit No. 07WE0021 Construction Permit No. 07WE0979 Construction Permit No. 08WE0920 Construction Permit No. 08WE0921 Fugitive Emissions, Inlet Compression - P007, C106, C110, C107, C109 (Feb. 2, 2010) - Inlet Compression - C112 (April 20, 2006) - Inlet Compression - C113 (April 20, 2006) - Residual Compression - C108 (April 20, 2006) - Refrigeration - C105 (Oct. 4, 2007) - Inlet Compression - C115 (Nov. 15, 2007) - Amine Unit (Feb. 2, 2010) - Amine Reboiler (Feb. 2, 2010) 2 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Lucerne Natural Gas Processing Plant 2. Facility identification code: CO 1230107 3. Specify Emission Source: 4. Do not use 5. Pollutant, Equipment, or Process 6. Colorado Air Quality Regulations 7. State Only Facility GHG Emission Below Major Source Threshold Regulation No. 3, Part A, Section I.B.44.d(i); 8. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, operating hours, etc.) State Only PERMIT SHIELD PROTECTION IDENTIFICATION FORM 2000-605 Rev 06-95 3 Operating Permit Application 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: Lucerne Natural Gas Processing Plant I. ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS FORM 09-94 Facility Identification Code: CO 1230107 This application contains the following forms: x Form 2000-100, Facility Identification X Form 2000-101, Facility Plot Plan 0 Forms 2000-102, -102A, and -102B, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one form for each facility boiler, printing 0 Form 2000-200, Stack Identification ❑ Font 2000-300, Boiler or Furnace Operation ❑ Form 2000-301, Storage Tanks ❑ Form 2000-302, Internal Combustion Engine ❑ Form 2000-303, Incineration ❑ Form 2000-304, Printing Operations ❑ Font 2000-305, Painting and Coating Operations 0 Form 2000-306, Miscellaneous Processes ❑ Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Form This application contains the following forms: ❑ Form 2000-400, Miscellaneous ❑ Form 2000-401, Condensers ❑ Form 2000-402, Adsorbers ❑ Form 2000-403, Catalytic or Thermal Oxidation ❑ Form 2000-404, Cyclones/Settling Chambers ❑ Form 2000-405, Electrostatic Precipitators ❑ Form 2000-406, Wet Collection Systems 0 Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Font This application contains the following forms (one for each facility boiler, printing operation, 0 Form 2000-500, Compliance Certification - Monitoring and Reporting ❑ Form 2000-501, Continuous Emission Monitoring ❑ Form 2000-502, Periodic Emission Monitoring Using Portable Monitors ❑ Fonn 2000-503, Control System Parameters or Operation Parameters of a Process ❑ Form 2000-504, Monitoring Maintenance Procedures ❑ Form 2000-505, Stack Testing ❑ Form 2000-506, Fuel Sampling and Analysis ❑ Form 2000-507, Recordkeeping 0 Form 2000-508, Other Methods 8 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan ❑ Form 2000-600, Emission Unit Hazardous Air Pollutants ❑ Form 2000-601, Emission Unit Criteria Air Pollutants 0 Form 2000-602, Facility Hazardous Air Pollutants ❑ Form 2000-603, Facility Criteria Air Pollutants ❑ Form 2000-604, Applicable Requirements and Status of Emission Unit g Form 2000-605, Permit Shield Protection Identification ❑ Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule ❑ Form 2000-607, Plant -Wide Applicable Requirements ❑ Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS formed after reasonable inquiry, I certify that complete. CONDITIONS (check one box only) is fully in compliance with all applicable is fully in compliance with all applicable A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief the statements and information contained in this application are true, accurate and B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE R. I certify that the facility described in this air pollution permit application requirements. ❑ I certify that the facility described in this air pollution permit application requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from 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 Joseph Kuchinski Title V.P. Area Operations North Signature (/�i2 ,./..(4.2.1„,:f., Date Signed 03 — 2 0 — b2 0/ v 9 Operating Permit Application 2000-800 Colorado Department of Health Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM Facility Name: Lucerne Natural Gas Processing Plant 09-94 Facility Identification Code: CO 1230107 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from 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 Joseph Kuchinski Title V.P. Area Operations North Signa Ax;ix.r.._ Date Signed ‘*7// TERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 6 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS SUMMARY FORM 1. FACILITY NAME: 2. PERMIT: Lucerne Natural Gas Processing Plant 3. REVIEW ENGINEER: 4. DATE OF APPLICATION: 5. DATE RECEIVED BY APCD COMPLETENESS DETERMINATION I. IDENTIFYING INFORMATION II. EMISSIONS III. APPLICABILITY IV. COMPLIANCE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLETE INCOMPLETE _ NOT APPLICABLE COMPLETE _ INCOMPLETE _ NOT APPLICABLE COMPLETE INCOMPLETE _ NOT APPLICABLE _ APPLICATION FORM CERTIFIED FOR TRUTH, ACCURACY, AND COMPLETENESS BY: OFFICIAL TITLE SIGNATURE DATE APPLICATION EVALUATION COMPLETE (BASIC INFORMATION PRESENT TO BEGIN PROCESSING) INCOMPLETE- RETURN WITH ADDITIONAL INFORMATION BY: COMMENTS REVIEWED BY: DATE 7 MAJOR SOURCE OPERATING PERMIT APPLICATION APPLICATION COMPLETENESS CHECK LIST I. IDENTIFYING INFORMATION COMPLETE _ INCOMPLETE _ NOT APPLICABLE A. FACILITY INFORMATION FACILITY NAME, LOCATION & MAILING ADDRESS YES NO PERMIT CONTACT PERSON YES NO RESPONSIBLE OFFICIAL YES NO PERMIT REQUESTED YES NO B. SOURCE DESCRIPTION 1. OPERATIONAL INFORMATION: YES NO SIC/SCC CODES YES NO YES NO LISTING AND DESCRIPTION OF EMISSION SOURCE(S) 2. IDENTIFICATION AND DESCRIPTION OF ALTERNATIVE OPERATIVE SCENARIOS (IF APPLICABLE) _ YES NO _ N/A C. PERMIT SHIELD REQUESTED YES NO II. EMISSIONS COMPLETE INCOMPLETE NOT APPLICABLE A. EMISSIONS INFORMATION 1. QUANTIFICATION OF ALL EMISSIONS OF REGULATED AIR POLLUTANTS _ YES NO 2. EMISSION SOURCES: IDENTIFICATION AND DESCRIPTION OF ALL EMISSION SOURCES IN SUFFICIENT DETAIL TO _ YES _ NO ESTABLISH THE BASIS FOR FEES AND APPLICABILITY OF REQUIREMENTS. A LIST OF INSIGNIFICANT EMISSIONS UNITS OR ACTIVITIES EXEMPTED _ YES NO N/A BECAUSE OF SIZE OR PRODUCTION RATE. 4. PROCESS INFORMATION TO THE EXTENT IT IS NEEDED TO DETERMINE OR REGULATE EMISSIONS: FUELS YES NO N/A RAW MATERIAL(S) / MATERIALS USED YES NO N/A PRODUCTION RATES YES NO N/A 5. FOR REGULATED AIR POLLUTANTS, LIMITATIONS ON SOURCE OPERATIONS AFFECTING: EMISSIONS YES NO N/A ANY WORK PRACTICE STANDARDS YES NO N/A 6.^ OTHER INFORMATION REQUIRED BY ANY APPLICABLE REQUIREMENTS FOR ALL REGULATED AIR POLLUTANTS SUCH AS: FLOW RATES YES NO N/A 8 STACK PARAMETERS YES NO N/A 7. CALCULATIONS ON WHICH EMISSIONS RELATED INFORMATION ARE BASED N/A YES NO 9 III. APPLICABILITY NOT APPLICABLE COMPLETE _ INCOMPLETE _ 1. CITATION AND DESCRIPTION OF ALL APPLICABLE REQUIREMENTS YES NO 2. OTHER SPECIFIC INFORMATION THAT MAY BE NECESSARY TO IMPLEMENT AND ENFORCE OTHER _ YES _ NO APPLICABLE REQUIREMENTS OR TO DETERMINE THE APPLICABILITY OF REQUIREMENTS 3. AN EXPLANATION OF ANY PROPOSED EXEMPTIONS FROM OTHERWISE APPLICABLE REQUIREMENTS _ YES _ NO N/A IV. COMPLIANCE NOT APPLICABLE _ COMPLETE INCOMPLETE A. COMPLIANCE STATUS 1. A DESCRIPTION OF THE COMPLIANCE STATUS OF THE SOURCE WITH RESPECT TO ALL _ YES NO APPLICABLE REQUIREMENTS 2. FOR APPLICABLE REQUIREMENTS WITH WHICH THE SOURCE IS IN COMPLIANCE, A STATEMENT THAT THE SOURCE WILL CONTINUE TO COMPLY WITH SUCH REQUIREMENTS 3. FOR APPLICABLE REQUIREMENTS THAT WILL BECOME EFFECTIVE DURING THE PERMIT TERM, _ N/A A STATEMENT THAT THE SOURCE WILL MEET SUCH REQUIREMENTS ON A TIMELY BASIS YES NO YES NO _ 4. FOR REQUIREMENTS FOR WHICH THE SOURCE IS NOT IN COMPLIANCE AT THE TIME OF _ YES NO _ N/A PERMIT ISSUANCE, A NARRATIVE DESCRIPTION OF HOW THE SOURCE WILL ACHIEVE COMPLIANCE WITH SUCH REQUIREMENTS 5. IDENTIFICATION AND DESCRIPTION OF AIR POLLUTION CONTROL EQUIPMENT AND COMPLIANCE _ YES _ NO MONITORING DEVICES OR ACTIVITIES 6. DESCRIPTION OF OR REFERENCE TO ANY APPLICABLE TEST METHOD FOR DETERMINING _ YES _ NO COMPLIANCE WITH EACH APPLICABLE REQUIREMENT B. COMPLIANCE SCHEDULE NOT APPLICABLE COMPLETE INCOMPLETE 1. A SCHEDULE OF COMPLIANCE FOR SOURCES THAT ARE NOT IN COMPLIANCE WITH ALL YES NO N/A APPLICABLE REQUIREMENTS AT THE TIME OF PERMIT ISSUES 2. A SCHEDULE FOR SUBMISSION OF CERTIFIED PROGRESS REPORTS NO LESS FREQUENTLY _ YES _ NO N/A THAN EVERY SIX MONTHS FOR SOURCES REQUIRED TO HAVE A SCHEDULE OF COMPLIANCE TO REMEDY A VIOLATION C. COMPLIANCE CERTIFICATION _ COMPLETE _ INCOMPLETE _ NOT APPLICABLE 1. CERTIFICATION OF COMPLIANCE WITH ALL APPLICABLE REQUIREMENTS BY NO A RESPONSIBLE OFFICIAL YES 2. A STATEMENT OF METHODS USED FOR DETERMINING COMPLIANCE, INCLUDING A DESCRIPTION _ YES _ NO OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS AND TEST METHODS 3. A SCHEDULE FOR SUBMISSION OF COMPLIANCE CERTIFICATIONS YES NO 4. A STATEMENT INDICATING THE SOURCES COMPLIANCE STATUS WITH ANY APPLICABLE _ YES _ NO ENHANCED MONITORING AND COMPLIANCE CERTIFICATION REQUIREMENTS OF THE FEDERAL ACT 10 Appendix B Equipment and Emissions • Facility -wide Emissions Inventory • Emission Calculations and back-up • Insignificant List • GHG Emissions 0. yE C c ma C I Regulation No 3, Part C, Section II E 3 k Regulation No 3, Part C. Section II E 3 k Regulation No 3, Part C, Section II E 3 a Regulation No 3, Pad C, Section II E 3 a Regulation No 3, Pad C Section 11 E 3 a Regulation No 3, Part C Section II E 3 a Regulation No 3, Part C Section II E 3 a Regulation No 3, Part C, Section II E 3 a Regulation No 3, Part C, Section II E 3 a Regulation No 3, Part C, Section II E 3 a Regulation No 3, Pan C, Section II E 3 a Regulation No 3, Pad C Section II E 3 a Regulation No 3, Part C Section II E 3 a Regulation Na 3, Part C Section II E 3 a Regulation No 3, Part C, Section it E 3 a Regulation No 3, Part C, Section II E 3 a 'Regulation No 3, Part C, Section II E 3 a Regulation No 3, Part C, Section II E 3 a Regulation No 3, Part C, Section II E 3 a Regulation No 3, Part C Section II E 3 aaa Regulation No 3, Pan C Section II E 3 aaa Regulation No 3, Pad C. Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Pan C. Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C. Section II E 3 a Regulation No 3, Part C Section II E 3 aaa Regulation No 3, Part C Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Pad C, Section II E 3 aaa 'Regulation No 3, Pad C, Section II E 3 aaa Regulation No 3, Pad C, Section II E 3 aaa Regulation No 3, Part C, Section it E 3 aaa Regulation No 3, Part C Section II E 3 aaa Regulation No 3, Part C Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3 Part C, Section II E 3 aaa Regulation No 3, Part C, Section II E 3 aaa Regulation No 3, Part C Section It E 3 a (Regulation No 3, Pan C Section II E 3 a Regulation No 3 Pan C, Section 11 E 3 a Regulation No 3 Pan C Section II E 3 a Emission Estimation Method N i s <C Engineennq Estimate Engineenng Estimate Engineennq Estimate Engineennq Estimate Engmeenng Estimate Engineering Estimate a I E E ww 0 0 C CC WW Engineennq Estimate AP -42/ Engineering Calcs N/A - Not a source of emissions N/A - Not a source of emissions N/A - Not a source of emissions IN/A - Not a source of emissions N/A - Not a source of emissions N/A - Not a source of emissions N/A - Not a source of emissions 0 C En '^ I ISlormwater with possibly some hydrocarbon tube oils Engineering Estimate Engmeenng Estimate >0000000000-0No000000ggga >00000000000o $C'EC$ggaggCCC+CCCCC0000 cccc O Coo1 000000000 N 0 00000000000000000000000000000000000 Do zoo 0 0 0 0 0 0 0 0 0 0 0 00000000000000000000000000000000000 m mtt1, ��(J2 LLLLLLlThiStiLL mNmmm4l (2‘2‘2"2"1(2)212“2 ��Q��2 UUUUUUU Ul �0� 4i ___ m e,mn PPP�p _ —330 21adOPOpap.0.0 _NN ____ _qq _aavva '$caa ___ 8gm"ggg Oo ao+MO QPpO�PPPsQL §0000§§8 M8 "' 8 La St+0i — 0 o — ON8§NN0c0m00t0�N pOp a� pDpD N8 �om8 en E yq S a p Office Heater Shoe Heater C105 Engine Blowdowns I` rind Fmmma Slowdowns �1 �1 m a ba FO5 IWIL 3OC )oc C109 Engine Slowdowns rt 1n Fnnine Slowdowns g ':$g m 2 Ema too IwLL 2(Nr )cc C115 Engine Blowdowns Flare Pressunzed Condensate Bullet Tank Pressurized V Grade Bullet Tank Pressurized V Grade Bullet Tank pressurized Y Grade Bullet Tank Pressurized NGL Bullet Tank Pressunzed NGL Bullet Tank Pressunzed Propane Tank Methanol Methanol Mathannl {op dy no i 2.c.2 m<(g= a f cQ c Used Oil Tank Kerosene Lube Oil Tank Sinn Oil Tank Slop Oil Tank Sion Oil Tank Slop Oil Tank Slop Oil Tank Slop Oil Tank Sinn Oil Tank (Slop Oil Tank Patna Lube Oil Expander Lube Oil Lobe Oil Tank Used Oil Tank Hot Oil Tank (Slop Oil Tank Produced Water Tank Waste Water Tank Press in irk I nadniit - Condensate Press Truck Loadout - Y Grade N E N W E 0 L O 0 C • . • • mo =0 U = O 0 7 01 0 Ii Form APCD-102 E LLI C rr H g . O o y '5 6. F G yCl y 0 V . 0 0 0 0 0 0 0=_ ==p O S o'E 0 0 • 0 0 . ry ry _ 0 . o • - = 'IS 0000000002. a a O • R t 8888888rNoo ! o • 0 • k iea O I m P O O' E O • I a • E • o U s M m P n n 0 O, f • O • i n T. m r r m m••- a E e e • •o e m ....... - - - ....... - - no n o • a a n 3 AAA"MMAA«AF;o i 0 • 0 • iSS n. -- 11.9 1 65 11.9 I 65 - - m m P -�- e 'e 4 - 0 0 - r - a 'ei u E=Z 11 - t u O >> 8 N«e;'a 'a '�nry rvno r v� I^Y ^ fJ - N • OO : • 8 •• M • N M •PPmnr•ryl A-- "4 2 N OO • N « N OO ry O o O O 0 0 O 0 O 00000 o O O O fl O 0O 4 O O 4 • O o • O e. 4 f d 0 0 0 0 0 0 m 0- o, P oe on 0 o e o a e e • so 0 •• 0 0 0 m•• 0 0 0- o P o e n o c 3 n o ry a o o 4 e 01 GO • mmm 0 0 0 0 SS OO IS o m0P0n' o- 0 0 0 4 a N o ^10 • OO a a ry • I Uncontrolkd PoteotMl to Emil (PTE) 11 1 00000000000 a a a 0 e • r(TPV)l US I 17.7 .1 1.1 1 l9 I 7.7 1 1.1 I IS I 0.0 1 401.4 1 0.0 I xN N N N N n N, N g 0 g 0 • a Y S a .0000000. P a a - ' f a w a a - N N N N N N n Se.: ry ry a a • ! M O a O a a • Rr FFRR n neo " e • o • VI i. t_ r aaaaaaaaaee n r r r r m P�,i t 0 0 0 0 b .O 0 a m O' d 4 a • 0 • N N N n N N n N n e' O • e • f �3s*5*`s Nh ra al Ao' m 0 • e • 3 0 _rim O n r1'n nn n A4 569.7 4 44,326 0.4 1 0 a o o • :m�m�mcn;u n : o• e a -- - m�'o�' x n 0 0 a 0 a e . O 066666 a O e a e O 60666 e e O - 11 a a O • a 00 e 0 . 0 0 0 000•-•000 00 4 O 0 0 : e m 7 2 7 la 0000000-00- •: n a !I • O c • 0 0 [' m• o m 0 0 m o m• 0 o m 0- O P o o e i I H_I01 Reefs ReboOer 6.0 MMBN/hr I i 1 p 59 I i f I dX F I II s • LL E r -IM Wank L7042 GSI 1.232 HP I 4$4 LillIii 3 3 3 rT 12 Wank L7042 GSI 1.232 HP I 4`x 'oo 3 3 • r -ins Wank L7042 GS11.478 HP I _ n I3 F AU01 Amine Unit 40 MMSCFU 175 gpm I Umi e..,h,# R.Mi4' IR MMRTI Pk ' g Q a e < EQQFQ e rEnnon- 0 6O=666 0 LLWLVIWiGI f_ ;66 Ina 1n "� 1 W 6 N Total VOC Emission Rate Total VOC Emission Rate ! § ! 5 ) ! ! cei ! ; | � ! 6 / LO 8 8 ! § § ; ; § 4 r § ; 8 ! 8 8 ( ) | Emission Factor La ! ) ) i i ( / \ a | / i Total VOC Emission Rate w ir Total VOC Emission Rate , ! ; ) Total HC Emission Rate ! , $ ! Uncontrolled Emission Rate ! ! , Lucerne Gas Processing Plant - N N C a C to C 0 . O C u a R C0LL C 0 J o 2 E J z: E w o c cL G cs)da W • J 0 gI U cS U O 67EI E 00 N o m Q.- 0 r ▪ U K Y Y C co • S w V d Nen 3 E E m F- 0 3 E E Q C LL CO 0 I E E_ QS U LL D LL E E Cntena Pollutant Emission Calculations Controlled Potential Emissions (ton/yr) CD N A °O'. m o N (mV 66 Emission Factors a o 2 0 g/bhp-hr 1 0 g/bhp-hr 194E-021b/mmBtu a 3 N `( 2 b ON m S.2 O w" Vml `' E m O 0 0 c D Emission Factors 13 1 g/bhp-IT 11 7 g/bhp-hr 1 0 g/bhp-hr 22 tom EE EE Hs Wy w 32 —.to C 2 0 0 C 3 m 1 C 0. m i 2 H 0 U aN g co co E 2 x O o s • e g9 42 h m N 8 G 5 J 4 E CC 50 50 50 50 50 50 50 50 s m m m¢¢¢¢¢¢QQQQUQQUQUQUUQUI Controlled Emissions (lb/yr) 82 O 27 30 0 52 wm NomelcoN208..-ccomg O 0 0 0- 0 6'- 4 i° O O m y Control Efficiency aeSSSS EEEEEEEEEEEEEEEEEEEE SSASXee eeeeee Potential Emissions (Ib/yr) oo ON 0 V 229 74 21656 130 10 <146 �'N' vv V V < 1646 8e 251 97 C0I8 m V- �pO V 45 95 <059 8N ' V Data Source EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA HAP Emission factors 2 53E -O5 Ib/mmBtu < 1 53E-05 Ib/mmBtu 22 mm EE EE 22 44 WW fm N fO V _ 2 79E-03 Ib/mmBtu 2 63E-03 Ib/mmBtu 1 58E-03 Ib/mm6tu < 1 77E-05 Ib/mmBtu =222222233=r 600000000066 EEEEEEEEEEEE EEEEEEEEEEEE 222222222222 99990999 pwlwpwlwOw�pp N M VVVV d V N N O.- N < O V 9" twwwwpw�w W V YI m Y] N V 1 95E-04 Ib/mmBtu 0 0315181 IblmmBtu 2 Z n 1,1,2,2-Tetrachloroethane 1,1,2-TrcNoroethane _ a 00 EE S2=>, 5ia2 =2-a 0Q m -¢¢ D 'p66 u m Benzene Carbon TetracNonde m 'eE 2b O O E 2 00 (Ethylbenzene Ethylene D,bromde Formaldehyde Methanol Methylene CNorde Naphthalene PAH Styrene m 4 Co Ss. 3 C r> Xylenes(m.p.o) TOTAL DCP Midstream, LP C I CO a m _c C N O 0 iiiiV c Q U a v.. U O• _i OO C o 2 E a .c / 0 r u w �UK • . w d P Y C -a, o C � N cN -sI a 3wca W • J O N d 0 m 3 E E E m 0 8 3 O E E P LL m n E E a 0 LL E E E Cntena Pollutant Emission Calculations v 6 Controlled Potential Emissions (ton/yr) 7 23 79 8 33 9 o 0 0 Emission Factors t L O 2 0 g/bhp-hr 0 7 g/bhp-hr 1 94E-02 Ib/mmstu 5 68E-04 Ib/mmBtu I 0 Emissions (ton/yr) g)c28oNo o • m 7 m o 66 0 Emission Factors 13 1 g/bhp-M_ 11 7 g/bhp-hr 1 0 g/bhp-hr _ _ aa a3 EE 22 LE9 N LE 42 m z 0 0 a N '88822888828o a 828 — C— 50 50 N O$ N 8 f omQQQQ¢QQQQ<UQQU<o<oo<UI Controlled Emissions (lb/yr) $mNn CO O 11487 108 28 Co? �o 053 0 56 22 �o�N�vmo 0'29 22 97 0 30 o m my Control Efficiency at ve N 8 e�p� 8 N ape aaz N N 0Oe 000 Y) N mol N a' a' N N av flee N '0 N N N N N Co Co Potential Emissions (lb/yr) o N N V Y° O p r V+ v r V Oi 1C N N O ot ^ O, M fl v o .-.- v V O N e- V v < 1646 88 251 97 ° O m a° N V m 6 O VVV 0 N y) O O V N v Data Source EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA EPA as W EPA EPA EPA HAP Emission factors 2 53E-05 Ib/mmBtu < 1 53E-05 Ib/mmetu 6 63E-04 Ib/mmBtu < 1 27E-05 lb/mmEttu 2 79E-03 lb/mmEttu 2 63E-03 Ib/mmBtu EEEE 2222 UMW v v v <248E-051b/mmBtu _ < 2 13E-05 Itr/mmBtu_ > > E E EEEEEE owwwLww ro 2 > E E ern.- V ≥ ≥ E E V 5 58E-04 Ib/mmBlu <718E-06 Ib/mmBtu 1 95E-04 Ib/mmBtu 0 0319181 IblmmBtu E 5 a 11,1,2,2-TetracNoroethane 1,1,2-Trichloroethane q C a ° mo O6 j Z ,0! .- -- Acetaldehyde Acrolan Benzene Carbon Tetrachloride E q° E 8 6 b 0 C U Elhylbenzene Ethylene Dibrombo O r ° C LI. E 'P 0 = Ug 0 L Ia:2 Toluene Vinyl Chloride Xyenes(m,p,o) TOTAL 4 Um N 5 'w U me m s° a g. E c • 9 as Y S m E ,° e o U s E D5 DCP Michtmam, LP C a m C o of (13 0 Q J Oa - TO m o CI(� 5 J O A CO CO N es N Ez w w m v tics a. • d c =O w J 0 N E U J N CO 0 0 L co OR L d1 Y C S A c 3wa C d 3 r -3 z E E 0 m ro U 3 0 5 E co ce J LL m a 5 m i E_ m 3 1 0 0 LL v E E_ Criteria Pollutant Emission Calculations Controlled Potential Emissions (ton/yr) IS m e o 0 Emission Factors I 2 0 g/bhp4r I III o - 9 a W 2 Emissions (ton/yr) 2282 `'O '0 0 0 Emission Factors 13 1 g/bhp-hr 11 7 g/bhp-hr I C 0 0 0 m mm E E -,aa t - 9W 82 Co a 0 O z 0 0 a s a a z N na F a Uy a N E 0 I aF a S I 9 ga E 11 8 3 m E c s m m j, V I N V I N N N[ i H N N O N VO] O N S N 8 S S 8 I m¢aaaaaaaaaoaaoaoaooaol Controlled Emissions (Iblyr) n O 32 75 0 83 mma•mSmNa RN w O O O 47418 151 14 8222S2iSM N4 dO 66N6 N O 9 63 < 1063 Control Efficiency 19 2222222x222o �00022R fl Potential Emissions (lb/yr) O N 'rNrr V y0j N W V V 0 N N Otpp r V N C. V V V P- n V,p V V N . r iy V o o V V poi m.- V1fS6 V N N V N V Data Source W W EPA EPA W W EPA EPA W W W W EPA EPA EPA EPA EPA EPA W W EPA HAP Emission factorsb 2 53E-05 Ib/mmBtu < 1 53E-05 Ib/mmBtu 00000 con EEEE EEEE a aaa 999 °N C'rNN V r b 1 58E-03 IblmmBtu < 1 77E-05 Ib/mmBtu g m m E E E E as 99 on rr V V < 2 48E-05 ib/mmBtu <2 13E-05 Ib/mmBtu 00000 630366000000000 EEEEEE EEEEEE 333333 99999 owwwww O t7OW—r r h V y V 5 58E-04 IblmmBtu < 7 18E-06 IblmmBtu 1 95E-04 lb/mmBtu 0 031!181 Ib/mmBtu Pollutant I1,1,2,2-TetracNoroethane 1 1 2-Tnchloroethane 2 2. a 5 5s mo rr 'Acetaldehyde Acrolem Benzene Carbon Tetrachloride IChlorobenzene Chloroform IEthylbenzene Ethylene Dibromide 'Formaldehyde Methanol Methylene Chloride Naphthalene PAH SMene 5 E a5 Xylenes(m.p.o) TOTAL 0 R H a On 6 as 0 • m 5.8 $ ,%0 sk E 4 t g ET, x .� 1.2 E c O 00 x 0 m o 0 v mm A E $ E 0 s k\§ MOW 32 k \ } \ \ \ 2 ! ! ) ) \ ] Criteria Pollutant Emission Calculations Controlled Potential Emissions (ton/yr) ]]§!§ Emission Factors -a, 2 0 g/bhp-h 1 0 g/bhp-h 1 94E-02 IbimmBtu } w Emissions (tonlyr) 174 57 I 7§!;TS Emission Factors 1 0 g/bhp-hr 1 94E-02 Ib/mmBtu 5 88E-04 Ib/mm8tu a. O a. ! / tai )42 20 g 761 )) }) E lsee@;; 501 50 sSp2§2 SS§§8§, Controlled Emissions (Ib/yr) §®\\ 7304 0 82 !!E!|\ 190 4 49 !d 25 79 0 33 en . Control Efficiency ■;;■■■!K§r!;§;!!Kr§/■ Potential Emissions (lb/yr) 234 <141 ]\§)\}V\)) < 1149 06 282 91 !}§\[))§ Data Source 22 EPA EPA EPA EPA 26 EPA EPA EPA EPA EPA EPA 2220. EPA EPA EPA HAP Emission factors e 2 53E-05 Ib/mmBlu < 1 53E-05 Ib/mmBtu 22322Z2222 tO al 9EEEEEEEEEE EEEEEEEEEE ZZBB 999999999 )§(§)E§§!§ CO CO 03 CO OD 03 M 03 0 02 lb/mmBtu 3 06E-03 Ib/mmBtu 4 12E-05 IbimmBtu < 9 71E-05 Ib/mmBtu 1 41E-04 Ib/mmBtu < 1 19E-05 Ib/mmBtu 22 Wm EE EE BB 99 \§ 1 95E-04 Ib/mmBtu 0 0315181 Ib/mmBtu ) ) 11,1,2,2-TetrachloroethaneI 1 1 2-TruHoroethane | 2° \\ Acetaldehyde Acrolan 8enzeno Carbon Tetrachloride CHoroberaene Chloroform Ethylbenzene Ethylene Dibromide Formaldehyde Methanol (Methylene Chloride Naphthalene !!| '!f)} 0 Xylenes(m,p,o) TOTAL \ § Amine Unit w/ RTO Control Lucerne Natural Gas Processing Plant DCP Midstream, LP Amine Unit Throughput (MMSCFD) 401 'Amine Circulation Rate (gpm)l 175 Am ne' Acid Gas & F ash Streams Total Uncontrolled Amine Emissions Iblhr ton/yr lb/hr ton/yr H 0.59 2.58 0.59 2.58 SO. 0.00 0.00 0.00 0.00 CO 5739.30 25138.13 5739.30 25138.13 Niw:en 0.10 0.44 0.10 0.44 Water 245.20 1073.98 245.20 1073.98 Methane 34.02 149.01 34.02 149.01 Ethane 21.42 93.82 21.42 93.82 •G -SA6 NWC7 L 1 [ no- 1r .:I1FIi .:1 rfrtf'' - -.`-!t Cr.=IL'fk'L•3L:1 pw »r 7 b1„- 1f O€:;_J DS r Ji' -Wi iI .-., . c ' cT 9'a_ -.fit. Lvl• : I t. " tom.,::. 6A4s9C i7iLi.'.. I V EL_I 10.740* r'tT'4K'a .alV girt ,:1 owitt i1 i fur ielleitMere 't-jriS+S' ':1 400:38 IIIINetalltM9 400.38 I iCtir "r d•n. ` i 32X:. •:I Sir ewe* teerthieNte j irl'g :riatilKaNt _ '.r —rot '.ff .=IL— {;.: fh•h �BK1�'14attii :a5 two:inn se0.63. ro,,,,t,,Z. ,^,k x. :v , :, r'r(3 0Arter Mg o.it:'$7l 0:4Br*t,'. Emissions from PROMAX model from 9/1/09 Application. Vent to RTO Stream. Amine Acid Gas Stream Amine Flash Stream Burner MMBTU/hr To Temp MMBTU/hr Total BTU 48.02 BTU/SCF — BTU/SCF 48.02 BTU/SCF Flowrate 0.04 MMSCF/hr — MMSCF/hr 4x24hr 16.34 MMSCF/yr 2.15 MMBTU/hr — MMBTU/hr 0.5 4 6.65 MMBTU/hr From stream properties in PROMAX run from 9/1/09 application. 23307.05068 MMBTU/yr Total Amine Emissions Total Amine Emissions wl Buffer Uncontrolled Controlled' Buffer Uncontrolled Controlled Iblhr ton/yr lb/hr ton/yr X lb/Pr ton/yr lb/hr ton/yr NOx 0.00 -a,b.0.009ato 0.45 *cu 0.7982* 0 0 o.r:7rt:0wkK. 0.45 .oh --t 0.790.04 CO 0.00 NM% 0.0044&8 2.46 last 4.31-S 0 0.00 %SA 0.00Ohos 2.46 &''4hk 4.31later SO, 0.00 MIS 0.007818 1.11 SO*44.86188 153 0.00 (PA 0.00'+sr*:0 2.81 *ha 12315 His 0.59 t 2.5829* 0.01 tee 0.03at 153 1.49 S' Ste 8.5488082 0.01 ;itB'6e 0.07881°6 VOC 130.06 >'H8 569.66%t 1.30 5844 5.69405 0 130.06 353 569.66 1.30 pNr-titia-. 9.593x4:40 C02 5739.30 % 25138.138, 5739.30 of 25138.13th 0 5739.30 • 25138.13x 5739.30 M0T 25138.1384 Benzene 5.06 m3822.16144 0.05 0.2204% 0 506 ,8,k 22.165 0.05 ≥5''W00 0.22?42s Toluene 3.99 4-38.17.4Boa 0.04 htslit 0.17daa: 0 399 43y17.48.50' 0.04 18#0.178040# Ethylbenzene 0.26 +tit 1.14"044 0.00 484* 0.018152 0 026 4:8521.14000:82 0.00 (SNP( 0.01#My6R Xylenes 2.02 %c R 8.85#-4f 0.02 5FIM 0.09%2X. 0 2 02 x x+. 5.5fa - 0.02 aNA 0.09sr5:`d n -hexane 0.17 Atzi 0.744805 0.00 eehe 0.01,4%. 0 0.17 :� 0.744eor 0.00 *'FF's0 0.01 -WO Total HAPS 11.50 *6.50.370,8, 0.12 0004 0.50000 0 11.50 002 50.37029 0.12 a 0.50.% --- The flash stream is recycled using a VRU with a back-up; Vier re assuming 100%control wIN 20% downtime. The acid gas A buffer has been added to the emissions H,5 and 50, to account for fluctuations In gas composition and operating parameters. NOx/CO Emission Factors from AP -42, Table 13.5-1 NOx 0.0681Wmmbtu CO 0. 701b/mmbtu Assume 100% conversion from H,S to $0, I 781 %Y 8 1� � ' im s f • s S 0606660066600E6660066666660 0000000000000 0r m P 0m a+s�P Wp0T0$ a NVS Y1 m •0 lV ^ O R VS W miXtVi1Vm OOOO, R IVGON ®^ " O Obgm O < °6 on m 00000000000000000000000000 qU O z^ E N 1` R p g A O np A R P O r O$ 0 op s F W I! n^ a a_ 8_ a W a O. g fl p; 0. O" O N OO R a 0 OO ' dg m 00 0.07 o. ^vaO�yay yyo�p-a $spasE 0app(il o yRvEE° ` Wm NQ-CINR-Rg^mN n 20;2$ m a 66 .2§§ g. or.- ra t_•p_ _' ON a o �lY a W g $ x 251$a ss 0a'o Vs� o4m�6NR^•^R000WS'°R^R1m1mB1ASj$3 a�� f ry - ^ N r {V m N `! NrrvP_R mn SEASF SRr o $ O Q 8 O X P 13 O R$ R M nmOSN6 O,AMjO. .090 rm^QI E'Q Rm- ci NO a� r I 2 f i II:F= 1111113181°1101'111€,111 m OSOOSSSMNrvMF N a M O O V ' R $ n of i n m $r$ S_o 0$-0 o -o 0 82 8'Pe ^y'y�R9'S; 4mRq`�' SSn OO ym a s O W E 2 m R 07N2 N 2 ;r?G4 S1 0� r:70 P- SAna O O 8002811lPNNna O m mAK MA00 O .C$0O i 0ccgg 0� «o(m32000 l§? O o a$ o^$ m^ E RR 66 r R FriI'�,S Rqo R ry o O O R^ l og m s m g P 8 oa�8"8gRF 4 Y O g P R1:5BE D . O O h G 0 l' m N r P Sq$Rgg .0 83NyNOW N N« RE p 'i g O 0 0 0 4'SSBc W 'r8R N.6 Rno O O N O O 0 RE r m2ry ilr8 Sooeq AiRR C m a Q J C O y E N CO 0yU 2: 2 j in in a. 0 V W f C =a 0 y o m 0 8 J Amine Heater Emission Factors Emission Factors m m f s n N 0 0 ZO O Emission (actors as per manufactures guaran D U U L L E E E E E d L.0 ozo Z OU >0-0 Emission Factors provided by AP -42 1.4-1 & 1.4-2(7/1998) 40 MMBTU/MMSCF Fuel Heating Value LU 0 0 s 0 0 N O 8 O 8 0 C, 0 E m CO 8 N E 0 co uo 0 X 0 m In uull 4 V 4 W N W W (WV W CN W O W N 4 V W r� W CI W W W N W l9V e W W 0 W W 0 W O ca W O e W W 6 W N e'- W N W W < 4 W e W Wv no W W cc N q, n 4 W 0<<<< 0 n 4 4 W W N O 0 4 W 0 4 W N 0 4 WW N 4 N P 0 4 W M N 4 WW 6 4 N O 4 W O t7 0 4 N 4 0 4 W 0 V 4 W O Cl 0 4 W O t7 4 W V n 0 4 WW !: 0 4 g ,- N 4 W N co4 W N O 4 W N 4 m V 4 WW t7 4 0 5g Z �3 3 ul W to 4 N 1.6E-06 1.6E-05 4 m 4 m 4 CU 4 m - 4 W N 4 cWi 4 m 4 ry 4 m 4 w 4 ry 4 ry r 4 o CO 4 w N 4 14 1" qQO x m 4 m u- 4 W 0,- 4 "n 4 o 0 4 a C6 I2-Methylnaphthalene 3-Methylchloranthrene 7,12-Dimethylbenz(a)ar m m L q IAcenaphthylene IAnthracene IBenz(a)anthracene ycy C l� c m N ac O W W 5 a z t IBenzo(g,h,i)perytene IBenzo(k)fiuoranthene m N,j C U IDilvenzo(a,h1anthracen IDichlorobenzene I Fluoranthene c 0 IL I Formaldehyde I "'Sr cu 2 C' °i n V. g N S 0 to Z I Phenanathrene cp R' N FO- Z :, Lucerne Gas Processing Plant - Permit Application Lucerne Gas Plant Inlet Gas Analysis Sample Date: October 29, 2007 GAS ANALYSIS DCP Midstream, LP Lucerne Gas Processing Plant Weld County, CO Component : Mole % Mole Frac. I d MW . Lb/Lb-mol I ' VOC H2S 0.000 0.00000 34.08 0.00 Helium 0.006 0.00006 4.00 0.00 Oxygen 0 0 32.00 0.00 CO2 2.314 0.02314 44.01 1.02 N2 0.322 0.00322 28.02 0.09 Methane 72.181 0.72181 16.04 11.58 Ethane 14.206 0.14206 30.07 4.27 Propane 6.761 0.06761 44.09 2.98 2.98 Isobutane 0.881 0.00881 58.12 0.51 0.51 n -Butane 2.084 0.02084 58.12 1.21 1.21 Isopentane 0.445 0.00445 72.15 0.32 0.32 n -Pentane 0.473 0.00473 72.15 0.34 0.34 Hexane+ 0.327 0.00327 93.00 0.30 0.30 100.000 1.000 22.63 5.67 Percentage of Vapors that are VOC 25.06% Percentage of VOCs that are HAPs (as Hexane+) 5.36% 3/28/2012 Lucerne Gas Processing Plant - Permit Application 1 | Regulation No. 3, Part C, Section 11.5.3k Regulation No. 3. Part C. Section II.E.3.k Regulation No. 3, Part C, Section II.E.3.a Regulation No. 3. Part C. Section II.E.3.a { }}/ } 1111 1111 !!!! 2 j Regulation No. 3, Part C, Section ILE.3.a Regulation No. 3. Part C. Section 11 E 3 a Regulation No. 3, Part C, Section II.E.3.a Regulation No. 3. PM C. Section II E 3 a (Regulation No.3, Pan C. Section II.E.3.a I Regulation No. 3. Past C. ca -boo 1l F.l a I / j) }j I! !! 11 (Regulation No.3, Pan C, Section ILE.3.a Regulation No.3. Pail C Section li E 3 a Regulation No. 3, Part C, Section II.E.3.a Regulation No. 3. Part C. Section II E 3 aaa (Regulation No.3, Part C, Section II.E.3.aaa Regulation No. 3. Pan C Section II E 3 aaa Regulation No. 3, Pan C, Section II.E.3.aaa Regulation No. 3. Pan C Sedan 11 E Sans Regulation No. 3, Part C, Section II.E.3.aaa Regulation No. 3 Pan C. Section II E 3 aaa Regulation No.3, Pat C, Section II.E.3.aaa Regulation No. 3. Pan C Sedan II E 3 a (Regulation No. 3, Pan C. Section II.E.3.aaa 'Regulation No. 3. Pan C. Section II E 3 can Regulation No. 3, Part C, Section II.E.3.aaa Regulation No 3 Past C caction II E 3 aae Regulation No.3, Pat C, Section II.E.3.aaa Regulation Na 3 Pan C Section II E 3 .aaa Regulation No. 3, Part C, Section II.E.3.aaa Regulation No. 3 Part C Swan IlE 3aaa Regulation No. 3, Pat C, Section 11.E.3.aaa Regulation No. 3. Part C. Section rl r no jI A /} !, Al 22 l Regulation No. 3, Part C, Section II.E.3.aaa Raoulabon No 3 PaR C cation II E 3 aaa Regulation No. 3, Part C, Section II.E.3.aaa Regulation No. 3. Part C Sedan IIFla 3 a Regulation No. 3, Part C. Section II.E.3.a Regulation No. 3. Part C Section II F 1 a Regulation No. 3, Pat C, Section II.E.3.a | | | „ ;>!!! !L } yy! 9 E ineenn Estimate E ineern Estimate E ineerin Estimate Estimate En 'main Estimate En neenn Estimate E neenn Estimate AP -42/ E ' Cares WA - Not a source of emissions WA - Not a source of emissions N/A - Not a source of emissions N/A - Not a souse of emissions WA - Not a space of emissions WA - Not a source of emissions WA - Not a source of emissions HYSYS/Tanks 4.09d Stemmata with possibly some hydrocarbon tube oils Engineering Estimate Engineering Estimate >OO 00; 0.12 0.12 0.12 0.12 rN,.......r|rlrr||!!!|r|rr||||||!rB|e|! e!lmm0000000 00000,0000,00,0,000000,000000000000. )!§o a a ao0000-00000000000000000000000000000000000, ,!!!L !!§#§§§ 3, flu §() !!,!!!!!!!!!!!!!!,!!!!!!!!!!!,!!! §§gggR»*.-. dO §§§§§§§8§§§!!:,§«l,....,ea.21 ma...,� - - 2§ SI \!6I #' l:l us Engine Slowdowns O106 Engine Slowdowns C107 Engine Slowdowns G108 Engine Slowdowns ' „ Mg /!/ Yresaunzeo Londensate Bullet Tank Pressurized Y Grade Bullet Tank Pressurized V Grade Bullet Tank Pressurized V Grade Bullet Tank Pressurized NGL Bullet Tank Pressurized NGL Bullet Tank Pressunzed P ne Tank Methanol 6!{ Lube Oil Tank Used Oil Tank Kerosene Lune Og Tank Slop Of Tank !! !!{ .„w / anc Rettig Lube Of Eaparlder Labe VII Lube Oil Tank Used Oil Tank Hoe Oil Tank Slop Oil Tank Produced Water Tank Waste Water Tank Press. Task Loadout - Condensate Heater Emissions DCP Midstream, LP Lucerne Gas Processing Plant Office Heater Unit Rating: 0.1201MM8tu hr Fuel usage : 0.000 MMscf/hr 1.01 MMscf/yr Operating hours: 8760 hours Fuel Heating Value 1040 Biu/sct Criteria Pollutant Emission Calcuatlons Criteria Pollutant Emission Factor Data Source Emissions (TO NOz 100 lb/MMscf AP -42 Section 1.4, Table 1.4-1 (July 1998 revision) 0.051 SO2 0.6 lb/MMscf AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.000 PM 7.6 Ib/MMsci AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.004 CO 84 lb/MMscf AP -42 Section 1.4, Table 1.4-1 (July 1998 revision) 0.042 VOC 5.5 lb/MMscf AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.003 Non -reportable Criteria Pollutant Emission Calculations Hazardous Air Pollutant (HAP) Emission Factor Data Source Emissions (ton/yr) De Minimus• (Ili/YO Benzene 2.1E-03 lb/MMscf AP -42 Section 1.4 1.06E-06 50 Dichlorobenzene 1.2E-03 lb/MMscf AP -42 Section 1.4 6.06E-07 — Formaldehyde 7.5E-02 lb/MMscf AP -42 Section 1.4 3.79E-05 50 Naphthalene 6.1E-04 lb/MMscf AP -42 Section 1.4 3.08E-07 500 n -Hexane 1.8E+00 lb/MMscf AP -42 Section 1.4 0.0 1000 Polycyclic Organic Matter (POM): 2-Methylnaphthalene <2.4E-05 lb/MMscf AP -42 Section 1.4 1.21E-08 — 3-Methylchloranthrene <1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E -f0 — 7,12-Dimethylbenz(a)anthracene < 1.6E-05 Ib/MMscf AP -42 Section 1.4 8.09E-09 — Acenaphthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 — Acenaphthylene <1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 Anthracene < 2.4E-06 lb/MMscf AP -42 Section 1.4 1.21E-09 — Benz(a)anthracene < 1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 — Benzo(a)pNene < 1.2E-06 lb/MMscf AP -42 Section 1.4 6.06E-10 — Benzo(b)fluorenthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 — Benzo(q,h,Qpeylene < 1.2E-06 lb/MMscf AP -42 Section 1.4 606E-10 — Benzo(k)fluoranthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 — CMysene < 1.8E-06 lb/MMscf AP -42 Section 1.4 9.10E-10 — Dibenz(e,h)antMacene < 1.2E-06 lb/MMscf AP -42 Section 1.4 606E-10 Fluoranthene <3.0E-06 lb/MMscf AP -42 Section 1.4 1.52E-09 — Fluorene <2.8E-06 lb/MMscf AP -42 Section 1.4 1.42E-09 Ir,deno(1,2,3-c,d)pyrene <1.8E-06 lb/MMscf AP -42 Section 1.4 910E-10 — Phenanthrene < 1.7E-05 lb/MMscf AP -42 Section 1.4 8.59E-09 Pyrene < 5.0E-06 lb/MMscf AP -42 Section 1.4 2.53E-09 - TOTAL POM 4.46E-08 50 Toluene 3.4E-03 lb/MMscf AP -42 Section 1.4 1.72E-06 1000 TOTAL < 1.88E+00 0.0 — • Colorado Regulation Number a. De Minimie levels for NonCMene Reportable Pollutants DCP Midstream. LP 3/28/2012 Heater Emissions DCP Midstream, LP Lucerne Natural Gas Processing Plant Shop Heater Unit Rating: 0.150IMMBtu/hr Fuel usage : 0.000 MMscf/M 1.26 MMscf/yr Operating hours: 8760 hours Fuel Heating Value 1040 Btu/scf Criteria Pollutant Emission Calcuations Criteria Pollutant Emission Factor Data Source Emissions (tpy) NO, 100 lb/MM9cf AP -42 Section 1.4, Table 1.4-1 (July 1998 revision) 0.063 5O2 0.6 tb/MMscf AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.000 PM 7.6 lb/MMscf AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.005 CO 84 lb/MMscf AP -02 Section 1.4, Table 1.4-1 (July 1998 revision) 0.053 VOC 5.5 lb/MMscf AP -42 Section 1.4, Table 1.4-2 (July 1998 revision) 0.003 Non -reportable Criteria Pollutant Emission Calculations Hazardous Air Pollutant (HAP) Emission Factor Data Source Emissions (ton/yr) De Mlnlmusa (Iblyr) Benzene _ 2,1E-03 lb/MMscf AP -42 Section 1.4 1.33E-06 50 Dichlorobenzene 1.2E-03 Ib/MMscf AP -42 Section 1.4 7.58E-07 — Formaldehyde 7.5E-02 lb/MMscf AP -02 Section 1.4 4.74E-05 50 Naphthalene 6.1E-04 lb/MMscf AP -42 Section 1.4 3.85E-07 500 n -Hexane 1,8E+00 lb/MMscf AP -42 Section 1.4 0.0 1000 Polycyclic Organic Matter (POM): 2-MethOnaphthelene < 2.4E-05 lb/MMscf AP -42 Section 1.4 1.52E-08 — 3-Methylchloranteene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — 7,12-Dimethylbenz(a)enthrecene <1.6E-05 lb/MMscf AP -42 Section 1.4 1.01E-08 — Acenaphthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — Acenaphthylene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — Anthracene < 2.4E-06 lb/MMscf AP -42 Section 1.4 1,52E-09 — Benz(a)antlracene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — Benzo(a)pNene < 1.2E-06 lb/MMscf AP -42 Section 1.4 7.58E-10 — Benzo(b)fluoranthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 Benzo(q,h,)perylene < 1.2E-06 lb/MMscf AP -42 Section 1.4 7.58E-10 — Benzo(k)fluoranthene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 - Cnysene < 1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — D/benz(a,h)anthacene < 1.2E-06 lb/MMscf AP -42 Section 1.4 7.58E-10 — Fluoranthene < 3.0E-06 lb/MMscf AP -42 Section 1.4 1.90E-09 — Morena < 2.8E-06 lb/MMscf AP -42 Section 1.4 1,77E-09 — Indeno(1,2,3-c,d)pyrene <1.8E-06 lb/MMscf AP -42 Section 1.4 1.14E-09 — Phenanthrene < 1.7E-05 lb/MMscf AP -42 Section 1.4 1.07E-08 — Pyrene < 5.0E-06 lb/MMscf AP -02 Section 1.4 3.16E-09 - TOTAL POM 5.57E-08 50 Toluene 3.4E-03 lb/MMscf AP -42 Section 1.4 2.15E-08 1000 TOTAL < 1.88E+00 0.0 — • Colorado Regulation Number 3, De Mi irnis levels for NonCotene Reportable Pollutants DCP Midstream, LP 3/28/2012 Engine Slowdown Emissions Lucerne Natural Gas Processing Plant DCP Midstream, LP Compressors Slowdown Volume mscf Annual Slowdown Volume ` mscf/yr Blowdown Emissions tonlyr C105 Engine Slowdowns 2.5 30.0 0.12 C106 Engine Slowdowns 2.5 30.0 0.12 C10T Engine Slowdowns 2.5 30.0 0.12 C108 Engine Slowdowns 2.5 30.0 0.12 C109 Engine Slowdowns 2.5 30.0 0.12 C110 Engine Slowdowns 2.5 30.0 0.12 C112 Engine Slowdowns 2.5 30.0 0.12 C113 Engine Slowdowns 2.5 30.0 0.12 C115Engine Slowdowns 2.5 30.0 0.12 ' Assume 12 blowdowns per engine per year. Component Helium Carbon Dioxide Nitrogen Methane Ethane Propanis-i. i-Butane:;: n -Butane i-Pentane. n-Pentllrte Hexane MW 4.00 44.01 28.01 16.04 30.07 Dry volimol%. 0.0060% 2.3140% 0.3220°'. 72.1810% 14.2060% 6.7610%% >. 0.881034' 2.0840% 0.4450%. ,',... 0.4730% .: 0.3270% MW•dry vol %. Wt% 0.00 1.02 0.09 11.58 4.27 2.98 0.01:.:::• 0.001202 5.095 0.451 57.935 21.372 .14.916 0.034 0.177 0.009 0.005 0.006 Total 100.0% VOC Wt% Gas MW 19.99 100.00 15.147 % 19.99 Ib/Ibmol Page 1 of 2 Calculation of VOC Emissions from Truck Loading Hoses Assumptions: There are two hoses connected to each truck during loadout. Liquid Hose Diameter = Vapor Hose Diameter Liquid Hose Length Vapor Hose Length 2 inches (average) 2 inches (worst case) 1.5 feet (average) 1.5 feet (worst case) Liquid Hose Volume 0.0327 cubic feet Vapor Hose Volume 0.0327 cubic feet Each truck is pressurized to storage tank pressure as listed below. Y -Grade Tank Pressure= 62.0 psia (NMNE VOC partial pressure) Condensate 22 psia Each tank truck has a capacity of 11,000 gallons. Assume 10,000 gallons/load. Tot. volume of products loaded/year and tot. loadout events/year as listed below. Product Gallon/yr Loads/vr Y -Grade Out 935,788 94 Condensate Out 1,516,704 152 All liquid lines contain liquid products at individual specific gravity. All vapor return lines contain products that behave as Ideal Gases at 60 deg. F and storage tank press. P*V=n*R*T Where : Y -Grade: Condensate P = pressure in hose at time of disconnect = storage tank pressure (prig) V = volume of hoses (cubic feet) n = number of lbmoles of product in hoses R = Universal Gas Constant =10.73 cubic feet *psi / Ibmole*deg R T = ave. loadout temp. = 60 deg F = n= n 0.0111 Ibmole/ft3 * 12.11b/Ibmol= 0.0039 Ibmole/ft3 * 32.4 Ib/Ibmol= 519.67 deg R 0.1345 lb/R3 0.1278 lb/R3 Page 2 of 2 VOC Emissions from Liquid Hoses Loaded Liq. Density Hose Vol. Loads Per Emission Emission Product flb/ft3i Yr Ib( /vr1 ton/ r Y -Grade 40.50 0.0327 93.5788 123.97 0.06 Condensate 43.62 0.0327 151.6704 216.39 0.11 VOC Emissions from Vapor Return Hoses Loaded Vap. Density Hose Vol. Loads Per Emission Emission Product Ib( /ft3) f�t3] Yr Ib( /vrl tton/ni Y -Grade 0.1345 0.0327 93.5788 0.41 0.00 Condensate 0.1278 0.0327 152 0.63 0.00 — — — 1.05 0.00 Y -Grade Total Loading Emissions Condensate Total Loading Emissions 0.06 tpy 0.11 tpy PW Calculations Working and Breathing Losses Flash from HYSYS 626.31 lb/yr VOC Emissions x 1 ton/2000 lb 0.31 tpy 0.010 tpy 0.01 tpy Total Emissions Working/Breathing and Flash 0.32 tpy tro f / §0 03 CD co 01 CD CD CO CO CD 03 03 n #k 27 O O to co 2 o To ro II o r LTD O Lll NOx/CO Emissions (tpy) NOxICO Emission Factors from AP -42, Table 13.5-1 /�\ O §\ 8 § O Lucerne Gas Processing Plant - Permit Application CO Summary of GHG Emissions Lucerne Natural Gas Processing Plant DCP Midstream, LP Controlled CO2e Amine Unit/RTO Combustion Sources Slowdowns compressors Combustor Tanks Loadout Total CO2e PTE 83,047 26344 56218 87 84 314 Neg Neg DCP Midstream, LP 3/28/2012 Amine and RTO GHG Emissions Lucerne Natural Gas Processing Plant DCP Midstream, LP CO2 5739.3 lb/hr 25138.134 ton/yr From PROMAX Methane 34.02 lb/hr 149.0076 ton/yr 1.490076 Methane post combustion 31.291596 Methane CO2e post combustion CO2 from combustion lb/hr ton/yr Component j lb/hr uncombusted lb/hr to combust MW #of carbon CO2 CO2 N2 0.100 -- Carbon Dioxide 5739.300 -- Methane 34.020 33.6798 16 1 92,6 405.6732 Ethane 21.420 21.2058 30 2 62.2 272.4521 Propane 13.130 12.9987 44 3 39.0 170.8029 n -Butane 6.760 6.6924 58 4 20.3 88.94892 Pentane 2.370 2.3463 72 5 7.2 31.40132 Hexane 2.760 2.7324 86 6 8.4 36.73871 Heptane 0.190 0.1881 100 7 0.6 2.537544 Octane 0.110 0.1089 114 ' 8 0.3 1.472787 Benzene 5.060 5.0094 78 6 17.0 74.26243 Toluene 3.990 3.9501 92 7 13.2 57.92221 Benzene, Ethyl- 0.260 0.2574 106.2 8 0.9 3.736808 m-Xylene 2.020 1.9998 106.2 8 6.6 29.03212 p-Xylene 0.000 0 106.2 8 0.0 0 o-Xylene 0.000 0 106.2 8 0.0 0 Hydrogen Sulfide 0.590 - Water 245.200 -- MDEA 0.000 - Piperazine 0.000 -- CO2 (total) Methane (total) CO2 from combustion Total CO2e 26344.41 CO2 e Totals 25138.134 31.291596 1174.981066 Total CO2 from Combustion 1174.98 tpy DCP Midstream, LP 3/28/2012 w c a rn c d O 0. Hi c N O Z W 0 33 . .2 da O 3 U U J o m a) x T.) LL C O Co a) 0. 0 Co c d O a CO 2 2 0 m 2 2 O m L 7 CO 2 2 O ai a m 2 2 O C of L a m 2 2 O V L 7 m 2 2 O of L 7 m 2 2 O of L 7 m 2 2 O of .C L L L L J 7 7 7 7 7 t m m m m m n 2222 2 2 2 2 22 2 w 2 COO O O On W O O CO CA tit N O U 4) a U K j y R 0 r Oas i U U N- co LL LL a i U Tv; To Ta U CO O CO r Nr N CCC O O O .- r C C C v 0 0 O O O 0 0 0 U U U U 0 U x x Cn C O N CA W C O N .0 E O U Emission Factor Source a O t co a n 7 CO a O t co a n J CO p O t m a n 7 CO •-- d T O 2r CO CO 01 CO Lo M 22.24 Global Warming PotentialM r O M r N T C 0 CO CO nj CO CO N r •; CI CO O r T .0 112,325,254.50 211.85 V' N Cp .C ir CO n N N CO N v O O 0.242 Emission Factor (kg/MMBtu) 53.02 O O O O O O c a) n 0 a n o 0 Z a U N a U U R CD m a a a (5 U co co co a a a OOco i 0) 00) aCO CO a a CZ CC Cr 0 U 0 7 7 Q CU a N O CO CO mm DCP Midstream, LP Compressor Blowdown Emissions Lucerne Natural Gas Processing Plant DCP Midstream, LP �Y a-��''ti�•, ..-� a. p4.� 4 f... �5 t��tm�i�3...wi44v f 9t !0 t,�.ryry�%P-[2�` �Le .... . }W Carbon Dioxide Helium 4.0 0.006 0.00 Oxygen 32.0 0.000 0.00 00 Nitrogen 28.0 I 0.09 0.40 Methane 16.0 72.181 11.55 51.20 Ethane 30.0 14.206 4.26 18.89 Propane 44.0 6.761 2.97 13.19 i-Butane n -Butane 58.0 2.084 i-Pentane n -Pentane Other Hexanes+ 86.0 r' 0.28 1.25 n -Hexane 86.0 0.000 0.00 0.00 Benzene 78.1 0.000 0.00 0.00 Toluene 92.1 0.000 0.00 0.00 Ethylbenzene 106.2 0.000 0.00 0.00 Xylenes 106.2 0.000 0.00 0.00 Volume @ 60 psi VOC wt% Methane Wt% CO2 Wt% 2500.0 cubic feet/event 24.99 % 51.20 % 4.51 % Vent ton/blowdown # /yr TPY VOC TPY Methane TPY CO2 TPY CO2e C-105 0.074 12 0.22 0.46 0.04 9.6 C-106 0.074 12 0.22 0.46 0.04 9.6 C-107 0.074 12 0.22 0.46 0.04 9.6 C-108 0.074 12 0.22 0.46 0.04 9.6 C-109 0.074 12 0.22 0.46 0.04 9.6 C-110 0.074 12 0.22 0.46 0.04 9.6 C-112 0.074 12 0.22 0.46 0.04 9.6 C-113 0.074 12 0.22 0.46 0.04 9.6 C-115 0.074 12 0.22 0.46 0.04 9.6 Total CO2e ' 86.6 Reciprocating Compressor Venting Lucerne Natural Gas Processing Plant DCP Midstream, LP Emission Calculation Compressor CH4 Emissions (scf)lal CH4 Emissions (MT CO2e)l°I CO2 Emissions (scf)lal CO2 Emissions (MT CO2e)I°I Total Emissions (MT CO2e) Total Emissions (TPY CO2e) C-105 9,480.0 8.4 527.0 0.03 8.4 9.3 C-106 9,480.0 8.4 527.0 0.03 8.4 9.3 C-107 9,480.0 8.4 527.0 0.03 8.4 9.3 C-108 9,480.0 8.4 527.0 0.03 8.4 9.3 C-109 9,480.0 8.4 527.0 0.03 8.4 9.3 C-110 9,480.0 8.4 527.0 0.03 8.4 9.3 C-112 9,480.0 8.4 527.0 0.03 8.4 9.3 C-113 9,480.0 8.4 527.0 0.03 8.4 9.3 C-115 9,480.0 8.4 527.0 0.03 8.4 9.3 Total 75.6 0.25 75.9 83.6 (a) 40 CFR Part 98 Subpart W, Equation W-29 (b) 40 CFR Part 98 Subpart W, Equation W-36 Standard T (°F) 60 Standard P (psia) 14.7 GHG Mole Fraction CH4(b) 0.95 GHG Mole Fraction O02(b) 0.01 Density CH4 (kg/cf) 0.0422 Density CO2 (kg/cf) 0.0526 Density N2O (kg/cf) 0.0526 GWP CH4 21 GWP CO2 1 GWP NO2 N 0 O N co N en A a O) C N N 8 O a` RI tn (9 CO A o d 0 .inc` w z ; E c V •'$a =O Pilot Emissions U m CO O O L O co O L co O L N O N N co co fM U 0 ti 32 U co y D a co (p d U U T) .as (T5 IL IL O W eC a) @ 0 @ 1 L TD 0 0 0 „0 Q O O O O LL a a d o.a N C O y E w C 0 in a O U Emission Factor Source Subpart Ccai Subpart C`°' I Subpart C`I' l) T O C U o O M N Co o O 0 Global Warming Potential(`) 0 M r N >. C O .—• Co (0 C7 N N O O O O co cei> N N. v CO O 7 W C- L C CO LO C. O O 0 O 0 Emission Factor (kg/MMBtu) 53.02 O O O oO O O Pollutant 0 O Z CH4 03 CD N N 0 O F- N U U ct d m 0 co co 0 U U 0 a n FR Part 98 S V OV p Combustor Emissions CO (0 CO o) CD Em LL U g 2 y 0 0N a h C C) 0 d i Co (0 m 3 v Co co c M O 0 N E N 00) 2 E 2 E w w mw `m N Q 0 2 T T 0 LL LL 22CO 2 N Co O O O 0) y C C m CO H J 0 0) N co O O0 L LLCO 0 o co C U' 0 > > > T N C O1 O) E 8 0 T 00 0 0.. CO CO h 0) LO co U) C m 0 i E 0 N N N 00 Total CO2e DCP Midstream, LP Appendix C Plot Plan I r ERN: fi N: NM" I�EIIII� 0 II 11 e It 11 I i ri,r! ICIPP qron pOW�Ni��i SPCC PLOT PLAN g1e ai 3 a tl I P. t 8 4 Appendix D AOS Table Engine Replacement Field Log Title V Operating Permit No. 95OPWE100 DCP Midstream, LP — Lucerne Gas Processing Plant CDPHE Plant ID No. 1230107 y d W JD 0Tx O Q y P. d eh" Q 0\ co h — 0 7 7/21/00 N 0 0 N en 0 o M m cO ‘O cc�o '.D cc�o 10 o O 1O vi V o 1/40 w '0 m, m W V] Q o0 O\ v 0 O en 0 O o C N 2/14/02 en 0 h en b 0 v D b 0 o '.D b 0 v 10 0 0 VD r>, Cr �n iD Replacement Engine Description Previous Location F 0 N F Louisiana Oklahoma Serial No. ii In CA 0 N L0 000 CA en N 1 N 252850 00 0 en 266454 0 00 en kin ',I - en d• 327597 176330 380839 py O , 450 00 , 00 , 00 , 1232 N .-i 1232 1232 1232 1232 o NN 0 3521 GU L7042GSI - ON 0 ON 0 L7042GSI C.7N 0 O 0 o N 0 O N 0 O N 0 o as X Waukesha L lo 3 Waukesha Waukesha Waukesha Waukesha Waukesha Waukesha z 1 3 Waukesha Waukesha Original Engine Description IS d • p co z H 7 et N 362302 N 00 0 N - N vi v1 iD en co v) Q\ 0 N 216421 252850 0 In en N 0 00 00 en 362517 QI 00 450 00 0 O 1232 N fel N 1232 1232 1232 Model N a 3521 GU G7- O , N a 00 O a CO O a M O a CO N a CO N a Cl) N a L7042GSI 0 Waukesha N Waukesha Waukesha Waukesha Waukesha Waukesha Waukesha Waukesha Waukesha 2 p x 3 Like -Kind Engine Replacement 0 z Yes X X X X X X X X X X k Source ID ^oj 0 0 a N 0 a en 0 a 0 0 a 0 0 a O 0 a en 0 P kn 0 0 a co 0 a in 0 a N 0 a 'p d 0 6 0 6 0 6 0 6 0 6 0 6 O — 6 0 6 N 0 - 6 6 N Appendix E Back-up Information • Email list of required documents • Copy of May 2011 Self Certification From: Smith, Bailey jmailto:Bailey.SmithCa�dohe.state.co.usl Sent: Wednesday, March 21, 2012 3:44 PM To: Tony Barlage Cc: Peter Knell Subject: RE: Question re: Title V renewal application The list provided is all I need to deem your application complete. Copies of APENs are not necessary. If you could include a column on the AOS execution spreadsheet that lists previous location of the replacement engine that would be more helpful than including copies of AOS submissions. We should theoretically already have copies of all applications, permits, APENS, AOS submissions, etc — but the AOS executions have a tendency to be difficult to track down. If, during the review and draft process, I find I need more information I will contact the permit contact listed. But provided the info you listed is submitted by the due date, the application will be deemed complete and the source will be granted an application shield. Hope this helps. Let me know if you have any other questions. Thanks, Bailey Kai Smith Permit Engineer Operating Permit Unit Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-691-49611 bailey.smith@state.co.us Glx;+oun., ra, From: Tony Barlage jmailto:tbarlacieCaoaconsultino.coml Sent: Wednesday, March 21, 2012 3:21 PM To: Smith, Bailey Cc: Peter Knell Subject: RE: Question re: Title V renewal application Importance: High Bailey, Happy Wednesday © Would you please tell me exactly what else we need to submit for the Lucerne TV renewal application, other than the list which you previously provided below? FYI, we will be including GHG emission calcs. Do we need to include copies of the existing APENS, AOS's, etc? Is there anything else that you will be looking for? Thanks! List you provided previously: • A cover letter explaining all requested changes (monitoring requirements, emissions or throughput limit increases, typos, etc.) and the additional equipment that was not included on the last operating permit. • A spreadsheet or list of the current engines (and serial numbers) if there have been any AOS executions since the last issuance. • Form 2000 - 100 • Facility plot plan • Emissions calculations for each piece of equipment, GLYCaIc and Tanks runs, etc. • Form 2000-602 and 603 or a Facility Wide Emissions Inventory Form • Form 2000- 605 if you want to add any new non -applicable requirements to the permit shield — include justification. • An updated list of insignificant activities • Form 2000- 800 with responsible official signature (in 2 places) Please reply all/cc Peter Knell on your reply, as I will be out of the office for the next two days. Thanks and take care, T From: Smith, Bailey [mailto:Bailev.Smith@dohe.state.co.usl Sent: Wednesday, March 14, 2012 8:23 AM To: Tony Barlage Subject: RE: Question re: Title V renewal application We don't need GHGs listed on any of our application forms with the criteria pollutants. For now, we just need to know whether emissions are above or below the 100,000 tpy CO2e threshold. We should add a check box, but we haven't updated the T5 forms since 2002. Accompanying calculations are helpful, but not necessary. From: Tony Barlage fmailto:tbarlage@oaconsulting.coml Sent: Wednesday, March 14, 2012 8:15 AM To: Smith, Bailey Subject: RE: Question re: Title V renewal application Good morning Bailey, I am assuming I need to include GHG emissions with this renewal application as well, yes? Thanks! T From: Smith, Bailey f mailto:Bailey.Smith@dohe.state.co.usl Sent: Friday, February 10, 2012 11:16 AM To: Tony Barlage Subject: RE: Question re: Title V renewal application Hi Tony, I would submit the following: • A cover letter explaining all requested changes (monitoring requirements, emissions or throughput limit increases, typos, etc.) and the additional equipment that was not included on the last operating permit. • A spreadsheet or list of the current engines (and serial numbers) if there have been any AOS executions since the last issuance. • Form 2000 -100 • Facility plot plan • Emissions calculations for each piece of equipment, GLYCaIc and Tanks runs, etc. • Form 2000- 602 and 603 or a Facility Wide Emissions Inventory Form • Form 2000- 605 if you want to add any new non -applicable requirements to the permit shield — include justification. • An updated list of insignificant activities • Form 2000 - 800 with responsible official signature (in 2 places) We need an original plus 3 copies. You also get bonus points for printing double sided. Hope this helps. Let me know if you have any questions. Bailey From: Tony Barlage jmailto:tbarlage@oaconsulting.com] Sent: Friday, February 10, 2012 10:49 AM To: Smith, Bailey Subject: Question re: Title V renewal application Bailey, Hello, I am beginning to work on a Title V renewal application for the DCP Lucerne Gas Processing Plant (Permit # 95OPWE100). Adam Berig suggested contacting you regarding which forms I will need to include in the application. Apparently you worked with him on previous DCP Title V renewals, and the first one we submitted was a bit overboard and included much more information/many more forms than were necessary. As of right now, it looks like a revised permit was issued on April 1, 2010, addressing changes regarding the responsible official, engine AOS's, and opacity requirements. Also, a construction permit for a DGA natural gas sweetening system (Permit #08WE0920) was issued August 30, 2011. I appears other construction permit applications were submitted since the permit was issued in 2008, but they were later cancelled. Some additional minor changes at the facility have occurred as well. If you would please assist me by helping me determine what all I will need to include in this application, I would greatly appreciate it. Thanks and take care, -T dcp Midstream. May 11, 2011 Hand Delivered Mr. Doug Ryder Colorado Department of Public Health and Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 DCP Midstream 370 17th Street, Suite 2500 Denver, CO 80202 303-595-3331 Lucerne Natural Gas Processing Plant Self -Certification for Construction Permits 96WE905, 08WE092, & 08WE0921 Request to Roil 96WE905, 08WE092, & 08WE0921 into Title V Operating Permit 95OPWE100 Dear Mr. Ryder: Please find the attached self -certification form for Construction Permits 96WE905, 08WE0920, & 08WE0921. This submittal is to certify that the equipment is meeting all requirements of the new construction permits. Permit 96WE905 includes four 1,232 hp Waukesha 7042 GSI engines (C-106, C-107, C-109, and C-110) along with plant fugitive emissions. Permit 08WE0920 includes a 40 MMSCFD amine gas sweetening unit (AU01) with the acid gas emissions being controlled by a regenerative thermal oxidizer (RTO). The flash gas is being recycled back to the inlet with a VRU. An updated APEN was submitted for the amine unit noting the addition of the VRU control for the flash gas on November 30, 2010. Permit 08WE0920 includes a 16 MMBtu/hr natural gas -fired amine regen heater (HT01). Permit 96WE905: Page 3, Condition 6, Annual Limits incorrectly lists C-105 with AIRS Point 015. This should be listed as C-106 associated with AIRS Point 015. The emission limits for this engine need to be corrected as follows: 23.79 TPY NOx, 11.90 TPY VOC, and 23.79 TPY CO. Also, the fuel use limit on Page 4, Condition 9, engine C-105 should be listed as C-106 with a fuel use limit of 79.18 MMSCF/yr. These four engines are in compliance with all conditions of the permit except for those referencing the major source provisions of NESHAP Subpart ZZZZ. Conditions 4, 13, 15, and 16 are not applicable as DCP contends that the Lucerne Natural Gas Processing Plant is an area source of HAP emissions. Although there are not specific permit limitations on any HAP emissions including formaldehyde, all engines at the facility are controlled with catalysts to meet federally enforceable VOC limits. Formaldehyde is a VOC. Since formaldehyde comprises a fraction of the total amount VOC emitted from each controlled engine, the formaldehyde fraction of the VOC emissions stream is controlled and the level of control is federally enforceable. Spindle is therefore , a synthetic minor source of HAP emissions. Thus, this facility is an area source of HAP emissions and not subject to the major source provisions of NESHAP Subpart ZZZZ. These engines are existing engines and are not subject to the control or testing requirements of NESHAP ZZZZ. Permit 08WE0920: To remedy a potential safety issue with the amine unit, the amine flash gas stream was re-routed to a VRU which recycles the vapors back to the plant inlet. A revised APEN was submitted on November 30, 2010, to reflect the changes to the flash gas stream (attached). Also, the permit notes that the unit is a DGA unit. DCP www.dopmidstrcam.com May 11, 2011 Page 2 of 2 requests that DGA be replaced with amine, as the solution that is used is a proprietary solution that DCP purchases from the amine vendor. Operating Permit 95OPWEI00 (April 1, 2010): The 220 hp G-3306TA Caterpillar engine (Point 031) listed as C-244 in the TV permit was never installed and the permit application was cancelled on April 16, 2009 (see attached). Please remove references to C-244 from Section 1.1 (pg. 1), Table 1 (pg. 10), Condition 5 (pgs. 31-33) and Section II, Condition 5.0. Condition 1.2.3 of the 4/1/10 revised TV permit was carried over from the previous TV permit. Condition 1.2.3 states "The source shall submit a report detailing the specific applicable and nonapplicable sections of NSPS KICK to the Division within six (6) months of the permit issue date following the format in Appendix H of this Operating Permit." Since nothing has changed since the 2008 TV permit and we are continuing to conduct KKK compliance monitoring, we will continue to submit our semi-annual NSPS KKK reports. Section II, Condition 1.1 of the 4/1/10 revised TV permit was also carried over from the previous TV permit. The condition states that an actual physical count of the components shall be completed within 90 days of issuance of the permit. The facility maintains a list of current components. Per Condition 18 of Permit 96WE905, Condition 24 of Permit 08WE0920, and Condition 15 of Permit 08WE092, DCP would also like to formally request that Construction Permits 96WE905, 08WE092, & 08WE0921 be rolled into Operating Permit 95OPWE100 when the renewal is issued. Attached are Title V forms 302, 604, and 800 as well as a copy of Construction Permits 96WE905, 08WE092, 08WE0921 and the most recent APENs. Should you have any questions regarding this submittal or if any additional information is needed, please contact me at 303-605-2009 or srondak@dcomidstream.com. Sincerely, DCP Midstream, LP Stephen Ondak Environmental Manager - North CC: Mr. Matt Burgett — CDPHE-APCD Operating Permit Unit Supervisor Wesley Hill — DCP Midstream, LP Senior Environmental Specialist Self Certification Forms Colorado Department of Public Health and Environment Air Pollution Control Division STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Whine, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.state.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 AIR POLLUTION CONTROL DIVISION CONSTRUCTION PERMIT FINAL APPROVAL SELF -CERTIFICATION FORM SOURCE NAME: [Insert Company Name] Colorado Department of Public Health and Environment FACILITY IDENTIFICATION NUMBER: [Insert AIRS number] _12 3 / 01 O -. /0143 (The AIRS number is found in the lower left corner of the permit) PERMIT NUMBER: [Insert Construction Permit Number] O8U)F092./ All information related to the Final Approval certification of the above referenced Initial Approval construction permit must be certified by a responsible official as defined on the attached page. This certification means that each condition of the Initial Approval permit has been reviewed and that the source is in compliance with all conditions of the permit. A Final Approval permit will be issued only if all permit conditions are being met. The attached memo provides guidance on what steps must be taken to certify compliance with various types of permit conditions. This signed certification document must be packaged with the documents being submitted for the request for Final Approval of this permit. A separate Certification along with the associated documentation is required for each individual Initial Approval permit. This includes "dash numbered " permits (e.g. 96LA199-2). I have reviewed the above paragraph, the attached document entitled "Guidance for Self -Certification", terms and conditions of the initial approval permit referenced above, and the information being submitted for final approval of this permit in its entirety. Based on information and belief formed after reasonable inquiry, I certify that the source is in full compliance with each permit and condition of this initial approval 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 § 1S-1-501(6), C.R.S., makes any false material statement, representation, or certification in this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7122.1, C.R.S. 34 ktf QAdc� c V-•-•"544_142_4a4ea4J M4.,a9�- . 1V00,41 Printed or Typed Name Tf41e 10 K:WORMS'TPA forms: SELFCERT.DOc Revised I/06 Colorado Department of Public Health and Environment Air Pollution Control Division STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of Ito people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 Located in Glendale, Colorado http://www.cdphe.slate.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Alit POLLUTION CONTROL DIVISION CONSTRUCTION PERMIT FINAL APPROVAL SELF -CERTIFICATION FORM SOURCE NAME: [Insert Company Name] Colorado Department of Public Health and Environment FACILITY IDENTIFICATION NUMBER: [Insert AIRS number] / 23/0 16 �- (The AIRS number is found in the lower left corner of the permit) PERMIT NUMBER; [Insert Construction Permit Number] 96 f r )E ql n S All information related to the Final Approval certification of the above referenced Initial Approval construction permit must be certified by a responsible official as defined on the attached page. This certification means that each condition of the Initial Approval permit has been reviewed and that the source is in compliance with all conditions of the permit. A Final Approval permit will be issued only if all permit conditions are being met. The attached memo provides guidance on what steps must be taken to certify compliance with various types of permit conditions. This signed certification document must be packaged with the documents being submitted for the request for Final Approval of this permit. A separate Certification along with the associated documentation is required for each individual Initial Approval permit. This includes "dash numbered " permits (e.g. 96LA199-2). I have reviewed the above paragraph, the attached document entitled "Guidance for Self -Certification", terms and conditions of the Initial approval permit referenced above, and the information being submitted for final approval of this permit in its entirety. Based on information and belief formed after reasonable inquiry, I certify that the source is in full compliance with each permit and condition of this initial approval 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 certification in this application is guilty of a. misdemeanor and may be punished in accordance with the provisions of § 25-7122.1, C.R.S. _540 pLen Ondo. aniticon mA4c I da.•S1 Titled:' A Printed or Typed Name /het1O, -1-OI/ Signature Date Signed K:IFORMS\FA forms: SEIFCERT.DOC 10 Revised 1106 Signature Colorado Department of Public Health and Environment Air Pollution Control Division STATE OF COLORADO John W. Hickenlooper, Governor Christopher E. Urbina, MD, MPH Executive Director and Chief Medical Officer Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Or. S. Denver, Colorado 80246-1530 Phone (303) 692.2000 Located in Glendale, Colorado http://www.cdp he.state.co.us Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230.6928 (303) 692-3090 AIR POLLUTION CONTROL DIVISION CONSTRUCTION PERMIT FINAL APPROVAL SELF -CERTIFICATION FORM SOURCE NAME: [Insert Company Name] Colorado Department of Public Health and Environment FACILITY IDENTIFICATION NUMBER: [Insert AIRS number] 12.37O1 t7 V 042, (The AIRS number is found in the lower left corner of the permit) PERMIT NUMBER: [Insert Construction Permit Number] All information related to the Final Approval certification of the above referenced Initial Approval construction permit must be certified by a responsible official as defined on the attached page. This certification means that each condition of the Initial Approval permit has been reviewed and that the source is in compliance with all conditions of the permit. A Final Approval permit will be issued only if all permit conditions are being met. The attached memo provides guidance on what steps must be taken to certify compliance with various types of permit conditions. This signed certification document must be packaged with the documents being submitted for the request for Final Approval of this permit. A separate Certification along with the associated documentation is required for each individual Initial Approval permit. This includes "dash numbered " permits (e.g. 96LA 199-2). I have reviewed the above paragraph, the attached document entitled "Guidance for Self -Certification", terms and conditions of the initial approval permit referenced above, and the information being submitted for final approval of this permit in its entirety. Based on Information and belief formed after reasonable inquiry, I certify that the source is in full compliance with each permit and condition of this initial approval 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 arty false material statement, representation, or certification 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. Sephan 04 die Y,Wr.J4MP14a! A/i knaq e�^ - ALA!!!! Printed or Typed Name v Title Date Signed 16:WFORMSFA tones: SELFCER'I'.DOC 10 Revised l/06 Title V Forms Operating Permit Application - BOILER OR FURNACE OPERATION Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE FORM 2000-300 09-94 I. Facility name: Lucerne Gas Plant 2. Facility identification code: CO 123/0107 3. Stack identification code: HT01 4. Unit code: P-043 (AIRS ID) 5. Unit description: Amine Regenerator Heater 6. Seasonal Fuel Usage(%) Dec -Feb: 25% Mar -May: 25% Jun -Aug: 25% Sep -Nov: 25% 7. Normal Operation Hours/Day: 24 Days/Week: 7 of Unit Hours/Year: 8760 8. Space Heat(%) 9. Indicate the boiler/furnace control technology status. X Uncontrolled Controlled lithe boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-404 2000.405 10. Furnace type: Natural Gas Fired 2000-403 2000-406 2000-407 11. Max continuous rating(minBTU/hr): 16.0 2. Manufacturer: Sigma Thermal 13. Model & Serial #: 09055-01 14. Date first placed in service: 11/23/2010 Date of last modification: 15. Fuels and firing conditions: Primary fuel Backup fuel Al Backup fuel f#2 Fuel name Natural Gas Higher heating value (with units) 1040 BTU/SCF Maximum sulfur content (Wt %) n/a Maximum ash content (Wt.%) n/a lr c�e4S Comb))usttop�trrtiR °�e9 l4 c}lorp ) yj l 0 „fi ? 5 j D b l �.SS.�.�r • tL, L . .1.., ,„—,000.0;.i' ,?', X33 ifs / fl .(' T^_' 'w,4 .f`l. A.l.. ^''F4�.iwtd h £1.,. `i tf. ta)°141w.'� '' ti i �0 ~ „ ..2Nlfr.�n Y, 1 ,eiR4wi.. ... iY::i�� { *9 it "y � =n T�lt,a '"i.•.t. ,' a Al• Tu. 9 1uA � j"�„u�S��r.T`t�c To'''a tx,a a: ��:,'a!F�MR �Jl' 4, i ry�1. :n ;✓J1I J"S(i •i. Moisture content Skis., 9 } iS �f 1 »Y ' L ( 9� \ / � ,�ftt:Ay'`y: , tt$ 11 '�7 �.;:t.aM:4a9....i-K it a'-. .. ;ki i s`r_ .• ,`�i ..t 2 ! P Y?aril,; a•. t f V." W s +. 7. } r ...'1.•-• %A .... s''`a VF -. + i OT rf i +FG K � { i {.fi 5 '� 1 ) ‘''S:•:',��KA,N �r. ji `u �� k ,., ! lN. I xL ? i,r'ia l f'hd % �. .f +.ik' 'i Y d , ,(��y J' f K H��ry �fR Maximum hourly fuel usage (units/hr.) 15384.6 SCF/hr i Ac₹ual annual fuel L. ,, a for>l ::,rs ^,a�4:: ;, t r y 4,.. ***** For this emissions unit, identify the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. ***** Please complete the Au Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. **** * 1 Opirating Permit Application Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06.95 1. Facility name: Lucerne Natural Gas Processing Plant 2. Facility identification code: CO I23/0107 3. Stack identification code: AU01 4. Process (Unit) code: P-042 (AIRS ID) 5. Unit description: 6. Indicate the control technology status. I Uncontrolled X Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 X 2000-401 2000-402 2000-404 2000-405 2000-406 2000-403 2000-407 Actual annual process rates for.l9; 8. Date first placed in service: 11/23/2010 Date of last modification: 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/yr. I 10. Describe this process (please attach aflow diaeram of the process). Acid gas removal using Amine (DGA). Attached? CI 11, List the types and amounts of raw materials used in this process: Material Storage/material handling process Aetualusag . , ,ilmtt • . ' • Maximum usage Units Natural Gas Process Rate DGA Recirculation Rate , nt,,,.,,.: ,, x,,. , 175 gal /min . Clean-up solvents ' + , (A, a. ,seina ; K • Other (specify) ist tare types an a amounts of finished products: Material Storage/material handling process gtualttgLZlt}afis`•3. i "� ��' ' " ivei ° , plrgdt ed r� Maximum Units amount produced },,..4fs j.lq Vi tt .V. „"'l5a""t Z"; , x•rocess rues usage: Type of fuel Maximum heat input to P process million BTU/hr, i'' ``Ac 1 ii .� : x t = . le •ti,ySA$ t .! >at, �.,�J.,, i r' z t,c�s?y L1a ttS :_' Maximum usage Units • 14. b Descrie any fugrttve emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: ***** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. 2 Operating Permit Application Operating Permit Application Colorado Departtnent orPublic Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE CONTROL EQUIPMENT - MISCELLANEOUS FORM 2000-400 Rev 06-95 1. Facility name: Lucerne Natural Gas Processing Plant 2. Facility identification code: CO 123/0107 3. Stack identification code: AU01 4. Unit identification code: P-042 (AIRS ID) 5. Control device code: AUOI C 6. Manufacturer and model number: Regenerative Thermal Oxidizer, Custom Unit/ VRU 7. Date placed in service: 11/23/2010 Date of last modification: 8. Describe the device being used. Regenerative (hernial oxidizer used to control the acid gas stream. Vapor recovery Unit used to control the flash gas stream. 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. i.t Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. VOC Pollutant (acid Gas) Inlet pollutant . concentration :' Emission capture ;, efficiency (%); Outlet pollutant concentration Control Efficiency (%) 99% RTO ;gr/acf ppmv gr/acf ppmv VOC (Flash Gas) _`�� car' nsi��'��r �7rsx � . ,r :. 99 % VRU h F . ` ;¢;� $t t At>. sit 7`: \ is ..::..;s? a e •RJfi § F's `tip a?t, �..r NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 3 Operating Permit Application Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE MISCELLANEOUS PROCESSES FORM 2000-306 Rev 06-95 1. Facility name: Lucerne Natural Gas Processing Plant 2. Facility identification code: CO 123/0107 3. Stack identification code: P007 (FUG) 4. Process (Unit) code: P-014 (AIRS ID) 5. Unit description: 6. Indicate the control technology status. X Uncontrolled Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 7. Actual annual process rates :for 19 8. Date first placed in service: Date of last modification: 11/23/2010 wl new equip 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/yr. I 10. Describe this process (please attach a Ilcnv diagram of the process). VOC emissions from fugitive equipment leaks Attached? ' I I. List the types and amounts of raw materials used in this process: Material Storage/material handling process opal usage;:::. nits:, Maximum usage Units See component counts and Calculations from application iri' i<S' Clean-up solvents Other (specify) 12. List the types and amounts of finished products: Material Storage/material handling process Ataual grluountt' ' y Unt)S' Maximum Units ,;.f' 3 radaced-t �� ,• t ; �'� A,..,, ,._ys,,..�, amount produced ::> • .t v.= fib'' .V . r'i( 1. „, b ,if _ y , : , ,y a 3. r 13. Process fuel usage: Type of fuel Maximum heat input to process million BTU/hr. ' AGtual usage Uniti �� t.f,.,� x . s, ., . � � � � ` ` •f Maximum usage Units SS 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc,: *'*** For this emissions unit, identify the method(s) of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 and its attachment(s) to this form. 4 Operating Permit Application Colorado Department of Public Health and Environment Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Lucerne Natural Gas Processing Plant 2. Facility identification code: CO 123/0107 3. Stack identification code: P007,HT01, AU01 4. Unit identification code: 014,042, 043 5. Pollutant 6. Colorado Air Quality Regulations or Construction Permit Number 7. State Only 8. Limitation 9. Compliance Status IN OUT 96WE905 X 08WE0921 X 08WE0920 X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an existing permit such as material usage, hours of operation, etc.) State Only Compliance Status IN OUT APPLICABLE REQUIREMENTS AND STATUS OF EMISSION UNIT FORM 2000.604 Rev 06-95 **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 5 Operating Permit Application 2000-800 Colorado Department of Health Air Pollution Control Division Facility Name: Lucerne Natural Gas Processing Plant L ADMINISTRATION TABULATION OF PERMIT APPLICATION FORMS Facility Identification Code: CO 123/0107 FORM 09-94 This application contains the following forms: Form 2000-100, Facility Identification Form 2000-101. Facility Plot Plan Forms 2000-102, -102A, and -102D, Source and Site Descriptions II. EMISSIONS SOURCE DESCRIPTION Total Number of This Form This application contains the following forms (one Fonn for each facility boiler, printing Form 2000-200, Slack identification X Fonn 2000-300, Boiler or Furnace Operation 1 Form 2000-301, Storage Tanks Form 2000-302. Internal Combustion Engine Form 2000-303, Incineration FOnn 2000-304. Printing Operations Form 2000.305, Painting and Coating Operations X Form 2000-306, Miscellaneous Processes 2 Form 2000-307, Glycol Dehydration Unit III. AIR POLLUTION CONTROL SYSTEM Total Number of This Fonn This application contains the following forms: X Form 2000-400, Miscellaneous 1 Form 2000-401, Condensers Form 2000-402, Adsorbers U Fonn 2000-403, Catalytic or Thennal Oxidation Form 2000.404, Cyclones/Settling Chambers Form 2000-405, Electrostatic Precipitators Form 2000-406, Wet Collection Systems Form 2000-407, IIaghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION --� Total Number of This Form This application contains the following forms (one for each facility boiler. printing operation, 0 Fonn 2000-500, Compliance Certification • Monitoring and Reporting Form 2000-501. Continuous Emission Monitoring D Form 2000.502, Periodic Emission Monitoring Using Portable Monitors Form 2000-503, Control System Parameters or Operation Parameters of a Process ti Form 2000-504, Monitoring Maintenance Procedures Form 2000-505, Stack Testing Form 2000-506, Fuel Sampling and Analysis Form 2000-507, Rocordkccping u Form 2000.508, Other Methods 6 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements, and developing a compliance plan I 1 Form 2000-600, Emission Unit Hazardous Air Pollutants J Form 2000-601, Emission Unit Criteria Air Pollutants Form 2000-602, Facility Hazardous Air Pollutants U Form 2000-603, Facility Criteria Air Pollutants x Form 2000-604, Applicable Requirements and Status of Emission Unit 1 Form 2000-605, Permit Shield Protection Identification t1 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule ti Form 2000-607, Plant -Wide Applicable Requirements ., Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. ❑ I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as deflated in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from 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 Joseph Kuchinski Title V.P. Area Operations North Signaturecc n //4� d 9a �'_"f Date Signed 5- it -aoil 11 Operating Permit Application 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM Facility Name: Lucerne Natural Gas Processing Plant Facility Identification Code: CO _ 1230107 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. i 7 I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification ill, or omits material information from 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 Joseph Kuchinski Title V.P. Area Operations North Signature �5� a Date Signed s'- //- 20a SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-BI 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 12 Construction Permits STATE OF COLORADO (:(-Zo• OTOZ :.IT d••OZ603M60 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (3031 692-3150 CONST UCTION PERMIT PERMIT NO: DATE ISSUED: ISSUED TO: 08WE0920 FEERII!.RY 2, 2010 DCP Midstream, LP initial Approval THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas processing facility, known as the Lucerne Gas Plant, located at 31495 Weld County Road 43, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: • Facility AIRS Equipment Point Description ID AUU1 042 One (1) DGA natural gas sweetening system acid gas removal with a design capacity of 40 MMSCF per day (Anguil, model 50, serial number: TBD). This emissions unit Is equipped with amine pumps(s), make, model, serial number: to be provided, with a total design capacity of 175 gallons per minute. This system includes a natural gas/amine contactor, a flash tank, and an amine reclaimer. All emissions are routed to a thermal oxidizer (make, model, and Serial number: to be. provid j THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 etseq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS; REQUIREMENTS TO SELF -CERTIFY FOR FINAL APPROVAL 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 AQCC Regulation No. 3, Part B, Section I1I.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 AIRS ID- 123/0107/042 Page 1 of 9 Amine Version 2008-1 DCP Midstream. LP Colorado Department of Public Health and Environment Permit No. 08WE0920 Air Pollution Control Division Initial Approval demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, 11_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. 111.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 111.E.) 5. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 8. The manufacturer model number and serial number of the subject equipment shall be provided to the Division 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, 111.E.) 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.A.4) Monthly Limits: l Facility Equipment ID AIRS Point Tons per Month NO, V0C CO SO: Emission Type AU01 042 0.07 0.48 0.37 1.05 Point Monthly limits are based on a 31 -day month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility Equipment ID t AIRS Point Tons per Year Emission Type Point NOR VOC CO SO: AU01 042 0.79 5.70 4.31 12.32 Facility -wide emissions of each Individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. AIRS ID: 123/0107/042 Page 2 of 9 OCP Midstream, LP Permit No. 08WE0920 initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division During the first twelve (12) months of operation, compliance with bcth 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, (Including all HAPs above the de-minimis reporting level) 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. Compliance with the emission limits in this permit shall be demonstrated by running the Promax model on a monthly basis using the most recent sour gas analysis. 9. Emissions from the amine unit flash tank, reclaimer still vent, and regenerator still vent shall be collected and controlled by a thermal oxidizer capable of reducing uncontrolled emissions of VOC and HAPS by at least 99%, in order to meet the emissions of volatile organic compounds and HAPS listed In Condition 7. Operating parameters for the thermal oxidizer identified in the operation and maintenance plan submitted with the application shall be followed. (Reference: Regulation No.3, Part B, Section HIE.) PROCESS LIMITATIONS AND RECORDS 10. This source shall be limited to the following maximum processing and/or operational rates as listed below. Monthly records of the actual natural gas processing and gas combustion rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, ll.A.4) Process/Consumption Limits Facility Equipment ID Auo1 AIRS Point Process Parameter 042 Natural Gas Throughput Annual I Monthly Limit E Limit (31 I days.).____..__ 14,600 1 1,24 _,MMscf/yr ;_MMscf/month During the first twelve (12) months of operation, compliance with both the monthly and yearly processing and 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 processing consumption limits shall be determined on a roiling 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 processing and combustion consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. This unit shall be limited to the maximum lean amine recirculation pump rate of 175 gpm. The lean amine recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. (Reference: Regulation No. 3, Part B, II.A.4) AIRS ID: 123/0107/042 Page 3 of 9 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 08WE0920 Air Pollution Control Division Initial Approval STATE AND/OR FEDERAL REGULATORY REQUIREMENTS 12. 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.) 13. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 14. This amine unit is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A, Subpart LLL, Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions, Including, but not limited to, the following: • 40 CFR, Part 60, Subpart A — General Provisions • §60.640 — Applicability and Designation of Affected Facilities o §60.640(b) - Facilities that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas (expressed as sulfur) are required to comply with §60.647(c) but are not required to comply with §§60.642_ through 60.646. • §60.647 — Record keeping and reporting Requirements o §60.647(c) - To certify that a facility is exempt from the control requirements of these standards, each owner or operator of a facility with a design capacity less that 2 LT/D of H2S in the acid gas (expressed as sulfur) shall keep, for the life of the facility, an analysis demonstrating that the facility's design capacity is less than 2 LT/D of H2S expressed as sulfur. OPERATING & MAINTENANCE REQUIREMENTS 15. Upon startup the applicant shall follow the operating and maintenance (O&M) plan and record keeping format submitted to the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference' Regulation No. 3, Part B, Section III,G,7.) 16. The thermal oxidizer combustion temperature shall be monitored and recorded daily in a log maintained on site and made available to the Division for inspection upon request. 17. The Inlet gas temperature end inlet gas pressure shall be measured and recorded weekly, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements i 8. The owner or operator shall complete the initial annual sour gas analysis testing required by this permit and submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. (Reference: Regulation No. 3, Part B, Section III, E.) 19. A source initial compliance test shall be conducted on emissions point 042 to measure the emission 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 AIRS ID123/01071042 Page 4 of 9 DCP Midstream, LP Permit No. 0$WE0920 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test shall be conducted without prior approval from the Division, Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time (Reference: Regulation No. 3, Part a., Section IIl.G.3) Sulfur Dioxide using EPA approved methods. Volatile Organic Compounds using EPA approved methods. Benzene, Toluene, Ethy!benzene, Xylenes. Methanol, and n -Hexane using EPA approved methods. Periodic Testing Requirements 20. The operator shall sample the inlet gas to the plant on an annual basis to determine the concentration of hydrogen sulfide (H2S) in the gas stream. The sample results shall be monitored to demonstrate that this amine unit qualifies for the exemption from the Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions (§60.640(b)). The testing required by Condition 21 may be used for this demonstration 21 The owner or operator shall complete an extended sour gas analysis prior to the inlet of the amine unit on an annual basis. Results of the sour gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per Condition 8. ADDITIONAL REQUIREMENTS 22. This equipment is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part 6, III.D.2.b. The requirements of condition number 19 above were determined to be RACT for this source. 23. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, tI.C) a. Annually whenever a significant increase In emissions occurs as follows; For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing 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. AIRS ID. 123/0107/042 Page 5 of 9 DCP Midstream, LP Permit No. 08WE0920 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division 24. 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. 25. 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) By: Dennis M. MyP.E. Permit Engineer Permit History Issuance Date 1 Description initial Approval This Issuance I Issued to DCP Midstream, LP AIRS ID 123/0107/042 Page 6 of 9 DCP Midstream, LP Permit No. 08WE0920 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permil 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 perrnittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The perrnittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part il.E.1. of the Common Provisions Regulation. See: h ltixl/www.cdphe.state.co. us/requlatlons/airregsf100102agcccommonprovisionsreq.pdf. 3) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This iriformation 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. AIRS Point _ Pollutant CAS # BIN Uncontrolled Emission Rate (lb/yr) Are the emissions reportat/le? YES Controlled 1 Emission i f. Rateslblyr) j 443 j 042 Benzene 71432 A 44,340 Toluene - 108883 C 34,940 YES 349 Ethytbenzene 100414 C 2,280 YES 23 Xylene 1330207 C 17,740 YES - 177 Hexane 110543 C 1,480 YES 15 Methanol 67561 C 800,792 YES 8,008 4) The emission levels contained in this permit are based on the Promax model using the extended sour gas analysis representative of the natural gas processed by this unit submitted with the permit application. Flare emissions are based on the following emission factors: Nitrogen Oxides: Carbon Monoxide: 0.1082 pounds per million cubic foot of natural gas processed. 0.5904 pounds per million cubic foot of natural gas processed. 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 AP EN expires on December 13, 2014. A revised APEN shall be submitted no later then 30 days before the five-year term expires. 6) This facility is classified as follows: Applicable Requirement Operating Permit PSD Status Major Source CO. NOx, VOC Synthetic Minor Source CO AIRS ID: 123/0107/042 Page 7 of 9 DCP Midstream. LP Permit No 08WE0920 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division NA NSR Major Source NOx VOC Major Source Requirements: Not Applicable MACT HH Area Source emRe qents: Not Apl;licable MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS i 60.1 -End 1 Subpart A - Subpart KKKK NSPS l Part 60, Appendixes ! Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 MACT 63.600.63.1199 Subpart A — Subpart Z Subpart AA — Subpart ODD MACT 63.1200-63.1439 MACT 63.1440-63.6175 MAC -T-5-3.6580-63.6830 MACT F 63.8980 -End Subpart EEE — Subpart PPP Subpart QQQ — Subpart YYYY Subpart ZZZZ — Subpart MMMMM Subpart NNNNN — Subpart XXXXXX AIRS ID* 123/0107/042 Page 8 of 9 DCP Midstream, LP Permit No. 08WE0920 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6.7 AND 8) 1 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. 2. 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. 3. 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 final approval 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. 4. This permit and any required attachments must be retained and made available for inspection upon request at the location set forth herein. With respect to a portable source that Is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as provided In AQCC Regulation No. 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 5. Issuance (Initial approval) of an emission permit does not provide "finer authority for this activityor operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of 25.7.114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Sedlon llt.(i, Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in alt respects with the conditions of the permit. If the APCD so determines, it will provide written documentation of such final approval, which does constitute "final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation. 6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of Issuance of this permit or the date on which such construction or activity was scheduled to commence as set forth in the permit, whichever is later; (2) discontinue construction fora period of 18 months or more; or (3) do not complete construction within a reasonable time of the estimated completion date. Extensions of the expiration dale may be granted by the APCD upon a showing of good cause by the permittee prior to the expiration date. 7. YOU MUST notify the APCD no later than thirty days aftercommeneementofthe 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. uslap/downiogdtorms.html, Failure to do so is a violation of AQCC Regulation No. 3, Part S, Section II1.0.1.. and can result in the revocation of the permit. You must demonstrate comptiiance with the permit conditions within 180 days aftercommencement of operation as stated in condition S. 8. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (AP£N) must pay an annual fee to coverthe costs of inspections and administration. It a source or activity Is to be discontinued, the owner must notify the Division in vatting requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 9. 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, dvii or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions). -122 (civil penalties), -122.1 (criminal penalties), C.R.S. AIRS ID: 123/0107/042 Page 9 of 9 SATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 4V - AIR POLLUTION CONTROL DIVISION'$I ; TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT 1t% -z o tzeoam80 PERMIT NO: 08WE0921 DATE ISSUED: FEBRUARY 2, 2010 ISSUED TO: DCP Midstream, LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas processing facility, known as the Lucerne Gas Plant, located at 31495 Weld County Road 43, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Initial Approval Facility AIRS Equipment Point ID Description HT01 043 One (1) natural gas fired amine regeneration heater. The reboiler is rated at 16.0 MMBtu/hr. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL APPROVAL 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/dovvnloadforms.html. Failure to notify the APCD of startup of the permitted source is a violation of AQCC Regulation No. 3, Part B, Section IIl.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 demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part 8, It.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 AIRS ID: 123/0107/043 Page 1 of 7 Ermine Version 20O3-7 c: DCP Midstream, LP Permit No. 08WE0921 Initial Approval 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 B, Hi.F.4.b. (Reference: Regulation No. 3, Part B, IIl.F.4.) 4 The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, lil.E.) (State only enforceable) 5, The manufacturer model number and serial number of the subject equipment shall be provided to the Division within thirty days (30) after commencement of operation. This information shalt be included on the Notice of Startup (NOS) submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility AIRS i Tons per Month _. -- Emission Type Equipment ID Point No, VOC 1 CO HT0t 043 0.22 0.03 0.43 Point 1 Monthly limits are based on a 31 -day month. Facility -wide emissions of each individual hazardous air pollutant shall be less than 1,358.9 lb/month. Facility -wide emissions of total hazardous air pollutants shall be less than 3,397.3 lb/month. Annual Limits: Facility Equipment ID AIRS Point HT01 043 Tons per Year NO„ VOC 2.59 0.37 co 5.05 Emission Type Point Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. During the first twelve (12) months of operation, compliance with both the monthly and 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, (including ail HAPs above the de-minimis reporting level) 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 calculatedm onthly emissions and keep a compliance record on site, AIRS ID: 123/0107/043 Page 2 of 7 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No 08WE0921 Air Pollution Control Division Initial Approval 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. PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual natural gas processing and gas combustion rates shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) ProcesslConsumption Limits Facility Equipment ID AIRS Point HT01 043 Annual I Monthly Process Parameter I I Limit (31 Limit I day_s)_ 134.77 11.45 Natural Gas Consumption I MMscf/yr MMscemonth During the first twelve (12) months of operation, compliance with both the monthly and yearly processing and 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 processing 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 processing and combustion consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE ANDIOR FEDERAL REGULATORY REQUIREMENTS 8. 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.) 9. This source is subject to the odor requirements of Regulation No.2. (State only enforceable) 10, This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part A Subpart Dc, Standards of Performance for Small Industrial - Commercial -Institutional Steam Generating Units including, but not limited to, the following: a. The owner or operator of the facility shall record and maintain records of the amount of fuel combusted during each month (40 CFR Part 60.48c(g)). b. Monthly records of fuel combusted required under the previous condition shall be maintained by the owner or operator of the facility for a period of two years following the date of such record (40 CFR Part 60.48c(i)). In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. c. At ail times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures AIRS ID: 123/0107/043 Page 3 of 7 OCP Midstream. LP Permit No. 08WE0921 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 d. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) e. Written notification of construction and initial startup dates shall be submitted to the Division es required under § 60.7. 1. Records of startups. shutdowns, and malfunctions shall be maintained, as required under § 60.7. 1 i . Particulate emissions shall be limited as per: Regulation 6, Part B, Il.C,2. ADDITIONAL REQUIREMENTS 12. This source shall be equipped with low NOx burners. The source shall be operated in such a manner to assure that good combustion practices are followed, in order to meet the manufacturer's guaranteed NOx emission rate of 0.037 lbs/MMBtu, as submitted in the permit application. 13. This equipment is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Ill.D.2.b. The requirements of condition number 12 above were determined to be RACT for this source. 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, WC) 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 60% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the division. b. Whenever there Is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 15. 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 AIRS ID: 123/0107/043 Page 4 of 7 DCP Midstream, LP Permit No. 08WE0921 initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by his permit. By: Dennis M. Myers, Permit Engineer Permit History Issuance i Date initial Approval 1 This issuance Description Issued to DCP Midstream, LP 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 Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: htto:l/www.cdohe.state.co.uslrequlatignsfairrectsl100102aocccommonprovisionsreo. pdf. 3) The emission levels contained in this permit are based on AP -42 Tablet .4, except for NOx and CO which are based on manufacturer's guaranteed rates. 4) in accordance with C.R.S. 28-7-114.1, 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 April 5, 2014. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 5) This facility is classified as follows; Applicable Requirement Status Operating Permit Major Source CONOx VOC , , PSD Synthetic Minor Source CO r NA NSR Major Source ^ NOx, VOC MACT HH Major Source Requirements. Not Applicable Area Source Re_quirements: Not Applicable _ MACT zzzz Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable AIRS ID: 123/0107/043 Page 5 of 7 DCP Midstream, LP Permit No. 08WE0921 Initial Approval 6) Full text of the Title 40. Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below• Colorado Department of Public Health and Environment Air Pollution Control Division h ttp;Ae cfr. g poaccess.govi Part 60: Standards of Performance for New Stationary Sources NSPS 160.1 -End Subpart A — Subpart KKKK NSPS Part 60. Appendixes Appendix A Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT -j 63.1-63.599 Subpart A — Subpart Z MACT 63.600.63.1199 Subpart AA— Subpart DDO MACT 163.1200-63.1439 MACT 63.1440-63.6175 MACT 63.6580-63.8830 MACT 63.8980 -End Subpart EEE — Subpart PPP Subpart QQQ ._ Subpart YYYY Subpart 7777 - Subpart MMMMM ' Subpart NNNNN - Subpart XXXXXX AIRS 1D: 123/0107/043 Page 6 of 7 DCP Midstream, LP Permit No 08WE0921 Initial Approval Colorado Department of Public Health and Environment Air Pollution Control Division GENERAL TERMS AND CONDITIONS: (IMPORTANTI READ ITEMS 5.6,7 AND 8) 1. 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. 2 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. 3. 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 eb Indio. This permit may be revoked at anytime prior to final approval 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 (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 Division's action. 4. This permit and any required attachments must be retained and made available for Inspection upon request at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source Is relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 5. Issuance (initial approval) of an emission permit does not provide "final" authority for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of25-7-114.5O2)(a)C.R.S. and AQCC Regulation No. 3, Parte, Section 111G. Final approval 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. If the APCD so determines, it will provide written documentation of such final approval, which does constitute "final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days alter commencement of operation. 6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of issuance of (his permit or the date on which such construction or activity was scheduled to commence es set forth In the permit, whichever Is later, (2) discontinue construction fore period of 18 months of more; or (3) do not complete construction within a reasonable time of the estimated completion dale, Extensions of the expiration date may be granted by the APCD upon a showing of good cause by the permittee prior to the expiration date. 7. 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 do sole a violation of AQCC Regulation No. 3, Part B, Section III.G.1., and can result in the revocation of the permit. You must demonstrate compliance wiN the penal, conditions within 180 days aftercommencement of opera Non as stated in condition 5. 8. 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. 9. 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. AIRS ID: 123/0107/043 Page 7 of 7 STATE OF COLORADO 96WE905-PERMIT-2010-02-D2 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONS T ' PERMIT NO: 96WE905 TI N P RMIIT Initial Approval DATE ISSUED: FEHRTJ/RY 2. 2010 ModifIcation No. 1 ISSUED TO: DCP Midstream, LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural gas processing facility, known as the Lucerne Natural Gas Processing Plant, located at 31495 Weld County Road 43, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description P007 014 Gas Plant Fugitive Emissions C-106 015 . Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Reciprocating Engine, 4 -cycle, Standard Rich Bum WI air/fuel ratio controller, Serial No. 266454, manufacturers maximum site rated at 1,232 horsepower, powering an inlet natural gas compressor. . C-110 017 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Reciprocating Engine, 4 -cycle, Standard Rich Burn WI air/fuel ratio controller, Serial No. 389890, manufacturer's maximum site rated at 1,232 horsepower, powering a residual natural gas compressor. C-107 018 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Reciprocating Engine, 4 -cycle, Standard Rich Burn wl air/fuel ratio controller, Serial No, 350086, manufacturer's maximum site rated at 1,232 horsepower, powering an inlet natural gas compressor. C-109 019 Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Reciprocating Engine, 4 -cycle, Standard Rich Burn WI air/fuel ratio controller, Serial No. 144345, manufacturer's maximum site rated at 1,232 horsepower, powering a residual natural gas compressor. AIRS ID: 123/0107 Page 1 of 15 Mul i-Unit version 2008-1 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 96WE905 Air Pollution Control Division Initial Approval — Modification No 1 THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seg1, TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL APPROVAL 1 Within one hundred and eighty days (180) after commencement of point 014 modification, 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 demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, II.G.2). 2. 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, IlI.F.4.) 3. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Reference: Regulation No. 3, Part B, Section III.E.) 4. The permit number and AIRS 1D number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, tII.E.) (Slate only enforceable) EMISSION LIMITATIONS AND RECORDS 5. Emissions from all insignificant activities, from the facility, shall not exceed 17.9 tons per year of carbon monoxide, and 23.9 tons per year of nitrogen oxides. The applicant shall track emissions from all NO„ and CO emitting insignificant activities on a yearly basis. This information shall be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities shall be defined as any activity or equipment, which emits any amount but does not require an Air Pollutant Emission Notice (APEN). 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) AIRS ID: 123/0107 Page 2 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division Annual Limits: Facility Equipment ID AIRS Point r Tons per Year Emission Type NO, VOC i CO P007 014 13.78 Fugitive C-105 015 28.54 14.27 28.54 Point C-110 017 23.79 11.90 23.79 Point C-107 018 23.79 11.90 23.79 Point C-109 019 23.79 11.90 23.79 Point Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling (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. 7. Points 015, 017-019: These engines shall be configured with non -selective catalytic reduction (NSCR) systems and air fuel ratio controllers. The NSCR shall be capable of reducing uncontrolled emissions of nitrogen oxides and carbon monoxide from the engines to the emission levels listed in Condition 6, above. Operating parameters of the control equipment shall be identified in the operation and maintenance plan. (Reference: Regulation No.7, Section XVI.) a. The operator shall calculate actual emissions from this emissions point based on representative actual component counts for the facility along with the most recent gas analysis, as required in the Periodic Testing Requirements section of this permit. PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum consumption, processing and/or operational rates as listed below. Monthly records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4). AIRS ID: 123/0107 Page 3 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Process/Consumption Limits Facility Equipment ID C-105 AIRS Point 015 Colorado Department of Public Health and Environment Air Pollution Control Division -r Process Parameter Annual Limit Consumption of natural gas as a 97.10 fuel MMSCF/yr C-110 017 Consumption of natural gas as a 79.'18 fuel MMSCF/y_r C-107 018 Consumption of natural gas as a 79.18 -- fuel MMSCF/yr I C-109 019 Consumption of natural gas as a 79.18 fuel MMSCFIyr 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/OR FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. (Reference: Regulation No. 1, Section 11,A,1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) OPERATING & MAINTENANCE REQUIREMENTS 12. The applicant shall follow the most current operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) PERIODIC TESTING REQUIREMENTS 13. On an annual basis, the permittee shall complete a gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This gas analysis shall be used in the AIRS ID: 123/0107 Page 4 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No, 1 Colorado Department of Public Health and Environment Air Pollution Control Division compliance demonstration as required in the Emission Limits and Records section of this permit. ADDITIONAL REQUIREMENTS 14. The above VOC emission rate for emission point 014 (gas plant fugitive emissions) is based on operational rates and numbers of components as stated In the application. The actual number of components at the facility shall be maintained by the applicant and made available to the Division for inspection upon request: (Reference: Regulation 3, Part B, III.E). 15. This source is subject to the New Source Performance Standards requirements of Regulation No. 6, Part B , Subpart KKK , Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants including, but not limited to, the following: a. Section 60.632 Standards. b. Section 60.635 Recordkeeping requirements. c. Section 60,636 Reporting requirements. In addition, the following requirements of Regulation No. 6, Part A, Subpart A, General Provisions, apply. a. At all times, including periods of start-up, shutdown, and malfunction, the facility and control equipment shall, to the extent practicable, be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. (Reference: Regulation No. 6, Part A. General Provisions from 40 CFR 60.11 b. No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which Is based on the concentration of a pollutant in the gases discharged to the atmosphere. (§ 60.12) c, Written notification of construction and initial startup dates shall be submitted to the Division as required under § 60.7. d. Records of startups, shutdowns, and malfunctions shall be maintained, as required under § 60.7. AIRS ID: 123/0107 Page 5 of 15 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 96WE905 Air Pollution Control Division Initial Approval -- Modification No. 1 16. The gas plant fugitive emissions covered by emission point 014 are located in an ozone non -attainment or attainment -maintenance area and are subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.b. The requirements of condition number 15 above were determined to be RACT for this source. 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, ll,C) a. Annually whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Points 015, 017-019: 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 or turbine, 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 or turbine. 19. 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. 19. MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Reference: Regulation No. 8, Part E) AIRS 1D: 123/0107 Page 6 of 15 DCP Midstream. LP Colorado Department of Public Health and Environment Permit No. 96WE905 Air Pollution Control Division Initial Approval — Modification No. 1 20. MACT Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8, Part E) 21. All previous versions of this permit are canceled upon issuance of this permit. By: 4 Dennis M. Myer• Permit Engineer Permit liisto Issuance Date Description Initial Approval Modification No.1 This Issuance Issued to DCP Midstream, LP; increase in fugitive components; elimination of points 011, 016, 020, and 021; permitted emissions change to match those of Title V permit Initial Approval March 5, 1998 Issued to Panenergy Field Services, Inc. 1 d 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 permlttee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: htte://www.cdphe.state.co.uslreaulations/alrregs/100102aecocommonorovisionsree.pdf. 3) In accordance with C.R.S. 25-7-114.1, the Air Pollutant Emission Notices (APENS) associated with this permit are valid for a term of five years. The five-year term for the APEN for point 014 expires on April 5, 2014. The five-year term for the remaining APENS for points 015, 017, 018, and 019 expires on August 8, 2012. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 4) This engine as well as replacements completed under the AOS included in this permit as Attachment X may be subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18. 2008 Federal Register posting - effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control AIRS ID: 123/0107 Page 7 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.govittnialw/areafirl 8ja °lost( 5) This engine as well as replacements completed under the AOS included in this permit as Attachment X may be subject to 40 CFR, Part 63. Subpart ZZJ_Z - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18. 2008 amendments to include requirements for area sources and engines ≤ 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart Is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ia08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www. eoa.gov/ttn/atw/area/arearules. html 6) This facility is classified as follows: Applicable Requirement Operating Permit Status PSD Major Source CO, NOx, VOC Synthetic Minor Source CO NA NSR Major Source NOx, VOC Major Source Requirements: Not Applicable Area Source Requirements: Not A licable Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable MACT HH MACT ZZZZ 7) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below; • h ttp://ecfr.g poaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A— Subpart KKKK NSPS Part 63: National Part 60, Appendixes Appendix A — Appendix I Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-83.1199 Subpart AA — Subpart DDD MACT 83.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart 7777 - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX AIRS ID: 123/0107 Page 8 of 15 DCP Midstream, LP Permit No. 96WE905 . Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ !TEMS 5,6,7 AND a) 1. 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 applicants agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 2. 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. 3. 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 al any time prior to final approval 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 tern or condition of the permit. If the Division denies a permit, conditions imposed upon a permit ate 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. 4. This permit and any required attachments must be retained and made available for inspection upon request at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No. 3, Part B, Section II.B, upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 5. Issuance (Initial approval) of an emission permit does not provide "final" authority for this activity or operation of this source. Final approval of the permit must be secured from the APCD In writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final approval 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. If the APCD so determines, it will provide written documentation of such final approval, which does constitute 'final" authority to operate. Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation. 6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of issuance of this permit or the dale on which such construction or activity was scheduled to commence as set forth In the permit, whichever Is later; (2) discontinue construction for a period of i8 months or more; or (3) do not complete construction within a reasonable time of the estimated completion dale. Extensions of the expiration date may be granted by the APCD upon a showing of good cause by the permittee prior to the expiration dale. 7. 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,cdnhe.state.co.us/apldownloadforms.html. Failure to do so is a violation of AQCC Regulation No. 3, Part B, Section 111.0.1., and can result in the revocation of the permit. You must demonstrate compliance with the permit conditions within 180 days after commencement of operation as stated in condition 5. 8. 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. 9. 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. AIRS ID: 123/0107 Page 9 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES December 10, 2008 The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B. Construction Permits, and Regulation No. 3, Part 0, 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 the engine Is in operation, If the engine operates only part of a day, that day shall count as a single day towards the 90 -day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit All replacement engines are subject to all federally applicable and state -only requirements set forth In this permit (Including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the permittee shall maintain a copy of all Applicability Reports required under section A.1.2 and make them available to the Division upon request. A.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the emissions from the temporary replacement engine comply with the emission limitations for the existing permitted engine as determined in section A.2. Measurement of emissions from the temporary replacement engine shall be made as set forth in section A.2. A.1.2 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 existing engine, 2) any permitted short-term emission limitations for the existing permitted engine, and 3) AIRS ill 123/0107 Page 10 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division the applicable emission limitations as set forth in the Applicability Report submitted to the Division with the Air Pollutant Emissions Notice (APEN) for the replacement engine (see htto://voww.cdr he,state co.usrao/oitgaspermittina.htmi 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 A2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non -Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that aro below the significance levels in Reg 3, Part 0, il.A.42. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at http://www.cdohe.state.co us/arvoilqaspermfllirglitml. This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of the source indicating that `based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete'. This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement, Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. A.2 Portable Analyzer Testing Note: in some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: http-//www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf AIRS ID: 123/0107 Page 11 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (Ib/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) 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 lime 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 § II.D.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 (MCI) 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 attainmenUmaintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 ton s/yr. For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations In NSPS JJJJ NOX: The emission limitations in NSPS JJJJ 8O2: Use of natural gas as fuel PM10: 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 AIRS ID: 123/0107 Page 12 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval -• Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division Any permanent replacement engine located within the boundaries of an ozone nonatlainment 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 rale greater than 500 hp shall use a non.seleclive catalyst and air fuel controller to reduce emission Loan burn engines s: ti a rn„a ;:faciurer's design rata gray ler than 500 hp shall use an oxidation catalyst to redtrCe errssicns The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition A.1.2. Emission Standards: Soction )(VILE — 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 HP Construction or Relocation Date Emission Standards in Ofhp-hr NOx CO VOC 100<Hp<500 January 1, 2008 2.0 _ 4.0 1.0 January 1, 2011 1.0 2.0 _ 0.7 500<^Hp July 1, 2007 2.0 4.0 ! 1.0 July 1, 2010 1.0 2.0 _ ( 0.7 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), AIRS ID: 123/0107 Page 13 of 15 DCP Midstream. LP Permit No. 96WE905 Initial Approval — Modification No. 1 Colorado Department of Public Health and Environment Air Pollution Control Division 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, § LB (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) MALT: 40 CFR Part 63, Subpart ZZZZ A.3.4.1 Area Source for HAPs A permanent replacement engine located at an area source that commenced construction or reconstruction after June 12. 2006 as defined in § 63.2, will meet the requirements of 40 CFR Part 63, Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under 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.3.4.2 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: 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 ZZZZ. New or reconstructed (construction or reconstruction commenced after 6/12/06) 4 stroke lean bum engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ New or reconstructed (construction or reconstruction commenced after 6/12/06) 2 stroke lean burn or 4 stroke rich burn engines with a site rating of 500 hp or less will meet the requirements of 40 CFR 63, Subpart 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. My testing required by the MACT is in addition to that required by this ADS. 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. AIRS ID: 123/0107 Page 14 of 15 DCP Midstream, LP Permit No. 96WE905 Initial Approval — Modification No. 1 A.3.5 Additional Sources Colorado Department of Public Health and Environment Air Pollution Control Division 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 ADS 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 art existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS iO. 123/0107 Page 15 of 15 Current APENs N O Q (Leave blank unless APCD hat already assigned a permit a & Permit Number: [Provide Facility Equipment lD to identify how this equipment is referenced within your organiatio Facility Equipment ID: AU01 2 -Requested Action (Check applicable request boxes) Section 01 — Administrative Information Request for NEW permit or newly reported emission source Change process or equipment Change permit Limit Request to limit ffAPs with a Federally enforceable limit on PIE a a 7.5 0 .0 x .0 V V A C a Z w rr aY ❑ ❑ D El Os N Nro N N o C o 3 O ≥ Z r W N r. O V a. C U 0. 0 0. r u O z W a < .o E 1 U 0 u is. O D Person To Contact: APEN to update control device for flash tank, no change to emissions 3 _10 z <�S Section 03 — General Information u, • • sources, opera:iion began x U 3 a q < c O O 8 0 N 0 7 of 5 f0 0 0 0 0 a a 0 O Q Q DO Z Z ❑ ❑ E 03 0 w cso O o r � m � ° -,1-0 5 C � C C.. N O O N c U1 a N u 2 u 0 •E ,c 3 i "8 g f.. . C u u E o '0 A s u 3 0 S g V a V .. vU y E C _ V A • V) E V O ti O o0 n ^ v r n n n cl • N N N ... on u : Y so 'o E C 6 p 0 r r vv� NW w ~� N .. to c,4 `� s t < m w Y N xx 59 w I .5 V .0 a v 0 60 @ Z cn E o ti P A M o A u '0 APEN forms: Application stat th u ion 04 — Amine 0 z U '0 0 4) 0 Sweet Gas Throughput U ti 0 N r ti N E-" Mole loading C05: a 2 x C g F S 2 OD ySN� N '4 8. P. a 8. P 6 V C Rich Amine Fecd: N Lean Amine Stream a d n U ° a -7g, N 0. O 2 ti o c. n o. P. Q O o Ct. 8 0. o s O '00 U V cr u UV OD h � EA ; 5 �^ U 7)0 O 1 03 N Ntp V zx u u 0 0� .0.5•• E'4v V ? '1 - g• -!!, 'v E 00. E 0 .O C a m2' E o E N Q V a 08� U L U U ¢d¢t ❑❑❑ FormAPCD-206-AmineUnitAPEN-Ver 940-2008.docx N 0 d0 a FORM APCD-206 w AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Co E z (Datum & either Lat/Long or UTM) rn Section 05 — Stack Information (Combustion stacks must be listed here) s W 9zg aco InCO ti y II a N n c o o ▪ 3 O `a I O e ❑_ g. .!.11 Y 2 L 0 y v rn ❑ u CO AZ z ❑ ea a 4 Y e y E Q Y. U fi g J s ❑S C g U yi >® 18 a P ri H EL Fh a rmation (Indicate if a control device control 7 — Control Device In C 0 143 In Information & Emission Control Information Section 08 - Emissions Inven Estimation Method • Of Emission Factor Source N C. 4 O W< N 1. a t4 4 o 2222 P. C 4 L 4 q O. 4 Ion -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. ... _ .e •_S. , .._.—......... n......n 6. FxnA m mm.xtrd nmittinne ❑ontrotleo (Tons/Year) N Vf N 00000 0 0 0 Requested Emirs Uncontrolled (Tons/Year) N O ot N n O t^ a ry _tai .a. " w N co O Controlled (Ions/Year) Actual Calendar "Si 5 OQ 8 Emission Factor "- 1 � C a I. .O O -- A la .0a d Uncontrolle.Basis • • co S o a «j n c o a vi in ry o LTV Zot Factor Documeatanon armelKn Data ]car stir rv.sI74,kJ��•td � nyy }yl i'x> t. ..,:t y4p • o HIV} u9 !} ? y 1� IJ Emission Pollutant g x U j V � 4g1 S -o u 4 > 5 ection 09— Y I - i Q Ca 0. FormAPCD-206-AmineUnitAPEN-Ver 9-10-2008.docx N w 0 N a" z W V 0 z z o — (o co z Q 8 F• -a 8 o -8, ao Q� J�' L VJ ce 0 w CG w H re O z 0 CO Q Permit Number: DCP Midstream, LP Company Name: U n N C 0 O Lucerne Gas Processing Plant, 31495 W.C.R. 43 Plant Location: U 7,5 Person to Contact stream.com E-mail Address: Controlled Actual Emissions Ohs/year) co 0 0 05 Uncontrolled Actual Emissions (lbs/year) N cm O O O C) 07 0 't N Emission Factor Source ProMax Mass Balance Emission Factor (Include Units) -(10 v.- 07 N Ni Control Equipment I Reduction (%) Co Reporting BIN U N/A 1 Chemical Name Methanol Sulfur Dioxide Chemical Abstract Service (CAS) Number Calendar Year for which Actual Data Applies: Reporting Scenario (1, 2 or 3): CO 0. O. (I) O N 0 t Q 7, Ca CJ 11) a) 0 0) C) Q Ca Ca a. 0 0) 0 4- 0 a co C a ro z Form Revision Date: December 4, 2006 AlR POLLUTANT EMISSION NOTICE (ADEN) & Application for Construction Permit -- Ggneral Emission Source AIRS ID: assigned a permit Y & AIRS ID] (Ixave Hint unless APCD has al ID lo identify how this equipment is referenced within 'mat organintlon.] (Provide Pacilily Ei uipmen F- Seel inn 02 — Requested Action (check applicable request loxes) 'c Bequest for NEVe permit or newly reported emission source Request PORTABLE source permit 31495 Wck] County Rood 43 I Transfer el -ownership Change permit limit Request to limit HAPN wk6 a Federally enforceable limit on PTE ZIP Code: 80202 Fax Number: 303.60& t 957 sources, the projected sl ulup dole is: 52 weeks/year C a:4 z 0 C z C z .2 Rater APEN 031109.doc FORM APCD-200 0 L C7 C e U u O a 0 •P dciz Pr Ft O (71 z 1/ a a x 6 Emission Source AIRS ID: Permit Number: ion (Attach a separate sheet with relevant information in the event of multiple releases; provide datum & either 1at/Long or UTM) 05—Emissio O J4 tam C. c "a 3 n a azS U AS d eu d F v V�4y gee o< F. rea 7 I IL O o 0 ❑ Serial No.: TBD onsumotion Information ta Section 06 —Combustion Emil a Manufacturer: TDD z s I v a fY+ a a a A In I on N V A In 3 aF 2 N 134.77 MMrcflyr yY 3h a U i z I a I E I I information & aN 1 ttrrll a E “2 < N < N `< N < i 5 2 N < I S li C hP'cr $p R i % �d $ a a a n a ."$ Y V C a C § pp _yy :�36 t 8§ A V F 1 V II urn 1 'w e § € Emission Factor 1 a a i X {C is a B a a Q'5 a aP b YP,i N h17 O a iiF1ii A F r -:V 14 ad V ti 0< a a a g h. 0w II ti Y 5th 2 a-ag UW < a 1 S a. 8 ys {gi I 1 6 i o x 81 a 3o a 4 2; O � a Q Ypp r R alY a G V • N Y'- u 9 a a ✓ C aa a $ a 8 a a g 3 C V a B ▪ h D P Y 3 of C a B P 1 U N Pw P R Inz M ✓ Y V q a y Y ts a • Cr\ Y P "N.4 b 6 \u P. 2 a v 0a a onent Leak Emissions 0 unless APCD halal 95OPWE100 A. Section 02 —Requested Action (Check applicable request boxes) Section 01 —Administrative information ! ) /,/ 2: .2a ))§)} e2 fl DO \)l k ��!/ /k|{( o a de 6a I • DO 00 \/ Lucerne Natural Gus Processing Plant •I 5 3145.3 Weld Couny Rand 43 37017' Street, Suite 2500 { ! k Phone Number: 303.60.3.1984 303.605.1957 a a | k � Eannil Address: urces, the projected startup data is: \ a CY a 9 t subject to NSPS 40 CFR Punt 60, Subtext KKK? Is this equipment subject to NFSIIAP 40 CFR Pad 63, Subpart Ilil? List any other NSPS a NESILAP Subpart that applies lu this equipment: Section 05 — Stream Constituents \} a` rat )k 3 it a ›.v \ $ k SS Fuginre APEN.doe 0 al ea FORM APCD-203 0 6 E a Emiss Permit Number; 95OPWEl00 a Section 06 —Location Information (Provide Datum and either Lat/Long or UTM) hi a ` 1d " O a z $ s g o oO'a $ -ii • o E a a e o• A g f b a xv sage5 s Y r s V m m 2z4a`i J O a® 6 Iv g U h D❑ e V ?9� a a Is4.1 a z Factor Information a C i g a° a a U Light Oil for Light Liquid) a 0 d 1 p3 O n co r r a i Units p I. itit O P 1 U o ti c: u L u r V O 0 p SI °e8 Equipment Type Ii IOpen -Ended Lints a >, � s 1 9 I 3 I I 9 I I u 2 i 1 585 a eN I g E w i i a I ay a a E a s il ligi a el i2 1 t s ri 13e u y 1 U 3° t. 9 a R t 2 3l 1;e s a 6 a •1 Emission Factor CO Wa 0 << a a a u4 y a 9tl < a $ as u3 co S s 4 Vh-a {V r. 0 Z 2 a I X g r a • I e, S a Jla 9 5. s .8 L" a 1 3M a 8 a; a ssq JJZI= ie a 2 S ▪ a. U• s ,.a .1 a 8 a °: W a 3 I;r pa Et E a 5 itI < gg y u Er am p e Sa as ii. 2, • a; :1 a e a a° a <2z T. xq 8a a ai �g{ 9 V III s9 a - AxA - u 'a 2. g 4n• E V \ a. �� V n E �. :.' ii g8;, ??S 3I .,:.J < x _ L J a e.\" a a . a I V, O N V a C-244 APEN Cancellation Page 1 of 1 Rosenberg, Susan E From: Rosenberg, Susan E Sent: Thursday, April 16, 2009 1:02 PM To: denise.onyskiw@state.co.us Cc: Ashley.Campsie@CH2M.com Subject: Lucerne Gas Plant and Cancellation of APENs The revised application for the Lucerne Natural Gas Processing Plant dated April 1, 2009 eliminated several proposed equipment for which APENs were previously submitted. In addition, a minor modification to the Title V permit allowed for the addition of the Caterpillar G3306TA (C-244). This unit has not been installed to date and there are no plans to install this unit. For these reasons, DCP Midstream is requesting the following points and associated APENs be cancelled. 031 Caterpillar G3306 Air Compressor 034 Caterpillar G3608 Inlet 1 035 Caterpillar G3608 Inlet 2 036 Caterpillar G3608 Inlet 3 037 Waukesha L7042 Residue 1 038 Waukesha L7042 Residue 2 039 Waukesha L7042 Residue 3 040 Solar Saturn 50 Genset 1 041 Solar Saturn 50 Genset 2 Susan Rosenberg DCP Midstream 370 17th Street, Suite 2500 Denver, CO 80202 303-605-1984 (office) 303-605-1957 (fax) 303-408-2955 (cell) 4/16/2009 WASTE MANAGEMENT January 16, 2013 Mr. Jerry Henderson Colorado Department of Public Health and Environment Hazardous Materials and Waste Management Division HMWMD-SWIM-B2 4300 Cherry Creek Drive South Denver, CO 80246-1530 Mr. Troy Swain Weld County Department of Public Health and Environment 1555 N. 17th Avenue Greeley, CO 80631 2400 West Union Avenue Englewood, CO 80110 303-914-1445 (Phone) 866.442-0285 (Fax) SUBJECT: NORTH WELD LANDFILL FOURTH QUARTER 2012 LANDFILL GAS (Methane) MONITORING REPORT Dear Mr. Henderson and Mr. Swain: Enclosed for your information is the Fourth Quarter 2012 Gas Monitoring Report for North Weld Landfill (NWLF). AquAeTer performed the monitoring of the subsurface and facility structures for methane migration in accordance with 6 CCR 1007-2 on December 17 and 18, 2012. The report contains monitoring results from the Phase 1 and 2 perimeter soil gas probes GP -06, GP -07, GP -10 through GP -20, structure probes GP -01 and GP -02, inside the shop and office, and confined spaces in the vicinity of the western boundary of the site. A map showing the gas probe locations, the scale house and maintenance shop is included as Figure 1. Section 2.3.1 of the Regulations Pertaining to Solid Waste Sites and Facilities, 6 CCR 1007-2, Part 1 (Regulations) requires that the percent of methane (explosive gas) in air (v/v) shall not exceed (A) 25% of the lower explosive limit (LEL) (i.e., 1.25% methane v/v) within facility structures, and (B) the LEL (i.e., greater than 5% methane v/v) at the facility boundary. During this monitoring event, methane was detected in structure probe GP -01 at 38.3% v/v and perimeter probe GP -06 at 6.7% v/v. In addition, although below regulatory levels, methane was detected in GP -12 at 2.3% v/v on December 17 and 1.3% v/v on December 18. Also below regulatory levels, methane was detected in GP -16 at 0.7% v/v on December 17 and 0.0% v/v on December 18. Methane was not detected in any of the other probes, shop, office or confined spaces during this monitoring event. The facility currently operates under an approved gas remediation plan prepared in response to previous elevated methane concentrations in structure probe GP -01 and perimeter probes GP -10 and GP -11. The plan includes monthly monitoring of these probes and utility corridor access points along WCR 25. Beginning in February 2012, the facility also began monthly monitoring of Dyrt rrLGC rGl GCt C citd%, L/3 C 3.05 L'� e7-77 Letter Jerry Henderson and Troy Swain January 16, 2013 Page 2 GP -06. Included in Attachment 1 are the October and November 2012 monthly reports. A summary of the monitoring results for these monthly events is provided in the following table. Percent (°/0) CH4 v/v Monitoring Probe October 2012 November 2012 GP -01 18.2 21.5 GP -06 1.7 0.8 GP -10 26.6 23.1 GP -11 0.0 0.0 Methane was not detected in the utility corridor access points or facility structures during the monthly monitoring. The approved remediation plan also included the installation and operation of passive gas vents constructed within waste along the western limit of the disposal area. As stated in the plan, the passive vents, which were installed in December 2009, may require one or more years to show consistent reduction in methane levels at perimeter probes GP -10 and GP -11 and structure probe GP -01. Until methane levels are below the regulatory threshold for three consecutive monthly events, monthly monitoring will continue to be performed. As previously indicated, GP -06 was added to the monthly monitoring program commencing in February 2012. Continuous methane monitors are in operation within the facility maintenance building, office and gatehouse and no methane detections have been observed. We have been evaluating options to augment the performance of the existing in waste passive gas vents in order to increase their radius of influence in the southwest corner of the disposal area. We have determined that replacing the wind turbines presently affixed to the top of the passive vents with solar flares should achieve this objective. The flares feature solar -powered continuous ignition and do not require an external power source. In addition, the flares will increase negative pressure at the gas vents, which should establish a more consistent inward gradient for landfill gas and better control its movement away from the waste mass. The augmentation of the gas vents with solar -powered flares is anticipated to accelerate attenuation of gas concentrations in the gas monitoring probes to below the regulatory limit. The first two solar flares were installed on the two southernmost passive vents on August 23. Among the seven passive vents installed at the site, these two vents are closest to the gas probes that have registered elevated methane readings. We plan to install solar flares on the remaining five passive vents this month. Please contact me at (303) 914-1445 should you have questions about this report. Sincerely, On behalf of North Weld Landfill Tom Schweitzer Engineer Letter Letter Jerry Henderson and Troy Swain January 16, 2013 Page 3 cc: Kim Ogle, WCDPS, w/o enc. Bill Hedberg, NWLF RECEWED JAM 1 ;; 7013 Neid County r,anniog Department GREELEY OFFICE 2013-0295 Hello