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Home My WebLink About20120991.tiff STATE s.io ,E• . ORADO John W. Hickenlooper,Governor 2012 APR 10 P I: 4U Christopher E.Urbina,MD,MPH /oF coto Executive Director and Chief Medical Officer Q/: Dedicated to protecting and improving the health and environment of the people of C f r C E I V ED * 4300 Cherry Creek Dr. S. Laboratory Services Division •'rays', Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department Located in Glendale,Colorado (303)692-3090 of Public Health http://www.cdphe.state.co.us and Environment April 4, 2012 Mr. Steve Moreno Weld County Clerk Box 1138 Greeley, CO 80632 Dear Mr. Moreno: On April 7, 2012,the Air Pollution Control Division will publish a public notice for DCP Midstream, LP in 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-Bl 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 (° fl NZ Thit,A11C keult ('a" "/4 /a. 2012-0991 'a- NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT NOTICE is hereby given that an 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 17ih Street, Suite 2500 Denver, CO 80202 Facility: Spindle Gas Processing Plant Sec 34, T2N, R67W Fort Lupton, CO DCP Midstream, LP has applied for a Renewal Operating Permit for their facility in Weld County, CO. The facility is a natural gas processing plant. A copy of the applications, including supplemental information,the Division analysis, and a draft of the Renewal Operating Permit 95OPWE039 has been filed with the Weld County Clerk's office. 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 at 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). If requested,the hearing will be held before the Commission at their regularly scheduled meeting 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: April 7, 2012 April 4, 2012 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 95OPWE039 AIRS ID#: 1230015 DATE: April 4, 2012 APPLICANT: DCP Midstream, LP—Spindle Gas Processing Plant REVIEW ENGINEER: Bailey Kai Smith SOURCE DESCRIPTION DCP Midstream, LP has applied for renewal of their Operating Permit issued for the Spindle Gas Processing Plant located near Fort Lupton, Weld County. The Spindle Plant processes natural gas via a gas processing skid and a fractionation assembly and is classified under SIC 1321. The facility consists of 12 reciprocating internal combustion engines, a TEG dehydrator, hot oil heater, four condensate storage tanks, a tank truck loadout, and fugitive VOC emissions from equipment leaks. 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. There are no affected states 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 major 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 eight Waukesha Model L-7042 GSI engines 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 Emission Unit NOx CO VOC Waukesha 1232HP Engine P160 39.6 39.6 9.7 Waukesha 1232HP Engine P161 39.6 39.6 9.7 Waukesha 1232HP Engine P162 23.8 39.6 9.7 Waukesha 1232HP Engine P163 23.8 23.8 6.0 Waukesha 1000HP Engine P164 19.3 38.6 9.7 Waukesha 1000HP Engine P165 39.6 39.6 9.7 Waukesha 1232HP Engine P166 39.6 39.6 9.7 Caterpillar 230HP Engine P168 5.0 r 5.0 2.2 Waukesha 1000HP Engine P169 19.3 29.0 9.7 Superior Ajax 1215HP Engine P170 23.5 17.6 11.7 Superior 600HP Engine P171 11.6 17.4 5.8 • Weatherford Dehy P178 0.9 • • Hot Oil Heater P179 6.3 5.3 Fugitives P181 28.9 Condensate Loadout P182 43.3 Condensate Tanks P183 18.0 Superior 474HP Engine CIG-S-2 22.9 22.9 4.6 Total Facility Potential to Emit 313.9 357.6 189.3 Actual Emissions(5/09-4/10) 216.2 264.7 111.1 EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. Engines — The Reg 7 requirement to install control equipment was included in the permit. The requirements from NESHAP Subpart ZZZZ were also added to the permit. The serial numbers were corrected for AOS executions. Hot Oil Heater — The annual emission limits for SOx, VOC, and PM were removed as the PTE is below reporting thresholds. The emission factors were updated with the most current version from AP-42 and the annual emissions limits adjusted accordingly. Other— The Reg 7 requirement to install control equipment on the dehy was added to the permit. The dehy's capacity was corrected and emissions limitations lowered. The two points for fugitive emissions from equipment leaks was combined and the annual emissions limitation increased in accordance with the most recent component count. Additional condensate tanks were added to the permit and the annual emission and condensate throughput limit was increased accordingly for both the tanks and loadout. 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 95OPWE039 DCP Midstream — Spindle Gas Plant Weld County Source ID 1230015 Prepared by Bailey Smith June -August, 2011 Purpose 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 Spindle Plant. The previous Operating Permit for this facility was issued on May 1, 1999, was last revised on June 26, 2002 and expired on May 1, 2004. 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 renewal application submitted on January 13, 2009, previous inspection reports and various email correspondence 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.cdphe.state.co.us/ap/Titlev.html. 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. II. Description of Source This plant is classified as a natural gas processing plant as set forth under Standard Industrial Classification 1321. The Spindle Gas Processing Plant consists of a gas processing skid and a fractionation assembly. The gas processing skid utilizes straight refrigeration coupled with cryogenic expander processes to recover natural gas liquid (NGL) mixtures from the inlet gas stream. The NGL stream is sent to the fractionation 123/0015 Page 1 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document— Renewal 1 assembly to make various fuel products. A high Btu content methane/ethane residue gas stream is created by the removal of the NGL. The residue gas stream is recompressed and routed to the sales pipeline. A triethylene glycol (TEG) dehydration system operates to dehydrate a slip stream of the residue gas used to regenerate the mole sieves. The mole sieves function to dehydrate the inlet gas. The fractionation assembly separates the NGL product from the gas plant into pure streams consisting of ethane, propane, and butane/gasoline mix (BG Mix). The ethane is recompressed and routed to the pipeline. The propane and BG mix are each stored in pressurized bullet tanks for transport off-site by truck. This Title V Operating Permit for the Spindle Plant also addresses the adjacent Spindle- CIG Booster Station previously owned by Colorado Interstate Gas, Inc. There are twelve (12) engines powering natural gas compressors operating in inlet, residue, refrigeration or air compressor service. As noted previously, one TEG dehydration unit operates to remove the water from the residue gas used to regenerate the mole sieves. The site also operates with a 15 million Btu per hour hot oil heater, one condensate loadout rack, and four (4) 300 barrel condensate storage tanks. Fugitive VOC emissions from the entire facility are subject to the leak control provisions of Subpart KKK. The plant is located west of Fort Lupton in Weld County, Colorado. 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 affected states within 50 miles of the plant. Rocky Mountain National Park is a Federal Class I designated area within 100 kilometers of the plant. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC and 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 (Potential to Emit of > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. This facility is categorized as a PSD major stationary source (Potential to Emit > 250 Tons/Year) for NOx and CO. Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) or a modification which is major by itself (Potential to Emit of > 250) 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. 123/0015 Page 2 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document—Renewal 1 Emissions (in tons/yr) at the facility are as follows: Emission Unit NOx CO VOC Waukesha 1232HP Engine P160 39.6 39.6 9.7 Waukesha 1232HP Engine P161 39.6 39.6 9.7 Waukesha 1232HP Engine P162 23.8 39.6 9.7 Waukesha 1232HP Engine P163 23.8 23.8 6.0 Waukesha 1000HP Engine P164 19.3 38.6 9.7 Waukesha 1000HP Engine P165 39.6 39.6 9.7 Waukesha 1232HP Engine P166 39.6 39.6 9.7 Caterpillar 230HP Engine P168 5.0 5.0 2.2 Waukesha 1000HP Engine P169 19.3 29.0 9.7 Superior Ajax 1215HP Engine P170 23.5 17.6 11.7 Superior 600HP Engine P171 11.6 17.4 5.8 Weatherford Dehy P178 0.9 Hot Oil Heater P179 6.3 5.3 Fugitives P181 28.9 Condensate Loadout P182 43.3 Condensate Tanks P183 18.0 Superior 474HP Engine CIG-S-2 22.9 22.9 4.6 Total Facility Potential to Emit 313.9 357.6 189.3 Actual Emissions (5/09 -4/10) 216.2 264.7 111.1 Greenhouse Gases Greenhouse gas emissions from this facility are less than 100,000 TPY CO2e. Future modifications greater than 100,000 TPY CO2e may be subject to regulation. Compliance Assurance Monitoring Pre-controlled NOx and CO emissions from each of the eight (8) Waukesha Model L- 7042 GSI engines are above the major source level. The control devices on the engines are used to meet their NOx, and CO emission limitations, therefore CAM applies to these units. 123/0015 Page 3 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document—Renewal 1 III. Discussion of Modifications Made Source Requested Modifications The source has submitted the following information in relation to the renewal operating permit. Mod 1 (4/14/2003): APEN received requesting a change in emissions limitation for engine P168/C217. Renewal (5/1/2003): The application requested the removal of the requirement to conduct Methane/Ethane composition analysis. DCP justified that the results of such analyses have shown little fluctuation in the gas composition. The renewal application also requested the notification period for the replacement AOS be extended to 14 days. Amendment (6/23/2003): The application was amended to correct several clerical errors. Mod 2 (10/20/2004): The minor modification application requested a change in emission factors for the condensate loadout from 4.42 lb VOC/1000 gallons to 5.76 lb/1000 gallons. There were no requested changes to the emissions or throughput limits. Mod 3 (11/22/2004): DCP submitted a construction permit application on October 20, 2004 for several atmosphere condensate tanks that were previously exempt from permitting. This modification added the four condensate tanks to the operating permit with a throughput of 4.467 Mgal/yr and emission of 4.7 tpy VOC. Mod 4 (3/25/2005): An APEN was submitted for P170/C212, a Superior 1215 HP lean burn engine. The APEN requested lower emission limits accounting for the oxidation catalyst, which was installed pursuant to Regulation No. 7 Section XVI.A.2. Mod 5 (4/28/2005): APEN received requesting a change in emission limits for the glycol dehydrator. The change in emissions is a result of installed control equipment. The APEN also changed the design capacity for the unit. Mod 6 (8/24/2005): Requested to combine the two fugitive emissions points, P181 (2.5 tpy VOC) and P181A (7.8 tpy) which are both subject to Subpart KKK. Also requested that emissions for the combined point increase from 10.3 tpy to 11.6 tpy. The Division notified the source that the application was incomplete. Additional information was not provided, so the previous limits remained in effect. Mod 7 (7/10/2006): This modification was received by the Division on March 27, 2007 and requested a 6 Mgal/yr condensate throughput limit for both the condensate tanks and loadout. The modification resulted in a tank emissions increase from 4.7 tpy VOC to 6.3 tpy and loadout emissions increase from 13.8 tpy to 17.28 tpy. Admin(4/2/2008): An administrative modification to update the responsible official was submitted on April 2, 2008. Mod 8 (4/30/2008): APEN received for AOS permanent replacement for engine P164/C139. The APEN requested emissions for the replacement engine lower than 123/0015 Page 4 of 11 DCP Midstream —Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document— Renewal 1 original unit. The requested emission limitations comply with the requirements in Reg 7 Section XVII.E.2 for relocated engines. Mod 9 (4/21/2009): APEN received for AOS permanent replacement for engine P162/C138. The APEN requested emissions for the replacement engine lower than original unit. The requested emission limitations comply with the requirements in Reg 7 Section XVII.E.2 for relocated engines. COC (4/24/2009): Compliance Order on Consent (Case Nos. 2009-207) was issued after a 2008 explosion on site that damaged an engine. The COC allowed DCP to operate a temporary flare to control condensate stabilization emission until the electrical system was repaired and to immediately replace the damaged engine with a replacement that reduced emissions. Mod 10 (7/31/2009): This minor modification requested a condensate throughput increase from 6 Mgal/yr (per Mod 7 requested increase) to 18 Mgal/yr for both the tanks and the loadout. The emission calculations used emission factors inconsistent with Mod 2 and Mod 3. The Division considers this change in methodology on the submitted supporting calculations a requested change. Accordingly, the tank emissions limit increased from 6.3 tpy VOC to 17.96 tpy and the loadout emission limit increased from 17.28 tpy to 43.33 tpy. Cancellation (6/21/2010): Request to cancel APEN for engine P167/C150. Mod 11 (7/19/2010): A minor modification to the fugitive emissions requested a VOC emissions limit increase to 28.9 tons/yr. The supporting material identified this change as a result in component count and a recent gas analysis. This modification treated the fugitive emissions as a single point, as requested in the incomplete Mod 6 application. The Division is considering this a new request to combine the points. Mod 12 (8/19/2010): Request to roll in Construction Permit 09WE0195 into the Title V permit, with exception of MACT Subpart ZZZZ conditions. This construction permit was issued for replacement of the damaged engine, P163/C147, per the COC. Mod 13 (3/17/2011): This minor modification requested a change in the site horsepower rating (and brake specific fuel consumption) for several engines and a small throughput increase from 78.6 MMScf/yr to 78.66 MMScf/yr. The application also included updated serial numbers for several replacement engines. AOS: In addition to the above modifications, the alternative operating scenario for replacing engines has been exercised many times since the last renewal. DCP has informed the Division of these replacements and associated applicable requirements for each of the replacement engines. Note that while several modifications have been incorporated into the operating permit in one action, each of these modifications is considered a separate project for purposes of determining the applicability of PSD/NSR requirements. The source's requested modifications were addressed as follows: Page following cover page 123/0015 Page 5 of 11 DCP Midstream —Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document— Renewal 1 • Revised the responsible official and permit contact information in accordance with information submitted on April 2, 2008. • The change in company name from Duke Energy Field Services to DCP Midstream, LP was reflected in the permit. Section I — General Activities and Summary • The most recent version of the AOS provisions has been included. This version requires notification within fourteen days of commencing operation of the replacement engine. • The serial numbers for the engines that have been replaced under the AOS was updated. These serial numbers are listed in the summary of emissions units table. The horsepower listed in this table has also been updated in accordance with Mod 13. Section II — Specific Permit Terms • The extended gas analysis requirement will remain in the permit. Periodic gas analyses are necessary to monitor compliance with emissions limitations. • Set the condensate loadout emission factor to 4.81 lb/1000 gallons loaded based on the most recent AP-42 equation parameters. • Engine P167/C150 was removed from the permit per the cancellation letter. • The emission limitations were lowered for engine P168/C217, P171/C212, P164/C139 and P162/P138 as requested in Mod 1, Mod 4, Mod 8, and Mod 9, respectively. • Changed design capacity for the glycol dehydrator from 15 MMscf/day to 10 MMScf/day and lowered emission limits to reflect control equipment in accordance with Mod 5. Note that the flare used for secondary control is not subject to the requirements in § 60.11 or § 63.11 since the flare is not used to comply with NSPS or MACT standards. • The condensate tanks were added to the permit as requested in Mod 3. The emissions and throughput limits were set in accordance with values requested in Mod 7. The tanks have potential uncontrolled emissions of 17.96 tons per year and are therefore exempt from Reg 7, Section XII under XII.A.5, which exempts sources from the applicability condition in Section XII. • The increases to the condensate loadout throughput and emissions per Mod 7 have been included in the permit. • The COC required certain control efficiencies for the P163 engine. These requirements are embedded in the emissions factors and annual limits set forth by the permit. 123/0015 Page 6 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document— Renewal 1 • The fugitive emission points were combined as requested in Mod 11. The new single emission point has an emission limitation of 28.9 ton/yr and is subject to the requirements of NSPS Subpart KKK. AIRS point 064 has been removed. • The construction permit 09WE0195 was rolled into the Title V permit as requested in Mod 12. The permit incorrectly identified the facility as major for hazardous air pollutants. The modification application submitted on August 19, 2010 specified that no control or testing requirements apply for area source. An amendment to NESHAP Subpart ZZZZ was published in the Federal Register on August 20, 2010 that applies to existing stationary spark ignition engines located at an area source. The appropriate NESHAP Subpart ZZZZ requirements applicable to the replacement engine P163 have been included in the Title V operating permit. The AIRS ID of engine P163, which was replaced per the COC, was updated. The emission limitations were changed per Colorado Construction Permit 09WE0195. All other requirements from construction permit 09WE0195 have been included in the Title V operating permit. • Engine emission factors in the calculation table in g/hp-hr were removed. The emission factors are based on a lb/MMBtu value. The appropriate emission factors to use in the emissions calculation equations are included in the specific condition table for each engine. Appendices • The most recent facility plot plan was included in Appendix A. • An updated list of insignificant activity, as submitted via e-mail on July 28, 2011, was included in Appendix A of the permit. 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: 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). 123/0015 Page 7 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document—Renewal 1 • Modified the language concerning postmarked dates for report submittals to reflect the Division's current standard language. Section I — General Activities and Summary • Revised the language in Condition 1.4 include current conditions that are state- only enforceable. • Updated Condition 3.1 (status of source with respect to NANSR and PSD requirements) to reflect Division's current standard language and current Regulation No. 3 citations. Section II — Specific Permit Terms • The underlying construction permit, 97WE0287, referenced throughout the Title V was never issued. The construction permit was never in effect and the source never received a copy of this document, therefore all references to the construction permit were removed from the Title V permit. Engines • The engine's annual emission and throughput limits were rounded to the tenths for consistency. • A requirement for monthly recording of hours of operation was added. This is a parameter necessary for calculating natural gas consumption of each engine. • The engines with a site rated horsepower greater than 500 HP are subject to the control equipment requirements in Reg 7 Sections XVI and XVII. The requirements in Section XVII are state-only and were streamlined from the permit. • Several engines were required to install control equipment pursuant to a Compliance Order on Consent (Case No. 1998-033). As mentioned in the technical review document for the original permit issuance, portable monitoring requirements should be included in the permit when the engine controls and new permit limits were added. The permit was modified on November 19, 2001 to incorporate the controls and did not include portable monitoring requirements where applicable. This oversight was corrected and the appropriate monitoring requirements were included. The Division considers quarterly monitoring adequate periodic monitoring for these engines. The semi-annual monitoring interval was kept for all engines that were subject to portable monitoring requirements in the last issuance of the Title V permit. • An amendment to NESHAP Subpart ZZZZ was published in the Federal Register on August 20, 2010 and applies to existing stationary spark ignition engines located at an area source. The appropriate NESHAP Subpart ZZZZ requirements applicable to the engines have been included in the Title V operating permit. 123/0015 Page 8 of 11 DCP Midstream —Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document—Renewal 1 Hot Oil Heater • The annual emissions limitations for SOx,VOC, and PM were removed. The potential uncontrolled emissions were below the de minimus reporting levels. • The emission factors for this unit were based on an outdated version of AP-42. The most recent emission factors from AP-42 were included in the permit and new limits were set in accordance with those emission factors. • This unit was previously identified as not subject to the requirements of NSPS Subpart Dc. The explanation for this determination was that APENs had identified the unit as constructed at an unknown date prior to the Subpart Dc applicability date of June 9, 1989. APENs filed on March 3, 1997, April 3, 2002, and February 16, 2007 all report the unit as installed in 1994 and therefore the heater is applicable to the requirements of NSPS Subpart Dc. The appropriate requirements were included in the renewal permit. • This heater is subject to the NSPS General Provisions in Reg 6 and these provisions have been included in the permit. • The hot oil heater is also subject to Reg 6 requirements for fuel-burning equipment in Part B, Section II.C. These requirements for PM emissions and opacity are equivalent to the Reg 1 requirements; however, they do not apply during periods of startup, shutdown and malfunction. Therefore, the less stringent Reg 6 requirements were streamlined from of the permit. Dehy • The Reg 7 Section XVII.D requirement to install control equipment was added to the permit and identified as a state-only condition. • The Division's standard language for glycol dehydrators was included in the renewal permit. The maximum BTEX levels were set using the values used in the GLYCaIc run that was used to set the permit limits. Fugitive • Removed the requirement to submit a NSPS KKK summary report. This report has already been submitted. Also removed the requirement in Condition 7.3.2 to record startup, shutdown and malfunctions in § 60.7. NSPS Subpart KKK in § 60.635(a) references § 60.486(k), which indicates that § 60.7(b) does not apply. Loadout • The statement to correct VOC emissions for nonmethane nonethane VOC was removed. VOC is already exclusive of methane and ethane emissions. 123/0015 Page 9 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document— Renewal 1 Other • Initial compliance testing requirements in Condition 9 were removed. The time period for which compliance testing was required has since passed. • Condition 10 regarding documents required was removed. The condition did not include specific requirements nor did it reference which documents it applied to. • Condition 11 on reporting was removed. This language is now included on the page following the permit's cover page. • The calculations in Condition 12 were removed and included under each specific emission unit. The conversion equations for stack flow data and portable monitoring calculation were removed from the permit. This information can be found on the portable monitoring info on the website. • Removed the upset and breakdown in Condition 13. This is already included in the General Permit Conditions, Section IV of the permit under Condition 3.g. • Updated portable monitoring requirements in Condition 14 with the most current Division approved language. • Catalytic converter Condition 15 and Condition 16 regarding the air/fuel ratio controller were removed. Management practices and monitoring requirements for the control equipment are included in the specific conditions under each emission unit. The standard Title V language was included, which requires parametric monitoring on a monthly basis. • The opacity requirements in Condition 17 were moved under the specific applicable emission units. Additionally, the permit did not identify all applicable opacity requirements. Specific activities under which the 30% opacity standard applies are: building a new fire, cleaning of fire boxes, soot blowing, startup, any process modification, or adjustment or occasional cleaning of control equipment. Based on engineering judgment the Division considers that building a new fire, cleaning of fire boxes and soot-blowing does not apply to the operation of an internal combustion engine. Although the engines have a control device, it does not control PM emissions and therefore would not affect opacity emissions. Process modifications may apply to the engines; however, based on engineering judgment, the Division believes that such activities would be unlikely to occur for longer than six minutes. Therefore, the 30% opacity requirement has been included in the operating permit only for startup of the units. However, compliance with the opacity limits is still presumed given that natural gas is the only fuel used in the engines. Section III — Permit Shield • Updated the Reg 3 Citation for the permit shield 123/0015 Page 10 of 11 DCP Midstream—Spindle Gas Plant Operating Permit No. 95OPWE039 Technical Review Document- Renewal 1 • The renewal application requested many non-applicable requirements to be identified in the permit shield. Some of these non-applicable requirements were in fact applicable. Additionally, there were several identified non-applicable requirements that were obvious and unnecessary to be identified in the permit. The purpose of the permit shield is to clarify situations where it is possible the stated conditions could apply. Clearly non-applicable requirements were not included in the permit. • The permit shield condition from Subpart Dc for the hot oil heater was removed. This unit was not in place prior to the Subpart Dc applicability date of June 9, 1989 as discussed above. Section IV— General Permit Conditions • Updated the general permit conditions to the current version (11/16/2010). Appendices • Updated Appendices B and C (Monitoring and Permit Deviation Reports and Compliance Certification Reports) to the newest versions (2/20/2007). • EPA's mailing address was revised in Appendix D. • Cleared the list of modifications from Appendix F related to the previous issuance. • The most recent AOS applicability reports were added in Appendix H. • CAM requirements for the eight Waukesha Model L-7042 GSI engines were added to Appendix I. 123/0015 Page 11 of 11 . OF 'fQlp 444 ict* ,2%- v / 4716 Vic Q 187G a‘ Colorado Department of Public Health and Environment OPERATING PERMIT DCP Midstream, LP Spindle Gas Processing Plant First Issued: May 1, 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Spindle Gas Processing OPERATING PERMIT NUMBER Plant FACILITY ID: 1230015 95OPWE039 RENEWED: DRAFT EXPIRATION DATE: DRAFT MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: DCP Midstream, LP Sec 34, T2N, R67W 370 17`" Street, Suite 2500 / mile north of Highway 52, Denver, CO 80202 3'h miles west of Ft Lupton, CO Weld County INFORMATION RELIED UPON Operating Permit Renewal Application Received: May 1, 2003 And Additional Information Received: April 4, 2003, June 23, 2003, October 20, 2004, November 22, 2004, March 25, 2005, April 28, 2005, August 24, 2005, July 10, 2006, March 27, 2007, April 2, 2008, April 30, 2008, April 21, 2009, April 24, 2009, July 31, 2009, June 21, 2010, July 19, 2010, August 19, 2010 and March 17, 2011 Nature of Business: Natural Gas Liquids Processing and Gathering Primary SIC: 1321 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Joseph Kuchinski Name: Wesley Hill Title: VP Area Operations Title: Senior Environmental Specialist Phone: (970) 378-6345 Phone: (303) 595-3331 SUBMITTAL DEADLINES Semi-Annual Monitoring Period: January 1 —June 30, July 1 —December 31 Semi-Annual Monitoring Report: August 1, 2012 & February 1, 2013 and subsequent years Annual Compliance Period: January 1 —December 31 Annual Compliance Certification: February 1, 2013 and subsequent years Note that the Semi-Annual Monitoring Reports and 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. Table of Contents: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2 3. Accidental Release Program (112(r)) 2 4. Alternative Operating Scenarios (ver 10/1/2011) 2 5. Compliance Assurance Monitoring (CAM) 8 6. Summary of Emission Units 9 SECTION II - Specific Permit Terms 11 1. Natural Gas Fired Internal Combustion Engines with AFR and NSCR> 500 HP 11 P160/C136—Waukesha 1232 HP Compressor Engine 11 P161/C137— Waukesha 1232 HP Compressor Engine 11 P165/C140—Waukesha 1000 HP Compressor Engine 11 P166/C141 —Waukesha 1232 HP Compressor Engine 11 P162/C138—Waukesha 1232 HP Compressor Engine 12 P163/C147 —Waukesha 1232 HP Compressor Engine 13 P164/C139—Waukesha 1000 HP Compressor Engine 14 P169/C153 —Waukesha 1000 HP Compressor Engine 15 P171/C212 — Superior 600 HP Compressor Engine 16 2. Natural Gas Fired Internal Combustion Engines Equipped with AFR and NSCR < 500 HP 28 CIG-S-2/C221 — Superior 474 HP Compressor Engine 28 P 168/C217 —Catepillar 230 HP Compressor Engine 29 3. Natural Gas Fired Internal Combustion Engines with Oxidation Catalyst 34 P170/C215 — Superior Ajax 1215 HP Compressor Engine 34 4. P178 - Triethylene Glycol Regeneration Unit 40 5. P179 - 15 MMBtu/Hr Natural Gas Fired Hot Oil Heater 42 6. P181 - Fugitive VOC Emissions from Equipment Leaks 44 7. P182 - Condensate Tank Truck Loadout 46 8. P183 — Stabilized Condensate Storage Tanks 47 9. Portable Monitoring (ver 6/1/06) 48 SECTION III - Permit Shield 50 1. Specific Conditions 50 2. General Conditions 50 3. Stream-lined Conditions 51 SECTION IV- General Permit Conditions (ver 11/16/2010) 52 1. Administrative Changes 52 2. Certification Requirements 52 3. Common Provisions 52 4. Compliance Requirements 56 5. Emergency Provisions 57 6. Emission Controls for Asbestos 57 7. Emissions Trading, Marketable Permits, Economic Incentives 57 8. Fee Payment 57 9. Fugitive Particulate Emissions 58 10. Inspection and Entry 58 11. Minor Permit Modifications 58 12. New Source Review 58 13. No Property Rights Conveyed 58 14. Odor 58 Table of Contents: 15. Off-Permit Changes to the Source 58 16. Opacity 59 17. Open Burning 59 18. Ozone Depleting Compounds 59 19. Permit Expiration and Renewal 59 20. Portable Sources 59 21. Prompt Deviation Reporting 59 22. Record Keeping and Reporting Requirements 60 23. Reopenings for Cause 61 24. Section 502(b)(10) Changes 61 25. Severability Clause 61 26. Significant Permit Modifications 62 27. Special Provisions Concerning the Acid Rain Program 62 28. Transfer or Assignment of Ownership 62 29. Volatile Organic Compounds 62 30. Wood Stoves and Wood burning Appliances 63 APPENDIX A - Inspection Information 1 1. Directions to Plant: 1 2. Safety Equipment Required 1 3. Facility Plot Plan: 1 4. List of Insignificant Activities. APPENDIX B 1 Reporting Requirements and Definitions 1 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 1 Required Format for Annual Compliance Certification Reports 1 APPENDIX D Notification Addresses 1 APPENDIX E Permit Acronyms 1 APPENDIX F NSPS KKK Example Report Format 1 APPENDIX G Permit Modifications 1 APPENDIX H Engine AOS Applicability Reports 1 APPENDIX I Compliance Assurance Monitoring Plan 1 Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit • Spindle Gas Processing Plant Permit# 95OPWE039 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 This plant is classified as a natural gas processing plant as set forth under Standard Industrial Classification 1321. The Spindle Gas Processing Plant consists of a gas processing skid and a fractionation assembly. The gas processing skid utilizes straight refrigeration coupled with a cryogenic expander process to recover natural gas liquid (NGL) mixtures from the inlet gas stream. The NGL stream is sent to the fractionation assembly to make various fuel products. A high Btu content methane/ethane residue gas stream is created by the removal of the NGL. The residue gas stream is recompressed and routed to the sales pipeline. A triethylene glycol (TEG) dehydration system operates to dehydrate a slip stream of the residue gas used to regenerate the mole sieves. The mole sieves function to dehydrate the inlet gas. The fractionation assembly separates the NGL product from the gas plant into pure streams consisting of ethane, propane, and butane/gasoline mix (BG Mix). The ethane is recompressed and routed to the pipeline. The propane and BG mix are each stored in pressurized bullet tanks for transport off-site by truck. This Title V Operating Permit for the Spindle Plant also addresses the adjacent Spindle-CIG Booster Station previously owned by Colorado Interstate Gas, Inc.. There are twelve (12) engines powering natural gas compressors operating in inlet, residue, refrigeration or air compressor service. As noted previously, one TEG dehydration unit operates to remove the water from the residue gas used to regenerate the mole sieves. The site also operates with a 15 million Btu per hour hot oil heater, one condensate loadout rack, and four (4) 300 barrel condensate storage tanks. Fugitive VOC emissions from the entire facility are subject to the leak control provisions of NSPS Subpart KKK. The plant is located west of Fort Lupton in Weld County, Colorado. 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 affected states within 50 miles of the plant. Rocky Mountain National Park is a Federal Class I designated area 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 for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permit(s): 09WE0195. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 2 1.4 All conditions in this permit are enforceable by the US Environmental Protection Agency (EPA), Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II, Condition 4.6 and Section IV, Conditions 3.d, 3.g (last paragraph), 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Record keeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. 2. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC and 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(Potential to Emit of> 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. This facility is categorized as a PSD major stationary source (Potential to Emit > 250 Tons/Year for NOx and CO. Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) or a 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. 2.2 There are no other Operating Permits associated with this plant for the purposes of determining the applicability of the PSD regulations. 3. Accidental Release Program (112(r)) 3.1 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. Alternative Operating Scenarios (ver 10/1/2011) 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. 4.1 Engine Replacement Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 3 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), 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. 4.1.1 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 NQ 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) 4.1.2 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 1 without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 4 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. 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. 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. 4.2 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). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 5 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 (lb/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 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 4.3 Applicable Regulations for Permanent Engine Replacements 4.3.1 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 PKo attainment/maintenance area, RACT applies to PM 1p 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 1o: Use of natural gas as fuel Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 6 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. 4.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. 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 Construction or Emission Standards in G/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500<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 2.1.2. 4.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 7 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 to the requirements of 40 CFR Part 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 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, § 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 Jill 4.3.4 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. 4.4 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 8 Table 1 Internal Combustion Engine Information for the AOS Emission Replacement Engine Periodic Subject Point Monitoring? to CAM? P160 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C136 4-cycle,Standard Rich Burn w/AFR controller P161 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C 137 4-cycle,Standard Rich Burn w/AFR controller P162 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C 138 4-cycle,Standard Rich Burn w/AFR controller P163 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C147 4-cycle,Standard Rich Burn w/AFR controller P164 Waukesha Model L-7042 1000 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C139 4-cycle, Standard Rich Burn w/AFR controller PI65 Waukesha Model L-7042 1000 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C140 4-cycle, Standard Rich Burn w/AFR controller P166 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine, turbocharged, Quarterly Yes C141 4-cycle, Standard Rich Burn w/AFR controller P168 Caterpillar Model G-342 NA, 230 HP, standard rich bum, turbocharged, low Quarterly No C217 emission design,natural gas fired engine w/AFR P169 Waukesha Model L-7042 GU, 1000 HP, standard rich bum, turbocharged, 4- Semi-annually Yes C153 cycle,natural gas fired engine w/AFR P170 Superior Ajax Model 8SGTB, 1215 HP, lean burn,turbocharged, natural gas fired Quarterly No C2 I5 engine w/oxidation catalyst and AFR P171 Superior Model 6G825, 600 HP, standard rich burn, turbocharged, natural gas Semi-annually No C212 fired engine w/AFR&NSCR CIG-S-2 Superior Model 6G825, 474 HP, standard rich bum, natural gas fired engine w/ Quarterly No C221 AFR 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: Pre-controlled NOx and CO emissions from each of the eight (8) Waukesha Model L-7042 GSI engines are above the major source level. The control devices on the engines are used to meet their NOx, and CO emission limitations, therefore CAM applies to these units. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 9 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: AIRS Plant ' .Description.. Size* Pollution Construction Stack Identifier Control Device Permit Number 051 P160 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective None C136 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle, Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 351321 052 P161 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective C137 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle, Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 350086 053 P162 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective C138 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Bum w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 367248 081 P163 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective 09WE0195 C147 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle, Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 286440 055 P164 Waukesha Model L-7042 GSI Natural Gas Fired 1000 HP Non-Selective None C139 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle, Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 335792 056 P165 Waukesha Model L-7042 GSI Natural Gas Fired 1000 HP Non-Selective C140 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 240413 057 P166 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective C141 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 260958 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 10 MRS Plant Description Size* Pollution Construction Stack Identifier Control Device Permit Number 059 P I 68 Caterpillar Model G-342 NA Natural Gas Fired 230 HP Non-Selective None C217 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle, Standard Rich Burn; low Reduction emissions design;equipped w/air/fuel ratio controller;powering a residue gas compressor. SN 71B03385 060 P169 Waukesha Model L-7042 GU Natural Gas Fired 1000 HP Non-Selective C153 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 277151 061 P170 Superior Ajax Model 8SGTB Natural Gas Fired 1215 HP Oxidation C215 Internal Combustion Reciprocating Engine, Catalyst turbocharged,4-cycle,Lean Burn,low NOx design; equipped w/oxidation catalyst and air/fuel ratio controller;powering a low pressure residue gas compressor. SN 315909 062 P I71 Superior Model 6G825 Natural Gas Fired Internal 600 HP Non-Selective C212 Combustion Reciprocating Engine,turbocharged,4- Catalytic cycle, Standard Rich Burn;equipped w/air/fuel ratio Reduction controller;powering a low pressure residue gas compressor. SN 19941 063 P178 Weatherford Natural Gas Dehydration System using 10 Condenser triethylene glycol;gas pressure at 850 PSI;gas MMscf/day Reboiler/Flare temperature of 95°F. SN 34418 064 P179 OPF-HMO natural gas fired heater for heating hot oil; 15 None Serial No.J87426 MMBtu/Hr 034 P181 Gas Plant Fugitive Emissions N/A None 066 P182 Condensate Truck Load-out N/A None 067 P183 Four(4)Condensate Storage Tanks 300 bbl each None 075 CIG-S-2 Superior Model 6G825 Natural Gas Fired Internal 474 HP Non-Selective C-221 Combustion Reciprocating Engine,4-cycle, Standard Catalytic Rich Bum;powering a natural gas compressor. Reduction SN 18653 * All horsepower(HP)values are site rated values as reported in APEN submittals Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 11 SECTION II - Specific Permit Terms 1. Natural Gas Fired Internal Combustion Engines with AFR and NSCR> 500 HP P160/C136—Waukesha 1232 HP Compressor Engine P161/C137—Waukesha 1232 HP Compressor Engine P165/C140--Waukesha 1000 HP Compressor Engine P166/C141 —Waukesha 1232 HP Compressor Engine Note: These limitations apply to each engine. Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (1b/MMBtu) Method Interval NOx 1.1 39.6 TPY 0.968 Recordkeeping& Monthly Calculation CO 39.6 TPY 0.968 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.7 MMscf/yr Consumption Btu Content of 1.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1,7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 12 P162/C138—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 23.8 TPY 0.582 Recordkeeping& Monthly Calculation CO 39.6 TPY 0.968 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.7 MMscf/yr Consumption Btu Content of 1.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1.7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 13 P163/C147—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (Ib/MMBtu) Method Interval NOx 1.1 23.8 TPY 0.473 Recordkeeping& Monthly Calculation CO 23.8 TPY 0.473 12 month rolling VOC 1.2 6.0 TPY 0.119 Natural Gas 1.3 96.9 MMscf/yr Consumption Btu Content of 1.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1.7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 14 P164/C139—Waukesha 1000 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 19.3 TPY 0.472 Recordkeeping& Monthly Calculation CO 38.6 TPY 0.945 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.6 MMscf/yr Consumption Btu Content of 1.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1.7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 15 P169/C153—Waukesha 1000 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 19.3 TPY 0.472 Recordkeeping& Monthly Calculation CO 29.0 TPY 0.708 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.6 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1.7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 16 P171/C212 —Superior 600 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 11.6 TPY 0.569 Recordkeeping& Monthly Calculation CO 17.4 TPY 0.853 12 month rolling VOC 1.2 5.8 TPY 0.284 Natural Gas 1.3 39.2 MMscf/yr Consumption Btu Content of 1.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 1.7 Limit Formaldehyde See Condition 1.7 ZZZZ concentrations to 2.7 ppmvd @ 15%O2 or Reduce Formaldehyde by 76% NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 17 1.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations stated in the tables above (Compliance Order On Consent Case Nos. 2009- 007 and Colorado Construction Permit 09WE0195 for engine P163/C147). Compliance with the emission limitations shall be monitored as follows: 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. 1.1.1 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 1.3) and the Btu content of the natural gas (as required by Condition 1.4) in the equation below tons/mo=JEF(lbs/MMBtu)x fuel use(MMscf/year)x heat content of fuel(MMBtu/MMscf)l 2000 lbs/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. If the results of the portable analyzer testing conducted under the provisions of Condition 1.1.2 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. 1.1.2 Portable monitoring shall be conducted for semi-annually engines P169/C153 and P171/C212 and quarterly for all other engines as required by Condition 9. 1.2 Volatile Organic Compounds (VOC) emissions from each engine shall not exceed the annual emission limitation stated in the tables above (Colorado Construction Permit 09WE0195 for engine P163/C147). Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor the monthly natural gas consumption (as required by Condition 1.3) and the Btu content of the natural gas (as required by Condition 1.4) in the equation below: tons/mo=[EF(lbs/MMBtu)x fuel use(MMscf/year)x heat content of fuel(MMBtu/MMsct)1 2000 lbs/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. 1.3 Natural gas consumption from each engine shall not exceed the above limitation (Colorado Construction Permit 09WE0195 for engine P163/C147). 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 1.5. Allocation of natural gas to each engine will be calculated using the following calculation: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 18 (Design Heat Rate x Hours of Operation x Site Rated Horsepower) do dUei engine Fuel Consumption= x Total Engine Fuel Use (Design Heat Rate x Hours of Operation x Site Rated Horsepower)e,Lh engine 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. 1.4 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 lower heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.5 Hours of operation of each engine shall be recorded monthly. Records shall be made available for Division review upon request. 1.6 Visible emissions shall not exceed 20% opacity (Colorado Construction Permit 09WE0195 for engine P163/C147 and 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. 1.7 (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 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. 1.7.1 This facility must comply with the applicable limitations no later than October 19, 2013. (§63.6595(a)(1)) 1.7.2 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). 1.7.3 For the non-selective catalytic reduction device installed to meet the requirement in Condition 1.8.2, the following operating requirements shall apply: (Table lb of Subpart ZZZZ, Item 1) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 19 1.7.3.1 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 1.7.3.2 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 1.7.4 Initial performance tests must be conducted within 180 days after the compliance date specified in Condition 1.7.1 according to the provisions of§63.7(a)(2). (§63.6612(a)) 1.7.4.1 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(b)) 1.7.5 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: 1.7.5.1 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 1.7.5.2 Measure O2 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 1.7.5.3 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 1.7.5.4 Measure formaldehyde at the inlet and the outlet of the control device a. Formaldehyde concentration must be at 15 percent O2, dry basis. Results of this test consist of the average of the three 1-hour or longer runs Demonstrating Compliance 1.7.6 Initial compliance with the requirement to limit concentration or reduce formaldehyde emissions in Condition 1.7.2 is demonstrated by achieving the following: 1.7.6.1 The average reduction of emissions of formaldehyde determined from the initial performance test is equal to or greater than the required formaldehyde percent 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 1.7.6.2 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 20 7.a.ii or 10.a.ii) and 1.7.6.3 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) 1.7.7 Demonstrate continuous compliance with the limitations in Condition 1.7.2 using the following methods described in Table 6 of Subpart ZZZZ. (§63.6640(a)): 1.7.7.1 Conduct performance tests according to Condition 1.7.5 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 1.7.7.2 Collect the catalyst inlet temperature data according to §63.6625(b); (Table 6 of Subpart ZZZZ, Item 10.a.ii) and 1.7.7.3 Reduce these data to 4-hour rolling averages; (Table 6 of Subpart ZZZZ, Item 10.a.iii) and 1.7.7.4 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature; (Table 6 of Subpart ZZZZ, Item 10.a.iv) and 1.7.7.5 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 1.7.8 Submit compliance reports semiannually according to the requirements in §63.6650(b). The report must contain the following: 1.7.8.1 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) 1.7.8.2 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 Subpart ZZZZ, Item 1.b) 1.7.8.3 If there was a malfunction during the reporting period, include the information in §63.6650(c)(4). (Table 7, Item l.c) 1.7.9 Submit a Notification of Compliance Status according to §63.6645(h). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 21 1.7.10 Submit all notifications that are applicable in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), (g) and (h). (§63.6645(a)) 1.7.11 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 1.7.12 Compliance with the emission limitations and operating limitations in this subpart must be achieved at all times. (§63.6605(a)) 1.7.13 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 1.7.14 Comply with the monitoring, installation, collection, and maintenance requirements in §63.6625. 1.7.15 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)) 1.8 [Federal-Only] These engines are subject to the requirements in 40 CFR Part 63 Subpart 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: 1.8.1 Prohibited activities and circumvention in § 63.4. 1.8.2 Performance testing in§63.7. 1.8.3 Monitoring in §63.8. 1.8.4 Notification in §63.9. 1.8.5 Recordkeeping and reporting in §63.10. 1.9 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.3). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 22 1.9.1 For engine P171/C212 only, the pressure drop across the catalyst and the catalyst inlet temperature shall be monitored and recorded monthly. The catalyst inlet temperature shall be kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. When portable monitoring is scheduled, the above parameters shall be recorded during the portable monitoring event. 1.9.2 The millivolt reading (AFR) for each engine will be monitored and recorded monthly to assess the air to fuel ratio controller operating condition. During those months 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. 1.9.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for each engine during each portable monitoring event required by Condition 1.1.2. 1.10 These engines, except engine P171/C212, are subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the NOx and CO emission limitations in Condition 1.1. 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 eight (8) Waukesha compressor engines, P160/C136, P161/C137, P162/C138, P163/C147, P164/C139, P165/C140, P166/C141, and P169/C153. 1.10.1 Excursions, for purposes of reporting are as follows: 1.10.1.1 The permittee shall follow the CAM Plan provided in Appendix I and excursions for purposes of reporting are as follows: a. Any monthly pressure drop across the catalyst that is not within+ 2 inches of water 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 the first portable analyzer test, required by Condition 1.1.2, conducted after this revised permit issuance [date]. For a 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. b. Any daily engine exhaust (catalyst inlet) temperature reading that is less than 750°F or greater than 1250°F Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 1.10.2 Operation of Approved Monitoring Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 23 1.10.2.1 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(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.2.2Except 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 are 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). 1.10.2.3 Response to excursions or exceedances 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). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance 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). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 24 1.10.2.4After 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). 1.10.3 Quality Improvement Plan (QIP) Requirements 1.10.3.1 Based on the results of a determination made under the provisions of Condition 1.11.2.3.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). 1.10.3.2The 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). 1.10.3.3 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). 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 1.11.3.3.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). 1.10.3.4If 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 25 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). 1.10.3.5Following implementation of a QIP, upon any subsequent determination pursuant to Condition 1.11.2.3.b, 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). 1.10.3.6Implementation 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). 1.10.4 Reporting and Recordkeeping Requirements 1.10.4.1 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: 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 1.11.3 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, Part C, Section XIV). 1.10.4.2General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section IV, Condition 22.a through c. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 26 a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 1.11.3 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(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.5 Savings Provisions 1.10.5.1 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 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)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.5.2Nothing 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). I.10.5.3Nothing 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 27 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 28 2. Natural Gas Fired Internal Combustion Engines Equipped with AFR and NSCR < 500 HP CIG-S-2/C221 —Superior 474 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (1b/MMBtu) Method Interval NOx 2.1 22.9 TPY 1.12 Recordkeeping& Monthly Calculation CO 22.9 TPY 1.12 12 month rolling VOC 2.2 4.6 TPY 0.225 Natural Gas 2.3 39.2 MMscf/yr Consumption Btu Content of 2.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 2.5 Recordkeeping Monthly Opacity 2.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 2.7 Change filters and inspect spark See Condition 2.7 ZZZZ plugs,hoses and belts NESHAP Subpart A 2.8 See Condition 2.8 Parametric 2.9 See Condition 2.9 Monitoring • Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 29 P168/C217—Catepillar 230 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (1b/MMBtu) Method Interval NOx 2.1 5.0 TPY 0.672 Recordkeeping& Monthly Calculation CO 5.0 TPY 0.672 12 month rolling VOC 2.2 2.2 TPY 0.299 Natural Gas 2.3 14.3 MMscf/yr Consumption Btu Content of 2.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 2.5 Recordkeeping Monthly Opacity 2.6 Not to Exceed 200/0 Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 2.7 Change filters and inspect spark See Condition 2.7 ZZZZ plugs, hoses and belts NESHAP Subpart A 2.8 See Condition 2.8 Parametric 2.9 See Condition 2.9 Monitoring 2.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations stated in the tables above. Compliance with the emission limitations shall be monitored as follows: 2.1.1 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. 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 2.3) and the Btu content of the natural gas (as required by Condition 2.4) in the equation below tons/mo=LEF(lbs/MMBtu)x fuel use(MMscf/vear)x heat content of fuel(MMBtu/MMscf)j 2000 lbs/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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 30 If the results of the portable analyzer testing conducted under the provisions of Condition 2.1.2 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. 2.1.2 Portable monitoring shall be conducted quarterly as required by Condition 9. 2.2 Volatile Organic Compounds (VOC) emissions from each engine shall not exceed the annual emission limitation stated in the tables above. Monthly emissions shall be calculated by the end of the subsequent month using the above emission the monthly natural gas consumption (as required by Condition 2.3) and the Btu content of the natural gas (as required by Condition 2.4) in the equation below: tons/mo= [EF(Ibs/MMBtu)x fuel use(MMscf/vear)x heat content of fuel(MMBtu/MMscf)1 2000 lbs/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 Natural gas consumption from each engine shall not exceed the above limitation. 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 2.5. Allocation of natural gas to each engine will be calculated using the following calculation: (Design Heat Rate x Hours of Operation x Site Rated Horsepower)iaa+eiaaai engine Fuel Consumption= x Total Engine Fuel Use E(Design Heat Rate x Hours of Operation x Site Rated l lorsepower)eaeh engine 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. 2.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually 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 lower heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 2.5 Hours of operation of each engine shall be recorded monthly. Records shall be made available for Division review upon request. 2.6 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 31 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. 2.7 [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 (RICE), as follows: These requirements included in this Condition 2.7 are only federally enforceable. As of the date of revised permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on August 20, 2010 have not been adopted into Colorado Regulation No. 8, Part E by the Division 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. 2.7.1 This facility must comply with the applicable operating limitations no later than October 19, 2013. (§63.6595(a)(1)) Operational Requirements 2.7.2 The following requirements apply to each non-emergency, non-black start, four- stroke rich burn spark ignition stationary RICE < 500 HP: (40 CFR Part 63 Subpart ZZZZ Table 2d) 2.7.2.1 Change oil and filter every 1,440 hours of operation or annually, whichever comes first (Table 2d, item 9.a) a. Sources have the option to utilize an oil analysis program as described in §63.6625(i) in order to extend the specified oil change requirement in Condition 2.7.2.1. (Table 2d. footnote 1) 2.7.2.2 Inspect spark plugs every 1,440 hours of operation or annually, whichever comes first (Table 2d, item 9.b) 2.7.2.3 Inspect all hoses and belts every 1,440 hours of operation or annually, whichever comes first, and replace as necessary (Table 2d, item 9.c) 2.7.2.4 During periods of startup minimize the engine's time spent idle and minimize the engine's startup time to a period need for appropriate and safe loading of the engine, not to exceed 30 minutes. (Table 2d) 2.7.3 Operate and maintain the engine according to the manufacturer's emission-related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (§63.6625(e)(4)) General Requirements Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 32 2.7.4 Compliance with the emission limitations and operating limitations in this subpart must be achieved at all times. (§63.6605(a)) 2.7.5 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)) Continuous Compliance Requirements 2.7.6 Demonstrate continuous compliance with the operating limitations in Condition 2.6.2 using the work and management practices described in Condition 2.6.3. (§63.6640(a)) 2.7.7 Report each instance in which the maintenance requirements of Condition 2.6.2 were not met. These instances are deviations and must be reported according to the requirements of§63.6650. (§63.6640(b)) Notifications and Records 2.7.8 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)). 2.8 [Federal-Only] This engine is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as specified in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following: 2.8.1 Prohibited activities in § 63.4(a). 2.8.2 Circumvention in § 63.4(b) 2.9 Parameters associated with the air-to-fuel ratio controller (AFR) and non-selective catalyst reduction unit shall be monitored as follows: 2.9.1 The millivolt reading (AFR) will be monitored and recorded monthly to assess the air to fuel ratio controller operating condition. Recording of the millivolt reading shall be used to verify that the AFR controller is operated in accordance with the manufacturer's recommendations. 2.9.2 The pressure drop across the catalyst shall be monitored and recorded monthly. Operating Permit Number: 95OPWE039 FIRST ISSUED: May I, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 33 2.9.3 The catalyst inlet temperature shall be monitored and recorded monthly and kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. 2.9.4 When portable monitoring is scheduled, the above parameters in Conditions 2.9.1 through 2.9.3 shall be recorded during the portable monitoring event. 2.9.5 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 2.1.2. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 34 3. Natural Gas Fired Internal Combustion Engines with Oxidation Catalyst P170/C215- Superior Ajax 1215 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 3.1 23.5 TPY 0.606 Recordkeeping& Monthly Calculation CO 17.6 TPY 0.454 12 month rolling VOC 3.2 11.7 TPY 0,302 Natural Gas 3.3 74.5 MMscf/yr Consumption Btu Content of 3.4 ASTM, EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 3.5 Recordkeeping Monthly Opacity 3.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below 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 NESHAP Subpart 3.7 Limit CO concentrations to 47 See Condition 3.7 ZZZZ ppmvd @ 15%O2 or Reduce CO by 93% NESHAP Subpart A 3.8 See Condition 3.8 Control Device 3.9 See Condition 3.9 3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations stated above. Compliance with the emission limitations shall be monitored as follows: 3.1.1 Except as provided below, the emission factors listed have been approved by the Division and shall be used to calculate emissions. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 35 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 3.3) and the Btu content of the natural gas (as required by Condition 3.4) in the equation below tons/mo=JEF(lbs/MMBtu)x fuel use(MMscf/year)x heat content of fuel(MMBtu/MMscfl 2000 lbs/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. If the results of the portable analyzer testing conducted under the provisions of Condition 3.1.2 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. 3.1.2 Portable monitoring shall be conducted quarterly as required by Condition 9. 3.2 Volatile Organic Compounds (VOC) emissions shall not exceed the annual emission limitation stated above. Monthly emissions shall be calculated by the end of the subsequent month using the above emission the monthly natural gas consumption (as required by Condition 3.3) and the Btu content of the natural gas (as required by Condition 3.4) in the equation below: tons/mo=[EF(Ibs/MMBtu)x fuel use(MMscf/vear)x heat content of fuel(MMBtu/MMscf)l 2000 lbs/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 Natural gas consumption shall not exceed the above limitation. Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured no on the same day that run time hours have been recorded in accordance with Condition 3.5. Allocation of natural gas will be calculated using the following calculation: (Design Heat Rate x Hours of Operation x Site Rated Horsepower)individual engine Fuel Consumption= x Total Engine Fuel Use E(Design Heat Rate x Hours of Operation x Site Rated Horsepower)each engine 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. 3.4 The Btu content of the natural gas used to fuel the engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 36 content of the natural gas shall be based on the lower heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 3.5 Hours of operation shall be recorded monthly. Records shall be made available for Division review upon request. 3.6 Visible emissions shall not exceed 20% opacity 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 this engine. 3.7 [Federal-Only] This engine is 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: These requirements included in this Condition 3.7 are only federally enforceable. As of the date of revised permit issuance [DATE], the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on August 20, 2010 have not been adopted into Colorado Regulation No. 8, Part E by the Division 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. 3.7.1 This facility must comply with the applicable limitations no later than October 19, 2013. (§63.6595(a)(1)) 3.7.2 Carbon Monoxide (CO) emission shall be limited to 47 ppmvd at 15% O2 or reduced by 93 percent or more (Table 2d of Subpart ZZZZ, Item 8). 3.7.3 For the oxidizing catalytic reduction device installed to meet the requirement in Condition 3.7.2, the following operating requirements shall apply (Table 2b of Subpart ZZZZ, Item 1): 3.7.3.1 Maintain the 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 3.7.3.2 Maintain the temperature of the engine's exhaust so the catalyst inlet temperature is greater than or equal to 450°F and less than or equal to 1350°F. Performance Tests 3.7.4 Initial performance tests must be conducted within 180 days after the compliance date specified in Condition 3.7.1 according to the provisions of§63.7(a)(2). (§63.6612(a)) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 37 3.7.4.1 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(b)) 3.7.4.2 Catalyst pressure drop and catalyst inlet temperature shall be recorded during the initial performance test. 3.7.5 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: 3.7.5.1 Measure O2 at the inlet and outlet of the control device using a portable CO and O2 analyzer. a. Measurements to determine O2 concentration must be made at the same time as the measurements for CO concentration. 3.7.5.2 Measure CO at the inlet and the outlet of the control device using a portable CO and O2 analyzer. a. CO concentration must be at 15 percent O2, dry basis. Demonstrating Compliance 3.7.6 Initial compliance with the requirement to limit concentration or reduce CO emissions in Condition 3.7.2 is demonstrated by achieving the following: 3.7.6.1 The average reduction of emissions of CO determined from the initial performance test is equal to or greater than the required CO percent reduction or the average CO 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 1.a.i or 2.a.i) and 3.7.6.2 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 1.a.ii or 2.a.ii) and 3.7.6.3 The catalyst pressure drop and catalyst inlet temperature have been recorded during the initial performance test. (Table 5 of Subpart ZZZZ, Item 1.a.iii or 2.a.iii) 3.7.7 Demonstrate continuous compliance with the limitations in Condition 3.7.2 using the following methods described in Table 6 of Subpart ZZZZ. (§63.6640(a)): 3.7.7.1 Conduct performance tests according to Condition 3.7.5 every 8,760 hours or 3 years, whichever comes first, to demonstrate that the required CO concentration or percent reduction is achieved; (Table 6 of Subpart ZZZZ, Item 10.a.i) and 3.7.7.2 Collect the catalyst inlet temperature data according to §63.6625(b); (Table 6 of Subpart ZZZZ, Item 10.a.ii) and 3.7.7.3 Reduce these data to 4-hour rolling averages; (Table 6 of Subpart ZZZZ, Item Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 38 10.a.iii) and 3.7.7.4 Maintain the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature; (Table 6 of Subpart ZZZZ, Item 10.a.iv) and 3.7.7.5 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 3.7.8 Submit compliance reports semiannually according to the requirements in §63.6650(b). The report must contain the following: 3.7.8.1 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 continuous monitoring system 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) 3.7.8.2 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 continuous monitoring system was out-of-control, as specified in §63.8(c)(7), include the information in §63.6650(e). (Table 7 of Subpart ZZZZ, Item 1.b) 3.7.8.3 If there was a malfunction during the reporting period, include the information in §63.6650(c)(4). (Table 7, Item 1.c) 3.7.9 Submit a Notification of Compliance Status according to §63.6645(h). 3.7.10 Submit all notifications that are applicable in §§63.7(b) and (c), 63.8(e), (1)(4) and (O(6), 63.9(b) through (e), (g) and (h). (§63.6645(a)) 3.7.11 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 3.7.12 Compliance with the emission limitations and operating limitations in this subpart must be achieved at all times. (§63.6605(a)) 3.7.13 At all times the engine 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, Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 39 review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§63.6605(b)) Maintenance Requirements 3.7.14 Comply with the monitoring, installation, collection, and maintenance requirements in §63.6625. 3.7.15 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)) 3.8 [Federal-Only] This engine is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as specified in 40 CFR Part 63 Subpart ZZZZ § 63.6665. These requirements include, but are not limited to the following 3.8.1 Prohibited activities and circumvention in § 63.4. 3.8.2 Performance testing in §63.7. 3.8.3 Monitoring in §63.8. 3.8.4 Notification in §63.9. 3.8.5 Recordkeeping and reporting in §63.10. 3.9 This engine shall be equipped with oxidation catalyst (Colorado Regulation No. 7, XVI.B.2). Upon compliance with the requirements of Condition 3.7. the following monitoring requirements shall no longer apply. Parameters associated with the catalyst shall be monitored as follows: 3.9.1 The pressure drop across the catalyst shall be monitored and recorded monthly. 3.9.2 The catalyst inlet temperature shall be monitored and recorded monthly and kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. 3.9.3 When portable monitoring is scheduled, the above parameters in Condition 3.9.1 and 3.9.2 shall be recorded during the portable monitoring event. 3.9.4 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 3.1.2. 3.9.5 All control equipment required by Condition 3.9 shall be operated and maintained pursuant to manufacturer specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. Manufacturer specifications or equivalent shall be kept on file. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 40 4. P178 - Triethylene Glycol Regeneration Unit Parameter Permit Limitations Emission Factor Monitoring Condition Number Method Interval VOC 4.1 0.9 tons per year GLYCaIc 4.0 or Parametric Monthly higher 12 month rolling Gas Processed 4.2 3,650.0 MMscf per year Recordkeeping& Monthly Caclulation 12 month rolling Lean Glycol Pumping 4.3 0.7 gallons per minute Recordkeeping Monthly Rate Extended Gas 4.4 EPA/Division Annually Analysis Approved Methods Days/Hours of 4.5 Recordkeeping See Condition 4.5 Operation [State-Only[ Control 4.6 See Condition 4.6 Device NESHAP Subpart HH 4.7 < 1984 lb/yr benzene or See Condition 4.7 <3 MMscf/day 4.1 VOC emissions shall not exceed the annual emission limitation stated above. Emissions of VOC and HAPs will be calculated monthly using the Gas Research Institute's GLYCalc (Version 4.0 or higher) Model. Parametric monitoring of triethylene glycol circulation rate, inlet gas pressure and inlet gas temperature for the dehydrator shall be performed to verify input to this model. Values recorded shall be representative of how the unit operated during the period. Recording interval for all parameters shall be on a monthly basis. Monthly calculation of emissions using GLYCalc will be conducted by the end of the subsequent month utilizing the gas data from the last analysis conducted as required by Condition 4.4 and the average monthly value of the monitored parameters. Monthly VOC 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 The gas processed by the glycol dehydration unit shall not exceed the limitations listed above. The gas throughput to the dehydration unit shall be recorded monthly using the existing flow meter. A twelve month rolling total will be maintained to monitor compliance with annual limitations. Records of throughput shall be kept in a log to be made available to the Division upon request. An average daily gas throughput rate shall be determined by dividing the monthly gas throughput by the number of operating days in the previous month. This average daily gas throughput rate shall be used in the monthly GLYCalc runs required by Condition 4.1. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 41 4.3 The maximum pumping rate of lean glycol shall not exceed 0.7 gallons per minute (a pump stroke correlation can be used). Monthly records of the actual pumping rate shall be maintained by the permittee and made available to the Division for inspection upon request. 4.4 Samples of inlet gas shall be collected and analyzed (extended gas analysis) annually to determine CI to C6, n-hexane, benzene, toluene, ethyl benzene and total xylene (BTEX) composition. If any of the analyses indicates the BTEX constituent concentrations exceed the values listed in the table below, frequency of extended gas analyses will become quarterly. The first quarterly sample shall be taken three months after the sample that indicated a BTEX constituent exceeded the parameters in the table was taken. Frequency of sampling and analysis will move to semi-annually after four (4) subsequent analyses and to annually after two (2) subsequent semi-annual analyses indicate that the BTEX constituents remain at or below the values in the table below. Constituent I Value Units Criteria Benzene 465 parts per million At or Below Toluene 212 parts per million At or Below Ethyl Benzene 3 parts per million Must Not Exceed Xylene 20 parts per million At or Below 4.5 Days and hours of operation shall be monitored and recorded monthly in a log that is to be made available to the Division upon request. Days of operation shall be used to calculate an average daily gas throughput as specified in Condition 4.2. Hours of operation for the month shall be used in the GLYCaIc runs required by Condition 4.1. 4.6 [State-Only] Any still vent and flash separator or flash tank shall reduce uncontrolled actual emissions of VOCs by an average of at least 90 percent through the use of air pollution control equipment. (Colorado Regulation No. 7, Section XVII.D) 4.7 The glycol dehydration units are subject to the requirements in 40 CFR Part 63 Subpart HH, "National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, including, but not limited to the following: 4.7.1 These dehydrators are exempt from all requirements, save recordkeeping in §63.774(d)(1), provided the criteria in Condition 4.7.1.1 or Condition 4.7.1.2 below is met: (§63.764(e)(1)) 4.7.1.1 The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere shall be less than 0.90 megagram per year, or 1984 lbs per year, as determined by the procedures specified in Condition 4.7.3 (§63.764 (e)(1)(ii)). OR 4.7.1.2 The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day (3.0 MMSCF/day), as determined by the procedures specified in Condition 4.7.4 (§63.764(e)(1)(i).) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit/4 95OPWE039 Page 42 4.7.2 Records shall be kept of the actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with Condition 4.7.3 §63.772(b)(2) (§63.774(d)(1)(ii)). 4.7.3 The determination of actual average benzene emissions from this glycol dehydration unit shall be made using the procedure described in Condition 4.7.3.1 below. Emissions shall be determined with federally enforceable controls in place. 4.7.3.1 The actual average benzene emissions shall be determined using the model GRI- GLYCaIc, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc, Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1) (§63.772(b)(2)(i)). 4.7.4 The determination of actual flowrate of natural gas to the glycol dehydration unit shall be made using the procedure described in Condition 4.7.3.1 below. 4.7.4.1 The facility shall install and operate a monitoring instrument that directly measures natural gas flowrate to the glycol dehydration unit with an accuracy of plus or minus 2 percent or better. The source shall convert annual natural gas flowrate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processed natural gas. (§63.722(b)(1)(i)) 5. P179 - 15 MMBtu/Hr Natural Gas Fired Hot Oil Heater Parameter Permit Limitations Emission Monitoring Condition Factors Number (lb/MMscf) Method Interval PM 5.1 0.25 lb per MMBtu Fuel Restriction Only Natural Gas is Used As Fuel NOx 5.2 6.3 tons per year 100 Recordkeeping& Monthly Calculation CO 5.3 tons per year 84 12 month rolling total Natural Gas 5.3 126.4 MMscf per year Fuel Meter Monthly Consumption Recordkeeping Opacity 5.4 Not to Exceed 20%Except Fuel Restriction Only Natural Gas is as Provided Below 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 NSPS General 5.5 As Required by NSPS General Provisions Provisions Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 43 5.1 Particulate Matter (PM) emissions shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). 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 in the heater. The numeric PM standards were determined using the design heat input for the heater (15 MMBtu/hr) in the following equation: PE = 0.5 x (FI)"°26' where: PE=particulate standard in lbs/MMBtu FI = fuel input in MMBtu/hr 5.2 Emissions of NOx, and CO shall not exceed the limitations listed above. Monthly emissions shall be calculated by the end of the subsequent month using the above emission factors (EF) (from "EPA's Compilation of Emission Factors (AP-42)", Section 1.4 (dated 3/98)) and the monthly natural gas consumption, as required by Condition 5.3 in the following equation: Tons/mo=JEF(Ibs/MMscf)x monthly natural gas consumption(MMscf/mo)] 2000 lbs/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. 5.3 Natural gas consumption shall not exceed the limitations stated above. Natural gas consumed in the heater shall be recorded monthly (40 CFR Part 60 Subpart Dc §60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A). Natural gas use shall be recorded monthly using the fuel meter. Monthly natural gas consumption shall be used to calculate annual emission as required by Condition 5.2. A twelve month rolling total shall be maintained to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of consumption shall be kept on site and made available for Division review upon request. 5.4 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). 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 unit. 5.5 The hot oil heater is subject to the requirements in 40 CFR Part 60, Subpart A — General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A as follows: 5.5.1 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 44 the gasses discharged to the atmosphere. (40 CFR 60 Subpart A §60.12, as adopted by reference in Colorado Regulation No. 6, Parts A, Subpart A and B, Section I.A). 5.5.2 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 (40 CFR Subpart A §60.11(d), as adopted by reference in Colorado Regulation No. 6, Parts A, Subparts A and B, Section I.A). 5.5.3 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 (40 CFR Part 60 Subpart A §60.7(b), as adopted by reference in Colorado Regulation No. 6, Parts A, Subparts A and B, Section I.A). 6. P181 - Fugitive VOC Emissions from Equipment Leaks Parameter Permit Limitation Emission Factor Monitoring Condition Number Method Interval VOC 6.1 28.9 tons per By Component- EPA Method 21 Semi-annually year EPA Protocol for Recordkeeping& Equipment Leak Calculation Estimates Leak Detection 6.2 As defined by approved plan per Subpart KKK and Repair NSPS General 6.3 See Condition 6.3 Provisions 6.1 Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lbs/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-01 7. These emission factors are fixed until changed by established permit modification procedures. 71.,-- 7L y 3 _ iA�lf60. 9 t 8 4 t1 comp®,1 It ltl :74.FraratValves 9.92 x 10-3 5.51 x 10" Connectors 4.41 x 10' 4.63 x 10' Flanges 8.60 x 10' 2.43 x 10' Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 45 Pump Seals 5.29 x 10-3 2.87 x 10-2 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 VOC content (wt%) x Emission Factor x Control Factor The total fugitive VOC emissions shall be the sum of emissions for each component. 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 analysis shall be separated by at least two (2) calendar months. The most recent inlet gas analysis shall be used to determine the appropriate %VOC to use in the above equation. 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. 6.1.1 The annual emission limit was based on the following component count, which includes a 10% buffer: Component Component Count Gas Service Liquid Service Valves 1715 2660 Connectors 1275 3549 Flanges 464 904 Pumps 36 Other* 132 27 VOC Content(wt%) 22.5 100 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms,hatches, instrument meters,polish rods, pumps and vents. A running total shall then be kept of all additions and subtractions to the component count. A manual component count shall be performed at least once every five (5) calendar years as a check against the running total. The most recent running total shall be used for emission calculation purposes. The records shall be kept at the site and made available for Division review upon request. 6.2 This source is subject to 40 CFR Part 60, Subpart KKK, New Source Performance Standards (NSPS) (Adopted into Colorado Regulation No. 6, Subpart KKK): Standards of Performance for Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 46 Equipment Leaks of VOC From Onshore Natural Gas Processing Plants. The following items apply: 6.2.1 Inspection and maintenance requirements as stated in §60.632, §60.633, and §60.634. 6.2.2 Record keeping requirements as stated in §60.635. 6.2.3 Reporting requirements as stated in §60.636. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. In addition, the document shall detail procedures for leak detection and leak repair for the equipment and piping subject to Subpart KKK. Any changes to the document required as a result of the Division review of the document shall be accomplished as directed in writing by the Division. The document shall be retained at the plant and reviewed at least annually by the permittee and revised as necessary. The document shall be made available for Division inspection upon request. The document may be used in a compliance evaluation and determination. The requirements of Subpart KKK include a number of options and alternatives. As a minimum the document shall detail all the applicable requirements, alternatives and options to be followed, the procedures and equipment used for the testing, the instrumentation calibration and performance requirements, action levels, actions to be taken, time frames for performing the actions, reporting requirements, and provide any additional information as might be needed to fully and completely demonstrate compliance with the Subpart KKK and Regulation No. 6, Part A, General Provisions. 6.3 Regulation No. 6, Part A, General Provisions applies as follows: 6.3.1 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 opacity standard or with a standard which is based on the concentrations of a pollutant in the gasses discharged to the atmosphere (§60.12) 7. P182 - Condensate Tank Truck Loadout Parameter Permit Limitations Emission Monitoring Condition Factor Number Method Interval VOC 7.1 43.3 tons per year 4.81 lb/1000 Record keeping and Monthly gallons calculation 12 month rolling total Condensate 7.2 18 million gallons Throughput per year 7.1 VOC emissions from condensate truck loading shall not exceed the limitations stated above. VOC emissions shall be calculated monthly using the compliance emission factor above (calculated from methodology in AP 42 Chapter 5-2) in the following equation: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 47 tons/mo=EF (lb/Mgallons) x Condensate Throughput(gallon/mo) 1000 gallons x 2000 (lb/ton) The parameters used to determine the emissions factor are as follows. The Division shall be notified should there be any change in these parameters that would result in a higher emission factor. Truck Loadout Emissions (lb/1000 gallons loaded) = (12.46 x S x P x M)/ (T x CF) where: S = Saturation Factor 0.6 Submerged loading, dedicated normal service P = Ave Vapor Pressure 5.0 psi M=Molecular Weight 66.0 lb/lb mole T=Average Temperature 512.45 degrees R (based on 52.45° F) CF = Control Efficiency 1 Monthly emissions of VOC will be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 7.2 The quantity of condensate loaded into trucks shall not exceed the limitations stated above. The quantity of condensate loaded into trucks shall be monitored and recorded monthly and used to calculate emissions as required by Condition 7.1. Monthly condensate throughput shall be the sum of all loading activities within that month. This sum will be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. Records of condensate throughput shall be kept in a log to be made available to the Division upon request. 8. P183—Stabilized Condensate Storage Tanks Parameter Permit Limitations Emission Factor Monitoring Condition Number Method Interval VOC 8.1 18.0 tons per year 2.0 Ib/Mgal Recordkeeping and Monthly calculation 12 month rolling total Condensate 8.2 18 million gallons Recordkeeping Monthly Throughput per yr 8.1 Emissions of VOC from the tank battery shall not exceed the limitations listed above. Compliance with the annual limit shall be monitored on a rolling 12-month total. The VOC emissions shall be calculated by the end of each subsequent month. Monthly emissions shall be calculated using monthly condensate production rates and the emission factor provided above (derived from EPA Tanks Model). Monthly emissions shall be used in a rolling twelve (12) month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data using the following equation: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 48 tons per month=Mgallons per month x 2.0 lbs per Mgallon x 2000 lbs per ton All calculations and compliance determinations shall be made available for Division review upon request. 8.2 The quantity of condensate processed through the tank battery shall not exceed the limit above. The quantity of condensate processed through the tank battery shall be monitored and recorded monthly and used to calculate emissions as required by Condition 8.1. The monthly quantity of condensate processed 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. 9. Portable Monitoring (ver 6/1/06) Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted semi- annually for engines P169/C153 and P171/C212 and quarterly for all other engines using a portable flue gas analyzer. At least one calendar month shall separate the quarterly tests and at least two months quarter for semi-annual tests. Note that if the engine is operated for less than 100 hrs in any quarterly or semi-annual period, then the portable monitoring requirements do not apply. An EPA Reference Method test can replace a required portable analyzer test if conducted within the same test period as the portable analyzer test it replaces. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual 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. 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. 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 49 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.. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 50 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 25-7-114.4(3)(a), C.R.S. 1. Specific Conditions Based upon 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 modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Applicable Requirement Justification • P160 Waukesha 1232 HP Engine Reg 1.III.A.I.b—Particulate Internal combustion engines are not considered fuel P 161 Waukesha 1232 HP Engine emissions from fuel-burning burning equipment for the applicable requirements of equipment Regulation I. P162 Waukesha 1232 HP Engine Reg LVLB.S.a—Sulfur dioxide P163 Waukesha 1000 HP Engine emissions from fuel-burning equipment P164 Waukesha 1000 HP Engine P165 Waukesha 1000 HP Engine P166 Waukesha 1232 HP Engine P168 Caterpillar 230 HP Engine P169 Waukesha 1000 HP Engine P170 Superior Ajax 1215 HP Engine P171 Superior 600 HP Engine CIG-S-2 Superior 474 HP Engine Plant-wide Reg 3.B.IV.D.3 -PSD Review Activities at this site have not yet required Prevention Requirements of Significant Deterioration (PSD) review or permitting. 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; Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 51 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; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)O), 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,Condition Colorado Regulation No. 7, XVII.E.3.b.(i) [install control equipment] — State Only 1.9 Requirement Section II, Colorado Regulation No. 7, Section XVI.B.3 [operation and maintenance] Conditions 1.10.1 and 3.10.4 Section 11, Condition Colorado Regulation No. 7, XVII.E.3.b.(i) [install control equipment] — State Only 3.9 Requirement Section II,Condition Colorado Regulation No. 6, Part B, Section II.C.2 [fuel burning equipment particulate matter 5.1 requirement]—State Only Requirement Section II,Condition Colorado Regulation No. 6, Part B, Section II.C.3 [opacity of emission shall not exceed 20%] — 5.4 State Only Requirement Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 52 SECTION IV - General Permit Conditions (ver 11/16/2010) 1. Administrative Changes Regulation No. 3,5 CCR 1001-5, Part A, § Ill, 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, § 1.B.1. The permittee 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, §§ 111.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 are 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: (i) 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 (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. 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 §§ ILA., ILB., ❑.C.,ILE., ILF., 11.1, and 11.J 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. 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 53 c. 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 test 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. 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 Note that until such time as the U.S. EPA approves this provision into the Colorado State Implementation Plan (SIP), it shall be enforceable only by the State. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 54 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 pattem 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 exceedances 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. e. Circumvention Clause 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit 14 95OPWE039 Page 55 f. 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. g. 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. 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 56 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, && III.C.9., V.C.I1. & I6.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 may be 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 Xl. of Regulation No. 3, Part C. d. 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. f. 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 (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. g. 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 57 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5,Part C, 6 VILE 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, Part 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 §§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 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. 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 APEN or revised APEN filed. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit # 95OPWE039 Page 58 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee 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. 11. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §§ 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, § V.C.1 l.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. 15. Off-Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5,Part C, § 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 59 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,§§ 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., ILC., ❑.D, III.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, §§ 111.B.6., IV.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 perrnittee'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 permittees 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 1001-5, 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: 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: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit ft 95OPWE039 Page 60 (i) 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. c. If any of the conditions in paragraphs b.i or b.ii above are 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 for 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, § II.; Part C, §§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 information: (I) date,place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s)on which analyses were performed; (Hi) 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. 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 61 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, § ILC.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 five 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 five-year term expires. Permittees 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 filed 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. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit,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(b)(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 permittee 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, § 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: 95OPWE039 FIRST ISSUED: May I, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 62 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, $ III.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 I in Appendix D of this permit. If the permittee 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, 88 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, $ 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, $& III&V. The requirements in paragraphs a,b and e apply to sources located in an ozone non-attainment area or the Denver 1-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 filling 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(RACT) is utilized. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Midstream, LP Colorado Operating Permit Spindle Gas Processing Plant Permit# 95OPWE039 Page 63 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 open 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 permittee 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - NSPS KKK EXAMPLE REPORT FORMAT G - PERMIT MODIFICATIONS H - ENGINE AOS APPLICABILITY REPORTS I - COMPLIANCE ASSURANCE MONITORING *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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A - Inspection Information 1. Directions to Plant: The facility is located in Section 34, T2N, R67W, which is a ''/ mile north of State Highway 52, 3'/z miles west of Fort Lupton, Colorado. From I-25 North take Exit 235 (CR 52) and go east on 52 --5 miles. Turn left at CR 19 and Spindle is -1/2 mile on the right. 2. Safety Equipment Required: Hard Hat, Safety Shoes, Ear Protection, Eye Protection, and Fire Retardant Clothing. 3. Facility Plot Plan: Figure 1 shows the plot plan as submitted on September 28, 2011. 4. List of Insignificant Activities: The following generic list of insignificant activities was provided in the Title V application: 2.2 MMBtu/hr, Heater S-175 1.75 MMBtu/hr, Reboiler S-178 2 MMBtu/hr, Heater S-179 1.97 MMBtu/hr, Regen Heater S-174 1.5 MMBtu/hr, Regen Heater S-172 Two (2) 1.6 MMBtu/hr, Heaters, 5-173 & S-176 Twelve (12) Compressor Blowdown Vents East Condensate Loading and Unloading West Propane Loading Rack East BG Loading Rack West Y-Grade Loading and Unloading Emergency Flare 500 gal, Kerosene tank 210-bbl, Lube Oil tank 6,000 gal, Lube Oil tank Two (2) 500 gal, Lube Oil tanks 470 gal, Lube Oil tank 300 gal, Lube Oil 4,512 gal, Used Oil tank 500 gal, portable Used Oil Tank Three (3) 225 gal, Used Oil Tanks 500 gal, Diesel tank 500 gal, Dyed Diesel tank 30 bbl, Slop Oil Tank Two (2) 80 bbl, Slop Oil Tanks 210 bbl, Slop Oil Tank Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 2 Two (2) 10 bbl, Slop Oil Tanks 220 gal, Slop Oil tank Four (4) 30,000 gal Pressurized NGL Storage Tanks Four(4) 80 bbl, Produced Water Tanks 80 bbl, Stormwater Tank 80 bbl, Wastewater Tank 10 bbl, Dehy water tank 1,000 gal, Methanol tank Four (4) 500 gal, Methanol tanks Two (2) 1,000 gal, Norkool tanks Two (2) 24 bbl, Norkool tanks 500 gal, TEG tank Two (2) 80,000 gal Pressurized Butane Storage Tanks 30,000 gal Pressurized Propane Storage Tank 18,000 gal Pressurized Methanol Storage Tank Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 3 I ro1��w�unlmi�N. r;„a ,muminulnnmllnll Ind YYnnlY.nl. 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'I __, ii , IIF g / ; i � l. i 1 P I • I,-` 1• 4 4�.._ — ; , 8 has =1 4 I l i 1 / II (1111 I . �''r �� ijj _! _ice}, I i• p II !!t I, IA- i -111 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 1 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 filed 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 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 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 specifies 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. 1, 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 exceedance 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. 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 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: • The identification of each term or condition of the permit that is the basis of the certification; • 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; • 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. • 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. 1 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report 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 are caused in part by poor maintenance or careless operation are 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation Report- Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. 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— Spindle Gas Plant OPERATING PERMIT NO: 95OPWE039 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Deviations Svt o noted During 3 on Za10 D qj Period?' iJniU m ilp Y NO S f3 f P160 Waukesha Model L-7042 GSI NG Compressor Engine. 1232 HP C136 P161 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C137 P162 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP CI38 P163 Waukesha Model L-7042 O51 NG Compressor Engine, 1232 1-IP C147 P164 Waukesha Model L-7042 GSI NG Compressor Engine, 1000 HP C139 P165 Waukesha Model L-7042 GSI NG Compressor Engine, 1000 HP C140 P166 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C141 P168 Caterpillar Model G-342 Residue Gas Compressor Engine,230 HP C217 P169 Waukesha Model L-7042 GU NG Compressor Engine, 1000 HP C153 P170 Superior Ajax 8SGTB Residue Gas Compressor Engine, 1215 HP C215 P171 Superior Model 6G825 Residue Gas Compressor Engine,600 HP C212 P178 Natural Gas Dehydration System;using triethylene glycol Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 Malfun notes tan Condition ng Period - e2 s y tption • YES NO PI79 Natural Gas Fired Heater for heating hot oil;Serial No.J87426 P181 Gas Plant Fugitive Emission P182 Condensate Truck Load-out P 183 Condensate Storage Tanks CIG-S-2 Superior Model 6G825 NG Compressor Engine,474 HP C-221 General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries,as appropriate 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 exceedance 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report - Part II FACILITY NAME: DCP Midstream, LP— Spindle Gas Plant OPERATING PERMIT NO: 95OPWE039 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation 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: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction 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 Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 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 J. Garcia, APCD Deviation Code Division Code QA: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report- Part III REPORT CERTIFICATION SOURCE NAME: DCP Midstream, LP— Spindle Gas Plant FACILITY IDENTIFICATION NUMBER: 123/0015 PERMIT NUMBER: 95OPWE039 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 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. 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 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 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page I APPENDIX C Required Format for Annual Compliance Certification Reports 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— Spindle Gas Plant OPERATING PERMIT NO: 95OPWE039 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/are 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. .� � {, '' Morntoiln&.. Was 010-#1 p. Method Per contttuoun; Unit ID 1.IAit-DeSeri tIOrk, _ Wf' t =i P �- � Permu7 in x t t Y q ]Qj*ICOntintioug'ratiMill P160 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C136 P161 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C137 P162 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C138 P163 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C147 P164 Waukesha L-7042 O51 NG Compressor Engine, 1000 HP C139 P165 Waukesha L-7042 GSI NG Compressor Engine, 1000 HP C140 P166 Waukesha L-7042 O51 NG Compressor Engine, 1232 HP C141 P168 Caterpillar G-342 Residue Gas Compressor Engine,230 HP C217 P169 Waukesha L-7042 GU NG Compressor Engine, 1000 HP O53 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page 2 grFs-.AWY 4 '= Mont "was..- TM j-t.beStenPtioq' .# ffi _u Ctl;777-f-ric a Cpl—. "-E MAW'griliA' t- I • tfous ,.r rBtl _ P170 Superior Ajax 8SGTB Residue Gas Compressor Engine, C215 1215 HP P171 Superior 6G825 Residue Gas Compressor Engine,600 HP C212 P 178 Natural Gas Dehydration System;using triethylene glycol P179 Natural Gas Fired Heater for heating hot oil P181 Gas Plant Fugitive Emissions P 182 Condensate Truck Load-out P183 Condensate Storage Tank CIG-S-2 Superior 6G825 NG Compressor Engine,474 HP C-221 General Conditions . Insignificant Activities 777 If deviations were noted in a previous deviation report, 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. 2 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. 3 Note whether the compliance status with 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 are 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 I)conducts all of the monitoring and recordkeeping 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. °Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page 3 IL 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 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: 95OPWE039 FIRST ISSUED: May I, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 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-T 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 Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 1 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP-42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA=Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate (MMBtu/hr) FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP-HR - Horsepower Hour (G/HP-HR= Grams per Horsepower Hour) LAER- Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf- Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PM10 - Particulate Matter Under 10 Microns PSD - Prevention of Significant Deterioration Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 2 PTE - Potential To Emit RACT - Reasonably Available Control Technology SCC - Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 1 APPENDIX F NSPS KKK Example Report Format DISCLAIMER: This is only an example report and does not cover all possible KICK requirements. NSPS SUBPART KKK STANDARDS OF PERFORMANCE FOR EQUIPMENT LEAKS OF VOC FROM ONSHORE NATURAL GAS PROCESSING PLANTS Acme Gas Processing FID: 9991234 Permit#: 93OPXX999 September 1, 1996 Determination of reporting requirements for 93OPXX999 under Subpart KKK Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. Note that any non-applicability determinations under the provisions of 60.630 must be accompanied by a detailed explanation including copies of any relevant test results or any other supporting documentation. Determination of NSPS KKK requirements: 60.630 (a) (1) Applies to Acme plant since it is an onshore natural gas processing plant. (2) Applies to Acme plant since compressors are in VOC service and wet gas service. (3) Applies to Acme Plant since the group of equipment, excluding compressors, is in wet gas service. (b) Applies to Acme since the plant was placed into operation after January 20, 1984. (e) Applies to the compressor station and glycol dehydration units since they are located at the plant. 60.632 (a) Subject to the provisions of this subpart and shall comply as soon as practical, but no later than 180 days after initial startup. 60.482-1 Subject to parts (a) and (b) requiring that compliance be demonstrated within 180 days of equipment initial startup. This compliance shall be determined by a review of records and reports, performance test results, and inspection Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 2 methods and procedures of 60.485. Part (d) applies but ACME has no equipment in vacuum service. 60.482-2 Exempt under 60.633 (d). 60.482-3 Exempt under 60.633(f). 60.482-4 Applies but superseded by 60.633 (b). 60.482-5 Exempt under 60.633(c). 60.482-6 Does Not Apply. ACME does not have any open-ended lines. 60.582-7 Applies to this facility. Valves shall be monitored monthly by methods in 485(b)-(e). An instrument reading of 10,000 ppm or greater indicates a leak. Any valve for which a leak hasn't been detected for 2 successive months will be monitored the first month of every quarter until a leak is detected. After detection of a leak, the valve shall be monitored monthly until a leak is not detected for 2 successive months. When a leak is detected, it shall be repaired as soon as practical but no later than 15 calendar days after detection. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 60.482-8 Does Not Apply. ACME has no equipment in heavy liquid service or pressure relief devices in light liquid service. 60.482-9 Applies to this facility. Delays of equipment repair allowed as specified under this subpart. 60.482-10 Does Not Apply. ACME has no closed vent systems or control devices. 60.483 Alternative Standards Acme has elected not to use the provisions of 60.483-1 which allows alternative standards for valves by complying with an allowable percentage of leaking valves of equal to or less than 2.0 percent. Acme has elected not to use the provisions of 60.483-2 which allows alternative standards for valves by skipping period(s) of leak detection and repair. 60.633 Exceptions (b) (1) Each pressure relief device shall be monitored quarterly and within 5 days after each pressure relief to detect leaks as per 60.485(b). (2) An instrument reading of 10,000 ppm or greater is a leak. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 3 (3) (i) When a leak is detected, it shall be repaired as soon as practical, but no later than 15 calendar days after detection. (ii) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. (4) Does Not Apply. Facility is staffed full-time. (c) Applies to this facility. As previously stated, ACME is exempt from the requirements of 60.482-5. (d) Applies, ACME has a design capacity to process 5 million standard cubic feet per day of field gas (less than the 10 mmscf/day limit). As such, ACME is exempt from the routine monitoring requirements of 60.482-2(a)(1) and 60.482-7(a), and paragraph (b)(1) of this section. (e) Does Not Apply. Facility not in the Alaskan North Slope. (f) Applies to this facility. All compressors are in wet gas service and are therefore exempt from the requirements of 60.482-3. (g) Does Not Apply. ACME has no flaring equipment. (h) Does Not Apply. ACME has no equipment in heavy liquid service. 60.634 Alternative Means of Emission Limitation Acme has not elected to use the provisions of 60.634 which allows an alternative means of emission limitation if approved by the Administrator and published in the Federal Register. 60.635 Record keeping requirements (a) Applies to this facility. Subject to the requirements of 60.486. 60.486 Record keeping requirements 60.482-7 - When each leak is detected as specified this provisions, the requirements of 60.486(b) and 60.486(c) apply. 60.482-1 to 60.482-10 - All equipment subject to these provisions are subject to the provisions of 60.486(e). 60.482-7(g), (h)- All valves subject to these provisions are subject to the requirements of 60.486(f). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 4 60.4860)- Information and data used to demonstrate that a piece of equipment is not in VOC service shall be recorded in a log that is kept in a readily accessible location. 60.635(b)(1) When a leak has been detected a weatherproof marker shall be placed on the pressure relief device. (b)(2) When each leak is detected, the following information shall be kept for at least 2 years in the operational log (i) the identification number of the instrument used to identify the leak the operator identification number and the identification number of the equipment responsible for the leak. (ii) the date the leak was detected and the dates of repair (iii) the repair methods used to repair the leak (iv) if the leak was above 10,000 ppm (v) if the repair was delayed and how many days (vi) signature of the owner or operator identifying and repairing the leak (vii) was the leak repaired in less than 15 days after the discovery of the leak and if it was not the reason for the delay. (viii) the dates of process unit shutdown that occurred to repair the leak (ix) the date of successful repair of the leak (x) the list of equipment identification numbers for no detectable emissions 60.636 Reporting requirements (a) Applies to this facility. Subject to the reporting requirements of 60.487. (b) Operator shall include the following information on a semi annual report: (1)-(4) Number of pressure relief devices subject to the requirements of 60.636(b) (e) (1) Number of pressure relief devices for which leaks were detected (c) (2) Number of pressure relief devices for which leaks were not repaired 60.487 Reporting requirements Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 5 (a) Each owner or operator subject to the provisions of Subpart VV shall submit semiannual reports beginning 6 months after the initial startup date. (b) The initial report to the administrator shall include the process unit identification and the number of equipment subject to 60.482-7, 60.482-2, 60.482-3. (c) All semiannual reports shall include the following information: (1) Process unit identification (2) For each month: (i) Number of valves for which leaks were detected under 60.482-7. (ii) Number of valves for which leaks were not repaired as required under 60.482-7. (iii-vi) Exempt under various provisions above (vii) The facts that explain each delay and repair and, where appropriate, why a process unit shutdown was technically infeasible. (3) Dates of process unit shutdowns within the semiannual reporting period. (4) Any new items not included in the initial list of subject equipment. (d) If electing to comply with alternative monitoring, the administrator shall be notified of the standard selected 90 days prior to implementation. (e) All performance tests shall be reported. The administrator shall be notified of any initial performance tests 30 days prior to testing. CONCLUSION OF FINDINGS In general, ACME is subject to the general monitoring for valves in gas/vapor service and pressure relief devices. Valves will be monitored monthly for leaks (readings above 10,000 ppm) except that 2 successive months without leaks shall allow the monitoring to be quarterly. Pressure relief devices will be monitored quarterly for leaks (readings above 10,000 ppm) and within 5 days after each pressure release. All leaking equipment will be marked with a weatherproof tag. All leaks will be repaired no later than 15 days after detection. A first attempt at repair shall be made no later than 5 calendar days after leak detection. Any changes in equipment which triggers additional requirements will be reported no later than the semi-annual report. Records shall be maintained on site with the information as described under 60.635 and 60.486, above. Reports shall contain the information described under 60.636 and 60.487, above. Therefore the following forms shall be submitted on a semi annual basis beginning September 1, 1997 for compliance under NSPS KKK. The form shall also report an estimated volume of VOC emissions which were associated with the leak, or failure of any pressure relief device reported on the log books, or in the reporting Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 6 form as attached. Acme does keep records of the testing and replacement of all pressure relief valves and a copy of these records is attached for review. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 1 APPENDIX G Permit Modifications DATE OF REVISION SECTION NUMBER, DESCRIPTION OF REVISION CONDITION NUMBER Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 1 APPENDIX H Engine AOS Applicability Reports ver 12/10/08 Note: A MS Word version of this Appendix can be found at: http://www.cdphe.state.co.us/ap/oilgaspermitting.html DISCLAIMER: These are only example reports and do not cover all possible requirements. Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports 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 I.B.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 I.B.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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 3 Colorado Regulation No. 7 Sections XVI and XVILE DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Acme Gas Processing Source ID: 999/1234/001 Permit#: 93OPXX999 Date: October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Construction date: 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 ❑ 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, § XVILE ❑ 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): 2.0 CO (g/hp-hr): 4.0 VOC (g/hp-hr): 1.0 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 4 Max Engine Construction or Emission Standards in g/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 5 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 1, 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 Performance for Stationary Spark Ignition Internal Combustion Engines Company: Acme Gas Processing Source ID: 999/1234/001 Permit #: 93OPXX999 Date: October 1, 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/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. ❑ NSPS JJJJ does not apply to this engine. ❑ 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 6 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 1, 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 1. Non-Emergency SI, Natural Gas, HP>500, Manufactured after 7/1/2007 NO„ 2.0 g/HP-hr or 160 ppmvd@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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 7 (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. (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 NON, 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 8 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 9 MACT ZZZZ Area Source 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 1, 2008 Manufacturer: Best Engine Company 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. ❑ 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 area 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 an area 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 an area source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? (c) A new or reconstructed stationary RICE located at an area source of HAP emissions that is subject to 40 CFR Part 60, must meet the requirements of this part by meeting the requirements of 40 CFR Part 60 subpart JJJJ. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to NSPS JJJJ, no additional requirements apply under MACT ZZZZ. Operating Permit Number: 95OPWE039 FIRST ISSUED: May I, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 10 MACT ZZZZ Major Source 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 1, 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. n MACT ZZZZ does not apply to this engine. n 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 11 (a) The engine is subject to the emission limits in table la and the operating limits in table Ib. 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 O2, 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 12 (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. (c) 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) & (c), 63.8(e), (0(4) and (f)(6), 63.9(b) thru (e) & (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 (0 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) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 13 (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with title v reports (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)(1)thru(e)(12) shall be provided. (0 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(f)(6)(i). (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 MACT 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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 14 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: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 1 APPENDIX I Compliance Assurance Monitoring Plan Background a. Emission Unit Description: Eight (8) Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engines, turbocharged, 4-cycle, Standard Rich Burn, powering a natural gas compressor. Engine ratings for each engine are as follows: Facility ID AIRS ID Site Rating P160 051 1232 HP CI36 P161 052 1232 HP C137 P162 053 1232 HP C138 P163 081 1232 HP C147 P164 055 1000 HP C139 P165 056 1000 HP C140 P166 057 1232 HP C141 P169 060 1000 HP C153 b. Applicable Regulation, Emission Limit, Monitoring Requirements: Engines P160/C136, P161/C137, P165/C140, P166/C141 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 39.6 tons/yr CO 39.6 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 2 Engine P162/C138 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 23.8 tons/yr CO 39.6 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine P163/C147 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 23.8 tons/yr CO 23.8 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine P164/C139 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 19.3 tons/yr CO 38.6 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine P169/C153 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 19.3 tons/yr CO 29.0 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature c. Control Technology: Each engine is equipped with an Air/Fuel Ratio controller and Non-Selective Catalytic Reduction (NSCR) to control NOx and CO emissions. IL Monitoring Approach Indicator 1 Indicator 2 I. Indicator Pressure Drop Across the Catalyst Catalyst Inlet Temperature Measurement Approach Pressure drop across the catalyst beds is The temperature of the exhaust gas into the measured using a differential pressure catalyst will be measured using an in line gauge. thermocouple. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 3 Indicator 1 Indicator 2 F II. Indicator Range Pressure drop shall be within±2 inches of The exhaust gas into the catalyst shall be water from the pressure drop baseline value greater than or equal to 750°F and less than established as specified Condition or equal to 1250°F. 1.10.1.1.a. Excursions trigger the permttee to Excursions trigger the permittee to investigate the engine performance and investigate the catalyst performance and make any repairs or adjustments necessary. make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded Any adjustments or repairs shall be recorded in the log to be made available to the in the log to be made available to the Division upon request. Division upon request. III. Performance Criteria a. Data The pressure drop across the catalyst is The catalyst inlet temperature is measured Representativeness measured at the catalyst inlet and outlet. upstream of the catalyst. The minimum accuracy is+/- 5°F b. Verification of N/A Guarantee from the thermocouple Operational Status manufacturer. c. QA/QC Practices and Pressure gauges shall be calibrated and Thermocouples shall be calibrated and Criteria replaced in accordance with manufacturer's replaced in accordance with manufacturer's recommendations. recommendations. d. Monitoring Frequency Monthly Daily. e. Data Collection The pressure drop shall be recorded monthly The catalyst inlet temperature shall be Procedures in a log to be made available to the Division recorded daily in a log to be made available upon request. to the Division upon request. f. Averaging Period None None III. Justification a. Background: The pollutant specific emission units are eight (8) internal combustion engines used to drive compressors. Each engine is equipped with a non-selective catalytic reduction unit to control NOx and CO emissions. The non-selective reduction catalyst reduces NOx emissions to nitrogen and water as well as reducing CO emissions by formation of CO2. 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 4 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. Since the monitoring is presumptively acceptable, the Division considers that the indicator range is also presumptively acceptable. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT PIDuke � DUKE ENERGY FIELD SERVICES (�Energy® S IN p) It C.-6F t 370 17th Street Suite 944 Field Services - 2.500 RECEIVED Denver, Co 80202 APCD STATIONARY SOURCES303 595 3331 NOV 24 04 November 22, 2004 VIA FACSIMILE & FIRST CLASS MAIL � / Mr. Jim King (J� \ it-e,0 n fs 1/2{),fti c f' Colorado Department of Public Health and Environment APCD-SS-BI c p 4300 Cherry Creek Drive South Denver- Colorado 80246-1530 12— j O1 Re: Minor Modification Request Dear Jim: Duke Energy Field Services, LP (DEFS)requested construction permits for the stabilized condensate tanks at Mewbourn Gas Plant, Enterprise Compressor Station, Spindle Gas Plant and Roggen Gas Plant with an application dated October 18, 2004. DEFS is requesting that application be processed as a Minor Modification to permits 95OPWE062, 95WEOP103, 95OPWE039 and 95OPWE055, respectively. Operating permit minor modification application forms have not been developed, therefore, this letter and the previous application dated October 18, 2004 serves as the application. The requested emissions are based on the permitted throughput currently listed in each operating permit for the condensate truck loadout with the exception of Roggen and therefore are the PTE for each set of tanks. A reduction in the Roggen throughput has been requested under separate cover(see minor modification dated October 19, 2004). Since the PTE for each modification is less than 40 tons per year VOC the referenced application can be processed as a Minor Modification. Please find below the suggested draft additions to the operating permits. Mewbourn - 95OPWE062 Add a condition to Section II titled P024—Stabilized Condensate Tanks with the following table and conditions. Move current conditions 7 through 15 to 8 through 16. Parameter Permit Compliance Limits Compliance Monitoring Condition Emission Method Interval Number Factor _ VOC 7.1 6.3 tons per year 1.995 lbs per Recordkeeping and Monthly Mgallons calculation 12 month rolling total 7.1 VOC emissions shall not exceed the limitations stated above. A twelve (12)month rolling Mr.Jim King CDPHG November 22,2004 Page 2 total of emissions shall be maintained to verify compliance with the emission limitations. A new 12 month rolling total shall be calculated for the previous 12 months by the end of each subsequent month. The monthly gallons recorded as required under Condition 2.1 shall be used to calculate monthly tank emissions using the following equation. Tons per month=gallons per month x 1.995 lbs per Mgallons/ 1000 gallons per Mgallons/2000 lbs per ton Enterprise - 95OPWE103 Add a condition to Section II titled P013—Stabilized Condensate Tanks with the following table and conditions. Move current conditions 6 through 10 to 7 through 11. Parameter Permit Compliance Limits Compliance Monitoring Condition Emission Method Interval Number Factor VOC 6.1 4.5 tons per year 2.25 lbs per Recordkeeping and Monthly Mgallons calculation 12 month rolling total 6.1 VOC emissions shall not exceed the limitations stated above. A twelve (12) month rolling total of emissions shall be maintained to verify compliance with the emission limitations. A new 12 month rolling total shall be calculated for the previous 12 months by the end of each subsequent month. The monthly gallons recorded as required under Condition 4.1 shall be used to calculate monthly tank emissions using the following equation. Tons per month=gallons per month x 2.25 lbs per Mgallons/ 1000 gallons.per Mgallons/2000 lbs per ton Spindle- 95OPWE039 Add a condition to Section II titled P183—Stabilized Condensate Tanks with the following table and conditions. Move current conditions 8 through 17 to 9 through 18. Parameter Permit Compliance Limits Compliance Monitoring Condition Emission Method Interval Number Factor VOC 8.1 4.7 tons per year 2.10 lbs per Recordkeeping and Monthly Mgallons calculation 12 month rolling total 8.1 VOC emissions shall not exceed the limitations stated above. A twelve(12) month rolling total of emissions shall be maintained to verify compliance with the emission limitations. A new 12 month rolling total shall be calculated for the previous 12 months by the end of each subsequent month. The monthly gallons recorded as required under Condition 3.1 shall be used to calculate monthly tank emissions using the following equation. Mr.Jim King ('10110 November 22,2004 Page 3 Tons per month=gallons per month x 2.10 lbs per Mgallons/ 1000 gallons per Mgallons/2000 lbs per ton Roggen - 95OPWE055 Add a condition to Section II titled P028—Stabilized Condensate Tanks with the following table and conditions. Move current conditions 14 through 16 to 15 through 17. Parameter Permit Compliance Limits Compliance Monitoring _ Condition Emission Method Interval Number Factor VOC 14.1 3.4 tons per year 3.40 lbs per Recordkeeping and Monthly Mgallons calculation 12 month rolling total 14.1 VOC emissions shall not exceed the limitations stated above. A twelve (12) month rolling total of emissions shall be maintained to verify compliance with the emission limitations. A new 12 month rolling total shall be calculated for the previous 12 months by the end of each subsequent month. The monthly gallons recorded as required under Condition 8.2 shall-be used to calculate monthly tank emissions using the following equation. Tons per month=gallons per month x 3.4 lbs per Mgallons/ 1000 gallons per Mgallons/2000 lbs per ton I can be reached at 303-605-2023 if you have any questions during your review of the above request. Sincerely, Duke Energy Field Services, LP akb, ce, Ashley Campsie, Y.E. Environmental Engineer Mr.Jim King CDPHE November 22,2004 Page 4 I have reviewed this Minor Modification application supplied under authority of Regulation No.3,Part C,Section X(5 CCR 1001-5) in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application. This certification conforms with Regulation No.3,part C,Section X.D.3 (5 CCR 1001-5). Mr. Stephen McNair Vice President—Rockies Region Printed or Typed Name Title 01,112,3 (z2l°l( Signature of Responsible Official Date • Duke DUKE ENERGY FIELD SERVICES pa Energy® 370 17th Street Field Services Suite 3T70 CS ck Denver, C080202 \\ 303 595 3331 October 18, 2004 Mr. Roland Flea 169633 Colorado Department of Public Health and Environment (L3( v :17: APCD-SS-B1 i�CE4300 Cherry Creek Drive South 0Cr 2Denver, Colorado 80246-1530 eta o Re: APENs for Previously APEN Exempt Activities Dear Roland: Duke Energy Field Services, LP (DENS) is submitting the attached APENs and construction permit application Corms for several atmospheric condensate tanks that store stabilized liquid condensate.] These types of tanks first became potentially subject to regulation when Regulation No. 3, Part A. Section [I D.1.ceee took effect at the end of December 2002. By letter dated December 27, 2002, DENS filed various APENs and construction permit applications in response to the new requirements and as determined by reference to emissions estimates derived from E&P TANK and the EPA TANKS model.' Based on updated technical information, we have determined that certain stabilized liquid storage tanks that were previously determined to he exempt (i.e., with estimated emissions of less than 2 tpy VOC), are AP EN reportable and subject to construction permitting requirements. The basis for our determination in this regard is explained below. The TANKS program used to determine working and breathing losses from storage tanks does not contain specific defaults for condensate or stabilized condensate when calculating VOC emissions. Historically. the Division, DENS, and others in the oil and gas industry have used the crude oil and gasoline defaults in the TANKS program to represent condensate.3 In this regard, the gasoline default in TANKS (which is more volatile) is typically used when representing unstabilized condensate and the crude oil default in TANKS (which is less volatile) is used to represent stabilized condensate. When calculating uncontrolled actual emissions of VOC from the stabilized condensate at each of the facilities in the table below using crude oil as the TANKS default, VOC emissions from working and "Stabilized"condensate liquids are those that are stored at atmospheric temperatures and prCxsures. Emissions from the storage tanks that contain stabilized condensate liquids result front normal working and breathing Ittsses born the tanks. See the Division's I'S Memo 'fl-DI regarding "MINKS Storage Tank Emission Calculation Software." TANKS is utilized to estimate normal working and breathing losses Rom petroleum liquids storage tanks. Regulation No. =. Part A. Section H.B.I provides that in die absence of actual test data, emissions tot APIA reporting shall be based upon estimations acceptable to the Division. which may include mass balance calculations. verifiable emission factors_ or other engineerimg calculatiuus_ I !se ur ihe'I'ANKS model, and the etude oil and gasoline defaults as described air consistent with historically accepted emissions estimation techniques relied oil be the I)ivistun and others for calculating working and breathing losses of Via Rom petroleum liquid storage tanks. breathing losses from the storage tanks in question are below 2 tons per year and therefore APEN exempt. These emissions estimates served as the basis for our December 2002 exemption determination. Recently, DEFS had some samples taken of stabilized condensate in Wyoming and used HYSIS (a process simulation program)to determine the parameters for a more specific stabilized condensate default for the TANKS 4.0 program. DEFS feels this "customized"default data better represents stabilized condensate than the crude oil default in TANKS the Division has relied on in the past. However, the uncontrolled actual emissions from previously APEN exempt tanks are now above the 2 tons per year exemption level and therefore subject to APEN reporting and, as we are requesting,construction permitting requirements. The table below lists the facilities for which an APEN and construction permit application is being filed, along with the VOC emissions estimate using the crude oil default in TANKS and DEFS' customized TANKS default. Facility Uncontrolled Actual using Uncontrolled Actual using Requested Permitted Crude Oil (worst 12 Customized Stabilized Emissions Limitation month rolling total) Condensate (2003) Mewbourn 1.8 tpy 4.8 tpy 6.3 tpy /23-60 90 - 70 Enterprise 1.1 tpy 2.9 tpy 4.5 tpy /23 -6277- 63 Spindle 1.7 tpy 4.4 tpy 4.7 tpy /23-0DIr-47 Roggen 0.8 tpy 2.0 tpy 3.4 tpy /23-con -,' DEFS believes that the revised emissions estimates derived from its customized default for stabilized condensate more accurately represent working and breathing losses from storage tanks containing stabilized petroleum condensate liquids. Please feel free to call me should you have any questions regarding the steps we have taken to ensure our use of the TANKS model is as accurate as possible. Thank you. Sincerely, Duke Energy Field Services, LP Ashley Campsiie, P.E. 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CO 80202 303 595 3331 fi t 1M. 7M\r f IG,�, cacc Ltt�c, October 19, 2004 lJ .2--0510?-12 1 Mr. Jim King ,i>'F '., Colorado Department of Public Health and Environment APCD-SS-B 1 our 20df3p0 4 300 Cherry Creek Drive South AfCD :3:atlonaj Denver, Colorado S0246-1530 Sources Re: MINOR MODIFICATIONS Enterprise Compressor Station (Enterprise) — 95OPWE103 M B Mewbourn Natural Gas Processing Plant (Mewbourn)— 95OPWE062 r'B Roggen Natural Gas Processing Plant (Roggen)—95OPWE055 G D Spindle Natural Gas Processing Plant (Spindle) — 95OPWE039 M C Dear Jim: Duke Energy Field Services, LP (DEFS)would like to make the following changes to the condensate truck loading emissions for the Enterprise, Mewbourn, Roggen and Spindle facilities located in Weld County, Colorado. DEFS is requesting these changes under a Minor Modification to 95OPWE103,95OPWE062, 95OPWF055 and 95OPWF039,respectively. Operating permit minor modification application forms have not been developed, therefore, this letter and attachments serves as the application. These changes are based on more accurate physical data on the stabilized condensate being loaded. All facilities are incompliance with the current and requested limitations based on actual throughput. Enterprise - 95OPWE103, Section I1, Condition 4 Please change the VOC limit from 8.68 tpy to 1 1 .5 tpy. Please change the emission factor to 5.76 Ib/Mgal. In addition, the following factors represented in Condition 4.1 should he changed as follows: P =4.65 psia M = 86.(1 Ih/lbmol T - 58.16F (518.83R) Mewbourn - 95OPWE062, Section II, Condition 2 Please change the VOC limit from 13.69 tpy to 18.2 tpy. Please change the emission factor to 5.76 Ib/Mgal. In addition, the following factors represented in Condition 2.1 should be changed as follows: P = 4.65 psia M — 86.0 Ib/Ibmol T-58.16 F (518.83 R) Roggen - 95OPWE055, Section II, Condition 8 Please change the VOC limit from 25.0 tpy to 5.8 tpy. Please change the emission factor to 5.76 lb/Mgal. Please change the throughput limit from 11,520,000 gallons to 2.0 MMgallons. N, f \\wet e Spindle - 95OPWE039, Section II, Condition 3.1 4 Please change the factors listed in Condition 3.1 to the following: P = 4.65 psia 9 M -- 86.0 lb/Ibmol "I‘= 58.16 F (518.83 R) The attachments included consist of three APENs and supporting calculations. I can be reached at 303- 605-2023 if you have any questions during your review of this application. Sincerely, Duke Energy Field Services, LP a-- Ashley Campsie, P.F. Environmental Engineer Attachments / Duke Energy® Duke Energy Field Services dhIr Field Services P.O.BOX 359 A New Kind of Energy- Borger,Texas 79008-0359 August 19, 2005 11 -p 414g Mr. Jim King 2 747 Colorado Department of Public Health and Environment AP;;o APCD-SS-B 1 &4`'or 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: MINOR MODIFICATIONS Mewbourn Natural Gas Processing Plant(Mewbourn)—95OPWE062 Spindle Natural Gas Processing Plant(Spindle)—95OPWE039 Dear Mr. King: Duke Energy Field Services, LP (DEFS) would like to make the following changes to the fugitive emissions for the Mewbourn and Spindle facilities located in Weld County,Colorado. DEFS is requesting these changes under a Minor Modification to 95OPWE062 and 95OPWE039, respectively. Operating permit minor modification application forms have not been developed, therefore, this letter and attachments serves as the application. These changes are based on new Regulation No. 7 requirements for gas plants. Neither Mewbourn nor Spindle have any grandfathered portions of the plant with respect to NSPS KKK. Therefore we would like to combine all fugitive emissions into one point. New APENs and the associated calculations are attached. Mewbourn -95OPWE062, Section II, Condition 4 - i 1,3 - )O ct o - <'>c, Please change the VOC limit from 2.66 to 9.2 tpy. This will include all fugitive emissions at the facility and therefore Condition 5 (F018) can be removed completely. Spindle-95OPWE039, Section II, Condition 7 ( 2L 3 - Go} - 0 195- , Please change the VOC limit from 7.8 to 11.6 tpy. Like Mewbourn,this will include all fugitive emissions at the facility and therefore Condition 6 (P181)can be removed completely. CgQ012aCk I e Nit:: G& P. - Fria2 - P,C7ft,01\ 1 . 1 . 3 Colorado Dept. of Public Health and Environment Air Pollution Control Division Phone Log for Matthew S. Burgett Date: _I 2(X_ Time: Call From/ Cap Back/Message From/Left Message Name: 17;r 1c VJo\d Phone: �e Permit No.: •_2 3� AIRS ID: Company: flL___ Location: FAX: Re: Xe W bO u(• n k .5 k4 P Summary of Conversation: I L SC `t etke5 4 e ✓lQ un -Cr no id c( ke e 1.0 Co /- ✓Koch 'CciiT�) QA- 641 we eceve CG.wk ' • co o-c cir �k es-N.:+ Ce r�� -k1 b re oxs b C e p. Yca-c, 0 t I a* -c me Pd u i'e_ -/ . / Fugitive VOC from KKK Components Spindle Gas Plant • October 2004 Hard Count Fugitive VOC Emissions from KKK Components Component Number of Emiss.Fact. HC Emiss. Percent Control Hrly Emiss. Type Components (lb/comp/hr) (Ib/hr) VOC* Factor (lb/hr) Valves 3089 0.00992 30.64288 30.00 75 2.298 Relief Valves 86 0.01940 1.6684 30.00 75 0.125 Compressors 8 0.01940 0.1552 30.00 75 0.012 Flange/Conn 698 0.00086 0.60028 30.00 30 0.126 Connectors 2166 0.00044 0.95304 30.00 75 0.071 Open-Ended 0 0.00441 0 30.00 75 0.000 Pump Seals 31 0.00529 0.16399 30.00 75 0.012 Total All 2.645 11.58 tpy c .-R' 30 v2 Go putiwki. ck70-1-Alt-- JX- G eirv4 Ct1 CAA- 20.1)2 Ht E Cr, t- o mr. v C _j n p • I,_,I .p Y c mQ E'>O O N fA UO O ._ W v N� JAN U.H w w OM O C Y O T C 6 6q. O -'N O M o0 m > Cu . od a �� O C Q N �- N 6 wOr-, 1. N o w v o U a a E m F _ Jo a' p '� C O m v t o. v c 0. Q, g:14 coN ct0 O N a n ° v v F" mo 3 c cn xrn y 9 co v a o 'E o, X '" c a, o.O w .o E c? .— ca‘ K O WWS O p. Q �O 'o ^� m o o - F — g y v ❑ a w CL cd col ` a .J a t; v `v x s. '5, a o o w 7 '- ° V a a ' U c w i C. m o O C v .� a z g w o 2' oo a5 d O o Q O o 0. 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Sincerely, Duke Energy Field Services, LP Paul Brewer Vice President of Operations—Northern Division Attachments Duke Energy®PP Field Services Duke Energy Field Services P.O.BOX 359 A New Kind of Energy- Borger.Texas 79008-0359 August 19, 2005 Mr. Jim King Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: MINOR MODIFICATIONS Mewbourn Natural Gas Processing Plant (Mewbourn) —95OPWE062 Spindle Natural Gas Processing Plant (Spindle) —95OPWE039 Dear Mr. King: Duke Energy Field Services, LP (DEFS) would like to make the following changes to the fugitive emissions for the Mewbourn and Spindle facilities located in Weld County,Colorado. DEFS is requesting these changes under a Minor Modification to 95OPWE062 and 95OPWE039, respectively. Operating permit minor modification application forms have not been developed, therefore, this letter and attachments serves as the application. These changes are based on new Regulation No. 7 requirements for gas plants. Neither Mewbourn nor Spindle have any grandfathered portions of the plant with respect to NSPS KKK. Therefore we would like to combine all fugitive emissions into one point. New APENs and the associated calculations are attached. Mewbourn - 95OPWE062, Section II, Condition 4 Please change the VOC limit from 2.66 to 9.2 tpy. This will include all fugitive emissions at the facility and therefore Condition 5 (F018) can be removed completely. Spindle - 95OPWE039, Section II, Condition 7 Please change the VOC limit from 7.8 to 11.6 tpy. Like Mewbourn,this will include all fugitive emissions at the facility and therefore Condition 6 (P181) can be removed completely. spindk. GP, Co 1.1. 3 DUKE ENERGY FIELD SERVICES Duke Energy® 370 Ilth Street COMM Services Suite 2500 Denver, CO 80202 303 595 3331 July 10, 2006 UPS Next Day Air Saver (Tracking No. 1ZF469151395690073) Mr. Jim King Colorado Department of Public Health and Environment APCD-SS-Bl 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: MINOR MODIFICATIONS Mewbourn Natural Gas Processing Plant(Mewbourn)—95OPWE062 Spindle Natural Gas Processing Plant(Spindle)—95OPWE039 Dear Mr. King: Duke Energy Field Services, LP (DEFS) would like to make the following changes to the Title V Operating Permit for the Mewboum and Spindle facilities. DEFS is requesting these changes under a Minor Modification to 95OPWE062 and 95OPWE039, respectively. Operating permit minor modification application forms have not been developed,therefore, this letter and attachments serves as the application. Production has increased in the Weld County area which has subsequently increased condensate production at our facilities. DEFS would like to increase the throughput and associated emission limits for the working and breathing loses (stabilized condensate) and the truck loadout emissions at both Mewbourn and Spindle. Draft changes to the permits can be found below: 95OPWE062 (Mewbourn) Section II,Condition 2(table): (changes to previously submitted minor mod(10/18/04) not yet in permit) Change VOC limit to 20.45 tpy and the Gallons Loaded limit to 7.1 MMgal/yr. Section II,Condition 7 (table): (changes to previously submitted minor mod(11/22/04) not yet in permit) Change VOC limit to 7.08 tpy. Duke (Energy, Field Services Mr. Jim King Page 2 of 2 July 10, 2006 95OPWE039 (Spindle) Section II,Condition 2(table): (changes to previously submitted minor mod(10/18/04) not yet in permit) Change VOC limit to 17.28 tpy and the Gallons Loaded limit to 6.0 MMgal/yr. Section II,Condition 8(table): (changes to previously submitted minor mod(11/22/04) not yet in permit) Change VOC limit to 6.30 tpy. The APENs associated with the above changes are attached. If you have any questions during your review of this application, I can be reached at(303) 605-1717. Sincerely, Duke Energy Field Services,LP Karin Kimura Senior Environmental Specialist Attachments I have reviewed this Minor Modification application supplied under authority of Regulation No. 3,Part C,Section X(5 CCR 1001-5)in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application. This certification conforms with Regulation No. 3,Part C,Section X.D.3 (5 CCR 1001-5). 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Transaction Date 11 Jul 2006 Address Information Ship To: Shipper: Colorado Dpt of Public Health &Env Duke Energy Field Services Mr. Jim King Karin Kimura 303-692-3150 3035953331 APCD-SS-B1 370 17th Street- Ste 2500 4300 Cherry Creek Drive South Denver CO 80202 DENVER CO 80246-1523 Shipment Information Service: UPS Next Day Air Saver *Guaranteed By: 3:00 PM, Wed. 12 Jul. 2006 Shipping: **13.34 Package Information Package 1 of I Tracking Number: 12F469151395690073 Package Type: UPS Letter Actual Weight: Letter Billable Weight: Letter RC Code: G93S Billing Information Bill Shipping Charges to: Shipper's Account F46915 Total: All Shipping Charges in USD **13.34 Note:Total shown is for reference only. It does not include applicable taxes. * For delivery and guarantee information, see the UPS Service Guide,To speak to a customer service representative, call 1-800-PICK-UPS for domestic services and 1-800-782-7892 for international services. ** Rate Includes a fuel surcharge. Responsibility for Loss or Damage Unless a greater value is recorded in the declared value field as appropriate for the UPS shipping system used,the shipper agrees that the released value of each package covered by this receipt is no greater than $100, which is a reasonable value under the circumstances surrounding the transportation. If additional protection is desired, a shipper may increase UPS's limit of liability by declaring a higher value and paying an additional charge. UPS does not accept for transportation and shipper's requesting service through the Internet are prohibited from shipping packages with a value of more than $50,000. The maximum liability per package assumed by UPS shall not exceed $50,000, regardless of value in excess of the maximum. Claims not made within nine months after delivery of the package (sixty days for international shipments), or in the case of failure to make delivery, nine months after a reasonable time for delivery has elapsed (sixty days for international shipments), shall be deemed waived.The entry of a C.O.D. amount is not a declaration of value for carriage purposes. All checks or other negotiable instruments tendered in payment of C.O.D. will be accepted by UPS at shipper's risk. UPS shall not be liable for any special, incidental,or consequential damages. All shipments are subject to the terms and conditions contained in the UPS Tariff and the UPS Terms and Conditions of Service, which can be found at www.ups.com. https://www.campusship.ups.com/cship/create?ActionOriginPair—print PrinterPage&POPUP_LEVEL... 7/11/2006 d cp DCP Midstream 370 17th Street,Suite 2500 Denver,CO 80202 Midstream 303-595-3331 April 29, 2009 Ms.Lisa Clarke Colorado Department of Public Health and Environment APCD-SS-131 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 Re: Execution of Alternate Operating Scenario(AOS)—Spindle Natural Gas Processing Plant, Operating Permit No.95OPWE039 Dear Ms.Clarke: This letter is a follow-up to the letter submitted April 15,2008 to notify you of the upcoming like-kind permanent engine replacement for engine P-164 at the Spindle Natural Gas Processing Plant.The replacement was completed on April 24,2008.Please find a revised APEN and supporting documentation required under Operating Permit 95OPWE039,Section 4.2. A$119.96 check is attached for the APEN filing fee. Compressor engine P-164 is identified in the operating permit as a 1,000 hp,Waukesha L7042GS1 engine. The serial number of the old engine was 388531 and the serial number of the replacement engine is 335792. The replacement engine commenced operation on April 2.4,2008 and was tested on April 25,2008,using a portable analyzer to measure NOx and CO emissions in its exhaust stream.The results of the portable analyzer test showed that the engine is in compliance with the current emission limits.This engine will also meet the current Regulation No. 7 emissions limits.The APEN has been updated to reflect these limits. A field log is maintained to document all like-kind engine replacements. Both the test results and a copy of the field log are provided with this submittal. Please feel free to contact me with any questions regarding the use of the AOS to account for the above mentioned like-kind engine replacement at the Spindle Natural Gas Processing Plant. Sincerely, DCP Midstream,LP Steph Ondak -- Senior Environmental Engineer www.dcpmidstream.com , 0 Y " 8 c.5 '_ w CC o - Y V M n r�- 4r C L E > TATg u .S I e !E= r4 P N U - U d b k . 3 J,o Y tY b b b 00 ° r °• c ° �y � d� E o mm m.°y�$ n w y° V o o O J^ p yy LG y. _Cy.' .< ` d 0_ 'a 6 AV1 L v v v �".Id al Li 11 FA to C p o Y V T Y d .o y I y t y ° ° W D Q'i U p 2 6 8 w E%J w Q VL. p! 9 f0 Q 6 r g i W w {1� ° Al �i L L '' .5 G� ° S }'n WfJ r' e w v c 'g a m e O i.. Y' '� 'S� S o a N 6 ei fn Y° 9 gg ° "2 8 a 4 e y- Wz .4 Y to a 8 ° 8 Strip $ 6 V. V EC w .9 p . te-iQ Ww O. n, y�. .0 p a e .. n GJ• g L a e 8 fi C 9 - 4ni2 wIls, inY E ' u e C V EE y q� a et a o ❑ ❑ Y 0 .g° m v L .A w 2 z6 W . O _ 3 0 " '9°. t C .`d. 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A -K a ti a u pgY f 0 {+1 O n Z T.; Y� .fffCp35HFFF'�9q s Q � : p x C {ii }} is x�x W C a �' Di' 'pN O I G 'C I 1 1 0 W I _ N e1 •�apC T a�Vi C a x O f7 ° O § 5 'N U G ' 0 4� N IHJ1 a$_ c° a —T'` 7 O .r° ueau® 0 a z > v N z w° ri • Waukesha 7042 GSI Emission Calculations Spindle Gas Processing Plant DCP Midstream, LP Waukesha 7042 GSI(4 Stroke, Rich Burn, 1000HP) Unit Rating: 1000 hp BSFC: 9340 btulhp-hr Maximum Heat Input: 9.3 mmbtulhr Operating Schedule: 8760 hr/yr FHV: 1040 blulsd axmum Fuel Use: 78.3 mmscf/yr Criteria Pollutant Emission Calculations Emission Factors' Potential Emissions Pollutant (tonlyr) NOx 2.0 gfbhp-hr 19.31 CO 4.0 g/bhp-hr 38.63 VOC 1.00 glbhp-hr 9.68 a Manufacturer's controlled emission factors which meet Current Reg 7 levels. Non-Criteria Reportable Pollutant Calculations Potential Emissions De Minimis° Pollutant NAP Emission factors b Data Source (Ib/yr) Bin (lb/yr) 1,1,2,2-Tetrachbroethane 2.53E-05 lb/mmBtu EPA 2.06 A 50 1,1,2-Trfchioroethane <1.53E-05 lb/mmBtu EPA <1.25 A 50 - 1,1 Dichioroethane <1.13E-05 lb/mm81u EPA <0.36 B 500 1,2 Dichloroe8lane <1.13E-05 lb/mmBtu EPA <0.36 A> 50 .. 1,2 Dichloropropane <1.30E-05 lb/mm8tu EPA <0.41 A • 50 - 1,3-Butadiene 8.63E-041WmmBtu EPA 54.01 A= 50 1,3-Dichloropropene <1.27E-05 lb/mmBtu - EPA <1.03 A . 50 Acetaldehyde 2.79E-03 IblmmBtu EPA 227.30 Acrolein 2.63E-03 lb/mmBtu EPA 214.28 A • 50 Benzene 1.58E-031WmmB1u - EPA 128.72 A 50 Carbon Tetrachloride <1.77E-05 lb/mmEltu EPA <1.44 A 50 Chlorobenzene <1.29E-05 lb/mmBtu EPA <1.05 A 50 Chloroform <1.37E-05 lb/mmBtu ., EPA <1.12 A 50 Ethyibenzene <2.48E-05 ltYmmBtu EPA <2.02 C 1000 Ethylene Dibromide <2.13E-05 lb/mmBtu EPA <1.74 A 50 Formaldehyde° 1.11E-021WmmBtu EPA 907.72 A 50 Methanol 1.17E-021WmmBtu EPA 953.18 C 1000 Methylene CMoride 4.12E-05 IWnanBtu ., EPA 3.36 A 50 Naphthalene <9.71E-05 lb/mmBtu EPA <7.91 C 50 PAH 1.41E-041WmmBtu EPA 11.49 A 50 Styrene <1.19E-05 lb/mmBlu EPA <0.97 C 1000 Toluene 5.58E-04lb/mmetu EPA 45.46 C 1000 Vinyl Chloride <7.18E-06 IWmmBtu - EPA - <0.58 A 50 X enes(m,p,o) 1.95E-041WmmBlu EPA - 15.89 C 1000 I IAL 0.0317357 IWmmBtu — <2584 — — °Uncontrolled emission factors for HAP from 4-stroke,Ridt-burn(4SRB)engines from GRIHAPCaIc 3.01,based on EPA's AP-42. °Deminimis levels for reportable non-criteria po4utants.per Colorado Regulation No.3. °Manufacturer's fomraMehyde emission factor. Cordilleran Compliance Services,Inc. 4/29/2008 .�ICI• iti it4: it 'IS 'Nish p O N N N m M M n 00 Fr Ai§ lie'IN d �{ I a. O O o O O 0 O M --c),,, y o }Y- 4. FS�pf� 1Nii b � Y'i W t-...4 N N N .� .�.! M N i f F P I t - fir h+ .=, rn v! n M -� v p E 1I •W. 1 . ills �, �ggR., fl ,et 'x �' '��f�'h�'"` ,YiV� N N N M m to 00 1 �I1. r a �[ 5-,r{(p 1 n y rn S o 0 O o m m o O O C x ,1 TI1:'.i!l Hs% I n h it. a oo :I,. m m V) C N ;---- it 5 x 1t iiI i ij +I � .-� °� a .�-i N b M a pp { Ix 4�lf� iVI ! tll °ss+ �. i `�.'�^fl i� l4d IFi .r CO Ii. y 1 1,,�y a"�Szj $I �. : 31ca i' �{ wni m M h N h N M N M M`rW pI -.` I t ` ",�, 6r Iz� w r P �D a v, m l ;�S' ; 4 I M M m N M N N r.- M N N m L# .'I ✓� Ly 1 .- y _ p Qp 8 8 8 p o pO p 8 .£ Clit, A�1 '' i { i x F O 0 O O O O O in M O O O O I I" NIA., iin ct.. YFr t it N 'ti d1 , c' u i� u. a C7 U V' EL'S' C7 C7 U Q' g V' g C7 • !,{ 1 = N N N N N N N n Z+ N N N N Ii drit.I•J- ;L b� �i, SI 4i4I;; , aa333a33 � aaaa g s l �Iy`� a �i i .w m vt G� O ,p n O N .. 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C �D�.� l3� �9 Ig FSV � 4u l J 22 y 04% iii of y ,3a Q.4%29!2,O09 09:0.4 DCP MIDSTREAM -* S13036051957 NO.751 DE12 f Colorado Emissions / S�� AFR Test Data Log S-i,_r"� Ol ?1l S3( W, M— iJ Weam_ M `.dJ°1'7 ^ I Ii. ikl Plant Location: Spindle Convertor Manufacturer J.M.we �- . `I i a.s Irnpoction Date: 4-25-2008 Converter Modek SSA-14 Plant Permit: Flange Sims; 14 I.j. Engine YmMachnor. Waukesha AFR Manufaclvrer. Altronic , 1 Engine Sorlal Number. 335792 AFR Serial Number .. r,;, Engine Model: L-7042GSI AFR Model: EPC-100 " !" ,itw"°t 'I unit Number, C-139 .414 SERIAL 4 3E001163 AIJTOZERC) I?ROTOCOL Enghro RPM 952 ^^ r Suction Pnmaure 5 --‘ D scharge Pressure 160 _ .'. Engine Timing 19.5 SERIAL 4 3E001183 .. ,., ENERAC MODEL 3000E Mein Fuel Pressure 20 1t COMBUSTION TEST RECORD R'a tl I . . iill ii FOR: DCP MIDSTREAM Pro-Convertor Pressure 6.8 r'�II 1Is41i PrePossurevoRor TIME: 09:46:00 !; r II Ldt8me 4.8 DATE: 04/25/08 t , LeR Bank YanMod :)i Pressure 101 Rlgin Bank Menlroa FUEL NATURAL CviiS:21870 BTU/LB Preuure 12.5 COMBUSTION EFFICIENCY: 96.4 1< `, ',.'. Lambda Wangs .98 AMBIENT TEMPERATURE: 63 I STACK TEMPERATURE: 73 °F ox genes Target .78 OXYGEN: 00.0 % +.a-•f i CARBON MONOXIDE:CM) 44 PPM 1; o2gerworvottaga ,78_,78 CARBON DIOXIDE: 12.9 X 4 . .._ COMBUSTIBLE GASES: 0.00 K !,s Pre-Convertor Exhaust , EXCTemp. 991 NITRIC R R OXIDE: (M) 56 PPM PostCoavorterEchauct NITROGEN DIOXIDE: 0 PPM Temp. 899 PDX < NO + NO2) : 56 PPM eH bank Erineusl STACK GAS VELOCITY: N.A. FPS t Temp. 1079 NOX CONTROL TEMP: UNDER 30 C GMEtml Unto t MODE:PPM OXYJREFCRUEt tome• 1078 PoetColmeriorCO i-.y I PPM; 44 Post-Converter N0X , F'r 'I PPM: 56 - '414 'n I I AtX1NL r �G SLN 118J 014 II CAL L HRA I ION 23RDTOCO a;r '! 02 Percent 0% ! //�� ,,,mot �f +;� ,q I I BY;-�rM'1 t 1lther' Iliy kl TIME: 09:43:25 i.ai DATE: 02/13/08 a;. Rerrlerke: NEW ENGINE TEST NO2 SPAN CAS 59 PPM ,'.,4, SENSOR CALIBRATION SUCCESSFUL N02 SENSOR OK "NO" SENSOR FILTER OR ENSRAC MODEL SAOtaE . ;,,$;h SERIAL V 3E001183 II III"' b, ,II:'' DCP Midstream, LP PAYEE NUMBER CHECK NUMBER 370 17th Street,State 2500 0000074502 00104741 Denver,Colorado 80202 APCustomerServIce®dcpmldstream.com PAYEE NAME CHECK DATE 303.605.2219 COLORADO- 041301O8 INVOICE NUMBER INVOICE DATE NET AMOUNT DESCRIPTION 0498-APEN FILING FEE 04/29/08 119.98 SPINDLE APEN FEE i - TOTAL PAID $11916 PLEASE RETAIN POR YOUR RECORDS TIIE FACE OFTHIS Pi CUIdENT HAS ACOLJ•Er CKGNr UND rN 1'fHITE A F•WITH VISIBLE FI E•S AND AT/iUF V'f•TEHMARK AK'1 HE HFVHi5E SIDE DCP 4Dke`ir s�hul4rw,?AX. ttreaB2 6Dit4,14 i{Y3A as ssTr:u 310 t ��D0 300.60 .2214 !'THE DRDEfi OF ( 0900074302 . /3918* 00104141 'NA7 N'EGDT7AFZ.EAMEBR.Ue.DAYB AArs.leu.. L1SA61 COLORADO . i DEPT OF PUBLIC HLTH&ENVRNMNT AIR PONCNTRLDIVt SSB1 4300 CHERRY CREE H M Dertver,CO 80246-15.30 ALITH RiIZE0S 0NATURE • One hundred nineteen and 95/100 Dollars HOLD BET hIEENTHUI:I B AND FOREFINGER OH BREATHE ON COLORED BOX.COLOR W ILL DISAPPEAR.THEN REAPPEAR. N00010474 Le r:0 2 1 309 379i: 60LB95196E• A5°` Monitor Frequency Count Report 6/30/2011 Site: DCP Midstream, L.P. - Spindle Regulation:NSPS KKK Unit: APLT _.._.._.._. _.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Compressor Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 1 0 0 0 1 Equipment Total: 1 0 0 0 1 Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 609 1095 0 0 1704 Yearly-04 249 0 0 0 249 Equipment Total: 858 1095 0 0 1953 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 3 0 0 0 3 Quarterly-1 21 9 0 0 30 Yearly-04 1 0 0 0 1 Equipment Total: 25 9 0 0 34 Pump Frequency Vapor Light Liquid Heavy Other Counts Monthly 0 6 0 0 6 Equipment Total: 0 6 0 0 6 Valve Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 25 12 0 0 37 Monthly 3 0 0 0 3 Quarterly-1 417 531 0 0 948 Yearly-04 49 12 0 0 61 Equipment Total: 494 555 0 0 1049 Unit Total: 1378 1665 0 0 3043 Unit: BPLT _.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 114 488 0 0 602 Equipment Total: 114 488 0 0 602 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 2 0 0 0 2 Quarterly-1 7 0 0 0 7 Equipment Total: 9 0 0 0 9 IDE N V I R O L I N K n2ry ,t«e"a ---N° ReportType:MEL 8 Counts---Name:Counts-Monitor Frequency by Regs Page 1 of 6 As of 7/14/2011 2:18:24 PM Monitor Frequency Count Report - As of 6/30/2011 Site: DCP Midstream, LP. - Spindle Regulation:NSPS KKK Unit: BPLT Pump -.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Frequency Vapor Light Liquid Heavy Other Counts Monthly 0 1 0 0 1 Equipment Total: 0 1 0 0 1 Valve Frequency Vapor Light Liquid Heavy Other Counts E _.._.._.._.._.._.._.._.._.. EXEMPT 6 22 0 0 28 Monthly 1 1 0 0 2 Quarterly-1 63 299 0 0 362 Yearly-04 3 3 0 0 6 Equipment Total: 73 325 0 0 398 Unit Total: 196 814 0 0 1010 Unit: FRACT Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 104 677 0 0 781 Equipment Total: 104 677 0 0 781 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 5 0 0 0 5 Quarterly-1 2 2 0 0 4 Equipment Total: 7 2 0 0 9 Pump Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 0 2 0 0 2 Monthly 0 2 0 0 2 Equipment Total: 0 4 0 0 4 Valve Frequency Vapor Light Liquid Heavy Other Counts ..._.._.._.._.._.._.._.._.._.._.._.._.._.._.._ _.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._ EXEMPT 11 1007 0 0 1188 Monthly 0 1 0 0 1 Quarterly-1 35 142 0 0 177 Yearly-04 0 5 0 0 5 Equipment Total: 46 255 0 0 301 Unit Total: 157 938 0 0 1095 Unit: PLANT Compressor Frequency Vapor Light Liquid Heavy Other Counts E N V I R O L I N K£ _t a"n"�.o.,'„" ReportType:MEL&Counts---Name:Counts-Monitor Frequency by Re $.."C e'a" q Y s 9 As of 7/14/2011 2:18:24 PM Page 2 of 6 As Q Monitor Frequency Count Report f 6/30/2011 Satrietatteattirt:r - Spindle Regulation:NSPS KKK Unit: PLANT ,_.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Compressor Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 1 0 0 0 1 Equipment Total: 1 0 0 0 1 Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 225 577 0 0 802 Equipment Total: 225 577 0 0 802 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 2 0 0 0 2 Quarterly-1 5 1 0 0 6 Yearly-04 4 3 0 0 7 Equipment Total: 11 4 0 0 15 Pump Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 0 1 0 0 1 Monthly 0 8 0 0 8 Equipment Total: 0 9 0 0 9 Valve Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 61 32 0 0 93 Monthly 0 1 0 0 1 Quarterly-1 76 241 0 0 317 Yearly-04 11 13 0 0 24 Equipment Total: 148 287 0 0 435 Unit Total: 385 877 0 0 1262 Unit: PLTIN _.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Compressor Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 8 0 0 0 8 Equipment Total: 8 0 0 0 8 Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 35 484 0 0 519 Equipment Total: 35 484 0 0 519 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts 3ENV 1 R O L IN K MiS `. "RR PORT PC ReportType:MEL&Counts---Name:Counts-Monitor Frequency by Regs d s.e a Page 3 of 6 As of 7/14/2011 2:18:24 PM Monitor Frequency Count Report As of 6/30/2011 Regulation:NSPS KKK Unit: PLTIN Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts Quarterly-1 _l._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.__.._.._.. Quarterly-1 26 2 0 0 28 Yearly-04 3 0 0 0 3 Equipment Total: 29 2 0 0 31 Pump Frequency Vapor Light Liquid Heavy Other Counts Monthly 0 3 0 0 3 Equipment Total: 0 3 0 0 3 Valve Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 204 1 0 0 205 Monthly 1 1 0 0 2 Quarterly-1 297 264 0 0 561 Yearly-04 14 15 0 0 29 Equipment Total: 516 281 0 0 797 Unit Total: 588 770 0 0 1358 Unit: PRDTK Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 45 365 0 0 410 Equipment Total: 45 365 0 0 410 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts Quarterly-1_ly_.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.. Quarterly-1 0 3 0 0 3 Yearly-04 2 0 0 0 2 Equipment Total: 2 3 0 0 5 Pump Frequency Vapor Light Liquid Heavy Other Counts Monthly 0 4 0 0 4 Equipment Total: 0 4 0 0 4 Valve Frequency Vapor Light Liquid Heavy Other Counts Quarterly-1_ly_.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._.._ Quarterly-1 26 144 0 0 170 Yearly-04 4 6 0 0 10 Equipment Total: 30 150 0 0 180 Unit Total: 77 522 0 0 599 1E N V 1 RO L 1 N K"°`T'7 n R..o.Tt»a ReportType:MEL&Counts---Name:Counts-Monitor Frequency by Regs As of 7/1412011 2:18:24 PM Page 4 of 6 As Of Monitor Frequency Count Report 6/30/2011 Site: DCP Midstream, LP. -Spindle Regulation:NSPS KKK Unit: TRKLD Compressor Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 2 0 0 0 2 Equipment Total: 2 0 0 0 2 Connector Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 20 109 0 0 129 Equipment Total: 20 109 0 0 129 Press Relief Device Frequency Vapor Light Liquid Heavy Other Counts Quarterly-1 13 0 0 0 13 Yearly-04 0 3 0 0 3 Equipment Total: 13 3 0 0 16 Pump Frequency Vapor Light Liquid Heavy Other Counts Monthly 0 4 0 0 4 Equipment Total: 0 4 0 0 4 Valve Frequency Vapor Light Liquid Heavy Other Counts EXEMPT 0 2 0 0 2 Monthly 1 1 0 0 2 Quarterly-1 75 374 0 0 449 Yearly-04 4 39 0 0 43 Equipment Total: 80 416 0 0 496 Unit Total: 115 532 0 0 647 Regulation Total: 2896 6118 0 0 9014 SOE N V I R O L I N K w,Psa=E tro.n.. ReportType:MEL&Counts---Name:Counts-Monitor Frequency by Regs Page 5 of 6 As of 7/14/2011 2:18:24 PM Monitor Frequency Count Report As Of 6/30/2011 site pep 1[ stream, L P, spindle Site Total: 2896 6118 0 0 9014 E N V I R O L l N K kl,.CP °a"r.a..,N4 ReportType:MEL 8 Counts---Name:Counts-Monitor Frequency by Reps As of 7/1412011 2:18:24 PM Page 6 of 6 d' oyl. _ _ Uo N 01 < 6 c rn o om ry v-, owe & 'c m'0 ~O tn� O m 44 E > cg° b < ii u N I- c o z o.g E. m c co Q O ¢ 4 - C L0 G C Cg > v c a \ c r,1 in s a F 2 mg t V N•?a o i u - y 4 C M a E X gi. a c y r c E ro • Q < _ c < o `g °° 2 == c m U by a 0 7 r, K , gee. W=9 at, .• . c C C coZ C 4. F J u v.= r: t:a a9 t o n W 6 P O c g uct ` „ o Vr0o g ¢ oN LU a a, F OF m Cµ CI rA e U� o.EEo3yw '°,�_a I¢ T.s✓,� 0 y 0 O 3 ¢ Si u.t> N , L 1, a t o'V< • c —.are es W W cc C t ' 0 tt'C u,E - '-$:.,z z.6 0 e o❑m W p V x u O DD d,Q V•yam G 6 6 ❑ WO z i 3 xz N � 3vS g .. r) '810 Ex oc0. ON o a ; = a ° z�uFcda o�u° 8 u°Ow" O "m '3''A: d mXZ D A0V Y. 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Le < ) - ; , ! t } oo \ 4o• 41 \ . 0 • C0 ; a _ . . } 0 § /z3--,5-64.5- w / 9 �� *=9O COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT \* ,� *� AIR POLLUTION CONTROL DIVISION N. �s76 * STATIONARY SOURCES PROGRAM COMPLIANCE ORDER ON CONSENT Case Nos. 2009-007 In the Matter of DCP Midstream, LP The Colorado Department of Public Health and Environment ("CDPHE"), through the Air Pollution Control Division ("Division"), issues this Compliance Order on Consent ("Consent Order"), pursuant to the Division's authority under § 25-7-115(3)(b), C.R.S. of the Colorado Air Pollution and Prevention and Control Act ("the Act") §§ 25-7-101 to 1309, C.R.S., and its implementing regulations, 5 CCR 1001, et seq ("the Regulations") with the express consent of DCP Midstream, LP ("DCP"). The Division and DCP may be referred to jointly as "the Parties." I. STATEMENT OF PURPOSE The mutual objectives of the Parties in entering into this Consent Order are: 1. To establish compliance requirements and criteria for the continued operation of DCP's Spindle Gas Plant, more fully described in Paragraph 4 below; and 2. To address actual and/or potential violations of the Act and the Regulations identified herein and as determined by the Division and described below. II. DIVISION'S FINDINGS OF FACT AND DETERMINATIONS Based upon the Division's investigation into and review of the matters identified herein, and in accordance with § 25-7-115(3), C.R.S., the Division has made the following determinations regarding actual and/or potential violations of regulatory, statutory and/or permit requirements associated with the Facility identified in Paragraph 4. 3. At all times relevant to the actual and/or potential violations cited herein, DCP was a Foreign Limited Partnership in good standing and registered to conduct business in the State of Colorado. 4. DCP owns and/or operates the Spindle Gas Plant located at 9101 Weld County Road 14, Fort Lupton, Weld County, Colorado ("Facility"). The Facility is subject to Colorado Air Quality Control Statutes and Colorado Air Quality Control Commission ("AQCC") Regulations, federal air quality regulations and Colorado Operating Permit Number COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No. 123/0015 95OPWE039 ("Permit 95OPWE039") issued to Duke Energy Field Services May 1, 1999 and last revised June 26, 2002. 5. Facility activities include natural gas processing and natural gas condensate stabilization. Under normal operating conditions, natural gas condensate "flash" emissions from the natural gas condensate stabilization process at the Facility are routed to the Facility inlet compression system as part of a closed-loop system. 6. On December 16, 2008, a fire caused damage to the Facility. The cause of the fire is currently unknown. 7. The damage to the Facility included, but was not limited to, damage to the Facility electrical and control systems that are needed for the Facility inlet compression system to operate. Natural gas condensate flash emissions from the natural gas condensate stabilization process cannot be routed to the Facility inlet compression in the absence of operational electrical and control systems. The fire did not damage the natural gas condensate stabilizer. DCP is currently receiving natural gas condensate at the rate of approximately three to four truckloads per day (approximately 26,000 gallons of condensate per day) as specified in an Air Pollution Emission Notice ("APEN") DCP filed with the Division on December 19, 2008. Until the electrical and control systems are repaired, DCP cannot operate the closed-loop portion of the natural condensate stabilization process. DCP could discontinue its receipt of natural gas condensate, but this would require the producing sources to hold and accumulate natural gas condensate and could result in adverse impacts to public health or the environment. DCP expects that repairs to the electrical and control systems can be completed by February 16, 2009, at which time the Facility inlet compression will be restored and natural gas condensate flash emissions can be routed to the Facility inlet compression system. 8. In addition to the damage to the electrical and control systems at the Facility, an engine and compressor package identified as Unit S-163 in Permit 95OPWE39 was destroyed. Unit S-163 is a Waukesha Model L-7042 GSI 1000 HP natural gas fired Rich Burn Engine operating with catalyst and air fuel ratio controller ("Compressor"). The Compressor is permitted to emit 4.1 grams per horsepower hour of nitrogen oxides ("NOx"), 4.1 grams per horsepower hour of carbon monoxide ("CO"), and 1.0 gram per horsepower hour of volatile organic compounds ("VOCs"). The Compressor supplies propane refrigeration for the Facility. The refrigeration is necessary to operate the natural gas processing functions of the Facility. 9. On December 19, 2008, following several preliminary communications with the Division, DCP representatives met with Division representatives to discuss the fire and related operational issues (the "Meeting"). At the Meeting, DCP proposed that it route the natural gas condensate "flash" emissions that are normally routed to the Facility inlet compression as part of the closed loop system, to an existing emergency thermal combustion unit, a John Zink Model STF-LI-I-168-24 ("Flare"), on a temporary basis. The Flare is currently unpermitted but not of 2 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream,LP AIRS No: 123/0015 the type the Division currently believes warrants any further permitting activity. The APEN DCP presented at the Meeting addressed the proposed temporary use of the Flare. 10. At the conclusion of the Meeting, the Division confirmed its appreciation for the exigencies of the situation and the need to take prompt but appropriate action in response to DCP's request. Based upon its review and consideration of the information presented to it immediately prior to and during the meeting, the Division expressed its findings and agreements, consistent with the following: a. DCP's proposed routing of the natural gas condensate flash emissions to the Flare would potentially violate at least AQCC Regulation 3 Part B, Section II.A.1; and b. DCP could begin routing natural gas condensate flash emissions to the Flare, as requested, only so long as it adhered to the Compliance Requirements contained in Paragraphs 14-18 of this Consent Order. 11. The Parties reached a settlement agreement at the Meeting that is now detailed in this Consent Order. III. ORDER and AGREEMENT Based on the foregoing factual and legal determinations, pursuant to its authority under § 25-7- 115, C.R.S., and in satisfaction of the actual and/or potential violations identified in paragraph 10(a) herein, the Division orders, and DCP agrees to the following: 12. DCP agrees to the terms and conditions of this Consent Order. DCP agrees that this Consent Order constitutes an order issued pursuant to section § 25-7-115, C.R.S., and is an enforceable requirement of the Act. DCP also agrees not to challenge: c. the issuance of this Consent Order; d. the factual and legal determinations made by the Division herein; and e. the Division's authority to bring, or the court's jurisdiction to hear, any action to enforce the terms of this Consent Order under the Act. Notwithstanding the above, DCP does not admit to any of the factual or legal determinations made by the Division herein, and any action undertaken by DCP pursuant to this Consent Order shall not constitute an admission of liability by DCP with respect to the conditions of the Facility, 3 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream,LP AIRS No: 123/0015 Compliance Requirements 13. Effective immediately and consistent with the terms of this Consent Order, DCP shall comply with the Act and the Regulations in the regulation and control of air pollutants from the Facility. 14. On December 22, 2008, DCP completed and filed with the Division an initial demonstration of compliance of the Flare via the calculations prescribed by 40 C.F.R. § 60.18 and using a representative analysis of all waste streams routed to the Flare. On January 12, 2009, counsel for DCP supplied to the Division on DCP's behalf an updated demonstration of compliance for the Flare as prescribed by 40 C.E.R. § 60.18 and using an updated gas analysis representative of all waste streams being routed to the Flare DCP. Compliance with 40 C.F.R. § 60.18 and operation of the Flare without visible emissions shall establish that the flare is meeting a 98% destruction efficiency. If DCP is unable to operate the Flare within all pertinent regulatory requirements, it will immediately discontinue operation of the Flare. 15. The Flare will have no visible emissions, except during startup. If at any time the Flare produces visible emissions, DCP agrees to immediately cease operation of the Flare and to immediately cease routing the natural gas condensate flash emissions to the Flare. 16. On December 19, 2008, DCP secured a portable John Zink LHT back-up flare that DCP may utilize in the event that the Flare does not demonstrate a 98% destruction efficiency as provided in Paragraph 15 above. The requirements of Paragraph 15 shall apply to the operation of the back-up flare, In the event that the back up flare will be used instead of the Flare, it shall be operated with no visible emissions and otherwise within all pertinent regulatory requirements. 17. DCP may utilize the Flare as a control for its natural gas condensate flash emissions at the Facility only if emissions resulting from operation of the Flare remain below any applicable NSR significance threshold contained in Regulation Number 3, Part D 11.A.42 and not beyond February 14, 2009, unless agreed otherwise, in a writing signed by the Division. As of the date of execution of this Consent Order, the facility electrical and control systems have been repaired and the closed-loop portion of the natural gas condensate stabilization process has been re-established. As such, the use of the Flare as a control for natural gas condensate flash emissions is no longer required. 18. DCP will replace the damaged Compressor, which has been permanently taken out of service, with either a like-kind Waukesha L7042 GS! Rich Burn Engine or a non-like kind Caterpillar G3516 1 150 HP Lean Burn Engine ("Replacement Compressor"). The Replacement Compressor is needed to reestablish the natural gas processing function at the Facility. The Replacement Compressor will operate with improved efficiently relative to the original Compressor and be permitted to emit approximately half of what the Compressor is currently 4 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream,LP AIRS No: 123/0015 permitted to emit. If a like-kind Waukesha L7042 GSI Rich Burn Engine is utilized, it will be permitted to emit no more than 2 grams per horsepower hour of NOx, 2 grams per horsepower hour of CO, and 0.5 grams per horsepower hour of VOC. If a non-like kind Caterpillar G3516 1 150 HP Lean Burn Engine is utilized, it will be permitted to emit no more than 1.5 grams per horsepower hour of NOx, 2 grams per horsepower hour of CO, and 0.5 grams per horsepower hour of VOC. On February 13, 2009, DCP filed a permit amendment application as necessary to ensure that the Replacement Compressor is properly authorized to operate under terms and conditions of the Title V permit and Regulation No. 3. In light of the emission reductions associated with the operation of the Replacement Compressor, the parties anticipate that the Replacement Compressor will be set and operated as soon as possible and, if necessary, prior to the issuance of the permit. Administrative Penalty Requirements 19. Based upon the factors set forth in § 25-7-122, C.R.S., the Division has determined that the issuance of a penalty against DCP is not appropriate so long as it complies fully with its commitments to the Division in relation to the Facility, including each of the Compliance Requirements, above. As such, DCP's utilization of the Flare will not be treated as a violation for purposes of any future enforcement action against DCP, unless DCP fails to comply fully with the Compliance Requirements. If DCP fails to comply fully with the Compliance requirements, DCP shall be required to pay all appropriate penalties associated with its violations including, but not necessarily limited to, operating the Flare without a valid permit and for those violations associated with the Compliance Requirements. IV. SCOPE AND EFFECT OF CONSENT ORDER 20. The Parties agree and acknowledge that this Consent Order constitutes a full and final resolution of the alleged violation addressed in paragraph 10(a), and further agree not to challenge the terms and conditions of this Consent Order in any proceeding before any administrative body or any judicial forum, whether by way of direct judicial review or collateral challenge. 21. This Consent Order constitutes a final agency order effective upon execution by DCP and the Division and shall be enforceable by either party in the same manner as if the Division had entered this Consent Order without agreement by DCP. The Parties agree that any violation of the provisions of this Consent Order by DCP concerning the Act, or the Regulations, shall be a violation of a final order of the Division for the purposes of§§ 25-7-1 15, 121, and 122, C.R.S., and may result in the assessment of civil penalties of up to Fifteen Thousand Dollars ($15,000.00) per day for each day of such violation. 22. The Parties' obligations under this Consent Order are limited to the matters expressly stated herein or in approved submissions required hereunder. All submissions made 5 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0015 pursuant to this Consent Order are incorporated into this Consent Order and become enforceable under the terms of this Consent Order as of the date of approval by the Division. 23. The Division's approval of any submission, standard, or action under this Consent Order shall not constitute a defense to, or an excuse for, any prior violation of any requirement under the Act, or any implementing regulations under the Act, or any subsequent violation of any requirement of this Consent Order, the Act, or the Regulations. 24. Entering into this settlement shall not constitute an admission of violation of the air quality laws by DCP, nor shall the Division or any third party infer it to be such an admission by DCP in any administrative or judicial proceeding. Except at provided in Paragraph 19 above, the described violation will not constitute part of DCP's compliance history for any purpose for which such history is relevant, including considering the violation described above in assessing a penalty for any subsequent violations, in accordance with the provisions of§ 25-7-122, C.R.S., against DCP. 25. DCP shall comply with all applicable Federal, State, and/or local laws and regulations and shall obtain all necessary approvals or permits to conduct the investigation and remedial activities required by this Consent Order and perform its obligations required hereunder. The Division makes no representation with respect to approval and permits required by Federal, State, or local laws or regulations other than those specifically referred to herein. 26. Nothing herein shall be construed as prohibiting, altering, or in any way limiting the ability of the Division to seek any other remedies or sanctions available by virtue of DCP's violation of this agreement or of the statutes and regulations upon which this agreement is based, or for DCP's violation of any applicable provision of law. V. LIMITATION RELEASES AND RESERVATION OF RIGHTS AND LIABILITY 27. Upon the effective date of this Consent Order, and during its term, this Consent Order shall stand in lieu of any other enforcement action by the Division with respect to the violations cited herein. This Consent Order does not grant any release of liability for any violations, regardless of when they occurred, that are not cited in this Consent Order. The Division reserves the right to bring any action it deems necessary to enforce this Consent Order. 28. Nothing in the preceding paragraph shall preclude the Division from imposing additional requirements necessary to protect human health or the environment pursuant to its authority under §§ 25-7-112, 113, C.R.S. 29. DCP reserves its rights and defenses regarding liability in any proceedings regarding the Facility other than proceedings to enforce this Consent Order. 6 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0015 30. Upon the effective date of this Consent Order, DCP releases and covenants not to sue the State of Colorado as to all common law or statutory claims or counterclaims arising from, or relating to, the violations of the Act or the Regulations specifically addressed herein. 31. DCP shall not seek to hold the Division liable for any injuries or damages to persons or property resulting from acts or omissions of DCP, or those acting for or on behalf of DCP, including its officers, employees, agents, successors, representatives, contractors or consultants in carrying out activities pursuant to this Consent Order. DCP shall not hold out the Division as (a) a party to any contract entered into by DCP in carrying out activities pursuant to this Consent Order; or(b) an owner, operator or generator of hazardous wastes at the Facility. Nothing in this Consent Order shall constitute an express or implied waiver of immunity otherwise applicable to the Division, its employees, agents or representatives. 32. The Division reserves the right to bring any action or to seek civil or administrative penalties for any past, present, or future violations of the Act and its implementing regulations, not specifically addressed herein. Further, the Division has the right to bring any action to enforce this Consent Order and to seek authorized penalties for any violation of this Consent Order. VI. NOTICES 33. Unless otherwise specified, any report, notice or other communication required under the Consent Order shall be sent to: For the Division: Legal Administrator Colorado Department of Public Health and Environment APCD-SS-B1-1400 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 For DCP: Joshua B. Epel, Esq. Associate General Counsel DCP Midstream, LP 900 Republic Plaza 370 Seventeenth Street Denver, Colorado 80246 VII. OBLIGATIONS UNAFFECTED BY BANKRUPTCY 34. The obligations set forth herein are based on the Division's police and regulatory authority. These obligations require specific performance by DCP of corrective actions carefully 7 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream,LP AIRS No: 123/0015 designed to prevent on-going or future harm to public health or the environment, or both. Enforcement of these obligations is not stayed by a petition in bankruptcy. DCP agrees that the penalties set forth in this Consent Order are not in compensation of actual pecuniary loss. Further, the obligations imposed by this Consent Order are necessary for DCP and the Facility to achieve and maintain compliance with State law. VIII. MODIFICATIONS 35. This Consent Order may be modified only upon mutual written agreement of the Parties. IX. BINDING EFFECT, AUTHORIZATION TO SIGN AND EFFECTIVE DATE 36. This Consent Order is binding upon the Parties to this Consent Order and their corporate subsidiaries or parents, their officers, directors, agents, attorneys, employees, contractors, successors in interest, affiliates and assigns. The undersigned warrant that they are authorized to bind legally their respective principals to this Consent Order. This Consent Order shall be effective upon the date signed by the last party. In the event that a party does not sign this Consent Order within thirty (30) calendar days of the other party's signature, this Consent Order becomes null and void. This Consent Order may be executed in multiple counterparts, each of which shall be deemed an original, but all of which shall constitute one and the same Consent Order. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT =' ( 1111 1' I i; l By: v 1tw ;,b l v/ i Vie: Michael Silverstein Deputy Director Air Pollution Control Division By: 4, ! f,5�..F�s Date: f`i'; ;/`;7 9 Kirsten King, Manager Stationary Sources Program Air Pollution Control Division 8 COMPLIANCE ORDER ON CONSENT In the Matter of DCP Midstream, LP AIRS No: 123/0015 DCP Midstream, LP By: / i Date: ,x7/ —G Ci 5 e: Jn a)1 1{wch:,.>1� ' (Print) Title: S,z, a;zecn'z (Print) cc: Bob Jorgenson, APCD Jen Mattox, APCD Lisa Clarke, APCD G. Faith Little,APCD Mark McMillan,APCD Shannon McMillan,APCD Scott Patefield, APCD Will Allison,Office of Attorney General Cindy Beeler, US EPA 9 DCP Midstream CO 370 17th Street,Suite 2500 --/ Denver,CO 80202 Midstream. 303-595-3331 July 29, 2009 UPS Ground Tracking No. 1ZF469150393641586 Mr. Jim King Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: MINOR MODIFICATION Spindle Natural Gas Processing Plant (Spindle)—95OPWE039 Dear Mr. King: DCP Midstream, LP (DCP) would like to make the following changes to the Title V Operating Permit for the Spindle Gas Processing Plant. DCP is requesting these changes under a Minor Modification to 95OPWE039. Operating permit minor modification application forms have not been developed, therefore, this letter and attachments serves as the application. Production has continued to increase in the Weld County area which has subsequently increased condensate production at our facilities. DCP would like to increase the throughputs for the stabilized condensate storage tanks (P-183) and associated emission limits for the working and breathing losses (stabilized condensate) and for the truck loadout emissions (P-182) at Spindle. Draft changes to the permits can be found below: Section II,Condition 8(P-183): (changes to previously submitted minor mod(7/10/06) not yet in permit) Change VOC limit to 17.96 tpy. Section II,Condition 2(P-182): (changes to previously submitted minor mod(7/10/06) not yet in permit) Change VOC limit to 43.33 tpy and the gallons loaded limit to 18 MMgal/yr. www dcpm i dstream.corn dP Midstream_ Mr. Jim King Page 2 of 2 July 29, 2006 Table 1 - Project Emission Changes Spindle Natural Gas Processing Plant Stabilized Condensate Tanks and Truck Loadout an P a: s o `, `S` �' a 4° n d �' tl r A2'�' � �₹ �" n $ , a�2",.r5 i # �� N. . to s Poteufia 1 rcChau er•f (4) 300-bbl Stabilized Condensate Tanks (P-183) _ , - Increase in potential throughput to 18 MMgal/yr 9.56 17.96 8.40 Stabilized Condensate Truck Loadout (P-182) - Increase in potential throughput to 18 MMgal/yr 12.45 43.33 30.88 ' " Site-Wide Net Change 39.28 NNSR Significance Threshold 40 NNSR Review: Spindle is located in Weld County which has been classified as a nonattainment area for the 8-hr Ozone standard. The changes in VOC emissions for this project, as shown in Table 1 above, are below the significance thresholds. Consequently,NNSR Review requiring emission offsets will not be triggered by this permitting action. The APENs associated with the above changes as well as the calculations are attached. If you have any questions during your review of this application,I can be reached at(303)605- 1716. Sincerely, DCP Midstream, LP - L '� Wesley Hill Senior Environmental Specialist Attachments I have reviewed this Minor Modification application supplied under authority of Regulation No. 3,Part C, Section X(5 CCR 1001-5) in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). 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Iig in lei iS a in 73 ; \( <- 00 cri > co 1 mo \ : _ kt .i : r _ _ f ! a !! / z % 0za 0_ \ : \ ) a §� , �� a, , � k Lu \ C. \ § ^! o : ( \\\\ \ ai ` ; ` . o co0 [ f:/j !!w # & _ _ \ !}(t ! : ; , \ 0 5, \ a \ \ t . , »\}\(\6 \ \\\� \ \ , . \ \ § \ _: \ : \ \/ \ \ }\\ ? \a , E- \ H z LL E w ca fu o La Pc 52 OF OOOO j _ 15 ) $ - s.2 €2 ..- { / ` - z;; ) =- _ \ : § > §u, � , w,- , w : : Or / \ : \ �§ 0- 0 � ( f\/} « to l; ; , _ \ P. ..E ( ) 7 811 0 O : — C ; �* \f §Ca g \ )\\ _ : 1 °- & _ ! ) . .90- 0 § W \ \ 200a Da 0ZZOJJ \\ \ \ \\\ \ \ ii " ii0 ,} \ M \ 0 *463 Z TANKS 4.0 Keport rage I ut J TANKS 4.0.9d Emissions Report - Detail Format Tank Indentification and Physical Characteristics Identification User Identification: Spindle 18 MMgal/yr Full working volume City: Denver State: Colorado Company: Type of Tank: Vertical Fixed Roof Tank Description: Spindle Plant-Four 300-bbl stabilized condensate tanks 18 MMgal/y quarter working volume using I Tank Dimensions Shell Height(ft): 15.00 Diameter(ft): 12.00 Liquid Height(ft): 15.00 Avg. Liquid Height(ft): 7.50 Volume(gallons): 12,600.00 Turnovers: 1,428.57 Net Throughput(gal/yr): 18,000,000.00 Is Tank Heated(y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Cone Height(ft) 0.00 Slope(ft/ft)(Cone Roof) 0.06 Breather Vent Settings Vacuum Settings(psig): -0.03 Pressure Settings(psig) 0.03 Meterological Data used in Emissions Calculations: Denver,Colorado(Avg Atmospheric Pressure= 12.12 psia) file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 1ANKS 4.0 Report rage L. V1 J TANKS 4.0.9d Emissions Report - Detail Format Liquid Contents of Storage Tank Spindle 18 MMgal/yr Full working volume -Vertical Fixed Roof Tank Denver, Colorado Liquid Daily Liquid Sud. Bulk Vapor Liquid Vapor Temperature(deg F) Temp Vapor Pressure(psis) Mol. Mass Mass Mol. Mixture/Component Month Avg. Mln. Max. (deg F) Avg. Min. Max. Weight. Fract. Enact. Weight Gasoline(RVP 10) All 58.16 4]20 69.12 52.45 50032 40205 6.1698 66.0000 92.00 file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 1 AIN&S 4.0 Report rags 3 O1 3 TANKS 4.0.9d Emissions Report - Detail Format Detail Calculations (AP-42) Spindle 18 MMgal/yr Full working volume -Vertical Fixed Roof Tank Denver, Colorado Annual Emission Calcaulations Standing Losses(Ib): 2,3406149 Vapor Space Volume(cu fl): 862.3672 Vapor Density(Ib/cu ft). 0.0594 Vapor Space Expansion Factor 0.3781 Vented Vapor Saturation Factor 0.3309 Tank Vapor Space Volume: Vapor Space Volume(cu ft): 862.3672 Tank Diameter(ft). 12.0000 Vapor Space Outage(ft): 7.6250 Tank Shell Height(ft): 15.0000 Average Liquid Height(ft): 7.5000 Roof Outage(ft): 0.1250 Roof Outage(Cone Roof) Root Outage(ft): 0.1250 Roof Height(ft): 0.0000 Roof Slope(ff/fty. 0.0625 Shell Radius(ft): 6.0000 Vapor Density Vapor Density(lb/cu ft). 0.0594 Vapor Molecular Weight(Ib/Ib-mole): 66.0000 Vapor Pressure at Daily Average Liquid Surface Temperature(psis): 5.0032 Daily Avg.Liquid Surface Temp.(deg.R): 51]8285 Daily Average Ambient Temp.(deg.F). 502125 Ideal Gas Constant R (psia cult/(Ib-mol-deg R)). 10.731 Liquid Bulk Temperature(deg.R). 512.1225 Tank Paint Solar Absorptance(Shell): 0.5400 Tank Paint Solar Absorptance(Roof): 0.5400 Daily Total Solar Insulation Factor(Btu/soft day). 1,568.5833 Vapor Space Expansion Factor Vapor Space Expansion Factor 0.3781 Daily Vapor Temperature Range(deg.Ry. 43.8350 Daily Vapor Pressure Range(psiay 2.1494 Breather Vent Press.Setting Range(psiay O0600 Vapor Pressure at Daily Average Liquid Surface Temperature(psia): 5.0032 Vapor Pressure at Daily Minimum Liquid Surface Temperature(psia): 4.0205 Vapor Pressure at Daily Maximum Liquid Surface Temperature(psis): 6.1698 Daily Avg.Liquid Surface Temp.(deg R): 51]8285 Daily Min.Liquid Surface Temp.(deg R): 506.8697 Daily Max.Liquid Surface Temp.(deg R): 528.7872 Daily Ambient Temp.Range(deg.R): 27.9417 Vented Vapor Saturation Factor Vented Vapor Saturation Factor 0.3309 Vapor Pressure at Daily Average Liquid'. Surface Temperature(psia): 5.0032 Vapor Space Outage(ft): 7.6250 Working Losses(Ib): 26,558.2194 Vapor Molecular Weight(Ib/Ib-moley. 66.0000 Vapor Pressure at Daily Average Liquid Surface Temperature(psia): 5.0032 Annual Net Throughput(gal/yr.). 18,000,000 0000 Annual Turnovers: 1,428.5714 Turnover Factor: 0.1877 Maximum Liquid Volume(gal): 12,600.0000 Maximum Liquid Height(ft): 150000 Tank Diameter(ft). 12.0000 Working Loss Product Factor: 1.0000 Total Losses(lb): 28,898.8343 file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 TANKS 4.0.9d Emissions Report - Detail Format Individual Tank Emission Totals Emissions Report for: Annual Spindle 18 MMgal/yr Full working volume -Vertical Fixed Roof Tank Denver, Colorado Losses(Ibs) Components Working Loss Breathing Loss l Total Emissiori Gasoline(RVP 10) 26,558.22 2,340.61 I 28,898.8 file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 • .... TANKS 4.0.9 Emissions Report Spindle Future Potential Stabilized Condensate TankThroughput Spindle 18 MMgal/yr Condensate Tank Throughput VOC Calculation Losses #Tanks Total VOC Emissions Working Losses 26558.22 lbs/yr * 1 ton/2000 lbs " 1 13.28 TPY Breathing Losses 2340.61 lbs/yr * 1 ton/2000 lbs * 4 4.68 TPY Total Working and Breathing Losses 17.96 TPY Note: The 4 condensate tanks are manifolded together on the bottom and top of the tanks. The working losses are throughput dependent, so the full throughput volume was used in the Tanks 4.0.9d run and the number of tanks does not matter in the calculation. The breathing losses are independent of the throughput volume and were calculated for each tank. TANKS 4.0 Report rage r 1.11 J • TANKS 4.0.9d Emissions Report - Detail Format Tank Indentification and Physical Characteristics Identification User Identification: Spindle 5.172 MMgal/yr Full working volume City: Denver State: Colorado Company: Type of Tank: Vertical Fixed Roof Tank Description: Spindle Plant-Four 300-bbl stabilized condensate tanks 5.172 MMgal/y quarter working volume usii Tank Dimensions Shell Height(ft): 15.00 Diameter(ft): 12.00 Liquid Height(ft): 15.00 Avg.Liquid Height(ft): 7.50 Volume(gallons): 12,600.00 Turnovers: 410.51 Net Throughput(gal/yr): 5,172,392.00 Is Tank Heated(y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Cone Height(ft) 0.00 Slope(ft/ft)(Cone Roof) 0.06 Breather Vent Settings Vacuum Settings(psig): -0.03 Pressure Settings(psig) 0.03 Meterological Data used in Emissions Calculations:Denver,Colorado(Avg Atmospheric Pressure= 12.12 psia) file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 TANKS 4.0 Report rage i 01 • TANKS 4.0.9d Emissions Report - Detail Format • Detail Calculations (AP-42) Spindle 5.172 MMgal/yr Full working volume -Vertical Fixed Roof Tank Denver, Colorado Annual Emission Calcaulations Standing Losses(lb)'. 2340.6149 Vapor Space Volume(cu ft)'. 862.3672 Vapor Density(lb/cu ft). 0.0594 Vapor Space Expansion Factor 0.3781 Vented Vapor Saturation Factor 0.3309 Tank Vapor Space Volume' Vapor Space Volume(cu ft)'. 862.3672 Tank Diameter(ft): 12.0000 Vapor Space Outage(ft): 7.6250 Tank Shell Height(ft). 15.0000 Average Liquid Height(ft). 7.5000 Roof Outage(fty. 0.1250 Roof Outage(Cone Roof) Roof Outage(ft): 0.1250 Roof Height(ft): 0.0000 Roof Slope(ft/fly. 0.0825 Shell Radius(ft): 6.0000 Vapor Density Vapor Density(lb/cu ft) 0.0594 Vapor Molecular Weight(lb/lb-mole). 66.0000 Vapor Pressure at Daily Average Liquid Surface Temperature(psia): 50032 Daily Avg.Liquid Surface Temp.(deg.R). 517.8285 Daily Average Ambient Temp.(deg.F)'. 50.2125 Ideal Gas Constant R (psia tuft/(lb-mot-deg R)): 10.731 Liquid Bulk Temperature(deg.R): 512 1225 Tank Paint Solar Absorptance(Shell). 0.5400 Tank Paint Solar Absorptance(Roof) 0.5400 Daily Total Solar Insulation Factor(Btu/soft day): 1,568 5833 Vapor Space Expansion Factor Vapor Space Expansion Factor. 0.3761 Daily Vapor Temperature Range(deg.R). 43.8350 Daily Vapor Pressure Range(psia): 2.1494 Breather Vent Press.Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid Surface Temperature(psia)'. 5,0032 Vapor Pressure at Daily Minimum Liquid Surface Temperature(psia) 4.0205 Vapor Pressure at Daily Maximum Liquid Surface Temperature(petal: 6.1698 Daily Avg.Liquid Surface Temp.(deg R): 517.8285 Daily Min.Liquid Surface Temp.(deg R): 506.8697 Daily Max.Liquid Surface Temp.(deg R)'. 528.7872 Daily Ambient Temp.Range(deg.R): 27.9417 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.3309 Vapor Pressure at Daily Average Liquid: Surface Temperature(psis): 5.0032 Vapor Space Outage(ft). 7 6250 Working Lasses(lb): 9,749.5344 Vapor Molecular Weight(lb/lb-mole). 66.0000 Vapor Pressure at Daily Average Liquid Surface Temperature(psia). 5.0032 Annual Net Throughput(galyr.): 5,172,392.0000 Annual Turnovers: 410.5073 Turnover Factor: 0 2397 Maximum Liquid Volume(gal) 12.600.0000 Maximum Liquid Height(fl): 15.0000 Tank Diameter(ft): 12.0000 Working Loss Product Factor. 1.0000 Total Losses(lb): 12,090.1493 file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 TANKS 4.0.9d . L--0- I Emissions Report - Detail Format Individual Tank Emission Totals Emissions Report for: Annual Spindle 5.172 MMgal/yr Full working volume - Vertical Fixed Roof Tank Denver, Colorado Losses(lbs) J Components Working Loss Breathing Loss I Total Emissions] Gasoline(RVP 10) 9,749.53 2,340.61 12,090.1 • file://C:\Program Files\Tanks409d\summarydisplay.htm 7/24/2009 TANKS 4.0.9 Emissions Report Spindle 2-Year Average (Past Actuals) Stabilized Condensate Tank Throughput Spindle 5.172 MMgal/yr Condensate Tank Throughput VOC Calculation Losses #Tanks Total VOC Emissions Working Losses 9749.53 lbs/yr 1 ton/2000 * 1 4.87 TPY • Breathing Losses 2340.61 lbs/yr 1 ton/2000 * 4 4.68 TPY Total Working and Breathing Losses 9.56 TPY Note: The 4 condensate tanks are manifolded together on the bottom and top of the tanks. The working losses are throughput dependent, so the full throughput volume was used in the Tanks 4.0.9d run and the number of tanks does not matter in the calculation. The breathing losses are independent of the throughput volume and were calculated for each tank. • 1)? - • ww�.. HE FACE •FTMIS ••CUMENT HAS AC•L•-E. :ACKG-•UN• •N WHITE A ER WITH VISI:LE FI:E-SAN.ATRUE WATE-MA-K •NTHE •EVE•SE SI•E. ' Midstream, LP JPMorgan Chase Bank,NA. 50-93"/213 N Syracuse,New York N 7th Street,Suite 2500 r Colorado 80202 a stomerService@dipmidstreamcorn PAYEE Na CHECK DATE CHECK Na GI 05.2219 0000074502 07/28/09 00194844 HE ORDER OF x 0003NL 80 CHECKAMOUNT NOT NEGOTIABLE AFTER 120 DAYS *******$305.80 0 COLORADO- 0 DEPT OF PUBLIC HLTH &ENVRNMNT AIR POll CNTRL DIV APCD SSB1 4300 CHERRY CREEK DR SOUTH Den `%�...., Denver,CO 80246-1530 %�/J�� AUTHORIZED SIGNATURE Three hundred five and 80/100 Dollars HOLD BETWEEN THUMB AND FOREFINGER,OR BREATHE ON COLORED BOX,COLOR WILL DISAPPEAR,THEN REAPPEAR. II'On 194RLLn' 1:n p l ;n9 ; 791: F,n La S 14C,u■ d CP DCP Midstream 370 17th Street,Suite 2500 Denver,CO 80202 Midstream. 303.595-3331 June 21,2010 Send Via UPS Tracking No: IZ F46 915 01 9203 5880 Ms.Jennifer Morse Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 Re: Emission Permit/APEN Cancellation Request DCP Midstream,LP Shut down Emission Sources Dear Ms. Morse: DCP Midstream, LP(DCP)is requesting the cancellation of the following APENs only: Emission Source Facility Name APEN Number P004(C-234) Enterprise Compressor Station 123/0277/054 Engine P120(C-121) Greeley Natural Gas Processing Plant 123/0099/101 Engine P-167(C-I50) Spindle Natural Gas Processing Plant 123/0015/023 ANGI-SOCO Drip Tank ANGI-SOCO Drip Station 123/1361/001 DCP is requesting the cancellation of the following APENs and construction permits: Emission Source Facility Name APEN Number Permit Number SVE-01 (Soil Vent w/Air Enterprise Compressor 123/053'1/069 98WB0015 Sparge) Station Duchant Booster Duchant Booster 017/0220/001 00CY0438 (Dechant Wellhead C.S.) Mayfield Delivery Tank Mayfield Delivery 017/0238/001 03CY0022 Weld To Spindle Drip Tank Weld to Spindle Drip 123/1359/001 03WE0018 The attached Emission Permit/APEN Cancellation forms have been completed for the above-referenced facilities. If you have any questions, please contact me at wdhill@dcpmidstream.com or by phone at 303-605-1716. Sincerely, DCP Midstream,LP "2""--% Wesley Hill Senior Environmental Specialist Attachments www.dcpmidstream.com Colorado Air Pollution Control Division EMISSION PERMIT/APEN CANCELLATION REQUEST Air Emission Permit NNumbest" , . . . APEN Number: /2 3/069 i S /l a z 3 Source Name: S13 i/e P-/a 7 (c- is-o) Source Address: 5f ,*iJi�f / 6 c ni?, cs t� /p�o „i- s t?c 34 Rk,7t,4..,, 7-_.z A.) :w. toe VolY Co . This cancellation request is bAsed on the following: Please circle the appropriate item. 1. he facility and/or source addressed by the permit o O i t longer exists. 2. The facility has been sold to another party and I do not wish to transfer the permit. New owners name: New owners address: New owners phone number: 3. The emissions from the permitted source no longer is above the threshold required for maintaining an ADEN or permit with the Division and the source does not want to maintain an active APEN or permit with the Division. ? / Date Equipment or Operations Ceased/Sold or Below Reporting Thresholds: 317`,317`, / / b Print Name: ke.S F 7(/ `i r Title: -Sr, _Ft NJ, "2 ?a( 5'c_1, 14 Signature: i✓(/��?!Z � ' ( Date: 64/ i at is Company Name: Mc 'G4/' S vtt / L P l Comp'annyAddress: ?7p i 7�� 5'/, S S1-e. 02 6D City: 11p.tiip.,p" State: C C Zip: S7d o2-® Phone number: 302— (17oC /7t" cicP DCP Midstream 370 17th Street, Suite 2500 Denver,CO 80202 Midstream i July 16, 2010 Sent Via UPS Tracking No.1Z F46 915 01 9611 6099 Mr. James king Colorado Department of Public Health and Environment Ji APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 SUBJECT: Spindle Natural Gas Processing Plant Operating Permit 95OPWE039 Minor Modification - U'y 8:1r \ Mr. King: c: , �j'� DCP Midstream, LP (DCP) requests the following change to the Title V •Operating Permit 95OPWE039 for the Spindle Natural Gas Processing Plant (Spindle). DCP is requesting this change as a Minor Modification to 95OPWE039. Since Operating Permit Minor Modification Application forms have not been developed, this letter serves as the application. DCP has recently reevaluated the Spindle fugitive emissions based on a recent gas analysis and an updated component count. With these data, DCP requests an increase in the fugitive VOC emission limit to 28.9 TPY. This requested emissions limit includes a buffer to accommodate the addition of any new components or future changes in gas composition. A signed responsible official certification form is attached for this minor modification application. Also, please find attached an APEN, supporting calculations, and check for $152.90 for the APEN filing fee. Should you have any questions regarding this minor modification request, please contact me at (303) 605-1984 or serosenberg@dcpmidstream.com. • Sincerely, DCP Midstream,LP C Wesley Hill Senior Environmental Specialist Attachments I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). Jerry Barnhill V.P. Environment Health & Safety Printed or Typed Name Title �7/ o"--O/t7 crespbleOil ronsi ' i ,Date Attachment A APEN Filing Fees ($152.90) Spindle Fugitives Attachment B APEN Spindle Fugitives Attachment C Emission Calculations and Supporting Documentation Spindle Fugitives 0 0 ry co rc 0 c > O o o_ > ) co T'' N (oc) N co OOO0) ‘r co N to0t() V Or OOO O N C) (DO E O V 0 0 0 O6 O O O O N 1 W @ CY • r o U 0 5a 0 j, o CO t0 O N N I 'y M t0 0) O CO O O O N V N r 0 O O. 0 0 0 0 t0 N va) (D O in V C) .-- O O o N 0 N co r c E F- W rn oo Ooo o E m wa_ Noo .= 000ruiroa T O 0 N C L w = 0 W co N 73 CO (O = ,� L N N CO CO D) 0) O O O r r CO CO J. 2 N N O r t0 to CO V N r N N 0 o 0 N O Q) C) `� it O O O O r N N t0 CO N r CO t0 O O CD O )0 r t0 T O `-' N6 0 0 0 0 0 E 0 N CD t0 r O N O O C) c0 r N r 0 C F- W V M6 o 06 0 0 o 0 .- o o r O U O U) C) CD N V O u C o 0 0 0 0 0 0 0 0 0 0 O 0 -C 0) O O p o CO O 0 o O o O O CD O O o 0 0 0 O O t0 O o 0 0 0 CO U o o 0 o o 0 0 0 0 0 0 o o p O O o 0 0 0 0 Co 0 t0 t0 t0 t0 to N t0 t0 t06 O6 0 g LLa N N N N N r r N r C) M C) co CO. 'Ili T To 0 C O. 0 0 C C Co O ^ 0 0 CO o N O "- >. O o o o o 0 - O o 0 0 0 o O o 0 0 0 p o C CO N CD CD CO CD CD CO N CO (D CD CO CO CD CO CO CO CO CD CO CO CD S N r r r r r r r r r NN r r r r r r N O = a.L... Co co co co CO W 0 Q CO CO CO CO CO CO CO CO CO CO NCO CO 0 a 0 x O C CO L O C o 0 0 0 O 0 0 0 0 0 0 0 o a 0 O O O O CD O O o C) 0 o 0 0 C) M U (D N O u) O N o to O to to O LO O = 0 > N O N6 N6 N6 N N6 N6 O a N ° N ° N ° N ° N N ° N D C 0 N 0 n U E t0 O O 0) . N 0 U O ; N Co o o o N L V CO CD O r z 0 0 r N .) V( 0) .O- w O C -a C E O O r to O t0 O O CO O C) U C O L O N O CO O CD O CO V CO CO V co CO .N 0 O 0) 0 Cr t0 'Cl" CD •V 10 V V '7 CO N 4. E 0 , g E0 O r r ca CD CO 0 0 0 p 0 .04 a) O = 0 0 0 O O O O O O o 0 0 o a 0 QJ W c O O O O O O O O O O O O O F C N j .4-. o d O O C) rn c,) a a _ a 1-- N Q ra 0 o d y a�-t a w 4 Lo v 0 Cocc; o To a C a Ro 0 p 'NO to N J to N J p` 'O o o O a y e% C a Q(9 � a) m CL s.C U) L m .� y o E .1-, 113 O 0 .m f6 J y N (n J 2 0 J J 0 J J L) C -PL. v L 0 N _ y L V /1 L O . c� (U (U w 0 C co o) > > o m CO o)v ,- °1 co LL E `o Z > 76 C 0 0 C N a to 0 0 J (o o Co 0 O J C O O C O U aoi C a m U E wI y > > O co , (li u u w (n 4 0 0 d U O. o o CD D O aci LT) L T= O Q �- > > .� .0 a E L CD C C C o) O)m E _ m 0 O Co I- a_ a > CF- W X c > W > > CCCC0a000UUu_ (iH wo u • DCP Midstream, LP Spindle Natural Gas Processing Plant Fugitive VOC's Detail Sheet July 9, 2010 Spindle Inlet Analysis Pollutant Molecular Percentage Gas Weight Corrected") Weight of Volume Weight Percent Wt. Percent (Ib/Ib-mot) (%) (Ib-%/lb-mol) (%) (%) Methane 16.01 75.7086% 12.1209 55.97% 59.20% Ethane 30.02 12.4812% 3.7469 17.30% 18.30% Total HC(Non-VOC) 88.1898% 73.27% 77.50% Propane 44.03 5.4296% 2.3907 11.04% 11.68% i-Butane 58.04 0.7615% 0.4420 2.04% 2.16% n-Butane 58.04 1.5987% 0.9279 4.28% 4.53% i-Pentane 72.05 0.4140% 0.2983 1.38% 1.46% n-Pentane 72.05 0.3720% 0.2680 1.24% 1.31% Hexane+(2) 86.06 0.2306% 0.1985 0.92% 0.97% Benzene 78.11 0.0119% 0.0093 0.04% 0.05% Toluene 92.14 0.0071% 0.0065 0.03% 0.03% Ethylbenzene 106.17 0.0001% 0.0001 0.00% 0.00% Xylenes 318.50 0.0009% 0.0029 0.01% 0.01% n-Hexane 86.18 0.0737% 0.0635 0.29% 0.31% Total NMNE VOC 8.9001% 21.28% 22.50% Carbon Dioxide 43.99 2.3200% 1.0206 4.71% N/A Nitrogen 28.02 0.5700% 0.1597 0.74% N/A H2S 34.1 0.0000% 0.0000 0.00% N/A Oxygen 31.98 0.0000% 0.0000 0.00% N/A Helium 4.00 0.0200% 0.0008 0.00% N/A Totals 100.000% 21.6565 100.00% 100.00% (I)Weight Fraction corrected to remove Carbon Dioxide and Nitrogen content, (2)=C6 minus HAPs Total Component Count . .....Estimated Source Count w/ Permitted Current Pressurized Count Source Tank Addition Including 10% Equipment Type Count' b Buffer` Valves-Gas 1417 1559 1715 Valves-Liquid 2418 . 2418 2660 Relief Valves-Gas 97 107 118 Relief Valves-Liquid 24 24 27 Pump Seals-Liquid 32 32 36 Connectors-Gas 1053 1159 1275 Connectors-Liquid 3226 3226 3549 Flanges-Gas 382 421 464 Flanges-Liquid 821 821 904 Other-Gas 0 0 0 Other-Liquid 0 0 0 Open-Ended Lines 0 0 0 Compressor Seals 12 12 14 TOTAL Components 9482 9779 10762 a 2010 Component Count ° Permitted count includes a 10%increase in the gas components to cover an upcoming project where pressurized storage tanks will be installed. ` Permitted count includes 10%buffer components to accommodate future changes. DCP Midstream,LP 7/16/2010 1 ''EMPACT ANALYTICAL SYSTEMS !NC._ - t . ' 365 S MAIN ST- `<( ,11,:.:7H.. .7,40> (' i BRIGHTON, CO 80601 303-637-0150 EXTENDED NATURAL GAS ANALYSIS("DHA) MAIN PAGE PROJECT NO. 201007056 ANALYSIS NO. : 02 COMPANY NAME: DCP MIDSTREAM-LP ANALYSIS DATE: JULY 9.2010 ACCOUNT NO. : SAMPLE DATE : JULY 8,2010 PRODUCER CYLINDER NO. : 1201 LEASE NO. : SAMPLED BY PAUL PARK NAME/DESCRIP: SPINDLE PLANT INLET-DRY @3:15 PM ***FIELD DATA"' SAMPLE TEMP.: 80 SAMPLE PRES. : 660 AMBIENT TEMP.: VAPOR PRES. : GRAVITY COMMENTS SPOT: NO PROBE GPM @ GPM @ COMPONENT MOLE% MASS% 14.650 14.730 ALCOHOLS 0.0001 0.0003 HELIUM 0.02 0.00 --- --- HYDROGEN 0.00 0.00 --- --- OXYGEN/ARGON 0.00 0.00 --- -- NITROGEN 0.57 0.74 --- --- CARBON DIOXIDE 2.32 4.71 --- --- METHANE 75.70860 55.96690 --- -- ETHANE 12.4812 17.2940 3.3306 3.3488 PROPANE 5.4296 11.0327 1.4927 1.5009 I-BUTANE 0.7615 2.0395 0.2491 0.2505 N-BUTANE 1.5987 4.2818 0.5022 0.5050 I-PENTANE 0.4140 1.3746 0.1501 0.1509 N-PENTANE 0.3720 1.2367 0.1341 0.1348 HEXANES PLUS 0.3243 1.3235 0.1260 0.1266 TOTALS 100.00000 100.00000 5.9848 6.0175 BTEX COMPONENTS MOLE% WT% BTU @ 14.650 14.730 BENZENE 0.0119 0.0429 LOW NET DRY REAL: 1130.7 /scf 1136.9 /scf TOLUENE 0.0071 0.0301 NET WET REAL: 1110.9 /scf 1117.2 Acf ETHYLBENZENE 0.0001 0.0005 IIIGH GROSS DRY REAL: 1246.1 Acf 1252.9 Acf XYLENES 0.0009 0.0044 GROSS WET REAL: 1224.3 Acf 1231.1 Act TOTAL BTEX 0.0200 0.0779 NET DRY REAL: 19784.5 /lb 19892.6 /Ib GROSS DRY REAL: 21801,9 /Ib 21921.0 /Ib RELATIVE DENSITY(AIR=1): 0.7489 WALE:(IPA SID 7145 a 1'P-fro 11.696 60 IA COMPRESSIBILITY FACTOR : 0,99639 '0111AILED1117JH(X'ARHON ANALY.Y3 NI 1993):A.SIM 06730 ]HIS BATA HAS HP:IN ACQ 10.01HROO(HAPPLI(ATION 0F('IAUU'INT VIA 1}:UF11/5:ARTANALYTICAL IF(-HNIQ(ES IHF USE OF THIS MAMMA TI(8d I.5 THE RESPON.SIHI.IIY OF 11/E USER.PTM1'A('T ANAL 17"'AL SYt7EMS.ASSUMES NO RESPONS'WHLI/YTOR Al '(/RA('('O/'77/P RF/t)67711)INFORM)(ION NOR AM'('ON1'FOUEN(55011ITS APP/J('ATION EMPACT ANALYTICAL SYSTEMS INC. f # 365 S. MAIN ST. - , BRIGHTON, CO II as 80601 303-637-0150 EXTENDED NATURAL GAS ANALYSIS(*DHA) GLYCALC INFORMATION PROJECT NO. : 201007056 ANALYSIS NO. : 02 COMPANY NAME : DCP MIDSTREAM-LP ANALYSIS DATE: JULY 9, 2010 ACCOUNT NO. : SAMPLE DATE : JULY 8, 2010 PRODUCER CYLINDER NO. : 1201 LEASE NO. : SAMPLED BY : PAUL PARK NAME/DESCRIP : SPINDLE PLANT INLET-DRY @ 3:15 PM *"*FIELD DATA*** SAMPLE TEMP. : 80 SAMPLE PRES. : 660 AMBIENT TEMP.: VAPOR PRES. : GRAVITY COMMENTS : SPOT; NO PROBE Componet Mole% Wt% Helium 0.02 0.00 Hydrogen 0.00 0.00 Carbon Dioxide 2.32 4.71 Nitrogen 0.57 0.74 Methane 75.70860 55.96690 Ethane 12.4812 17.2940 Propane 5.4296 11.0327 Isobutane 0.7615 2.0395 n-Butane 1.5987 4.2818 Isopentane 0.3947 1.3122 n-Pentane 0.3720 1.2367 Cyclopentane 0.0193 0.0624 n-Hexane 0.0737 0.2927 Cyclohexane 0.0216 0.0838 Other Hexanes 0.1473 0.5820 Heptanes 0.0412 0.1893 Methycyclohexane 0.0138 0.0624 2,2,4 Trimethylpentane 0.0000 0.0000 Benzene 0.0119 0.0429 Toluene 0.0071 0.0301 Ethylbenzene 0.0001 0.0005 Xylenes 0.0009 0.0044 C8+ Heavies 0.0067 0.0354 Subtotal 99.99990 99.99970 Oxygen/Argon 0.00 0.00 Alcohols 0.0001 0.0003 Total 100.00000 100.00000 THE DATA PRESENTED HEREIN HAS BEEN ACQUIRED THROUGH JUDICIOUS APPLICATION OF CURRENT STATE-OF-THE ART ANALYTICAL TECHNIQUES. THE APPLICATIONS OF THIS INFORMATION IS THE RESPONSIBILITY OF THE USER. EMPACT ANALYTICAL SYSTEMS,INC.ASSUMES NO RESPONSIBILITY FOR ACCURACY OF THE REPORTED INFORMATION NOR ANY CONSEQUENCES OF IT'S APPLICATION. EMPACT EXTENDED NATURAL GAS ANALYSIS(*DHA) DIIA COMPONENT LIST PROJECT NO. 201007056 ANALYSIS NO._ 02 COMPANY NAME DCP MIDSTREAM-I-P ANALYSIS DATE. JULY 9,2010 ACCOUNT NO. SAMPLE DATE : JULY 8,2010 PRODUCER CYLINDER NO.: 1201 LEASE NC). SAMPLED BY PAUL PARK NAME/DESCRIP SPINDLE PLANT INLET-DRY @ 3:15 PM ***FIELD DATA*** SAMPLE TEMP.: 80 SAMPLE PRES. 660 AMBIENT TEMP.: VAPOR PRES. GRAVITY COMMENTS SPOT:NO PROBE GPM iit) GPM @ COMPONENT PIANO 4 MOLE% MASS% 14.650 14.730 Helium --- 0.02 0.00 -- --- Hydrogen --- 0.00 0.00 -- -- OxygeNArgon --- 0.00 0.00 Nitrogen --- 0.57 0.74 --- -- Carbon Dioxide --- 2.32 4.71 Methane PI 75 70860 55.96690 --- -- Ethane P2 12.4812 17.2940 3.331 3.349 Propane P3 5.4296 11.0327 1.493 1501 i-Butane 14 0.7615 2.0395 0.249 0.251 n-Butane P4 1.5980 4.2799 0.502 0.505 2,2-Dimethylpropane IS 0.0039 0.0129 0.001 0,001 i-Pentane [5 0.3908 1.2993 0.143 0.144 UnknownC4s t14 0.0007 0.0019 0.000 0.000 n-Pentane P5 0.3718 1.2361 0.134 0.135 t-13utanol X4 0.0001 0.0003 0.000 0.000 2,2-Dimethylbutane I6 0.0046 0.0182 0.002 0.002 Cyclopentane N5 0.0193 0.0624 0.006 0.006 23-Dimethyl6utane 16 0.0118 0.0469 0.005 0.005 2-Methylpentane 16 0.0655 0.2601 0.027 0.027 3-Methylpentane 16 0.0336 0,1335 0,014 0.014 llnknownC5s U5 0.0002 0.0006 0.000 0.000 n-I Iexane P6 0.0737 0.2927 0.030 0.030 2,2-Dimethylpentane 17 0.0003 0.0014 0.000 0.000 Methylcyclopentane N6 0.0318 0.1233 0.011 0.011 2,4-Dimethylpentane 17 0.0024 0.0111 0.001 0.001 2,2,3-Trimethylbutane 17 0.0003 0.0014 0.000 0.000 Benzene A6 0.0119 0.0429 0.003 0.003 3,3-Dimethylpentane 17 0.0004 00018 0.000 0.000 Cyclohexane N6 0.0216 0.0838 0.007 0.007 2-Methylhexane 17 0.0066 0.0305 0.003 0.003 2,3-Dimethylpentane 17 0.0026 0.0120 0.001 0.001 I,I-Dimethylcyclopentane N7 0.0023 0.0104 0.001 0.001 3-Methylliexane 17 0.0065 00300 0.003 0.003 I e,3-Dimethylcyclopentane N7 0.0025 0.0113 0.001 0.001 It3-Dimethylcyclopentane N7 0.0023 0.0104 0.001 0.001 3-Ethylpentanc I7 0.0001 0.0005 0.000 0.000 It,2-Dimethylcyclopentane N7 0.0036 0.0163 0.002 0.002 n-Fleptane P7 0.0107 0.0494 0.005 0.005 I e,2-Dimethylcyclopentane N7 0.0001 0.0005 0.000 0.000 Methyleyclohexane N7 0.0138 0.0624 0.006 0.006 2,2-Dimethylhexane IS 0.0005 0.0026 0.000 0.000 1,13=IDimethylcyclopentanc N7 0.0001 0.0005 0.000 0.000 Page 1 EMPACT Analytical Systems,Inc 365 S.Main Street.Brighton, CO 80601 303-637-0150 Ethylcyclopentane N7 0.0004 0.0018 0.000 0.000 2 5-Dimethylhexane 18 0.0002 0.0011 0.000 0.000 2 4-Dimethylhexane I8 0.0003 0.0016 0.000 0.000 Ic-2L4-Trimethylcyclopentane N8 0.0004 0.0021 0.000 0.000 3,3-Dimethylhexane 18 0.0001 0.0005 0.000 0.000 It,2c,4-Trimethylcyclopentane NS 0.0003 0.0016 0.000 0.000 Toluene A7 0.0071 00301 0.002 0.002 2.3-Dimethylhexane IS 0.0002 0.0011 0.000 0.000 2-Methylheptane 18 0.0008 0.0042 0.000 0.000 4-Methylheptane 18 0.0002 0.0011 0.000 0.000 Ic,2L3-Trimethylcyclopentane N8 0.0011 0.0057 0.001 0001 3-Ethylhexane 18 0.0001 0.0005 0.000 0.000 IL4-Dimethylcyclohexane N8 0.0004 0.0021 (1.000 0.000 I,I-Dimethylcyclohexane NS 0.0001 0.0005 0.000 0.000 I,I-Methylethylcyclopentane NS 0.0001 0.0005 0.000 0.000 IL2-Dimethylcyclohexane NS 0.0003 0.0016 0.000 0.000 n-Octane P8 0.0009 0.0047 0.000 0.000 1,1A-Trimethylcyclohexane N9 0.0002 00011 0.000 0.000 2,2,3-Trimethylhexane I9 0.0001 0.0006 0.000 0000 Ethylcyclohexane N8 0.000 I 0.0005 0.000 0.000 Ethylbenzene 18 0.0001 0.0005 0.000 0.000 I,3-Dimethylbenzene(m-Xylene) • A8 0.0005 0.0024 0.000 0.000 1,4-Dimethylbenzene(p-Xylene) A8 0.0002 0.0010 0.000 0.000 I,2-Dimethylbenzene(o-Xylene) AS 0.0002 0.0010 0.000 0.000 UnknownC8s US 0.0001 0.0005 0.000 0.000 n-Nonane P9 0.0001 0.0006 0.000 0.000 UnknownC9s U9 0.0001 0.0006 0.000 0.000 TOTAL 100O0000 100.00000 5.9848 6.0175 BT EX COMPONENTS MOLE% WT% BTU r(7i 14.650 14.730 BENZENE 0.0119 0.0429 LOW NET DRY REAL: 1130.7 /scf 1136.9 /scf TOLUENE 0.0071 0.0301 NET WET REAL: 1110.9 /scf 1117.2 An( ETHYLBENZENE 0.0001 0.0005 MGM GROSS DRY REAL: 1246.1 /scf 1252.9 /scf XYLENES 0.0009 0.0044 GROSS WET REAL: 1224.3 /scf 1231.1 /ea TOTAL BTEX 0.0200 0.0779 NET DRY REAL: 19784.5 /Ib 19892.6/IL GROSS DRY REAL: 21801.9 /Ib 21921.0/Ib RELATIVE DENSITY(AIR=1): 0.7489 (CAL(':GPA,702715 h IRIS&911.6964 6010 COMPRESSIBILITY FACTOR : 0.99639 HIHNAILED HYDROCARBONANALYSLVN/1993);A.57M 06730 TAGS DATA IIAS BIi1NACQ(111tED THROUGH APPLICATION OF CURRENT 7/A YE-ONIN ARTANALYTICAL TECHNIQUES'' THE USE OF THIS INFORMATION IS ME RF_5'I'ON5'IBLI'TY OF%'HIl USER. IMPACT ANALYTICAL 51'.517/S ASVUMliS NO It/iSPON5I11IJTY TOR ACCURACY OF THE REPORTED INFOIWA LION NOR ANY CONSEQUENCES'OF ITSAPPLICAIION Page 2 EM PACT Analytical Systems,Inc 365 S.Main Street,Brighton, CO 80601 303-637-0150 (SCx� DCP Midstream P Street,Suite 2500 �c— Denver,CO 80202 Midstream. �� Q • 303-595-3331 u s 19;2010 i A(4 s°°' re\t P Pao- No:1Z F46 91 5019180 6870 Mr. Doug Ryder Colorado Department of Public Health and Environment APCD-SS-B I 4300 Cherry Creek Drive South Denver,Colorado 80246-1530 SUBJECT: Spindle Natural Gas Processing Plant Self-Certification for Construction Permit 09WE0195& Request to Roll 09WE0195 into Facility Title V Operating Permit 95OPWE039 Mr. Ryder: Please find the attached self-certification form for Construction Permit 09WE0195. This permit is for a 1,232 HP, Waukesha L7042GSI compressor engine,serial number 286440. This engine replaced an existing engine (C-I47/P163)that was damaged beyond repair by a fire that occurred at Spindle on December 16,2008. The electrical and control systems needed to operate the inlet compression system at the facility were also severely damaged in the fire. As a result,emissions from the natural gas condensate stabilization process at Spindle could not be routed to inlet compression for control. Rather than shut the producers from whom DCP receives gas for Spindle,which would have had adverse environmental consequences,DCP and the Division entered a Compliance Order on Consent(Case Nos.2009-007)(COC)that allowed DCP to operate a temporary flare to control condensate stabilization emissions until the electrical system was repaired and to immediately replace the damaged engine with a replacement engine at reduced emission rates. Per the COC,a permit application for the replacement engine was submitted on February 13,2009 to update the permitted emissions for engine C 147/P163. Under the COC,the replacement engine commenced operation on May 20,2009. An initial stack test using a portable analyzer was completed May 26,2009 confirming that the engine met the emission limits established in the COC.An AOS was also submitted to the Division on June 2,2009 to notify the Division that the engine switch had been completed and to notify the Division that the replacement engine had commenced operation. The new construction permit for engine C-1471P163 was issued on April 26,2010(Construction Permit 09WE0195). This submittal is to certify that the engine is meeting all requirements of the new construction permit. This engine is in compliance with all conditions of the permit except for those referencing MACT Subpart ZZZZ. As provided in a December 31,2009 e-mail from Olsson Associates to Stephanie Rucker,Conditions 4, 13, 15,and 16 in the permit do not apply because Spindle is an area source of HAP emissions.'As an"area source"of HAP emissions,Spindle is not subject to the major source provisions of Subpart ZZZZ.In addition, the engine was manufactured on April 11, 1975;therefore it is an existing spark ignition RICE and not subject to the control or testing requirements in Subpart ZZZZ. All engines at the facility are controlled with catalysts to meet a federally enforceable VOC limits. Since formaldehyde,for example,is a VOC and it 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. www.dcpmidstream.com Mr.Doug Ryder August 19,2010 Page 2 of 2 To achieve compliance with Condition 20,DCP is requesting that Construction Permit 09WE0195 be rolled into Operating Permit 95OPWE039 when the renewal is issudd. Attached for this purpose are Title V forms 302,604,and 800 as well as a copy of Construction Permit 09WE0195 and the most recent APEN. If any further information is needed for this,please let me know. Finally,it should be noted that while Condition 18 does not require certification,it is somewhat confusing. More specifically,Condition 18"cancels"the P163 point from operating permit 95WEOP039 when,as we understood the basis of the COC,the P163 point was to continue with the replacement like-kind engine(albeit with lower emissions),thus making it an AOS change,as provided in the June 2,2009 notice. Therefore,when the requirements of Construction Permit 09WE0195 are rolled into the Title V permit,as provided in Condition 20,the Division may want to consider simply maintaining P163 with the replacement engine as it would with a typical AOS. Should you have any questions please contact me at 303-605-2009 or srondak0idcpmidstream.com. Sincerely, DCP Midstream,LP Stephen Ondak Senior Environmental Engineer CC: Jim King—CDPHE-APCD Operating Permit Unit Supervisor Jennifer Mattox—CDPHE-APCD Environmental Protection Specialist Wesley Hill—DCP Midstream,LP Senior Environmental Specialist Self Certification Form Colorado Department of Public Health and Environment ,en,� Air Pollution Contra!Division OIL AND GAS INDUSTRY CONSTRUCTION PERMIT SELF- • CERT le ,' r ED PERMIT NO:09WE0195 • NAY tit. AIRS ID: 123/0015/081 Issuance 1 DCP)1pm ISSUED TO: DCP Midstream, LP , Estimated Wakh&Safey IMPORTANT NOTICE TO PERMIT.HOLDER: The renewing Self-Certification document must be completed and submitted within 180 days of starting any and all equipment described in the above permit PURSUANT TO C.R.S.§25.7-114.6,FAILURE TO SUBMIT A COMPLETE SELF-CERTIFICATION FOR EACH UNIT WITHIN 130 DAYS OF START-UP MAY RESULT IN FORMAL ENFORCEMENT ACTION AUTHORIZED BY C.R.S. §26.7-115,. UP TO AND INCLUDING PERMIT REVOCATION. This document must be completed and signed by a responsible official as defined Colorado Air Quality Control Commission Regulation No. 3, Part A, §1.8.38. T�.cem�, form. instal on the soaraerdate lines below. All supporting documentation must be submitted with this form. A Construction Permit Final Authorization to Operate will be issued only if all permit conditions are being met. Please save a copy of this completed form for your records. 1. Start-up The following equipment as described in permit number 0SWE0195 has been installed and started: All equipment described in this permit has been installed and started. Notice of Start-up(s) have been filed,and this self-certification document encompasses all equipment listed on the permit 2. `Opacity X I certify this equipment is generating no visible emissions In excess of permit ` limits. (Formal Visible Emissions reading NOT required). AIRS ID: 123/OO15/031 Page 1 of 3 Permit Number. 0SWE0195 Issuance 1 Colorado Department of Public Health and Environment ts Air Pollution Control Division ° tat rtib 3. Emissions and Process Limits ; Xx I certify that this sour] r3mAllance with the permit's process limits for ` Natural Gas Consume DIP 4. Operations and Maintenance Plan • X I certify that upon start-up,this source began following the O&M plan submitted with the permit application,and continues to do so. I certify that to calculate emissions,this source is using the emission factors or methodology described in the permit. I certify that this source is in compliance with the permit's short-term ( emissions limits. S. Compliance Testing and Sampling X1 I certify that the required compliance testing for the equipment described in 1.4 I above has been completed,and the results: pa were submitted to the Division on (ef z-(ZCcet (DATE). 11,44-44' Ais5 ❑ will be submitted to the Division on or before (DATE). 6. NSPS&MACT I certify this source is in compliance with the applicable requirements of: NSPS NESHAPIMACT Not applicable 40 CirR e3 Su remoras for engines greater jthorns P.et me urea aLNAPs Np4 Pitt?\'wind; Note that NSPS JJJJ,MACT Z22%requirements Ibr engines at area sources and MACT =requirements tbrengLas less than or equal to 500 horsepower at major sources of HAP are net currently adopted into Colorado RegcdaSn Na S and are therefore not lncorporsbd Into Issuance 1 of Permit No. l 195 AIRS ID: 123/001S/081 Page 2 of 3 Permit Number 09WE01GS Issuance 1 Colorado Department of Public Health and Environment As rd'), Air Pollution Control Division .„i 77 t 7. Other Requirements X1 certify that the each piece of equipment has been marked with the permit number and AIRS ID. g. I certify that this engine is equipped with an NSCR control device and air fuel ratio control in accordance with Colorado Regulation No.7,XVI.B.1. The responsible official whose signature appears below further certifies to the following: I have reviewed the above paragraphs, the terms and conditions of the Construction Permit referenced above, and the information being submitted for final approval of this 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 condition of this construction 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 S 15-1.501(8), 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 S 25-71221,CAS. doseP H Rut t, , fik , \/rce ?A Ps;DF/YT Printed or Typed Name Title 6 h `it A..,�.. ,„ .--6" W - /E . /0 atu Date Signed • • MRS IO: 123/0015/081 Page 3 of 3 Permit Number: 09WE0195 Issuance 1 Title V Engine Forms Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Natural Gas Processing Plant 2. Facility identification code: 123/0015/ 3. Stack identification code: P-163 4. Engine(Unit)code: C-147 4a. Date first placed in service: 5/20/2009 Date last modified: Ella 5. Engine use: Natural Gas Compression 6. Engine Features: 2-Cycle LI 4-Cycle X Spark-ignition ❑ Diesel [l Standard rich burn X Standard lean burn Li Air/fuel ratio controller X Turbocharger X Low-NOx design ❑ Other(Describ): 7. Emission controls: 11, No x Yes Check all of the following that apply Non-Selective catalytic reduction X Three-way catalyst L Selective catalytic reduction I I Ammonia injected C Oxidation catalyst ❑ Other: 8. Manufacturer: Waukesha 9. Model No: L7042GSI S/N: 2$6440 10. Max Fuel Design Rate: 11.5 rnmBTU/lir 11. Horsepower Max Design: 1,232 Site: 1,232 12. Heat Rate: 9,340 BTU/1-kP-hr 13. Operating Temp: Min. Max. EF 14. Fuels: Primary Fuel Backup Fuel #1 Fuel "1'ype: Natura 1 Gas Heating Value ETU/SCF 1, 040 Sulfur Content (Wt.%) neg Ash Content, (Wt.%) neg Moisture Content (%) Maximum Hourly Consumption (Ft3,gal) J.1, 0 6 4 Maximum Yearly Consumption(Ft',gal) 96, 920, 00 0 NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration I5.OperationaC F�arameters: f 1 yLOW ; , .• -REMARKS Igntagn Ttmrng(degrees)ci.n`,:� wl:, !! ,.. �'. . 1�``" � ,r.•. :{^i .r... •� r f:Sv rr li.'Cr' r+'•. T �s. +, Ini ake'AIr:TTtnnp�'(EF) ;x .` •"3::LJ `cJ r;t;nV. t •;s: ". Au apd Fuel Mati}�old.Pressure' • .trwl I'v: ita� ., .t ., .... .. : . .r + .. ..,.'wt. :�•:a.'�:r'�4:•r eE�.a, ..a.., Exhaust'I't:in r2tnrt•�L "` ��-.i,:�k•,r e„i, ..s4 �;;f?K�'��{c „+tKp,'� c^,> .t;:��t�, :��s::��,�t ..;';t�rr,z';�,.•_;�;�:w,las:�:�'r,. �al,'.� )� {�a�2st` .. ... . . .. , s it �S�� .f, t;.. .s d'.Lr .rte.-'ai.'- ...s• ^4*:xw.r.� , a,�'=,��'t'e:� `•:ii - ....1'.: '.l' - :•:.xA'.: '•:K:J't'i .it-%i. �'Y.' ..a;ExhaustOx ena; - ;a:�:�:..: ;.,i. ,_ �::;-�'• � t:��.: Yg.. ..\.. ,RS 1,� ,,,v "b. f ia�St`:4..'tc„.: .3„ ' ?•„aAy r.' s"r is;`+'��;',i� 'b' .. tl�,r. it[l.•x�"{, a .-. ., -. 4... .. ^. � iy', v;.x yt:. F:.•' .*.h, 'ri°2, its .A(.. ..'t�+•. .. "i.; .3 ;r Vaste:.Gate Positions'.°:ixr;p'a .: :r,r F,.,;.ay, l -.F:� •+,' :;.:: - <?t :s^',; . ..-S� .: . ..;.:.•7:`,t. lk,•7'�•,.::.t2 ;f.T:' ., � :! i ! Fr+ Ct.F '4 7.� •:• >.+.Nl»t es:.. : i 4' telrReguLator`$C7<ttn�;. + b + k, f: 's'5 `�.,...u: i •:.: a s4^V.�r4��,'.�''�rt� `�' .. ... ".. .. lS::: ...•:��. .�.i�!}ta`t�••,'• ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06.95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spmdle Natural Gas Processing Plant 2. Facility identification code: 123/0015/ 3. Stack identification code: P-163 4. Unit identification code: C-147 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number See below 10. Other requirements(e.g., malfunction reporting, special operating conditions from an State Only Compliance existing permit such as material usage, hours of operation, etc.) Status IN OUT See attached construction permit 09WE0195. X DCP is currently in compliance with that permit. ****USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 2 • Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-44 Air Pollution Control Division Facility Name: Spindle Natural Gas Processing Plant Facility Identification Code: 123/0015/ I. ADmIlAsTRATION This application contains the following forms: o Form 2000-100,Facility Identification ❑ Form 2000-101,Facility Plot Plan ❑ Forms 2000-102,-102A,and-102B,Source and Site Descriptions II. EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the following forms ❑ Form 2000-200,Stack Identification (one form for each facility boiler,printing _ ❑ Form 2000-300,Boiler or Furnace Operation ❑ Form 2000-301,Storage Tanks x Form 2000-302,Internal Combustion Engine - 1 ❑ Form 2000-303,Incineration ❑ Form 2000-304,Printing Operations ❑ Form 2000-305,Painting and Coating Operations • ❑ Form 2000.306,Miscellaneous Processes ❑ Form 2000-307,Glycol Dehydration Unit III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: 0 Form 2000-400,Miscellaneous ❑ Form 2000-401,Condensers O Form 2000-402,Adsorbers ❑ Form 2000403,Catalytic or Thermal Oxidation ❑ Form 2000-404,Cyclones/Settling Chambers O Form 2000-405,Electrostatic Precipitators ❑ Form 2000-406,Wet Collection Systems ❑ Form 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following forms ❑ Form 2000-500,Compliance Certification-Monitoring and (one for each facility boiler,printing Reporting ❑ Form 2000-501,Continuous Emission Monitoring ❑ Form 2000-502,Periodic Emission Monitoring Using Portable Monitors ❑ Form 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 ❑ Form 2000-508,Other Methods 3 V. EMISSION SUMMARY AND Total Number COMPLIANCE CERTIFICATION of This Form This application contains the following forms ❑ Form 2000-600,Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan O Form 2000-601,Emission Unit Criteria Air Pollutants ❑ Form 2000-602,Facility Hazardous Air Pollutants C Form 2000-603,Facility Criteria Air Pollutants x Form 2000-604,Applicable Requirements and Status of 1 Emission Unit ❑ Form 2000-605,Permit Shield Protection Identification ❑ Form 2000-606,Emission Unit Compliance Plan- Commitments and Schedule O 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 OR 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. 0 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 Title: Vice President, Operations Northern Division Joseph Kuchinski Signature Date Signed >s� tro g 4 Operating Permit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department of Health 09-9d Air Pollution Control Division Facility Name: Spindle Natural Gas Processing Plant Facility Identification Code: 123/0015/ 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§ 25-7122.1, C.R.S. Printed or Typed Name Title: Vice President, Operations Northern Division Joseph Kuchinski Signature Date Signed //Sy Ad, SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 5 Construction Permit 09WE0195 • STATE OF COLORADO .r . COL a 9 6 DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT • AIR POLLUTION ° DIVISION ( `�J TELE . . E:(303)492-3150 CONSTRUCTION PERMIT PERMIT No: 09WE019.5 • APR 26 2010 issuance 1 DATE 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 Spindle Natural Gas Processing Plant, located In Sec. 34,T2N, R67W,in Weld County,Colorado. • THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility AIRS Description Equipment ID Point One(1)Waukesha,Model L7042GSI, Serial Number 286440,natural gas-feed,turbo-charged,4SRB reciprocating internal combustion engine,site rated at 1232 C-147/P163 081 horsepower at 1000 RPM.This engine shall be equipped with non-selective catalytic reduction(NSCR)system and air-fuel ratio control.This emission unit is used for natural gas compression. • This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7042GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (21.7-101 am), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the APCD no later than thirty days after commencement of the • permitted operation or activity Dv submittina a Notice of Startup(NOS)form to Mt APCD. The Notice of Startup (NOS) form may be downloaded online at • vrww.cdphe.stats.co.us/al/downloadforms htrni. Fadure to notify the APCD of startup of • the permitted source is a violation of AQCC Regulation No.3,Part B,Section III.G.1 and can result in the revocation of the permit AIRS ID: 123/00181081 Page 1 of 18 • NGffngfM Version 2009-1 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 09WE0195 Air Pollution Control Division Issuance 1 ... ........... 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 B, II.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (I) does not commence c onstruction/modifioation 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 gram extensions of the deadline per Regulation No. 3, Part B, ili.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The operator shall complete aft initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self certiflcatlon process. (Reference:Regulation No. 3, Part B, Section PILE.) 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, IIL€.) (State only enforceable) 6. The operator shall retain the permit final authorization letter issued by the Division after completion of self-certification, with the most current con-, permit This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations(as calculated in the Division's preliminary analysis).(Reference: Regulation No. 3, Part B,Section IIA4) Monthly Limits: Facility AIRS Pounds per Month Equipment ID Point NO, VOC co Emission Type C-1471P153 051 4042 1010 4042 PoiM Monthly limits are based on a 31-day month: Annual Limits: Facility AIRS Tens per Year Equillawet 1W Point NO2 VOC Co Emission Type c-141P153 031 23.8 5.9 23.8 Point See tides to Pernik Holder S4 for irdemmatno r cry _.,.:, rectors end methods used to WSW*tmks. During the first twelve (12) months of operation, compliance with both the monthly.and yearly emission limitations shall be required. After he first twelve (12) months of operation,compliance with only the yearly limitation shall be required. AIRS ID: 12310015/081 Page 2 of 18 DCP Midstream, LP Colorado Department of Public Health and Environment • Permit No.09WE0195 Air Pollution Control Division issuance 1 Compliance with the emission limits for this facility shad be determined by no ng the facility's annual criteria pollutant emissions, (including all HAPs above the de.minints reporting level) from each emission unit, on a Sing (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 ADEN,at this facility. 8. This engine shall be equipped with non-selective catalytic reduction(NSCR)system and • air-fuel ratio control. The NSCR shall be capable of reducing uncontrolled emissions of NOx, VOC, CO from the unit to the emission levels listed above. Operating parameters of the control equipment are identified in the operation and maintenance plan. (Reference: Regulation No.3,Pan B,Section IILE.) . PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the fogey/mg maximum consumption 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, IIA4) Process/Consumption Limits Facility sloe Annual Monthly Limit Equipment Point Press Parameter Limit (31 days) 23 C-1411P143 081 Consumption of natural gas as a fuel micf cu • • MMaaeFAr MMsdhnontim • During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve (12) months of operation,compliance with only the yearly limitation shall be required. Compliance with the yearly consumption limits shall be determined on a rolling twelve (12) month totaL By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility,for Division review. • STATE AND FEDERAL REGULATORY REQUIREMENTS 10. Visible emissions shall not exceed twenty percent(20%)opacity during normal operation • • of the source. During periods of startup, process modifiation, or adjustment of control equipment viable emissions shall not exceed 30% opacity for more than six minutes in any sixty cue minutes. (Reference:Regulation No. 1,Section 11.AI&4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) s. 12. This impipment is subject to the control requirements for stationary and portable engines in the 8-hots ozone control area under Regulation No. 7, Section XVI.B.1. For rids burrs reciprocating internal combustion engines,anon-selective catalyst reduction system and • an air fuel controller shall be required. AIRS ID: 123/1013/081 • Pa ge 3 Mill DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.O9WE0195 Air Pollution Control Division Issuance 1 13. This source is subject to the requirements ot. • Regulation No. 8, Part E, Subpart IN.FFFf.: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines(RICE)of 40 C.F.R. Part 63, Subpart 7777 and • Regulation No. 8, Part E Subpart LA, National Emission Standards for Hazardous Air Pollutants for Scree Categories: General Provisions, 40 CFR Part 63 including, but not limited to, the following: • Emission and Operating Limitations • o 963:8800(a) -If you own or operate an existing, new, or reconstructed spark ignition 4SRB stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions, you must comply with the following emission limitations(Table 1a, Subpart 7777 to Pan 63): • Reduce formaldehyde emissions by 76 percent or more,or • Limit the concentration of formaldehyde in the stationary RICE exhaust 350 ppbvd or less at 15 percent O2. o §63.6800(a) -If you own or operate an existing, new, or reconstructed spark ignition 46RB stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions, you must comply with the following operating limitations(Table lb, Subpart ZZZZ to Part 83): • Maintain your catalyst so that the pressure *op 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 amass the catalyst measured during the initial performance test and • Maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 750 °F and less than or equal to 1250 T. • General Compliance Requirements o §83.6605(a) - You must be in compliance with the emission limitations and operating limitations in this subpart that apply to you at all times, except during periods of startup,shutdown, and malfunction. o §13.8805(b) - if you must comply with emission limitations and operating limitations,you must operate and maintain your stationary RICE, inducting air pollution control and monitoring equipment in a manner consistent with flood air pollution control practices for minimizing emissions at all limes,including during startup,shutdown, and malfunction. • • Testing and Initial Compliance Requirements o 303.8810(a) -You must conduct the initial performance test or other initial compliance demonstration in Table 4 to Subpart ZZZZ of Part 83 that apply to you within 180 days after the compliance date that is specified for your stationary RICE In§63.8595 and according to the provisions in§633.1(a)(2), AIRS ID: 123/0015/061 Peg*4018 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Ak Pollution Control Division Issuance 1 o §63.6615 - If you must comply with the emission limitations and operating limitations, you must conduct subsequent performance tests semiannually(as per Table 3 of Subpart ZZ22 to Part 83). After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent • annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission . , o n, or you deviate from any of • your operating limitations,you must resume semiannual performance tests. o §63.6625(a) - If you elect to install a CEMS as specified in Table 5 of this • subpart, you must install, operate, and maintain a GEMS to monitor CO and either oxygen or CO2 at both the inlet and the outlet of the control device • according to the requirements in paragraphs 63.6625(aX1) through 63.6625(4)of Subpart 7777 to Part 63. o §63.6625(b)-If you are required to install a continuous parameter monitoring system (CPMS) as specified in Table 5 of this subpart you must install, operate,and maintain each CPMS according to the requirements in§63.8. o §63.6630(a) - You must demonstrate initial compliance with each emission and operating limitation that applies to you according to Table 5 of Subpart ZZZZ to Par 63. • o §63.6630(b) - During the initial performance teat, you must establish each operating limitation in Tables lb and 2b of Subpart ZZZZ to Part 63 that applies to you o §63.6630(c) - You must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in§63.6645. • Continuous Compliance Requirements o §63.6635(b) - Except for monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), you must monitor continuously at all times that the stationary RICE is operating. • o §63.5635(c) - You may not use data recorded during . monitoring • malfunctions, associated repairs, and required quality assurance or control • activities in data averages and calculations used to report emission or operating levels.You must, however, use all the valid data collected during all other periods. o §63.6640(a) - You must demonstrate continuous compliance with each emission imitation and operating limitation in Tables 1a and lb and Tables 2a and 2b of subpart 7777 of Part 83 that apply to you according to methods • specified in Table 8 of Subpart ZZZZ of Part 63. • o §63.It640(b)-You must repot each Inatome in which you did not meet each emission limitation or operating limitation in Tables 1a and lb and Tables 2a and 2b of Subpart ZZZZ of Part 63 that apply to you. These Instances are deviations from the emission and operating limitations hi this subpart. These i deviations must be reported according to the requirements in 863.6650.1f you • AIRS ID: 123/0015/081 Page 5 of le DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division • Issuance 1 • change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE. o §63.6640(d) - Consistent with §§63.6(e) and 63.7(e)(1), deviations from the emission or operating limitations that occur during a period of startup, shutdown, or malfunction are not violations if you demonstrate to the Administrator's satisfaction that you were operating in accordance with • §63.8(e)(1). For new, reconstructed, and rebuilt stationary. RICE; deviations from the emission or operating limitations that occur during the first 200 hours of operation from engine startup(engine bum-in period) are not violations. o §83.6640(e) -You must also report each instance in which you did not meet the requirements in Table 8 of Subpart 7777 to Part 83 that apply to you. • Notifications,Reports and Records o §63.6645(a) - If you own or operate a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions you must submit all of the notifications in §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) that apply to you by the dates specified. o §63.6645(g) - If you are required to conduct a performance test you must submit a Notification of intent to conduct a performance test at least 60 days before the performance test is =o uled to begin as required in§63.7(b)(1). o §63.6645(h)-if you are required to conduct a performance test or other initial compliance demonstration as specified In Tables 4 and 5 of Subpart 2222 to Part 63, you must submit a Notification of Compliance Status according to §63.9(h)(2)60. . • §63.6646(h)(1)-For each initial compliance demonstration required in Table 5 of Subpart ZZZZ to Part 63 that does not include a performance test, you must submit the Isle le of Compliance Status before the dose of business on the 30th day following the completion of the initial compliance demonstration. • §63.6645(h►(2)-For each initial compliance demonstration required in Table 5 of Subpart Z2ZZ to Part 63 that includes a performance test • conducted according to the requirements in Table 3 to this subpart, you must submit the Notification of Compliance.Status, including the performance test results,before the close of business on the 60th day following the completion of the performance test according to §83.100(2). . o $63.6650(a) - You must subunit each report in Table 7 of Subpart ZZZZ to • Part 63 that applies to you.. o §63,6655(a)-If you must comply with the emission and operating limitations, you must keep the records descrtied m §63.6655(E)(1) through (a)(3), §63.6655(b)(1)through(b)(3)and§63.6655(c). AIRS ID: 12310015/061 Page 6 of 18 - DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division .7 Issuance 1 o §83.6686(d) - You must keep the records required in Table 6 of Subpart • 7777 of Part 63 to show continuous compliance with each emission or • operating limitation that applies to you. o §63.6660(a) -Your records must be in a form suitable and readily available for expeditious review according to§63.10(bx1). o §63.6660(b)-As specified in §63.10(b)(1), you must keep each record for 5 • years following the date of each occurrence, measurement, maintenance, corrective action,report, or record. o §63.6680(c)-You must keep each record readily accessible in hard copy or • electronic form on-site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report or record, according to §63.10(b)(1).You can keep the records off-site for the remaining 3 years. • Other Requirements and Information o §63.6668 - Table 8 to this subpart shows which parts of the General Provisions in§§63.1 through 63.15 apply to you. OPERATING&MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the applicant shall follow the operating and maintenance (OW)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 OW plan are subject to Division approval prior to Implementation. (Reference: Regulation No. 3, Part 8, Section IILG.7.) • COMPLIANCE TESTING AND SAMPLING 1` I Testina Requirements 15. This engine is subject to the initial testing requirements of 40 C.F.R Part 63, Subpart alt/ • Periodic Testing Reaulrementi • 16. This engine is subject to the periodic testing requirements of 40 C.F.R Past 63, Subpart ZZZZ • 17. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. ADDITIONAL REQUIREMENTS • 18. This permit replaces the Sowing points, which are canceled upon issuance of this psi Permit No. AIRS ID Notes S OPWE039 123/0015/054 P163. This engine has been removed and the point will be canceled. AIRS ID: 123/0015/081 Pape 7 of 18 • DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 19. A revised Air Pollutant Emission Notice (APEN) shall be filed (Reference: Regulation No. 3, Part A, [LC) 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. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative o ting scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the permit.* is exercising an afternative'operating scenario and is installing a permanent replacement engine. 20. This source Is subject to the provisions of Regulation Number 3, Pail C, Operating Permits (Title V of the 1990 Federal Clean Arc Act Amendments). The provisions of this construction permit must be incorporated into the operating pert The application for the modification to the Operating Permit is due within one year of commencement of operation of the equipment or modification covered by this permit GENERAL.TERMS AND CONDITIONS: t 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AOCC Regulation No. 3, Part B, Section It.6 upon a request for transfer of ownership and the submittal of a revised APEN and the required fee 22. If this permit specifier states that final authorization has been granted, then the remainder of this condition is not applicable.Otherwise,the issuance of this construction permit does not provide"final"authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25.1-114.5(12Na)C.R.S. and AOCC RegtdatIon No. 3, Part B, Section KG. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit Once self-certification of all points has been reviewed and approved by the Division, It wilt provide written documentation of such,final authorization. Details for AIRS ID: 123/0015/081 Page s of 1s DCP Midstream. LP • Colorado Department of Public Health and Environment • Permit No. 09WE0195 Air Pollution Control Division Issuance 1 obtaining final authorization to operate an located in the Requirements to Self- .. _ Certify for Final Authorization section of this permit 23. 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 . o- identified on the permit 24. 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.RS. 25. 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 ale hallo. This • permit may be revoked at any time prior to self-cert fication and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit If the Division denies a permit conditions imposed upon a permit are contested by the applicant, or the Division revokes a permit the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25.7-114.7(2)(a), C.R.S. requires that all sources required to fie an Air Pollution Emission Notice (APEN) must pay an annual be to cover the costs of inspections and administration. It 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. 27. .Violation of the terms of a permit or of the provision 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 (In)unctions),-122(civil penalties),-122.1 (criminal penalties),C.R.S. • By4euJc; LrkPA. ngineer Permit History • • • Issuance Date Description Issuance 1 This Issuance Issued to DCP Midstream, LP • AIRS ID: 123/0015/051 Page 9 of le • DCP Midstream, LP • Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 Notes to Permit Holder 1) The production or raw material ping 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 exceedence 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 Il.E1. of the Common Provisions Regulation. See:htipJ/w.ww.cdehe.state:eo.us/reaulationslairrecs/100102a000commonorovisioceree:adf. 3) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as Indicated in this permit This information is listed to inform the operator of the Division's analysis of the specific compounds embed if the source(s) operate at the permitted limitations. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Point Pollutant CAS S BIN (lb/yr) reportable? . Rate:04/yr) Formaldehyde 5000 A 2089 Yes 207 Methanol 87581 C 308 No 154 Acetaldehyde 75070 A 281 Yes 141 081 Acrolein 107028 A 285 Yes 133 Benzene 71432 A 159 Yes 80 1,3-Butadiene 108990 A 87 Yes 33 Toluene 108883 C 58 No 2e 4) The emission levels contained in this permit are based on the following emission factors: Perot 081: Emission Factors- Emission-Fasten- Uncontrolled Controlled CAS Pollutant 16IMMBta glbhp-hr Ib/MMBtu glbhp-hr NOx 25964 11.0000 0.4721 2.0000 CO 1.8803 8.0000 0.4721 2.0000 VOC 0.3541 1.50011 0.1180 0.5000 5000 FonnaldehWde 0:9205 0.0808 0.OQ21 (.0087 61561 Methanol 04031 0.0'130 0,0015 410065 75070 Acetaldehyde. 0:0028 0.0118 0.0014 0.0050 107028 Acrolein 0020 0.0111 0.0013 ' 0.0056 71432 semen 0.0016 0.0061 0.0008 0.0033 106990 1,3-Butadiene 0:0001 0.0028 0.0003 00014 108883 Toluene 0.0008 0.0024 0.0008 0.0012 Emission factors are based on a Brake-Specifc Fuel Consumption Factor of 9340 Btulhp-hr, a site-rated horsepower value of 1232,and a fuel heat value of 1040 BW/scf. AIRS ID:12310015/081. Page 10 of 18 DCP Midstream,LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 Emission Factor Sources: CAS Pollutant Uncontrolled EFseurce EP Source NOx Historical referonce for engine typo Catalyst Guarantee CO Historical reference for.engine type Catysteirraetee VOC Historical reference for engine type Catalyst Guarantee 5000 Formaldehyde AP-4Z Table 3.23(712000):NSW Gas Catalyst Guarantee 87561 Methanol AP-42;Table 3.23(7/2000);Nagai Gas Catalyst Efficiency 75070 Acetaldehyde AP-42;Table 3.24(1/2900);Natural Gas Catalyst EAlclency 107028 Acrolein ' AP-4Z Table 3.23(7/2000):Natural Gas Catalyst Efficiency 71432 Snow AP-42;Table 3.24.(1/2000):Natural Gas Gately*Ef$dsncy 106990 1,3-Butadiene AP-42;Table 3.24(112000).Natural Gas Catalyst EBldency 108883 Toluene AP-42;Table 3.2-3(7/2000k Natural Gas Catalyst Efficiency 5) In accordance with C.R.S.25-i-114.1,the Air Pollutant Emission Nods(MEN)associated with this permit is valid for a term of five years. The five-year term for this ADEN expires on February 12, 2014. A revised MEN shall be submitted no later than 30 days before the five-year term expires. 8) This facllty is classified as follows: Applicable Requirement Statue Operating Permit Major Source NOx,CO,VOC Major Source NANSR NOx,CO,VOC MALT HH Major Source Requirements: Applicable Area Source Requirements: Not Applicable MACT ZZZZ Major Source Requirements: 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 weblike listed below: hflpJ/ecf.gpoaccess.gov/ Part It Standards of Performance for New Stationary Sources • NSPS 60.1-f£nd Subpart A—Subpart KIM( NSPS Pot 90,Appendixes Appendix A—Appendix I Put 83:National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 83.148.599 Subpart A—Subpart Z MACT 63.60083.1199 Subpart AA—Subpart OGG MACT 83.120083.1439 Subpart EEE—Subpart PPP MACT 83.144043.6175 Subpart QQO—Subpart YYYY MACT 83.6550 34830 Subpart ZZZZ—Subpart MMMMM MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX AIRS ID: 123/(X115/081 Page 11 of 18 DCP Midstream,LP Colorado Department of Pubfic Health and Environment Permit No.0SWEA195 Air Pollution Control Division Issuance 1 8) An Oil and Gas Industry Construction Permit Sel-Certification Form is included with this permit packet Please use this torn to complete the self-certification requirements as specified in the permit conditions. Further guidance on self-certification can be found on our website at: http:/Avvnv.cdphe.staba.co.us/aploilgaspermitting.html AIRS ID: 123/0015/051 Pages of 18 • DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 • 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.,Pat A,Section IV.A,Operational Flstdbility-AltemaWe 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 requirement This permit incorporates and shall be considered a Construction Permitter any engine replacement performed in accordance with this AOS,and the • permitter)shall be allowed to perform such engine replacement without applying fora 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 ensile engine that requires the use of either a temporary or permanent replacement engine. "Temporary is defined as in the same service for ao 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 monthperiod. The 90 days is the teal number of days that the engine is in operation. Nth.engine operates only part of a day,that day steel 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 pent Al 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 X 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 permits*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 eingine(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 AppUcabilty Reports required under section A1.2 and make them available to the Division upon request • A1.1 The permittee may temporarly replace an extstihe compressor engine that is subject to the emission limits set forth in this permit with at engine that is of tie same manufacturer,model,and horsepower or a different manufacturer,model,or horsepower as the adoring engine without modifying this permit, so long as the emissions from the temporary replacement engine comply with the emission • Imitations for the existing permitted engine as determined in section At Measurement of emissions' from the temporary replacement engine shall be made as set forth in section A.2. A1.2 The penalise 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 permieed annual emission Imitations for the • AIRS ID: 123/0015f(IB1 Page 13 of 18 DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 existing engine,2) any permitted short-term waggon limitations for the existing permitted engine,and 3) the applicable emission limitations as set forth in the Applicability Report submitted to the Division with the Air Pollutant Emissions Notice(APEN)for the replacement engine(see ht//www.cdahe.state.co.us/ao/ouaasoemdttina html for example applicability report formats). • Measurement of emissions from the pemianerit replacement engine and compliance with the applicable emission limitations shall be made as set forth in section A/. 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 snaky shall be filedwith 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 permiuee is exercising an akemative 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 jatio://www.cdohe.state.co.usbobligasoermittine.html. This submittal shall be accompanied by a certification from a person legally authorized to act on behalf of the source Indicating that"based on the information and belief brined after reasonable inquiryy,the • statements and information Included in the submittal ere sue,accurate and complete". This AOS carrot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permitee 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 PSDMANSR requirement. Additionally,in the event that any permanent engine replacement(s)constitute(s)a circumvention of applicable PSDMANSR requirements,nothing in this AOS shall excuse the permitee frem complying with PSI SR and applicable permitting requirements. Al Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplcativetesting 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(Le.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 permitt a 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 pennittse 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. • • AIRS ID: 123/0015/081 Page 14 of 16 :V. DCP Midstream,LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 All portable analyzer testing required by this permit shall be conducted using the Divhbn's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's website at http://mws.cdpite.state.co.uslap/down/portanalyzeproto.pdf Results of the portable analyzer tests shall be used to matte the compliance status of this unit For comparison with an annual(tons/year)or short term(leslunit of time)emission limit,the results of the tests shat be converted to a lb/hr bass and multiplied by the allowable operating hours in the month or year(whichever apples)in order to monitor=implants. Us source is not leaked in its hours of operation the test results will be multiplied by the madman number of hours in the month or year(6760),whichever applies. For comparison with a short-term limit that is either input based(kulmmtibu),output based(g/hp-hr)or concentration based(ppmvd©15%O2)that the existing unit is enemy 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 =~ it 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 fall 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 oftlne. • A.3 Applicable Regulations for Permanent Engine Replacements A.3.1 Reasonably Available Control Technology(RACY):Reg 3,Part B§110.2 NI permanent replacement engines that are located In an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology(RACY) for the pollutants for which the area Is attainment/maintenance or nonettanment. Note that both VOC and NOX we precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area Is in attainment/maintenance or nonattainment,except as follows: • In the Denver Metropolitan PM10 attainment/maintenance area,RACT apples to PM10 at any level of emissions and to NOX and$O2,as precursors to PM10,New potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes adds 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 Imitations inn NSPS JJJJ • NOX The emission limitations in NSPS JJJJ SO2: Use of nature)gas as fuel PM10: Used natural gas es fuel As dinned In 40 CFR Part 60 Subparts GO(§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. AIRS ID: 123/0015/081 Page 15 of 16 • • DCP Midstream, LP Colorado Department of Public Health and Environment Permit No. 09WE0195 Air Pollution Control Division • Issuance 1 A3.2 Control Requirements and Emission Standards:Regulation No.7,Sections XVI.and'XVII.E (State-Only conditions). Control Requirements:Section XVI • Any permanent replacement engine located within the boundaries of an ozone nonaltainment area is subject to the applicable control requirements specified in Regulation No.7,section XVI,as specified below: Rich burn engines with a manufacturets design rate greater than 500 hp shall use a non- selective catalyst and at 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 shad be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition Al2.. • Emission Standard:Section WILE—State-only requirements • • Any permanent engine that is either constructed or to the state of Colorado from another state, alter the date listed le 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. • Construction or Emission Standards in Glhp-hr Max Engine HP Relocation Date NO,r • CO VOC January 1,2008 2.0 4.0 1.0 100<Hpc500 January 1,2011 1.0 2.0 0.7 500<Hp Juy 1',2009 2.0 4.0 1.0 July 1,2010 1.0 2.0 0.7 The source shaii submit copies of the relevant Applicability Reports required under Condition&1.2 - A3.3 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 then 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 use subject 40 CFR 60.Subpart JJJJ. An analysis of applicable monitoring,recorcetteping..and reporting requirements for the permanent • engine replacement shad be included in the Applicability Reports required under Condition A1.2.My ' tasting required by the NSPS is in addition to that required bythis AO$. Nob that the initial test required try NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition A2,if approved in advance by the Division,provided that such test is conducted within the time frame specified hi Condition • A2. • • Note that under the previsions of Regulation No.8.Parts,section Le.that Relocation of a source from outalde of the State of Colorado into the Stab of Colorado is considered to be a new source,subject to AIRS ID: 123/101S/081 Page 16 of le DCP Midstream, LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance 1 the requirements of Regulation No.6(I.e.,the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). • However, as of November 1, 2008 the Division has not yet adopted NSPS JJJJ. Until such Nina as It • does,any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ,there wit be en addifknnaf step added to the determination of the NSPS. Undertlie provisions o1Regulation No.6,Part 9, §IS(watch is referenced in Part A),any engine relocated from • outside of the State of Colorado into the State of Colorado is considered to bee new solace,subject to the requirements of NSPS JJJJ. A3.4 Reciprocating Internal combustion engine(RICE)MACT:40 CFR Part 83,Subpart ZiZZ A3.4.1 Area Sauce 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,w6 meet the requirements of 40 CFR Part 63, Subpart ZZZZ by meeting the requirements of 40 CFR Pail 60,Subpart JJJJ. M analysis of the applicable monitoring,re ordkeeping,and repotting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition A1.2. My 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 Al,if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition A.2. • A3.42 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 speck ignition 4 stroke rich bum 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 12/19102)2 stroke and 4 stroke lean bum engines with a site rating of more than 600 hp are subject to the requirements in 40 CFR Part 63 Subpart 2227 New or reconstructed(construction or reconstruction commenced after 6/12/06)4s0*.lean burn engines with a site rating of greater than or equal to 250 but less or equal to 500 hp and were manufactured on or after 1/1/08 are subject to the requirements in 40 CFR Part 63 Subpart ZZZZ. New or reconstructed(construction or reconstruction commenced after 6/12/06)2 stroke lean bum or 4 stroke rich bum 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(kxnsb uejon or reconstruction commenced after 6112/06)4 stroke lean burn engines with a site rating of less than 250 he wig meat the requirements of 40 CFR 63. Subpart 2332 by meeting the requirements of 40 CFR 60,Subpart JJJJ. M analysis of the apple monitodng,reconlkeeping,and reporting requirements for the permanent engine replacement shell be included in the Applicability Reports required under Condition Al2 My testing required by the MACT is In addition to that required by gate AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS MRS ID: 123/0015/081 Page 17 of 18 DCP Midstream,LP Colorado Department of Public Health and Environment Permit No.09WE0195 Air Pollution Control Division Issuance I under Condition A2,if approved in advance by the Division, provided that such testis conducted within the time frame specified in Condition A2 A3.b 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 therefor)essentially an advanced construction permit review. The AOS cannot be used for additional new emission point for any ea 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 o =«_ prior to installation. • • AIRS ID: 123/0015/081 Page 18 of 1a Current APEN aof i I � �• 1 'TW' �+• r1�A ❑ T xi 1 ill I $$i. II 1 M11 I i 11 S / G j - 3 • 13I§ �) phi % � 11M/�1 6 oeat 5, ,4 Eii Lp a afl a b 6t0-Fes I i If ii ' ! ifl ! IIl f: I xI IllIIuuII 8�i I P1 'gals " FigAlv Zoo o ❑ ❑ 10 i E .,® I cal ' iii I1Lfl il I ' II I ei H '� Z 0-40- '! 11 I I8 6 s 3 ?Mil p„ g W I I M a ❑❑al g s s o 2 I 1 I kJ] I .tai❑ & .6411 6m taa. ' I °' �! if; ill I ItII1 �( i IiiiL 6 ijil illI jJ •� Jii I 1 1 • ' 1 . 1 ill' H _ Z 4 3 co Ws t i n ill aiti4 2qt:if ii' Iii tg at 3 ! 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I x0000@0000000101111110 ®onuu®®ueeuaeeioiiiia - .• } 0aaaaaaa99a1aa1111111 - - 4 Ieeeleee99e1®®1111111 - 9 r 111D11111DI1e911111© - - a ; a I 11011111911@9111111® = g lIIiu 0AI011AA1111101111119 = 5 5 5 9 9 8 m U 61110119111111191111® g A��__ j l99999999999699I111110 • • = ; I I d 900990090009691111119 4 IL 000008090000001111110 a a _ I - @ 990090090090001111119 I !IIIIFI P S � 4 It to} Q$d asa�6!0.>a8m max $ e�6$ J cddi ic' 1 b oil Correspondence DCP Spindle Gas Plant-09WE0195 Page I of 2 Hill, Wesley D From: Adam Beng[abeng@oaconsulting.com] Sent: Thursday, December 31, 2009 11:11 AM To: Stefanie Rucker Cc: Hill,Wesley 0; Ondak, Stephen R Subject: RE: DCP Spindle Gas Plant-09WE0195 Stefani, Please find my comments to for the draft permit below. Condition 1: This unit has already started up. It was switched out as an AOS on May 20, 2009. An AOS submittal was turned in on June 2, 2009. If an additional start-up notice aside from this AOS submittal is needed, please let us know. Please remove this condition or correct it to say within 30 days of issuance of this permit. Condition 2: Since the engine has been running since May. Please change this to say within 180 days from issuance of the permit. Condition 4: This condition mentions initial testing. There should not be any initial testing required. (see below) Condition 5: Please remove permit number from this condition or make it the title V permit number as the engine will be rolled in shortly. Condition 13: The manufacture date of the engine is April 11, 1975 making it an existing 4SRB engine at an area source of HAP emissions. Therefore, this engine is not subject to MACT ZZZZ requirements. Please remove the ZZZZ language from the permit. Condition 15: Engine not subject to the ZZZZ requirements, please remove. Condition 16: Engine not subject to the ZZZZ requirements, please remove. Thank you, Adam Adam Berig, PE I Air Consulting Services I Olsson Associates 4690 Table Mountain Drive,Suite 200 I Golden, CO 80403 I aberig@oaconsulting.com TEL 303.237.2072 I EXT 2229 I CELL 303.589.1945 ] FAX 303.237.2659 \OLSSON AssocIAtes From: Stefanie Rucker[mailto:Serucker@smtpgate.dphe.state.co.us] Sent:Tuesday, December 22, 2009 10:26 AM To: Wesley D Hill;Adam Berig 8/19/2010 DCP Spindle Gas Plant- 09WE0195 Page 2 of 2 Subject: DCP Spindle Gas Plant-09WE0195 Attached is a draft permit for the replacement Waukesha engine,Point 081. This engine will replace the previously permitted Waukesha engine under Point 054. If you have any comments or questions,please let me know by December 31,2009. Thanks! Stefanie E. Rucker Environmental Engineer APCD-Oil&Gas (303)692-3188 8/19/2010 UPS-CampdsShip: Shipment Label Page 1 of 1 UPS CampusShip: View/Print Label I. Print the label(s): Select the Print button on the print dialog box that appears. Note: If your browser does not support this function select Print from the File menu to print the label. L. Fold the printed label at the solid line below. Place the label in a UPS Shipping Pouch. If you do not have a pouch, affix the folded label using clear plastic shipping tape over the entire label. 3. GETTING YOUR SHIPMENT TO UPS Customers without a Daily Pickup Schedule a same day or future day Pickup to have a UPS driver pickup all your CampusShip packages. Hand the package to any UPS driver in your area. Take your package to any location of The UPS Store®, UPS Drop Box, UPS Customer Center, UPS Alliances(Office Depot®or Staples®)or Authorized Shipping Outlet near you. Items sent via UPS Return ServicessM (including via Ground) are also accepted at Drop Boxes. To find the location nearest you, please visit the Resources area of CampusShip and select UPS Locations. Customers with a Daily Pickup Your driver will pickup your shipment(s)as usual. FOLD HERE w 1 O 0 1 zIMPIIIIIIIIINIMPIIMOIMEN 5C cn N N g pp CO o a o x' co - $ N O rn coo V 41: I:147 c6 c,7 A � Tr utt'' g kiel *.se I 0 N a- - �pbgli wa CA p 6 ; §N No alavv A §1.•. © z • 7 tioa7G z i T E Ecl a https://www.campusshM.ups.comkshipicreateMctionOriginPair=print Receipt&POPUP_LEVEL=1&... 8/19/2010 im DCP Midstream icLr] 370 17th Street, Suite 2500 Midstream. Denver,CO 80202 3Q3-595-3:3?? March 17, 2011 Hand Delivered Mr. Jim King ;1 Colorado Department of Public Health and Environment APCD-SS-B 1 ``'` '. 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: MINOR MODIFICATION Spindle Natural Gas Processing Plant(Spindle)—95OPWE039 Dear Mr. King: DCP Midstream, LP (DCP) is filing for a minor modification of the Title V Operating Permit No. 95OPWE039 for the Spindle Gas Processing Plant. Minor modification application forms for Title V permits have not been developed,therefore,this letter and attachments serve as the application. The required APENs and emissions calculations are attached. Checks totaling $611.60 are also enclosed. The minor modification serves two purposes that are related. First, this modification addresses what would otherwise qualify as a like-kind replacement of P161 (C-137 -AIRS ID 123/0015/052). Compressor engine P161 is identified in the Title V permit as a 1,000 hp, Waukesha L70424 GSI engine. The serial number of the old engine is 286434, while the serial number of the replacement engine is 350086. The replacement engine commenced operation on March 3, 2011. It was tested on March 7, 2011 using a portable analyzer to measure NO,and CO emissions. The results of the portable analyzer test show that the engine is in compliance with the current emission limits. The replacement engine was relocated from within Colorado (i.e., from the Lucerne Plant) to Spindle, so Regulation No. 7, Section XVII.E does not apply(see attached documentation). A field log is maintained to document all engine replacements. Both the test results and copy of the field log are provided with this submittal. The modification also seeks to adjust the horsepower rating of both P161, in addition to the following Waukesha L7042 GSI engines which are also located at Spindle: • P160 (C-136), AIRS ID 123/0015/051; • P162 (C-138), AIRS ID 123/0015/053;'and • P166 (C141), AIRS ID 123/0015/057. l Please note that on April 20,2009, this unit was the subject of an AOS and a related determination under Regulation No. 7 that effectively lowered the emission limits for the unit. On July 29,2010, we filed a revision to the April 2009 AOS to address a serial number discrepancy discovered in the earlier filing. The unit will continue to meet the lower level of emissions specified in the April 2009 AOS. www.dcpmidstream.com dcp Midstream. March 17, 2011 Page 2 of 3 The horsepower adjustment better represents the compression and horsepower that could occur during operation of the units during warmer summer months. The brake specific fuel consumption (BSFC)value has also been adjusted to accurately represent the most recent BSFC data specified by Waukesha(see attached Waukesha specification sheet). The compliance emission factors in the permit are not affected by the modification. All four engines are equipped with AFRs and NSCRs. Each unit meets and maintains compliance with the current emission limits in the Title V permit. Based on this, the horsepower rating for units "S160, S161, S I62, and S166"should be changed to 1,232 hp in the following Sections of the Title V permit: • Section I, Condition 4.2.10, Table 1 and Condition 6.1; • Section II, Conditions 1 and 12; • Section III, Condition l; • Appendix B.2; and • Appendix C.1. The changes qualify for treatment as a minor modification under Regulation No. 3, Part C, Section X because they: • Do not violate any applicable requirement; • Do not involve significant changes to existing monitoring, reporting, or record keeping requirements in a permit; • Do not require or change a case-by-case determination of an emission limitation or other standard or a source-specific determination for temporary sources of ambient impacts. or a visibility or increment analysis; • Do not seek to establish or change a permit term or condition for which there is no corresponding underlying applicable requirement and that was assumed to avoid an applicable requirement to which the source would otherwise be subject; • Are not accepted from the definition of permit modification in Regulation No. 3, Part C, Section I.A.3.; and • Based on our review of Regulation No. 3, they do not otherwise require processing as a significant modification. Please note that the current Title V permit for Spindle expired on May 1, 2004. DCP filed a timely renewal application on May 1, 2003, which the Division has yet to process. In the interim, Spindle has been operating under a Title V renewal application shield. At such time that the Division processes the Title V renewal application, we request that this minor modification be reflected in the renewal permit. dcp Midstream_ March 17, 2011 Page 3 of 3 If you have any questions, feel free to contact me at(303) 605-1716. Sincerely, DCP Midstream, LP Wesley Hill Senior Environmental Specialist Attachments I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). Joseph Kuchinski Vice President, Operations Printed or Typed Name Title • 3 ^ii-/-0201/ ature f es on ible Official Date Waukesha L7042GSI Emission Calculations Spindle Natural Gas Processing Plant DCP Midstream,LP Engines C-136,C-137,C-141 (4 Stroke,Rich Burn,1,232 HP)-PTE using 7580 btulhp-hr BSFC Unit Rating: 1,232 hp BSFC: 7,580 btu/hp-hr Maximum Heat Input: 9.3 mmbtu/hr -Operating Schedule: 8.760 hr yr . FHV: 1.040 btu/scf Maximum Fuel Use: 78.66 mmscf/yr Criteria Pollutant Emission Calculations Uncontrolled Controlled Uncontrolled Uncontrolled Emssions Emission Factors' Potential Emissions Pollutant Emission Factors (ton/yr) (ton/yr) NOx' 11.0 gibhp-hr 130.86 3.33 g/bhp-hr 39.62 CO' 8.0 g/bhp-hr 95.17 3.33 g/bhe-hr 39.62 VOC' _ 1.5 g/bhp-hr 17.84 0.82 g/bhp-hr 9.74 PM b 9.50E-03 lb/mmbtu 0.39 9.50E-03 lb/mmbtu 0.39 SO2b 5.88E-04 lb/mmbtu 0.02 5.88E-04 lblmmbtu 0.02 'Manufacturers emissions factors b Uncontrolled emission factors from 4-stroke,Rich-bum(4SRB)engines from AP-42,Chapter 3,Table 3.2-3.(7/00). Non-Criteria Reportable Pollutant Calculations Potential Emissions Control Efficiency Controlled Emissions De Minimis' Pollutant HAP Emission factors° Data Source (lblyr) % (Ib/yr) Bin (Ib/yr) 1,1.2,2-Tetrachloroethane 2.53E-05lb/mmBtu EPA 2.07 50% 1.03 A 50 1,1,2-Trichloroethane <1.53E-05 lb/mmBtu EPA <1.25 50% 0.83 A 50 1,1 Dichloroethane <1.13E-05 lb/mmBlu EPA <0.36 50% 0.18 B 500 1,2 Diehtoroethane <1.13E-05 lb/mmBtu EPA <0.36 50% 0.18 A 50 1.2 Dichloropropane <1.30E-05 ib/mmBlu EPA <0.41 50% 0.20 A 50 1,3-Butadiene 6.83E-04 1b/mm9lu EPA 54.24 50% 27.12 A 50 1,3-Dichloropropene <1.27E-05 lb/mmEttu EPA <1.04 50% 0.52 A 50 Acetaldehyde 2.79E-03 lb/mm8tu EPA 228.25 50% 114.12 A 50 Acrolein 2.63E-03lb/mmBtu EPA 215.16 50% 107.58 A 50 Benzene 1.58E-03 lb/mmBtu EPA 129.26 50% 64.63 A 50 Carbon Tetrachloride <1.77E-05 lblmmBtu EPA <1.45 50% 0.72 A 50 Chlorobenzene <1.29E-05 Ib/mmBtu EPA <1.06 50% 0.53 A 50 Chloroform <1.37E-05 Ib/mmBtu EPA <1.12 50% 0.56 A 50 Ethylbenzene <2.48E-05 lb/mmBtu EPA <2.03 50% 1.01 C 1000 Ethylene Dibromide <2.13E-05 Ib/mmBtu EPA <1.74 50% 0.87 A 50 Formaldehyde 2.05E-02 lb/mmBtu EPA 1677.10 76% 402.50 A 50 Methanol 3.06E-03lb/mmBtu EPA 250.34 50% 125.17 C 1000 Methylene Chloride 4.12E-05 IblmmBtu EPA 3.37 _ 50% 1.69 A 50 Naphthalene <9.71E-05 lblmmBtu EPA <7.94 50% 3.97 C 50 PAH 1.41E-04 lb/mmBtu EPA 11.54 50% 5.77 A 50 Styrene <1.19E-05 lb/mmBtu EPA <0.97 50% 0.49 C 1000 Toluene 5.58E-04 lb/mmBtu EPA 45.65 50% 22.82 C 1000 Vinyl Chloride <7.18E-06 tb/mmBtu EPA <0.59 50% 0.29 A 50 Xylenes(m,p,o) 1.95E-04 lb/mmBtu EPA 15.95 50% 7.98 C 1000 TOTAL 0.0324537 IblmmBtu -- <2653 -- -- °Uncontrolled emission factors for HAP from 4-stroke.Rich-bum(4SRB)engines from AP-42,Chapter 3,Table 3.2-3,(7/00). °Deminimis levels for reportable non-criteria pollutants.per Colorado Regulation No.3. Cordilleran a Division of Olsson Associates 3/16/2011 Waukesha L7042GSI Emission Calculations Spindle Natural Gas Processing Plant DCP Midstream,LP Engines C138(4 Stroke,Rich Burn,1,232 HP)-PTE using 7580 btu/hp-hr BSFC-REG 7 Applicable Unit Rating: 1,232 hp BSFC: 7,580 btu/hp-hr Maximum Heat Input 9.3 mmblu/hr Operating Schedule: 8,760 hr/yr FHV: 1,040 btu/5Cf Maximum FuelDse: 78.66 mmscf/yr Criteria Pollutant Emission Calculations Uncontrolled Controlled Uncontrolled Uncontrolled Emsslons Comp OF Emission Factors• Potential Emissions Pollutant Emission Factors (ton/yr) Ib1MMBTU (ton/yr) NOx• 11.0 gibhp-hr 130.86 0.58 2.00 g/bhp-hr 23.79 CO• 8.0 g/bhp-hr 95.17 0.97 333 g/bhp-hr 39.62 VOC• 1.5 glbhp-hr 17.84 0.24 0.82 g/bhp-hr 9.74 PM° 9.50E-03 lb/mmbtu 0.39 9.50E-03 lb/mmbtu 0.39 SO,° 5.88E-04lb1mmbtu 0.02 5.88E-041b/mmbtu 0.02 •Manufacturer's emissions factors o Uncontrolled emission factors from 4-stroke,Rich-bum(4SRB)engines from AP-42,Chapter 3,Table 3.2-3,(7/00). Non-Criteria Reportable Pollutant Calculations Potential Emissions Control Efficiency Controlled Emissions De Minlmis° Pollutant HAP Emission factors° Data Source (iblhr) (Iblyr) % (Ib/yr) Bin (Ib/yr) 1,1,2,2-Tetrachloroethane 2.53E-05 lb/mm8tu EPA <2.36E-04 2.07 50% 103 A 50 1,1,2-Trichloroethane <1.53E-05 lb/mmetu EPA <1.43E-04 <1.25 50% 0.63 A 50 1,1 Dichloroethane <1.13E-05 lb/mm6tu EPA <4.07E-05 <0.36 50% 0.18 a 500 1,2 Dichloroethane <1.13E-05 lb/mm8tu EPA <4.07E-05 <0.36 50% 0.18 A 50 1.2 Dichloropropane <1.30E-05 lb/mmetu EPA <4.68E-05 <0.41 50% 0.20 A 50 1,3-Butadiene 6.63E-04IblmmBtu EPA 6.19E-03 54.24 50% 27.12 4 50 1,3-Dichloropropene <1.27E-05 lb/mmBtu EPA <1.19E-04 <1.04 50% 0.52 A 50 Acetaldehyde 2.79E-03Ib/mmBtu EPA 2.61E-02 228.25 50% 114.12 A 50 Acrolein 2.63E-03lb/mm6tu EPA 2.46E-02 215.16 50% 107.58 A 50 Benzene 1.58E-03Ib/mmBlu EPA 1.48E-02 129.26 50% 64.63 A 50 Carbon Tetrachloride <1.77£-05 lb/mm8tu EPA 1.65E-04 <1.45 50% 0.72 A 50 Chlorobenzene <1.29E-05 Ib/mmBtu EPA 1.20E-04 <1.06 50% 0.53 A 50 Chloroform <1.37E-05 Ib/mmBtu EPA 1.28E-04 <1.12 50% 056 A 50 Ethylbenzene <2.48E-05 Ib/mmQtu EPA 2.32E-04 <2.03 50% 1.01 C 1000 Ethylene Dibromide <2.13E-05 Ib/mm0tu EPA 1.99E-04 <1.74 50% 0.87 A 50 Formaldehyde 2.05E-02 lb/mmetu EPA 1.91E-01 1677,10 76% 402.50 A 50 Methanol 3.06E-03 lb/mmetu EPA 2.86E-02 250.34 50% 125.17 C 1000 Methylene Chtonde 4.12E-05 Ib/mm8tu EPA 3.85E-04 3.37 50% 1.69 A 50 Naphthalene <9.71E-05 Ib/mm6tu EPA <9.07E-04 <7.94 50% 3.97 50 PAH 1.41E-04 lb/mmetu EPA <1.32E-03 11.54 50% 5.77 A 50 Styrene <1.19E-05 Ib/mm6tu EPA <1.11E-04 <0.97 50% 0.49 1000 Toluene 5.58E-04 tb/mm0tu EPA 5.21E-03 45.65 50% 22.82 C 1000 Vinyl Chloride <7.18E-06Ibimm8tu EPA 6.71E-05 <0.59 50% 0.29 A 50 Xylenes(m.p,o) 1.95E-04Ib1mmBtu EPA <1.82E-03 15.95 50% 7.98 C 1000 TOTAL 0.0324537 IblmmBtu <3.03E-01 <2653 °Uncontrolled emission factors for HAP from 4-stroke,Rich-bum(ISRB)engines from AP-42,Chapter 3,Table 3.2-3,(7100). °Deminimis levels for reportable non-criteria pollutants,per Colorado Regulation No 3 • Cordilleras a Division of Olsson Associates 3/17/2011 Documentation of Former Location of C-137 Replacement Engine FormerLocationSpindleC-137.txt facility_name equipment_name serial_nbr equip_type manufacturer_name model_name equipment_status start_date end_date Lucerne Gas Processing Plant C-107, 123/0107/018 350086 Engine waukesha L-7042GSI Shutdown / Never Built 11/30/2005 00:00:00 06/17/2010 07:55:11 Page 1 IO z. 1, r'� a a rIi h a` 5 ') N a''o vi Ci g y o cH � 8 �t ° �e N o z N FFe r a -I vM t o m - N G a p.g e F• a: 50 li , E 1 cn c F V •,: N g p a T aU V E e T F Ec734. y '- ra g y [2 ❑ o m " m I a aa. i1 u g ,8 uu p. 3 O I �H{ NLr, "+ ite a 6. 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X60 �._I �'� �m Za Q y „ ' � l V QUI wil be Fti g S a •� a g h 3 w u �B e c •C N Q Z I 'a c a .7 7 GG « X i I" n m• 4 I �v B y ,z _ „ Fam�6 a„ _u . yo < .a F c O0. = •afia W w 8 8.1 , wr I = F• _ I 0.e0.4,_ g �,p� ,; w• ° Pl ≤ a g SG�d 4r- F - ° 0 5 ' P .n h a 10 p .4 ^ 8 a'.�� A $ ° s3 o �d a z € QC0 )aa cc .S _ c9 �Sa1 SW y °4 ° o fT Q O u°. 0 8 'nag m o O Z z z WH.. E rat $.4(JA114 o d a. a CO) o? rG se o ._ 3' "I u� g ' Ord /"d cU �o a'' x S zm, p. 1 a O 8 z 8 n z a 9 i za a g 2 ' rax c ' l FW °m u .8 W Sa e ' wP- '4 53t Manufacturer's Specifications Waukesha L7042GSI RATINGS & STANDARDS 2 ENGINE RATINGS AND FUEL CONSUMPTION CONTINUOUS RATING FOR MODEL L7042GSI 130' F (54°C) INTERCOOLER WATER PART LOAD FUEL CONSUMPTION WASTEGATES SET FOR CONTINUOUS HP RATING 10000" I I I I I II 9800 _ F-__ 10%OVERLOAD RATING 9800 W , CONTINUOUS DUTY RATING Z r fl•cc*= 9200 - %b 9000 .. 1- Or' 1 8800IL 21 i O M 8600 F" a- moo I , • 1 8200 r g ' sooco4 , U l 7800 f i • W 0 H 1200 _ � 75�/......;14r00-1 �.. 1000 7200► 800 1 7000 4 - 600 I r , . 200 300 400 S00 600 700 800 900 1000 1100 1200 1300 1400 1300 1000 1700 1800 BHP RPM 700 800 900 1000 1100 1200 CONTINUOUS BHP 862 985 1108 1232 1355 1478 OVERLOAD BHP 946 1081 1216 1351 1486 1621 OVERLOAD 10%Allowed 2 Flours Per 24 Hours STANDARD CONDITIONS Barometer Ambient Temperature 29.54 in. Hg. (100 kPa) 77°F(25°C) DEDUCTIONS Altitude.2 Percent per 1000 ft. (305 m)above 6000 ft (914 m) Ambient Temperature: 1 Percent per 10°F(5.5°C)above 100°F(38°C) FUEL Dry Natural Gas—900 Btu/ft3(33.5 J/cm3)SLHV Refer to S-7884-7 for Full Fuel Specification EQUIPMENT Engine Equipped with Lube Oil and Cooling Water Pumps but without Radiator Fan ENGINE DATA Turbocharged&Intercooled with 130°F(54°C)Intercooler Water 8:1 Compression Ratio NOTES: 1. Engine carburetors adjusted to stoichiometric air/fuel ratio(Lambda= 1). 2. Standard engine turbocharger match for 600— 1200 rpm Page 1 of 1 immiiiimmignmil DRESSER ENGINE TINGS AND FUEL CONTINUOUS RATING MO EOLNL7042GSION EN: 114363 RCf. 130°F(54°C)I.C.WATER TEMPERATURE DATE: 4/02 278-,7 Waukesha C-137 Portable Engine Test Data ...................... ....................... O vl Vl V O N n O P h O N Vl O P VI W W W or'' ° ° ° 0 -1- O O ^ P O 0 O YI } O N Y O V } O N U U 4 ON OM (I) 00W V1 O 4 Vi N O O O 4N N. O0 O OJ W O V W O O.. . s 0 -1- w 4 W L V 4 P 0m O O, n n rn O M h O V cep 4 O n '. � ry 0000 ,n � o or, O 'nYo ^ } d. 6 ° e N N ° ° ° 0e crl 4 n .O O O O W O ICI W O V W O V• W d u 4• ,,-. o e } o Y o "4 Y o } 4 � r o .o mo obrno � v, Oern o � � 0000n PM oc Y, o •ooY o .i j, o � Y 0. U N O n 0 " P Vl O N VJ V] O fA V O O O 4 ,n O• T e O O 04 = b W W O O W 62 O O } O NI Y O O Y O N } 0. U m N Occ }: b 4 O V n oc conO O O W = O v) EnW O O W O r6 W q.; ... - 0 ° 0 0 P n O V-1 >. O N Y un Y o O ry Y N: 4 U m W: N ; w. N a q: my eN no = - W = bW cimW . bW 000 o w a; - 001 >. 6 `>. = 4" ›.. .= m ). M 4. 6 w {v� rim[,' ty 3 C IsQ 88 N '. 4C X 00 4 of O VI O V h O CI) O V Vi •fi::,4}....,,,...,::4I:•. : 'R • o 0 0 o w m o c{ Yon Y o °` Yon } as D: Gk a a () m a 61 en 4 e 0 0 y M: 4 N O F N _ II � 0, 0 V n o 0 o e r- n o ? m W . b W o e W . • W x.::::„0:::::::::::;.,:„....:, o o. d. V _ w m - 0 0 Y om ai oe } cc' } O R5: P D M! O C. o N ' " L_ N j"S M m 0 .0n er- no o °° W o0 W O4 COI c ^ W . . - - oo0ow m ^ occYomY 0 < } 0 :` Y 0 ry = 8 U w .... m F > o 3 O0 E c N 015 8 o N.o o o P o e "tot; ^ e c W °> " W e ld Z ��, rvv o. UM ,Onaon P � 6O -‘2,_. .% � �, oc� y -La,: } N 0 o 6 + p Ej ^ 4 N ✓r '• `p e 1 O V e O VJ O b h O _ Et, O V VJ W - !; U H s - 000 _ m o: n ocC Y, onY oaYonY c V 000 lil II II u. a * 000 ao .m.m II I p II %� II II II p O L L = p N . a = 3 3 II 1.: ,,:-_. y. E a .• r .. $ m E `m `m II II II II II ,�= c �,'- F." II a � u $ II EEC F aaE00:1une Va ;,;1 u.-o..] Ii = °' o 0 o a n 3 m " m = 0 m = 0 et 0�' E O 5 E O EE :° Uxm � aEL) ! U y ;jZ ' ;jZ s. u u U c t A F ..l T y W T . >..4 . a. � E d m .. z n E y E ," ❑ Ce > a a Ey ,z` hj. W ' 5W 'EY '"V" E II h .. > ≥ " E = o W •E r ,_,= 'E -0 H W s " W s = 4 ,2 3 m 6 ,L.38 ,!„!,. .,.., ,&, V U T o o U v V U d Z O d Z 0 ; C. m �' mU U wz W z d z u u = 0 o EAZin V iw W K ` 18 . '" "8 . .41 '° . .°47 . L v " " E _? •of u v x .xv n m E E R E E ,8t0 ,8 •80 EE E uxi 4.. E HvI 'v3 w 222 Z 2 2' 2 Eau c`. U G a . Colorado Emissions AFR Test Data Log Midstream_ Plant Location: SPINDLE Converter Manufacturer: Inspection Date: 3/7/201 1 Convertor Model: Plant Permit: 950PWE020 Flange Sizes: Engine Manufacturer: WAUKESHA AFR Manufacturer: Engine Serial Number: 350086 AFR Serial Number: Engine Model: 7042-GSI AFR Model: Unit Number: C-137 Engine RPM 977 ENERAc3000E: ON COMM 1 EN I SS INS TEST RECORD Suction Pressure 5 08:H01-09:00:01 03/07/11 PARANiEirR AVG OXYGEN Discharge Pressure 690 0 CARBON ONOXIDE 54.98 Engine Timing 20 N I TR I C'►X I DE 79.05 N I TROGF, DIOXIDE 0. Main Fuel Pressure 20 OX I DES P1I 1'ROG 79.05 Cony.DIH.Pressure 1.4 Left Bank Maniflod Pressure 6.2 Right Bank Manifold Pressure 8.1 Lambda Settings 02 Sensor Targot .80 02 Sensor Voltage .79-.79 Pre-Converter Exhaust Temp. 970 Post-Convertor Exhaust Temp. 986 Loft Bank Exhaust Temp. 1175 Right Bank Exhaust Temp. 1195 Posl-Convortor CO PPM: 54.9 Post-Converter NOX PPM: 79.0 02 Percent: 0 Remarks New engine start-up Remarks 1ST SEMI TEST L J'b!/11 E NERr;C P.147:.IDIEI.... C317-300E: No Aufozero Errors on Sensors SERIAL tt 3E001180 rJER 1C 1'•1•�•DL 3 o o�E C-7AL " ERr+T TI ON PR OT000L SERIAL ti 3E001180 '- ►, y�.E R r��/JT''I :^•N 7� 'o.r r�•�.�� L. BY: 4iJh �C�' BY: v" �i► TIME: 09:34: 11 DATE: 04/07/11 TIM : 08:27: 14 DATE: 03/07,11 CO SPAN GAS: 1000 PPM' CO SPAN GAS: 1000 PPM SENSOR CALIBRATION SUCCESSFUL SENSOR CALIBRATION SUCCESSFUL • CO SENSOR OK 1;NER�C M•7,.DEL. 3 01313E CO SENSOR OK SERIAL 11 3E001198 E l'AERPIC MODEL 3 C.3 0 OE �:Rr'3T I • NP7?OTOC:` L SERIAL U 3E00I180 C A FRrT I 0 R! F>R�.T-O c�OL BY: �.hi CXX BY: TIME: 09:38:57 —' DATE: 03/87/1Y1' t TIM : 08:32:31 DATE: 03/07/11 "NO"SPAN GAS 500 PPM "NO"SPAN GAS; 680 PPM SENSOR CALIBRATION SUCCESSFUL • SENSOR CALIBRATION SUCCESSFUL. J Engine Replacement Log ' DCP Midstream, LP PAYEE NUMBER CHECK NUMBER 370 17th Street,Suite 2500 0000074502 00278763 Denver,Colorado 90202 PAYEE NAME CHECK DATE APCustomerService@dcpmidstream.com 303.605.2219 COLORADO- 03/16/11 INVOICE NUMBER INVOICE DATE NET AMOUNT DESCRIPTION SpindleC-137APEN0308 03/08/11 152.90 return check to Wes Hill 1 .10 \ p'serTOTAL PAID $152.90 PLEASE RETAIN FOR YOUR RECORDS a IJ O Midstream, LP JPMorgan O,ase Bank,NA. so-4n/213 .7th Street,Suite 2500 Syracuse,New York ;� er,Colorado 80202 u. istomerService@dcpmidstreantcom PAYEE NO.. CHECK DATE CHECK NO. 505.2219 0000074502 03/16/11 00278763 HE ORDER OF OOOOOO,[)O3,g, �.� 'tl7lDe CHECK AMOUNT Ni NOT NEGOTIABLE AFTER 120 DAYS *******852.90 COLORADO- DEPT OF PUBLIC HLTH &ENVRNMNT y w AIR POII CNTRL DIV APCD SSB1 25405 4300 CHERRY CREEK DR SOUTH Den Denver,CO 80246-1530 AUTHORIZED SIGNATURE 9ne hundred fifty two and 90/100 Dollars H•L. :ETWEENTHUM:AN. F• EFINGE ,•- :•EATHE 'NC+L'•E. :•X,C•L' WILL 'ISA EAR,THEN REA PEA . ii'00 278 76 3O 1:0 2 1 309 3 791: 6O 189 5 196O DCP Midstream, LP PAYEE NUMBER CHECK NUMBER 370 17th Street,Suite 2500 0000074502 00278764 Denver,Colorado 80202 APCustomerService@depmidstreamcom PAYEE NAME CHECK DATE 303.605.2219 COLORADO- 03/16/11 INVOICE NUMBER INVOICE DATE NET AMOUNT DESCRIPTION Spindle7042APENS0309 03/09/11 458.70 return check to Wes Hill F-(1/4 Q c` TOTAL PAID $458.70 PLEASE RETAIN FOR YOUR RECORDS �l'1�7RNX I•SN1111gwhi'/P1[d A]•Id 791N7N•I 111`1 i 7`Yr`I'IYI�"F•r�9 111'Y 1691-IH'I'7"-{,•/\ I lYll•In-"/tl"9 /1•Pf 7'YI°I i / 6' ll 7� JPMorgan Chase Bank,N.A. P Midstream, LP 50-937/213 .r. 17th Street,Suite 2500 Syracuse,New York her,Colorado 80202 -ustomerservice@dhpmidstream.com ` PAYEE NO. CHECK DATE CIIECK:NO. 505 2219 0000074502 03/16/11 00278764 THE ORDER OF 00000000P Y4S8Lo CHICKAMoVNT NOT NEGOTIABLE AFTER 120 DAYS *******$458.70 COLORADO- DEPT OF PUBLIC HLTH &ENVRNMNT AIR POll CNTRL DIV APCD SSB1 p O, 4300 CHERRY CREEK DR SOUTH Den h� a A r �- - Denver,CO 80246-1530 Ara-- AUTHORIZED SIGNATURE Four hundred fifty eight and 70/100 Dollars 2 H•L• =ETWEENTHUM- AN• F• EFINGE ,•- 'REATHE •NG•L•`E• .•X,C•L• WILL HSA FA ,THEN EA EA _ 11'00 27876411' I:0 2 1 309 3 791: 60 L895 19611' 0 L Y 0 N C O 0 N N N M M en Vl 00 ON C1 C ty TY Ca Ol O 0 O O O O O M 0 0 0 0 0 0 0 C) R u .•• -2' r N M co CT V (-1 c--;-) 0 N , v1 en 'D -" N G C u m N .N. N.. N \ .. \O \ �\ N \ N F4 Q V) (~ T \-. Ol --. Vl N M .--- V V Vl M D W C 0 C) O O N N N en en tr. oo O .C C Cr. O O 0 0 0 en en 0 0 V 0 0 C\ 0 - 'j 4, i' N N 00 7 00 t� 0 O\ oO V 2O 0 C R h N N N -- 00 00 N CO h N N 00 N en ,Z •la V] G - 01 .-•. .-. 0 Vl 0 en ^ 7 7 in M LU 0. 00 00 - en enN 00 t� M 7 en N vl 0 0 V M O .�. 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M 0/ N M — 00 T O A b 0 LCD 0 '-O l0 l0 'O 0 '0 0 0O 0 0 O �O N 'CO C d a. F a a d. a s 0. 0. a. 0a. a a a a as „ � ,3 C O .9 en T0 O 0\ Ol tt en 00 O —N b N O D` 00 t` to V en en V .r. en O" InN en en 'C M M V M N dCp DCP Midstream 370 17th Street,Suite 2500 -�...■�� Denver,CO 80202 Midstream 303-595-333 April 29, 2009 o. Ms. Lisa Clarke Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Execution of Alternate Operating Scenario (AOS)-Spindle Natural Gas Processing Plant, Operating Permit No. 95OPWE039 Dear Ms. Clarke: This letter is a follow-up to the letter submitted April 15, 2008 to notify you of the upcoming like-kind permanent engine replacement for engine P-164 at the Spindle Natural Gas Processing Plant.The replacement was completed on April 24, 2008.Please find a revised APEN and supporting documentation required under Operating Permit 95OPWE039, Section 4.2. A $119.96 check is attached for the APEN filing fee. Compressor engine P-164 is identified in the operating permit as a 1,000 hp, Waukesha L7042GS1 engine. The serial number of the old engine was 388531 and the serial number of the replacement engine is 335792. The replacement engine commenced operation on April 24, 2008 and was tested on April 25, 2008, using a portable analyzer to measure NOx and CO emissions in its exhaust stream.The results of the portable analyzer test showed that the engine is in compliance with the current emission limits. This engine will also meet the current Regulation No. 7 emissions limits.The APEN has been updated to reflect these limits. A field log is maintained to document all like-kind engine replacements. Both the test results and a copy of the field log are provided with this submittal. Please feel free to contact me with any questions regarding the use of the AOS to account for the above mentioned like-kind engine replacement at the Spindle Natural Gas Processing Plant. Sincerely, DCP Midstream, LP Steph Ondak Senior Environmental Engineer www.dcpmidstream.com N N N VO O N m p N E ?, C r. a a any s N O mss, ; .� � E C 0 I 0 o ` E ^4 F rn N en Q V 0 O .z .> CO EA 'O J N O` N p'1 2 L ro u O\ V G\ cn r. c o a '> 4 O u c b ^\o m 0 Z. V, n c e E c c E = n M M E n o c1 c v u `o W o0 " `° c 0 0 C, O 'n : ro I C i i irgF n ^ > 9 c = t L er, r0 `. O O — 2 co W to N Vi O e c L '� R C _ n w z I,F. -O r V C. 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O a .9 I n 'e I o u° I ev aci t v, v d > ... y eva Z F ` e.U ti v --0.Z o Z U F- ❑ 'in o O� �°� C L C d am A o u.@)vs er .; `� o 0- CI)a y 00 m et o co) s O Lilo u] to co on U Q V) Z r.- Waukesha 7042 GSI Emission Calculations Spindle Gas Processing Plant DCP Midstream, LP Waukesha 7042 GSI (4 Stroke, Rich Burn, 1000HP) Unit Rating: 1000 hp BSFC: 9340 btu/hp-hr Maximum Heat Input: 9.3 mmbtu/hr Operating Schedule: 8760 hr/yr FHV: 1040 btu/scf Maximum Fuel Use: 78.3 mmscf/yr Criteria Pollutant Emission Calculations Emission Factorsa Potential Emissions Pollutant (ton/yr) NOx 2.0 g/bhp-hr 19.31 CO 4.0 g/bhp-hr 38.63 VOC 1.00 g/bhp-hr 9.66 a Manufacturer's controlled emission factors which meet current Reg 7 levels. Non-Criteria Reportable Pollutant Calculations Potential Emissions De Minimis° Pollutant HAP Emission factors b Data Source (Ib/yr) Bin (lb/yr) 1,1,2,2-Tetrachloroethane 2.53E-05 lb/mmBtu EPA 2.06 A 50 1,1,2-Trichloroethane <1.53E-05 lb/mmBtu EPA <1.25 A 50 1,1 Dichloroethane <1.13E-05 lb/mmBtu EPA <0.36 B 500 1,2 Dichloroethane <1.13E-05 lb/mmBtu EPA <0.36 A 50 1,2 Dichloropropane <1.30E-05 lb/mmBtu EPA <0.41 A 50 1,3-Butadiene 6.63E-04 lb/mmBtu EPA 54.01 A 50 1,3-Dichloropropene <1.27E-05 lb/mmBtu EPA <1.03 A . 50 Acetaldehyde 2.79E-03 lb/mmBtu EPA 227.30 A 50 Acrolein 2.63E-03 lb/mmBtu EPA 214.26 A 50 Benzene 1.58E-03 lb/mmBtu EPA 128.72 A 50 Carbon Tetrachloride < 1.77E-05 lb/mmBtu EPA <1.44 A 50 Chlorobenzene <1.29E-05 lb/mmBtu EPA <1.05 A 50 Chloroform < 1.37E-05 lb/mmBtu EPA <1.12 A 50 Ethylbenzene <2.48E-05 lb/mmBtu EPA <2.02 C 1000 Ethylene Dibromide <2.13E-05 lb/mmBtu EPA <1.74 A 50 Formaldehyde° 1.11E-02 lb/mmBtu EPA 907.72 A 50 Methanol 1.17E-02 lb/mmBtu EPA 953.18 C 1000 Methylene Chloride 4.12E-05 lb/mmBtu EPA 3.36 A 50 Naphthalene <9.71E-05 lb/mmBtu EPA <7.91 C 50 PAH 1.41E-04 lb/mmBtu EPA 11.49 A 50 Styrene < 1.19E-05 lb/mmBtu EPA <0.97 C 1000 Toluene 5.58E-04 lb/mmBtu EPA 45.46 C 1000 Vinyl Chloride <7.18E-06 lb/mmBtu EPA <0.58 A 50 Xylenes(m,p,o) 1.95E-04 lb/mmBtu EPA 15.89 C 1000 TOTAL 0.0317357 lb/mmBtu — <2584 -- — ° Uncontrolled emission factors for HAP from 4-stroke,Rich-burn(4SRB)engines from GRI-HAPCalc 3.01,based on EPA's AP-42. c Deminimis levels for reportable non-criteria pollutants,per Colorado Regulation No.3. ° Manufacturer's formaldehyde emission factor. 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Englno Model: L-7042OS1 AFR Model: EPC-100 - ° ii Wilt Number. C-139 ,,. SERIAL a 3E001183 q Au1'OZERC., PR4TOCOL Engine RPM 952 I Suction Pressure 5 Discharge Prossuro 160 Engine'Boling 19.5 SERIAL it 3E001193 E NERAC MODEL 300216E 0 6E Meln Fool Pressure 20 COMBUSTION TEST RECORD Pro-Convortor Proseuro 6.8 FOR: DCP MIDSTREAM Post.Convonor TIME: 09:46:00 Proasuro 4.8 DATE: 04/25/08 Loft Bank Hammed 10.1 FUEL NATURAL GAS:21870 21870 ETU/LB Rigtrt Bank Man[fold Pressure 12.5 COMBUSTION EFFICIENCY: 96.4 Lambda Siting .98 AMBIENT TEMPERATURE: 63 °F STACK TEMPERATURE: 73 °F 02 Sensor Target .78 OXYGEN: 00.0 /. CARBON MONOXIDE: (M) 44 PPM 02 Sensor voltage .78_.78 CARBON DIOXIDE: 12.0 % Pro-CommmvElhoust COh1BUSTIRIF G/SES: 6.N0 . '1 EXCESS AIR: 0 % Tamp nvortorEcheust 991' NITRIC OXIDE: (M) 56 PPMPast- NITROGEN DIOXIDE: 0 PPM Tomp. 899 4OX ( NO + NO2) : 56 PPM Loft Bank Exhaust STACK GAS VELOCITY: N.A. FPS Temp 1079 NOD CONTROL TEMP: UNDER 30 C Right Bank Exhaust MODE:PPM OXY. -.J2EF=TRUE Temp. 1078 Poct-onvorter CO PPM: 44 ' Post-Cenvortor NOX PPM: 56 JLKJ.NL 4 .LO@l It1.i CAL P HRe ct ION PRO-rOCO 02 Percent 0% BY: I LL 'cri TIME: 09:43:25 DATE: 02y1 ,08 Remarks: NEW ENGINE TEST NO2 SPAN GAS 52 FPM em SENSOR CALIBRATION SUCCESSFUL NO2 SENSOR OK NO" SENSOR FILTER OK ENERAC MODEL 3001aE SERIAL tt 3E01103 Copy P.O. Box 5493 Duke Energy® Denver, Colorado 80217 Pi%Field Services 370 17`h Street, Suite 900 Denver, Colorado 80202 Direct: 303-595-3331 A New Kind of Energy Fax: 303-893-8902 May 1, 2003 Mr. Michael E. Jensen Air Pollution Control Division Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Duke Energy Field Services, LP Spindle Gas Plant Title V Operating Permit Renewal Application —95OPWE039 Dear Mr. Jensen: Duke Energy Field Services, LP (DEFS) is submitting the attached Title V Operating Permit Renewal Application for operating permit 95OPWE039. DEFS is submitting a complete application despite only minor changes to the operation in order to have an up to date and accurate application and information on file with the Colorado Air Pollution Control Division due to several previous changes. Some of the changes that DEFS would like to address in the operating permit Renewal include the following. DEFS is requesting that the Methane/Ethane composition analysis requirement in section 5.1 of the Title V Permit be removed. It is DEFS' belief the consistency in the percent methane/ethane has been shown to be consistent based on significant amounts of data previously retrieved. DEFS would like to alter the Alternate Operating Scenario (AOS) for Spindle Gas Plant. Currently, DEFS is required to "notify the Division in writing at least five calendar days prior to undertaking and permanent engine replacement" (Section 4.2.1 in the Title V Permit). Based on recent EPA evaluation of like-kind engine swaps at PSD facilities, DEFS believes the requirement can be changed to match the AOS at other similar facilities, where an APEN may be submitted for the replacement engine within fourteen days of commencing operation. With this submittal, DEFS is including eleven revised Air Pollution Emission Notices (APEN). The APENs for these units would expire in the near future or required revisions. DEFS is sending a check for the APENs in the amount of$1319.56 under separate cover. Please find attached the following appendices: Appendix Documents A State of Colorado Title V Operating Permit Application Forms B Previously submitted APENs C Revised APEN with this application D Portable Testing Monitor User's Manual and Manufacturer's Information E Map and Plot Plan of the facility F Compliance Assurance Monitoring Plan Should you have any questions or require additional information, please do not hesitate to call Dirk Wold at 720-944-9220 or email him at dlwold@duke-energy.com. Sincerely, Duke Energy Field Services, LP George, ourcier General Manager of Operations— Rockies Region Cc: Ashley Campsie—Regional Environmental Representative— Rockies Region, DEFS John Admire—Acting Environmental Manager—Rockies Region, DEFS James Wakeley—Asset Manager—Weld County, DEFS Operating Permit Application FACILITY IDENTIFICATION FORM 2000-100 Colorado Department of Public Health and Environment Air Pollution Control Division Rev 06-95 SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name and Name Spindle Gas Processing Plant mailing address Street or Route 9101 Weld County Rd 14 City, State, Zip Code Ft Lupton, CO 80621 2. Facility location Street Address 3 1/2 miles west of Fort Lupton, CO (No P.O. Box) City,County, Zip Code Fort Lupton, Weld, 80621 3. Parent corporation Name Duke Energy Field Services, LP Street or Route PO Box 5493 City, State, Zip Code Denver, CO 80217 Country (if not U.S.) 4. Responsible Name George Courtier official Title General Manager of Operations — Rockies Region Telephone 303-595-3331 5. Permit contact person Name Ashley Campsie Title Environmental Engineer (If Different than 4) Telephone 303-595-3331 6. Facility SIC code:1321 7. Facility identification code: CO 123-0015 S. Federal Tax I. D. Number: 841041166 9. Primary activity of the operating establishment: Natural Gas Liquids Processing and Gathering 10. Type of operating permit New Modified / Renewal 11. Is the facility located in a "nonattainment" area: Yes ✓ No If "Yes", check the designated "non-attainment" pollutant(s): Attainment for all Pollutants Carbon Monoxide Ozone PM 10 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 Application FACILITY PLOT PLAN FORM 2000-101 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Spindle Gas Processing Plant Facility Identification Code: CO 123-0015 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 11", 8 1/2" X 14" or 11" X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. .2. The maximum height of each buiidiag fetichiciiin slack height;. 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. 1 i (2 2111(2121 t 1 pro; ern: b n i r - 5. Identify direction "North" on all submittals. Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? Yes ✓ No If"Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? ✓ Yes No List the name(s) of any neighboring state(s) within a 50 mile radius of your facility: None • 2 Operating Permit Application SOURCE AND SITE DESCRIPTIONS FORM 2000-102 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name:$pindle Gas Processing Plant Facility Identification Code: CO 123-0015 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use "NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. 1.Briefly describe the existing Unit(s) to be permitted. Attach copies of Form 2000-700 as needed to provide the information. Process owsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the cation and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing 'understanding of the processes involved. The Spindle Gas Processing Plant consists of two operations: a gas processing skid and a fractionation assembly. The gas plant skid consists of two expander plants identified as Plant A and Plant B. The gas processing skid utilizes straight refrigeration coupled with cryogenic expander processes to recover natural gas liquid (NGL) mixtures from the inlet gas stream. The NGL stream is sent to the fractionation assembly to make various fuel products. A high Btu content methane/ethane residue gas stream is created by the removal of the NGL. The residue gas stream is recompressed and routed to the sales pipeline. A triethylene glycol(TEG) dehydration system operates to dehydrate a slip stream of the residue gas used to regenerate the mole sieves. The mole sieves function to dehydrate the inlet gas. There are twelve (12) engines powering natural gas compressors operating in inlet, residue, refrigeration or air compressor service. One(1) TEG dehydration unit operates to remove the water from residue gas used to regenerate the mole sieves. The site also operates with a 15 million Btu per hour hot oil heater, one condensate loadout rack, one propane and BG mix loadout rack, four (4) 300 barrel condensate storage tanks, six (6) small natural gas fired heaters for various purposes, and one emergency flare stack. 2.Site Location and Description(Include instructions needed to drive to remote sites not identified by street addresses) The Plant is located near 3 'h miles west of Ft. Lupton in Weld County, Colorado. The Plant address is 9101 Weld County Road 14, Fort Lupton, CO 80621. Driving Directions: From Fort Lupton, go 3.5 miles west on Highway 52 and then 'A mile north on County Road 19. 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: Protection Other, specify /Hard Hat /Safety shoes /Hearing Protection /Gloves 3 Operating Permit Application SOURCE DESCRIPTION-APENS FORM 2000-102A Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Spindle Gas Processing Plant Facility Identification Code: CO 123-0015 NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of$100 per APEN. 1.For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice(APEN)on file with the Division. If the cost current APEN was not completely and correctly filled out,a revised APEN is required. List an APEN number,date,and a brief description f the unit/process covered by the APEN. (No filing fees are needed for these copies) S160 Waukesha L7042GSI 5/1/2003 S161 Waukesha L7042GSI 5/1/2003 S162 Waukesha L7042GSI 5/1/2003 S163 Waukesha L7042GSI 5/1/2003 S164 Waukesha L7042GSI 5/1/2003 S165 Waukesha L7042GSI 5/1/2003 S166 Waukesha L7042GSI 12/09/2002 S167 Waukesha F1197 GU 4/14/2003 S168 Caterpillar G342NA 4/14/2003 S169 Waukesha L7042 GU 5/1/2003 S170 Superior 8SGTB 5/1/2003 S171 Superior 6G825 5/1/2003 S002 Superior 6G825 5/1/2003 FS181 Non-KICK Fugitives 10/6/2000 FS181A KKK Fugitives 10/6/2000 S178 TEG Dehydration System 1/26/2001 8179 15 MMBtu Hot Oil Heater 3/21/2002 FS182 Condensate Truck Loadout 5/01/2003 2.No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a onstruction permit application. 4ew APEN and permit application submitted with this application OR under separate cover to Construction Permits Section 3.A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A evised APEN is needed where a significant increase in emissions has occurred, or is planned;or a major modification of the unit has occurred or s planned;or the existing information needs correction or completion. A construction permit application may need to be submitted. :evised APEN submitted as part of this application: ✓Yes No ✓Filing Fee Enclosed New permit application enclosed: Yes /No Permit modification application enclosed: Yes ✓No S182 Condensate Truck Loadout 5/1/2003 S160 Waukesha L7042GSI 5/1/2003 S161 Waukesha L7042GSI 5/1/2003 S162 Waukesha L7042GS1 5/1/2003 S163 Waukesha L7042GSI 5/1/2003 S164 Waukesha L7042GSI 5/1/2003 S165 Waukesha L7042GSI 5/1/2003 S169 Waukesha L7042 GU 5/1/2003 S170 Superior 8SGTB 5/1/2003 S171 Superior 6G825 5/1/2003 S002 Superior 6G825 5/1/2003 NOTE: Use additional copies of Form 2000-700 as needed to provide the above information. 4 NOTE: Use additional copies of Form 2000-700 as needed to provide the above information. Operating Permit Application SOURCE DESCRIPTION- INSIGNIFICANT ACTIVITIES FORM 2000-102B Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division Facility Name: Spindle Gas Processing Plant Facility Identification Code: CO 123-0015 NOTE:The operating permit must be prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessary to provide complete information in the operating permit application.The Division will not consider or act upon your application unless each form used has been entirely completed. main categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source •iely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's aissions trigger the major source threshold as defined in Part A, Section I.B.58 of Regulation 3. For the facility, mark all insignificant ,isting or proposed air pollution emission units, operations, and activities listed below. (a)noncommercial (in-house) experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories, environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non-criteria reportable pollutant. Disturbance of surface areas for purposes of land development, which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). V Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, which uses gaseous fuel, and which has a design rate less than or equal to 5 million Btu per hour. (See definition of fuel burning equipment, Common Provisions Regulation). Petroleum industry flares, not associated with refineries, combusting natural gas containing no H2S except in trace (less than 500 ppmw) amounts, approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. Chemical storage tanks or containers that hold less than 500 gallons, and which have a daily throughput less than 25 gallons. Landscaping and site housekeeping devices equal to or less than 10 H.P. in size (lawnmowers, trimmers, snow blowers, etc.). Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. ✓ Chemical storage areas where chemicals are stored in closed containers, and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from, to, or between such containers. V Oil production wastewater (produced water tanks), containing less than 1% by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. s Storage of butane, propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met, where applicable. ✓ Storage tanks of capacity G 40,000 gallons of lubricating oils. Venting of compressed natural gas, butane or propane gas cylinders, with a capacity of 1 gallon or less. Fuel storage and dispensing equipment in ozone attainment areas operated solely for company-owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. /Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii) the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils #1 through#6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of.025 PSIA). ✓ Each individual piece of fuel burning equipment which uses gaseous fuel, and which has a design rate less than or equal to 10 million Btu per hour, and which is used solely for heating buildings for personal comfort. Stationary Internal Combustion Engines which: (i) power portable drilling rigs; or (ii) are emergency power generators which operate no more than 250 hours per year; or (iii) have actual emissions less than five tons per year or rated horsepower of less than 50. Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. "Air pollution emission units, operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets (MSDS) do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY 7 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S160 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P160 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ✓ Engine Location Identified 6. Indicate by checking: "'This stack has an actual exhaust point l le .)al li leers are ni,.rc(1 trl l!eins This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP)exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): ✓ Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum_ (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature(normal): 1055 (?F) 11. Does process modify ambient air moisture content? Yes V No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: . ✓Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 8 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S161 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P161 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The Viral n re ;we entered in Items 7-13, This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 1055 (? F) 11. Does process modify ambient air moisture content? Yes ✓ No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: "Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes "No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 9 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S162 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P162 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: ✓This stack has an actual exhaust point. File.parameters tat. entered in !It IIIS 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): ✓Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature(normal): 1055 (? F) 11. Does process modify ambient air moisture content? Yes ✓ No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: - /Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 10 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S163 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P163 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 "Engine Location Identified 6. Indicate by checking: "This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): "Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 1055 (?F) 11. Does process modify ambient air moisture content? Yes I No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: "Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes "No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 11 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S164 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P164 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: "This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): "Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 1055 (? F) 11. Does process modify ambient air moisture content? Yes V No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ✓Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 12 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S165 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P165 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When suck height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum ' (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature(normal): 1055 (? F) 11. Does process modify ambient air moisture content? Yes ✓ No If"Yes", exhaust gas moisture content: Normal ' percent Maximum percent 12. Exhaust gas discharge direction: ✓Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes /No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 13 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S166 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P166 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 36 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 1 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 1055 (? F) 11. Does process modify ambient air moisture content? Yes ✓No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: /Hp Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes /No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 14 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S167 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P167 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 16.8 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 0.5 (feet) Rectangular length(feet) ` width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 52.2 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 1100 (? F)11. Does process modify ambient air moisture content? Yes ✓ No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ✓Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 15 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S168 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P168 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ✓Engine Location Identified 6. Indicate by checking: 1This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice(GEP)exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7: : . Discharge height above ground-level:: 14 '(feet) 8.. Inside dimensions at outlet(check one and complete): ✓Circular .: -0:67 (feet). Rectangular length (feet)` feet width(feet) 9. `~,Exhaust tlovli-rate:;:`-: _ _ = Normal (ACFM) ': Maximum (ACFM) Velocity 48.9 FPS Calculated .-Stack Test =. . - . ' -• .. . - 10. Exhaust gas temperature(normal): 1170 (? F) Does process modify ambient air moisture content? Yes ✓.Na:- 11. , If"Yes", exhaust gas moisture content: Normal . percent . `Maximum percent 12. : Exhaust gas discharge direction: ✓Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes "Na . *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 16 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S169 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P169 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice(GEP)exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7.:' - Discharge height aboveground level: 26 (feet) 8, " Inside dimensions at outlet(check one and complete): ✓Circular - 1 (feet) Rectangular length(feet) width(feet) 9: . Exhaust flow rate: ;�` •Normal. (ACFM) - Maximum (ACFM) Velocity 114.1 -:`"(FPS) Calculated Stack Test - ` . 10. Exhaust gas temperature(normal): 1055- (? F) . 11. Does process modify ambient air moisture content? ""Yes ✓No If"Yes",exhaust gas moisture.content: Normal percent Maximum percent 12.::.:`_ Exhaust gas;discharge`direction: ✓Up Down Horizontal 13. Is this stack equipped with.a rainhat or any obstruction:.to the.-free:flow of the exhaust gases from the stack? Yes /No *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 17 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S170 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P170 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 "Engine Location Identified 6. Indicate by checking: "This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice(GEP)exceeds 65 meters(Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. Discharge'height above ground level: 24 :.(feet). 8. ;;._Inside dimensions at outlet(check one and complete)::-: ✓Circular';: 1.17 _(feet). _ Rectangular length(feet) `.width(feet) =9.. ,°:__ ,Exhaust flow rate: __.Normal (ACFM) Maximum' (ACFM) • Velocity:.: 135.6 (FPS).. Calculated Stack Test ! -� - 10. Exhaust gas-temperature(normal): 970 (?:F).. _ 11. Does process modify ambient air moisture content? .'Yes ✓No If"Yes",exhaust gas moisture content: -. Normal • percent Maximum percent 12. : . Exhaust gas discharge direction: ✓Up Down Horizontal 13 .:Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 18 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S171 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 P171 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 24 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 0.67 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 1165.5 (FPS) Calculated Stack Test 10. Exhaust gas temperature(normal): 1250 (? F) 11. Does process modify ambient air moisture content? Yes 1 No If"Yes" exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: /Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 19 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: C0123-0015 3. Stack identification code: P002 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 CIG-S-2 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 /Engine Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice(GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 13.7 (feet) 8. Inside dimensions at outlet(check one and complete): /Circular 0.66 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) - : Maximum (ACFM) Velocity 168.85 (FPS) Calculated Stack Test 10. Exhaust gas temperature(normal): 1040 (? F) 11. Does process modify ambient air moisture content? Yes ✓No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: /Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of -- the exhaust gases from the stack? Yes /No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 24 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S178 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 2000-307 P178 5. Stack identified on the plot plan required on Form 2000-101 /Dehydration System Location Identified 6. Indicate by checking: This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7, Discharge height above ground level: (feet) 8. Inside dimensions at outlet(check one and complete): Circular (feet) Rectangular '- length(feet) width(feet) 9. Exhaust flow rate: : Normal (ACFM) Maximum (ACFM) Velocity (FPS) Calculated Stack Test. 10. Exhaust gas temperature (normal): (? F) 11. Does process modify ambient air moisture content? Yes No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 20 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: S179 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 P179 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 "Heater Location Identified 6. Indicate by checking: /This stack has an actual exhaust point. The parameters are entered in Items 7-13. This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: 33 --(feet) 8. Inside dimensions at outlet (check one and complete): ✓Circular 3 (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 13 (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): 675 (? F) 11. Does process modify ambient air moisture content? Yes ✓No If''Yes", exhaust gas moisture content Normal percent Maximum percent 12. Exhaust gas discharge direction: ✓Up Down Horizontal 13. ` Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes ✓No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 21 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: FS181 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s)2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 P181 2000-307 5. Stack identified on the plot plan required on Form 2000-101 6. Indicate by checking: This stack has an actual exhaust point. The parameters are entered in Items 7-13. V This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D) data entry is required for Item 7. 7. Discharge height above ground level: (feet) 8. Inside dimensions at outlet(check one and complete): Circular (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): (? F) 11. Does process modify ambient air moisture content? Yes No If"Yes", exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 22 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO123-0015 3. Stack identification code: FS181A 3a. Construction Permit Number: 95OPWE039 4. Exhausting Unit(s), use Unit identification code from appropriate Form(s) 2000-300, 301, 302, 303, 304, 305, 306, 307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306 P181A 2000-307 5. Stack identified on the plot plan required on Form 2000-101 6. Indicate by checking: This stack has an actual exhaust point. The parameters are entered in Items 7-13. V This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. When stack height Good Engineering Practice (GEP) exceeds 65 meters (Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: (feet) 8. Inside dimensions at outlet(check one and complete): Circular (feet) Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity (FPS) Calculated Stack Test 10. Exhaust gas temperature (normal): (? F) 11. Does process modify ambient air moisture content? Yes No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: Up Down Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? Yes No *****Complete the appropriate Air Permit Application Forms(s) 2000-300, 301, 302, 303, 304, ***** 305, 306, or 307 for each Unit exhausting through this stack. 23 Operating Permit Application BOILER OR FURNACE OPERATION FORM 2000-300 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 95OPWE039 3. Stack identification code: S179 4. Unit code: P179 5. Unit description: OPF-HMO natural gas fired heater for heating hot oil 6. Seasonal Fuel Dec-Feb: 25 Mar-May: Jun-Aug: 25 Sep-Nov: 25 Usage(%) 25 7. Normal Operation Hours/Day: 24 Days/Week: Hours/Year: 8. Space Heat(%) NA of Unit 7 8760 9. Indicate the boiler/furnace control technology status. /Uncontrolled Controlled If the boiler/furnace is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-401 2000-402 2000-403 2000-404 2000-405 2000-406 2000-407 10. Furnace type: Hot Oil Heater 11. Max continuous rating(mmBTU/hr): 15 13. Model &Serial #: J87426 12. Manufacturer: OPF 14. Date first placed in service: 1994 Date of last modification: 15. Fuels and firing conditions: Natural gas fired Primary fuel Backup fuel #1 Backup fuel #2 Fuel name Residue Higher heating value (with units) 1040 btu/scf Maximum sulfur content (Wt.%) Neg. Maximum ash content (Wt.%) Neg. Excess Combustion Air OR %O2(Circle choice) Moisture content(as fired) (%) Maximum hourly fuel usage(units/hr.) 14.4 mscf/hr Actual annual fuel usage for 19 ***** 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 Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 25 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Engine (Unit) code: P160 4a. Date first placed in service: 1974 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle V 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn Air/fuel ratio controller Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓Yes- Attach control device form Cheek all of the following that annlv V Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042GSI S/N: 389002 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel#1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(FP,gal) 8973 scf/hr Maximum Yearly Consumption(Ft,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) • Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 26 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Engine (Unit)code: P161 4a. Date first placed in service: 1974 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle V 4-Cycle Spark-ignition Diesel V Standard rich burn Standard lean burn V Air/fuel ratio controller it Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No V Yes- Attach control device form Check all of the following that apply V Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042G51 S/N: 232481 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 27 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Engine (Unit) code: P162 4a. Date first placed in service: 1974 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle V 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn ✓Air/fuel ratio controller "Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No V Yes- Attach control device form Check all of the following that apply V Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042GSI S/N: 262110 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption (Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing (degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 28 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Engine (Unit) code: P163 4a. Date first placed in service: 1974 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle ✓4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn ✓ Air/fuel ratio controller /Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes- Attach control device form Check all of the following that apply ✓ Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042GSI S/N: 319041 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel#1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(FP,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing-(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 29 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Engine (Unit) code: P164 4a. Date first placed in service: 1992 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle V 4-Cycle Spark-ignition Diesel V Standard rich burn Standard lean burn ✓Air/fuel ratio controller /Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes-Attach control device form Check all of the following that apply V Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042G51 S/N: 388531 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 30 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Engine (Unit)code: P165 4a. Date first placed in service: 1974 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle ✓4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn /Air/fuel ratio controller /Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No / Yes- Attach control device form Check all of the following that apply ✓ Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042G5I S/N: 362517 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 31 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Engine(Unit)code: P166 4a. Date first placed in service: 1974 Date last modified: 2002 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle ✓ 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn ✓Air/fuel ratio controller ✓Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓Yes- Attach control device form Check all of the following that apply ✓ Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042G5I S/N: 386916 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Selling ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 32 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Engine (Unit) code: P167 4a. Date first placed in service: 1993 Date last modified: 2003 5. Engine use: Powering an air compressor 6. Engine Features: 2-Cycle ✓ 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn "Air/fuel ratio controller "Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes-Attach control device form Check all of the following that apply "Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: F 1197 GU S/N: 306927 10. Max Fuel Design Rate: 0.99 mmBTU/hr 11. Horsepower Max Design: Site: 125 12. Heat Rate: 7920 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel#1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 952 scf/hr Maximum Yearly Consumption(Ft3,gal) 8.34 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 33 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Engine (Unit) code: P168 4a. Date first placed in service: 1993 Date last modified: 2003 5. Engine use: Powering a residue gas compressor 6. Engine Features: 2-Cycle ✓ 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn "Air/fuel ratio controller "Turbocharger "Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes-Attach control device form Check all of the following that apply "Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Caterpillar 9. Model No: G-342 NA S/N: 31B3201 10. Max Fuel Design Rate: 1.7 mmBTU/hr 11. Horsepower Max Design: Site: 230 12. Heat Rate: 7391 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Residue Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 1632 scf/hr Maximum Yearly Consumption(Ft3,gal) 14.3 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp.(?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 34 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Engine (Unit)code: P169 4a. Date first placed in service: 1974 Date last modified: 2002 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle V 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn ✓Air/fuel ratio controller /Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes- Attach control device form Check all of the following that apply ✓Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Waukesha 9. Model No: L-7042GU S/N: 277151 10. Max Fuel Design Rate: 9.34 mmBTU/hr 11. Horsepower Max Design: Site: 1000 12. Heat Rate: 9340 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 8973 scf/hr Maximum Yearly Consumption(Ft3,gal) 78.6 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 35 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Engine (Unit) code: P170 4a. Date first placed in service: 1993 Date last modified: 5. Engine use: Powering a low pressure residue gas compressor 6. Engine Features: 2-Cycle /4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn /Air/fuel ratio controller /Turbocharger ✓ Low-NOx design Other(Describe): 7. Emission controls: ✓ No Yes-Attach control device form Check all of the following that apply Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Superior Ajax 9. Model No: 8SGTB S/N: 315909 10. Max Fuel Design Rate: 8.85 mmBTU/hr 11. Horsepower Max Design: Site: 1215 12. Heat Rate: 7284 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Natural Gas Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption (Ft3,gal) 8509 scf/hr Maximum Yearly Consumption(Ft3,gal) 74.54MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (?F) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 36 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Engine (Unit) code: P171 4a. Date first placed in service: 1993 Date last modified: 5. Engine use: Powering a low pressure residue gas compressor 6. Engine Features: 2-Cycle ✓ 4-Cycle Spark-ignition Diesel ✓ Standard rich burn Standard lean burn ✓Air/fuel ratio controller /Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes- Attach control device form Check all of the following that apply / Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Superior 9. Model No: 6G825 S/N: 19941 10. Max Fuel Design Rate: 4.65 mmBTU/hr 11. Horsepower Max Design: Site: 600 12. Heat Rate: 7750 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel #1 Fuel Type: Residue Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 4475 scf/hr Maximum Yearly Consumption(Ft3,gal) 39.2 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing (degrees) Speed(RPM) Intake Air Temp.;OF) Air and Fuel Manifold Pressure Exhaust Temperature(?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 37 Operating Permit Application INTERNAL COMBUSTION ENGINE OPERATION FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Engine(Unit) code: CIG-S-2 4a. Date first placed in service: 1977 Date last modified: 5. Engine use: Powering a natural gas compressor 6. Engine Features: 2-Cycle ✓ 4-Cycle Spark-ignition Diesel V Standard rich burn Standard lean burn Air/fuel ratio controller Turbocharger Low-NOx design Other(Describe): 7. Emission controls: No ✓ Yes-Attach control device form Check all of the following that apply ✓ Non-Selective catalytic reduction Three-way catalyst Selective catalytic reduction Ammonia injected Oxidation catalyst Other: 8. Manufacturer: Superior 9. Model No: 6G825 S/N: 18653 10. Max Fuel Design Rate: 4.65 mmBTU/hr 11. Horsepower Max Design: Site: 474 12. Heat Rate: 9810 BTU/HP-hr 13. Operating Temp: Min. Max. °F 14. Fuels: Primary Fuel Backup Fuel#1 Fuel Type: Residue Heating Value BTU/SCF 1040 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) 0 Maximum Hourly Consumption(Ft3,gal) 4475 scf/hr Maximum Yearly Consumption(Ft,gal) 39.2 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15. Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp.OF) Air and Fuel Manifold Pressure Exhaust Temperature (?F) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 38 Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181 4. Process (Unit) code: P181 5. Unit description: Gas Plant Fugitive Emissions Not Subject to Subpart KKK Indicate the control technology status. ✓Uncontrolled Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 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: 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/yr. 10. Describe this process_pea, amid: a low diatzra n of rho pr>c oss�. Attached? This process relates to leaks from components in the normal operation of the facility 11. List the types and amounts of raw materials used in this process: Material Storage/material Actual usage Units Maximum usage Units handling process Clean-up solvents Other (specify) 12. List the types and amounts of finished products: Storage/material Actual amount Maximum Material handling process produced Uni Units ts amount produced 13. Process fuel usage: None Maximum heat input to Type of fuel process Actual usage Units Maximum usage Units million BTU/hr. 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: Fugitive emissions from leaking equipment at the facility such as connectors, flanges, and other components. ***** 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. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 39 Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Process (Unit) code: P181A 5. Unit description: Gas Plant Fugitives Subject to Subpart KKK 6. Indicate the control technology status. Uncontrolled V Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 C-FS181A 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: 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/yr. 10. Describe this process pieasc attach a tlov diagram of the process). Attached? This process relates to leaks from components in the normal operation of the facility 11. List the types and amounts of raw materials used in this process: Material Storage/material Actual usage Units Maximum usage Units handling process Clean-up solvents Other(specify) 12. List the types and amounts of finished products: Storage/material Actual amount Maximum Material handling process produced Units Units amount produced 13. Process fuel usage: None Maximum heat input to Type of fuel process Actual usage Units Maximum usage Units million BTU/hr. 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: Fugitive emissions from leaking equipment at the facility such as connectors, flanges, and other components. ***** 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. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 40 Operating Permit Application MISCELLANEOUS PROCESSES FORM 2000-306 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS182 4. Process (Unit) code: P182 5. Unit description: Condensate Tank Truck Loadout 6. Indicate the control technology status. ✓Uncontrolled Controlled If the process is controlled, enter the control device code(s) from the appropriate form(s): 2000-400 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: 9. Normal operating schedule: 24 hrs./day 7 days/wk. 8760 hours/yr. 10. Describe this process (,,ca attach a ilok d _ra l A.the rocesl. Attached? This process involves truck loadout of condensate from storage tanks at the facility. 11. List the types and amounts of raw materials used in this process: Material Storage/material Actual usage Units Maximum usage Units handling process Condensate Storage tanks 4.467 million gal/yr Clean-up solvents Other(specify) 12. List the types and amounts of finished products: Material Storage/material Actual amount Units Maximum Units handling process produced amount produced Condensate Truck loadout tank 4.467 million gal/yr 13. Process fuel usage: None Maximum heat input to Type of fuel process Actual usage Units - Maximum usage Units million BTU/hr. 14. Describe any fugitive emissions associated with this process, such as outdoor storage piles, unpaved roads, open conveyors, etc.: Leaks from hoses during loading process and venting of residual VOCs from tanks after loading. ***** 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. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 41 Operating Permit Application GLYCOL DEHYDRATION UNIT FORM 2000-307 Colorado Department ofPublic Health and Environment Rev-G6-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Dehydrator(Unit) code: P178 5. Unit description: Natural Gas Dehydration System using triethylene glycol 6. Indicate the dehydrator control technology status. /Uncontrolled Controlled If the dehydrator is controlled, enter the control device number(s) from the appropriate forms: 2000-400 2000-403 9.Regenerator heater design rate or maximum 7. Manufacturer: Weatherford 1.75 continuous rating (mmBTU/hr): 8. Model &serial number: Model? Custom S/N: 34418 10. Date first placed in service: 1993 Date of last modification: 11. Flash Tank: ✓ Yes No Flash tank vented to: atmosphere ✓process 12. Glycol Circulation rate: 0.684 gallons per minute gallon per pound of HZO OR 13. Pipeline Capacity: (mmscf/day): 15 14. Glycol Type: ✓Triethylene Glycol Ethylene Glycol Other (specify) 15. Glycol Make-up Rate (gallons/year): 16. Computer model input &output printout attached 17. Gas Pressure (psi): 550 18. Gas Temperature(°F): 90 19. Gas composition test results VOC BTEX HEXANE Test date: 10/21/02 value units value units value units 7.04 Mol % 0.02 Mol % 0.28 Mol % *****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 Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** NOTE: THE SPECIALIZED APEN FOR A GLYCOL DEHYDRATION UNIT MUST BE COMPLETED AND SUBMITTED IF THE STILL VENT EMISSIONS HAVE NOT BEEN REPORTED BEFORE 42 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Control device code: C160 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 8. Describe the device being used. Attach a diagram of thhe_5 Stem. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant Emission capture Outlet pollutant Control concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic Compounds 1.0 g/hp-hr 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system.The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 43 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. Control device code: C161 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 8. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant Emission capture_ Outlet pollutant Control concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include,but not,be limited to the following: a. Identification of the individual(s),by title, responsible for inspecting,maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors,CEMs). d. An inspection schedule and items or conditions that will be inspected. 1. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 44 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Control device code,: C162 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 9. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10: Discuss how the collected material will be handled for reuse or disposal: 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. his suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 45 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Control device code: C163 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 10. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal 11. Prepare a malfunction prevention and abatement plan for this pollution control system.The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough,the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance: c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 46 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Control device code: C164 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 11. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough,the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided (temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 47 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Control device code: C165 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 12. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant Emission capture Outlet pollutant Control concentration efficiency(%) concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic Compounds 1.0 g/hp-hr 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting,maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 48 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. Control device code: C166 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 13. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppn' Nitrogen Oxides 4.1 g/hp-hr Carbon Monoxide 4.1 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. • Discuss how the collected material will be handled for reuse or disposal. • 11..- _ Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM [S OPTIONAL 49 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 , 5. Control device code: C167 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 14. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 2.3 g/hp-hr Carbon Monoxide 2.3 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 50 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment - --- - Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Control device code: C168 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 15. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 2.3 g/hp-hr Carbon Monoxide 2.3 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application.`It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 51 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Control device code: C169 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 16. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 2.0 g/hp-hr Carbon Monoxide 3.0 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include,but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 52 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and-Environment — -- Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Control device code: C171 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 17. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 2.0 g/hp-hr Carbon Monoxide 3.0 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individuai(s),by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 53 Operating Permit Application CONTROL EQUIPMENT-MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Control device code: C002 , 6. Manufacturer and model number: Johnson Matthey 7. Date placed in service: Date of last modification: 18. Describe the device being used. Attach a diagram of the system. Non-Selective Catalytic Reduction 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Inlet pollutant Emission capture Outlet pollutant Control Pollutant concentration efficiency(%) concentration Efficiency(%) gr/acf ppmv gr/acf ppmv Nitrogen Oxides 5.0 g/hp-hr Carbon Monoxide 5.0 g/hp-hr Volatile Organic 1.0 g/hp-hr Compounds 10. Discuss how the collected material will be handled for reuse or disposal: • 11.- Prepare a malfunction prevention and abatement plan for this pollution control system:-The plan does not have to be • submitted with the application. Iris suggested the plan include, but not be limited to the following: a: Identification of the individual(s), by title, responsible for inspecting,maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. : ._._- c. What type of monitoring equipment will be provided (temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 54 Operating Permit Application CONTROL EQUIPMENT- MISCELLANEOUS FORM 2000-400 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Unit identification code: P181A , 5. Control device code: C-FS181A 6. Manufacturer and model number: Unknown 7. Date placed in service: Date of last modification: 19. Describe the device being used. Attach a diagram of the system. Equipment Leak Detection and Repair consistent with requirements of Subpart KKK 9. List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant Emission capture Outlet pollutant Control concentration efficiency(%) concentration Efficiency (%) gr/acf ppmv gr/acf ppmv Volatile Organic 75%/30% Compounds 10. Discuss how the collected material will be handled for reuse or disposal. 11. Prepare a malfunction prevention and abatement plan for this pollution control system. The plan does not have to be submitted with the application. It is suggested the plan include, but not be limited to the following: a. Identification of the individual(s), by title, responsible for inspecting, maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough, the correct operating range of these variables, and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors, pressure sensors, CEMs). d. An inspection schedule and items or conditions that will be inspected. f. Where is this plan available for review? NOTE: COMPLETION OF INFORMATION IN SHADED AREA OF THIS FORM IS OPTIONAL 55 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM)- Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): V Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping -Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 56 Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures- Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): V Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds V Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 57 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): V Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds V Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 58 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing -Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping -Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 59 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s)to this form). Continuous Emission Monitoring(CEM) -Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): V Fuel Sampling and Analysis (FSA) - Form 2000-506 • Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe)- Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 60 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM)- Form 2O00-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA)- Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds V Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) -Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 61 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s)to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): V Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 62 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): V Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds V Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 66 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis(FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5 63 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) -Form 2000-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 67 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis(FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5 64 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): /Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds ✓ Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other (please describe) -Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 68 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): ✓ Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Nitrogen Oxide, Carbon Monoxide Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): ✓ Fuel Sampling and Analysis (FSA)- Form 2000-506 Pollutant(s): Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds V Recordkeeping - Form 2000-507 Pollutant(s):Nitrogen Oxide, Carbon Monoxide, and Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 65 Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures- Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ✓ Recordkeeping - Form 2000-507 Pollutant(s): Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 69 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S179 4. Unit identification code: P179 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s)to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA)- Form 2000-506 Pollutant(s): ✓ Recordkeeping - Form 2000-507 Pollutant(s): Volatile Organic Compounds ✓ Other (please describe) - Form 2000-508 Pollutant(s): Visible Emissions 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 70 Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: 5181 4. Unit identification code: P181 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures -Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ✓ Recordkeeping - Form 2000-507 Pollutant(s): Volatile Organic Compounds Other (please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 71 Operating Permit Application COMPLIANCE CERTIFICATION- MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S181A 4. Unit identification code: P181A 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring(CEM) - Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures- Form 2000-504 Pollutant(s): Stack Testing - Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ✓ Recordkeeping - Form 2000-507 Pollutant(s): Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitorine reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 72 Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually, and may need to be more frequent if specified by the underlying applicable requirement or by the Division. • SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S182 4. Unit identification code: P182 5. For this Unit the following method(s) for determining compliance with the requirements of the permit will be used (check all that apply and attach the appropriate form(s) to this form). Continuous Emission Monitoring (CEM) - Form 2000-501 Pollutant(s): Periodic Emission Monitoring Using Portable Monitors - Form 2000-502 Pollutant(s): Monitoring Control System Parameters or Operating Parameters of a Process - Form 2000-503 Pollutant(s): Monitoring Maintenance Procedures - Form 2000-504 Pollutant(s): Stack Testing -Form 2000-505 Pollutant(s): Fuel Sampling and Analysis (FSA) - Form 2000-506 Pollutant(s): ✓ Recordkeeping - Form 2000-507 Pollutant(s): Volatile Organic Compounds Other(please describe) - Form 2000-508 Pollutant(s): 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: February 1, 2003 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 73 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM)may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? ✓ Yes No 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 74 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? ✓ Yes No f- " 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 75 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 66-93' Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Pollutant(s) or diluent(s)being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? ✓ Yes No e k 10. Type: In situ ✓ Extractive Dilution Other (specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 76 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS -- Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown =ate u%Th r:^E'er -x 8. Is this an existing system. V Yes No 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 77 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING.PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? V Yes No 10. Type: In situ V Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application ***** Any test value over the emission limit shall be reported as an excess emission. ***** 78 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION - FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model & serial number: Unknown 8. Is this an existing system? ✓ Yes No :x office _ „ v-vow 10. Type: In situ ✓ Extractive Dilution Other (specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 79 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code: a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model & serial number: Unknown 8. Is this an existing system? ✓ Yes No 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 80 Operating Permit Application COMPLIANCE DEMONSTRATION$YP_ERIODIC EMISSION- -- - FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model & serial number: Unknown 8. Is this an existing system? ✓ Yes No $' t 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 81 Operating Permit Application - -COMPLIANCE-DEMONSTRATION BY-PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model&serial number: Unknown 8. Is this an existing system? ✓ Yes No 10. Type: In situ ✓ Extractive Dilution Other (specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 82 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor(CEM)may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Pollutant(s) or diluent(s)being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model & serial number: Unknown f4' X ry 8. Is this an existing system? ✓ Yes No 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 83 Operating Permit Application - - COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? / Yes No 10. Type: In situ ✓ Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly /Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 84 Operating Permit Application COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor(CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model &serial number: Unknown 8. Is this an existing system? ✓ Yes No 10. Type: In situ ✓ Extractive Dilution Other (specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application *****Any test value over the emission limit shall be reported as an excess emission. ***** 85 Operating Permit Application — -COMPLIANCE DEMONSTRATION BY PERIODIC EMISSION FORM 2000-502 Colorado Department of Public Health and Environment MONITORING USING PORTABLE MONITORS Rev 06-95 Air Pollution Control Division The use of a portable continuous emission monitor (CEM) may be acceptable as a compliance demonstration method. A monitoring plan shall contain the following information: the name and address of the source; the source facility identification code; a general description of the process and the control equipment; the pollutant or diluent being monitored; the manufacturer, model number, and serial number of each portable monitor; the operating principles of each portable monitor; and a schematic of the CEM system showing the sample acquisition point and the location of the monitors while sampling. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S002 4. Unit identification code: P002 5. Pollutant(s) or diluent(s) being monitored: Nitrogen Oxides and Carbon Monoxide 6. Name of manufacturer: Ecom AC Plus and Other 7. Model & serial number: Unknown 8. Is this an existing system? ✓ Yes No 10. Type: In situ V Extractive Dilution Other(specify) 11. Very briefly explain the measurement design concept of the monitor: Manufacturer's User Manual is attached 12. Backup system: Another similar portable monitor from another area of the company 13. Compliance shall be demonstrated: Daily Weekly Monthly V Other-specify Semi-annually 14. Quality Assurance/Quality Control: A quality assurance/quality control plan for the portable monitor is attached for Division review. The plan is not attached, but will be submitted to the Division by Duke Energy Field Services uses the manufacturer's Users Manual as a quality assurance and quality control plan. The Manufacturer's User Manual is attached to this application ***** Any test value over the emission limit shall be reported as an excess emission. ***** 86 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 6. Fuel being sampled: Natural Gas used to fuel the 5. Pollutant being monitored: NON, CO, & VOC engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? V Yes No 9. Implementation Date: May 1999 10. Automated sampling V Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly V Other- specify Semi-Annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 87 Operating Permit Application COMPLIANCE DEMONSTRATION BY -" FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 6. Fuel being sampled: Natural Gas used to fuel the 5. Pollutant being monitored: NO„ CO, & VOC engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with ASTM GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? V Yes No 9. Implementation Date: May 1999 10. Automated sampling V Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other— specify Semi-Annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 88 - Operating Permit Application-- COMPLIANCE DEMONSTRATION BY FORM-2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 6. Fuel being sampled: Natural Gas used to fuel the 5. Pollutant being monitored: NO„ CO, & VOC engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling V Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly V Other- specify Semi-Annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 89 - Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Pollutant be ng monitored: NO„, CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? V Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓Other- specify Semi-Annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 90 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Pollutant being monitored: NO„ CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? V Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other- specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the ESA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 91 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Pollutant being monitored: NO , CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other - specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 92 Operating Permit Application -—COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 6. Fuel being sampled: Natural Gas used to fuel the 5. Pollutant being monitored: NO , CO, & VOC engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling V Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other- specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 93 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. Pollutant being monitored: NO , CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other - specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 97 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 • 5. Pollutant being monitored: NO , CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other- specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 95 Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Pollutant being monitored: NO„ CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly V Other - specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 98 - Operating Permit Application COMPLIANCE DEMONSTRATION BY TORM 2000-506 Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. Pollutant being monitored: NO„ CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: May 1999 10. Automated sampling V Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other- specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 96 —Operating Permit Application - COMPLIANCE DEMONSTRATION BY FORM 2000-506 _ Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Pollutant being monitored: NO, CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? V Yes No 9. Implementation Date: May 1999 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other- specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 99 - Operating Permit Application COMPLIANCE DEMONSTRATION BY " "FORM 2000-506 - " Colorado Department of Public Health and Environment FUEL SAMPLING AND ANALYSIS Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Pollutant being monitored: NO„ CO, & VOC 6. Fuel being sampled: Natural Gas used to fuel the engines 7. List the ASTM or EPA fuel sample collecting and analyzing methods used: The Btu content of the natural gas used to fuel the engines shall be verified semi-annually in accordance with GPA method 2261 or an equivalent methodology. 8. Is this an existing FSA system? ✓ Yes No 9. Implementation Date: 10. Automated sampling ✓ Manual sampling 11. Backup system? NA 12. Compliance shall be demonstrated: Daily Weekly Monthly ✓ Other— specify Semi-annually 13. Quality Assurance/Quality Control: The FSA system certification is attached for Division review. The FSA system is not certified, but the certification package was submitted to the Division on The FSA system certification will be submitted to the Division by the date shown in our monitoring/compliance plan. A Quality Assurance/Quality Control plan for the fuel sampling program is attached for Division review. The QA/QC plan is not attached, but will be submitted to the Division by Duke Energy field Services uses an internal fuel sampling database. The operation of this database includes fuel system certification and quality assurance and quality control. Further information is available upon request. 14. Attach a schematic of the FSA system showing the sample acquisition point and the location of the machine that produces the daily, weekly, or monthly composite fuel sample. *****Any composite sample over the emission limit shall be reported as an excess emission. ***** 94 Operating Permit Application COMPLIANCE DEMONSTRATION - FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 100 Operating Permit Application COMPLIANCE DEMONSTRATION ----FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording(see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly V Monthly Batch(not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 101 Operating Permit Application COMPLIANCE DEMONSTRATION --- -FORM-2000-507 - Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 102 Operating Permit Application COMPLIANCE DEMONSTRATION - '- FORM 2000-507 - -""- Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly / Monthly Batch(not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 103 Operating Permit Application COMPLIANCE DEMONSTRATION - FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly "Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 104 Operating Permit Application COMPLIANCE-DEMONSTRATION FORM 2000-507- Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 105 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch(not to exceed monthly) Other-specify 12 b. Compliance shall be demonstrated: Daily Weekly / Monthly Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 106 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 110 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 108 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch(not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other-specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 111 Operating Permit Application COMPLIANCE DEMONSTRATION - FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 .5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly "Monthly Batch (not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 109 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 112 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Pollutant(s) being monitored: Nitrogen Oxide, 6. Material or parameter being monitored and recorded: Carbon Monoxide, and Volatile Organic Compounds Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS conducts calculations to determine the fuel consumption for each unit. The fuel consumption is used in conjunction with other information such as heating value to calculate actual estimated emissions. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other-specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control as required. The format for these submittals can be found in the previous submittals from Duke Energy Field Services. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 107 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: VOCs Gas processed and glycol circulation rate 7. Method of monitoring and recording (see information on back of this page): Information will be obtained to use in conjunction with the GLYCaIc Model to estimate emissions from the Triethylene Glycol Regeneration Unit. The information recorded and maintained will include an extended gas analysis of the natural gas delivered to the glycol dehydration unit, the natural gas throughput recorded on the first day of each month, the triethylene glycol circulation rate, inlet gas pressure, and inlet gas temperature. 8. List any EPA methods used: NA 9. Is this an existing method of demonstrating compliance? 10. Start date: May 1999 ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly /Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly V Monthly Batch (not to exceed monthly) Other- specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado APCD as required. The format for these submittals can be found in previous submittals from DEFS. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 113 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDICEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S179 4. Unit identification code: P179 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: NO„ CO, VOC, PM10, SO2 Fuel Consumption 7. Method of monitoring and recording (see information on back of this page): DEFS records and monitors facility wide fuel consumption. DEFS uses a plant fuel meter to monitor fuel consumption for each heater on a monthly basis. The fuel consumption and fuel heating value are used in conjunction with other information to calculate estimated emissions of NO„ CO, VOC, SO2 and PMIO. The use of natural gas ensures that the opacity standard of 20% will not be exceeded. 8. List any EPA methods used: The heating value of the natural gas is determined using GPA Standard 2261 or the equivalent. 9. Is this an existing method of demonstrating 10. Start date: May 1999 compliance? I. Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other - specify 12 b. Compliance shall be demonstrated: Daily Weekly ✓ Monthly Batch(not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS maintains an internal database to ensure the recordkeeping is being conducted with proper frequency and correctly. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado APCD as required. The format for these submittals can be found in previous submittals from DEFS. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 114 Operating Permit Application -"-COMPLIANCE-DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181 4. Unit identification code: P181 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: VOCs Maintain an updated component count 7. Method of monitoring and recording (see information on back of this page): A component count at the facility is maintained to estimate VOC emissions from equipment leaks. Emission factors from the EPA are used for VOC emission calculations and a plant inlet gas analysis is performed at least once a year to determine VOC % in the inlet stream. Emissions are then estimated by multiplying the component count by 8760 hrs and VOC % and EPA emission factors. 8. List any EPA methods used: Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017; EPA Method 21, record keeping and calculation. 9. Is this an existing method of demonstrating 10. Start date: May 1999 compliance? ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly Monthly Batch (not to exceed monthly) ✓ Other - specify Semi-annually 12 b. Compliance shall be demonstrated: Daily Weekly Monthly Batch (not to exceed monthly) ✓ Other- specify Semi-annually 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado APCD as required. The format for these submittals can be found in previous submittals from DEFS. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 115 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. • SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Unit identification code: P181A 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: VOCs Maintain an updated component count 7. Method of monitoring and recording (see information on back of this page): A component count at the facility is maintained to estimate VOC emissions from equipment leaks. Emission factors from the EPA are used for VOC emission calculations and a plant inlet gas analysis is performed at least once a year to determine VOC % in the inlet stream. Emissions are then estimated by multiplying the component count by 8760 hrs and VOC % and EPA emission factors. 8. List any EPA methods used: Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017; EPA Method 21, record keeping and calculation. 9. Is this an existing method of demonstrating 10. Start date: May 1999 compliance? ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly Monthly Batch (not to exceed monthly) ✓ Other - specify Semi-annually 12 b. Compliance shall be demonstrated: Daily Weekly Monthly Batch (not to exceed monthly) ✓ Other- specify Semi-annually 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado APCD as required. The format for these submittals can be found in previous submittals from DEFS. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 116 Operating Permit Application COMPLIANCE-DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This zorrelation may constitute the certification of the system. For an existing program, the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed, please submit it within 60 days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S182 4. Unit identification code: P182 5. Pollutant(s) being monitored: 6. Material or parameter being monitored and recorded: VOCs Gallons of condensate throughput for tanks 7. Method of monitoring and recording (see information on back of this page): Emissions from truck loadout will be based on the recordkeeping of the gallons of throughput for the tanks on a monthly basis. VOC emissions and gallons of condensate loaded for a month shall be calculated by the end of the following month and are based on AP-42 equations and adjusted for non-Methane, non-Ethane VOC content. 8. List any EPA methods used: EPA Method 21, record keeping and calculation. 9. Is this an existing method of demonstrating 10. Start date: May 1999 compliance? ✓ Yes No 11. Backup system: NA 12 a. Data collection frequency: Daily Weekly ✓ Monthly Batch (not to exceed monthly) Other- specify 12 b. Compliance shall be demonstrated: Daily Weekly V Monthly Batch (not to exceed monthly) Other - specify 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications, calibration requirements, and quality assurance procedures. A quality assurance/quality control plan for the recordkeeping system is attached for Division review. The plan is not attached, but will be submitted to the Division by DEFS currently conducts recordkeeping associated with this facility. DEFS uses an internal database to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. A proposed format for the compliance certification report and excess emission report is attached. DEFS currently submits compliance certification reports and excess emission reports to the Colorado APCD as required. The format for these submittals can be found in previous submittals from DEFS. `**** The compliance records shall be available for Division inspection. `**** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day. Hazardous air releases shall be reported to the Division immediately. 117 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit Identification code: P161 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 119 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit Identification code: P162 5. Pollutant(s) or Parameter(s)being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 120 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit Identification code: P163 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 121 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit Identification code: P164 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 122 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit Identification code: P165 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 123 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit Identification code: P166 5. Pollutant(s)or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 124 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit Identification code: P167 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 125 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit Identification code: P168 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 126 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit Identification code: P170 5. Pollutant(s)or Parameter(s)being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 128 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit Identification code: P171 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 130 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S002 4. Unit Identification code: P002 5. Pollutant(s)or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 18 of Operating Permit 95OPWE039 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 129 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 Air Pollution Control Division 1. Facility Name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: 5179 4. Unit Identification code: P179 5. Pollutant(s) or Parameter(s) being monitored: Opacity of effluent 6. Description of the method of monitoring: Because natural gas fuel is the only fuel being used, compliance with the 20% opacity limit set forth by Condition 26 of Construction Permit 97WE0287 shall be presumed. 7. Compliance shall be demonstrated: (Specify the frequency with which compliance will be demonstrated) NA 131 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public I lealth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic Actual emissions Allowable OR I t t , s - Potential to emit Pollutant Name -7f4.4444-(-0.0 # ,. a r. Quantity Measurement Units 71432 Benzene k ern 349.6 lb/yr 50000 Formaldehyde r 907.7 lb/yr 75070 Acetaldehyde5 ' TM- 62.2 lb/ r rte,. v. , k A 4.m {'wad - /A s _sue L � eW S's vi'x- t i :r 3' a t..L' NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 132 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic z r Actual emissions,itctt." Allowable OR 3 .. ,* 4 Potential to emit Pollutant Name eaSia Quantity Measurement Units 71432 Benzene w"4;- I:a " "l�'r�,_ r- 349.6 lb/yr 50000 Formaldehyde °w4 n - ' 907.7 lb/yr 75070 Acetaldehyde 62.2 tb/ r Y t3 $ R *1E -a *vim � x NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 133 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public I lealth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic ,_Actuallemissions Allowable OR r , - ' Potential to emit Pollutant Name +fiiantrty ,7`4 eai4"�ii_e; i'eht ''l Quantity Measurement Units 71432 Benzene r ; 349.6 lb/yr 50000 Formaldehyde 907.7 lb/yr 75070 Acetaldehyde zt. 62.2 lb/yr arra 7.jgrt _ Ipara t . w . r r }`?x 8, 'a .. x— ; } NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 134 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public I lealth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic Qctual epttsstotu', Allowable OR _ Potential to emit t t , _ Pollutant Name I eastf AI#,M. Quantity Measurement is S Units +kx , 4 71432 Benzene 349.6 lb/yr 50000 Formaldehyde F� 907.7 lb/yr 75070 Acetaldehyde r; y 62.2 lb/yr xkrta _ . mil R' yPoT_• 6 f� � j �j,'�NA N. jai b e ..,N'w: 4.. Wil-9 Erie? attr- Pt'Tira- , 4 NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 135 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar near 19 Pollutant CAS Common or Generic , ctuatemiss`io"ns - Allowable OR ,,g z Potential to emit Pollutant Name s,•`n� w` '"' a tta >z Quantity Measurement Units 349.6 lb/yr 71432 Benzene 50000 Formaldehyde "' y £ Formaldeh lb/yr 75070 Acetaldehyde a * y ° 62.2 lb/yr .71 .'34V ,<•t -t tea Ara-k41:4A-st`,/stt Y: } F•s' � ��• 4j,} :� t � ti trttl atP tae e JGr yr$y NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 136 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic etual Monsl*,h Allowable OR `fz, ,,, Potential to emit Pollutant Name a-'; ttrikt ': Quantity Measurement Units 71432 Benzenea m - � ^ 349.6 lb/yr 50000 Formaldehyde 907.7 lb/yr 75070 Acetaldehyde 6 62.2 lb/yr a' n, a 'i Eit `rx fad r4rs* v a'.r � n r. a— z NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 137 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic ni ActuaR misst•ons• '7ertk #[ Allowable OR Potential to emit Pollutant Name • ' -r e. . Quantity Measurement ri r Units 71432 Benzene '%3 `" . � 349.6 lb/yr 50000 Formaldehyde 'jr 907.7 lb/yr 75070 Acetaldehyde 62.2 lb/yr ,yr= � a.. _y 'p H vHW :1,4n YY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 1.38 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic btualemtsstons1> Allowable OR Potential to emit Pollutant Name moment; Quantity Measurement frlit 1Im Units 71432 Benzene t fy 166.5 lb/yr 50000 Formaldehyde ' 430.2 lb/yr • ($.• a.., . .. Y ,'�4�is x-e'u tEcsc" x erf-i 7;S §�mc» fi r_e F• 42;',h1;,. Tahf'gs* µ x i xp NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 139 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic Ina,. anal emissions' - Allowable OR a" ` fa.,, Potential to emit -c ,kirtf Pollutant Name an+ e `~ 'f' Quantity Measurement Units 71432 Benzene s• e 80.4 lb/yr 50000 Formaldehyde a V4 Y 208.8 lb/yr rq•€ ., �a.r t, i xt x a � ,. r kn73 ,a fir_ "may _... '"' ' l Yxk ficc y `r ix• r tNC NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 140 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Ilealth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached .Actual Emissions Data is for calendar vear 19 Pollutant CAS Common or Generic i° '� btu":I mtsstons - Allowable OR i t i zr Potential to emit Pollutant Name Measurement "w Quantity Measurement nibs Units 71432 Benzene r b 849.4 lb/yr 50000 Formaldehyde t r o r 2150.8 lb/yr 75070 Acetaldehyde y lb/yr Y f z fi t, *K; 4,,,,o-,.3,-1.4-:24,-;:r x"w t v +x r `*' A tip"- .: .r wig ..: ".•'-,',V4‘.4-_ ,» iln x I c o-a' TE . m=", Tk h ST c t i ' ri „_,,,,,,--1,-, NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 141 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar war 19 Pollutant CAS Common or Generic - - dual o salons; , Allowable OR Potential to emit Pollutant Name r 1°{ s e¢I .. Quantity Measurement Units �- ry:. 50000 Formaldehyde R n� ;��, b.,11-'k 113.5 lb/hr y�yyyx i P �°4' tl �~ ti.w—.qCep. �. .�� ''r •re ' a. x � � � T� • r 4 Yt al. U w t s a *Vs' ] .vim --g.-`1/ .yY Y; ax NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 142 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Ileallh and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic .}`� dual emtsr:n'sr Allowable OR Potential to emit 9 Pollutant Name 0 t r j t':,t :774::, Quantity Measurement a4 tit; g.r t • rip.** s Units M. "+. f"u 7 ^ �s • 71432 Benzene 349.6 lb/ r Y 50000 Formaldehyde o- � „ 907.7 lb/yr 75070 Acetaldehyde Y l s 62.2 lb/yr GJ +4y •Y by h S� d aC „ f ,�f ^f_ i ate ' Mx-' T,LeT'�F'3ltY�.lLYe'a. Axon: i+ li NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 143 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Unit material description: Natural gas fired compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic nr.TACtifatemissions C: Allowable OR Potential to emit Pollutant Name Qt4anttt+ v„w tlleastire�ment Quantity Measurement �l "'d TJni Units 71432 Benzene 210 lb/yr y 50000 Formaldehyde ux ; 545 lb/yr v y .r 3jjA__ ��SS r .'5 '4 l.i I'd yf��L 7k« r'. ;r4 ; z re r $ } iY f. ₹ - -t x" w. „ NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 144 Colorado Department of Public Ilealth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. Unit material description: TEG Dehydration System 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Pala is for calendar year 19 Pollutant CAS Common or Generic - '�' c`.,l emissions Allowable OR 3se„, Potential to emit Pollutant Name ®" r r tyk _'r e ent t.= Quantity Measurement Units 71432 Benzene : wt� 2435.8 lb/yr 108883 Toluene vu , �,'"�,,,� 5689.4 lb/yr 1330207 Xylene 1 �` Y t 5093.8 lb/yr r wu. rc3: 9 14 a x -3 4 -*r grx ad . Ya NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 146 Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S182 4. Unit identification code: P182 5. Unit material description: Condensate Loadout 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached Actual Emissions Data is for calendar year 19 Pollutant CAS Common or Generic "Actualemi ssions a Allowable OR Potential to emit Pollutant Name .� annttty'k' e Quantity Measurement yLs x> ° a Units 71432 Benzene w/.,/.C..z/4.',`. lb/yr Y 'il $$ Lek _ ''''.2110-7 • AVs uttJ.-iiti S _.. �Y fti At I 1 h4'dY r�4 -0t <441:, qt y.}C 2 r} g`. I.n.. ti: NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 145 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates(TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides • Units (U) should be entered as follows: = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 8 =other(specify) 9 =other(specify) to =other(specify) Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division 148 SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY U TPY Particulates(TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U)should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 8 = other(specify) 9 =other(specify) 10 = other(specify) 149 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: I = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 =Ib/mmscf 8 =other(specify) 9 =other(specify) 10 =other(specify) 150 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-I0 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: t = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9 = other(specify) 10 = other(specify) 151 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 =gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9 =other(specify) 10=other(specify) 152 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9 = other(specify) 10 =other(specify) 153 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.969 2 39.6 Volatile organic compounds 0.236 2 9.7 Carbon monoxide 0.969 2 39.6 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: = lb/hr 2 = lb/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other(specify) 9 =other(specify) 10 =other(specify) 154 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS -FORM 2000-601 Colorado Department of Public Health and Environment 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.556 2 2.41 Volatile organic compounds 0.279 2 1.21 Carbon monoxide 0.835 2 3.62 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9=other(specify) 10 =other(specify) 155 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.597 2 4.44 Volatile organic compounds 0.896 2 2.22 Carbon monoxide 0.299 2 6.66 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9 = other(specify) 10 = other(specify) 156 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.551 2 19.31 Volatile organic compounds 0.276 2 9.66 Carbon monoxide 0.826 2 28.96 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: = lb/hr 2 = lb/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other(specify) 9=other(specify) 10 =other(specify) 157 Operating Permit Application EMISSION UNIT CRITERIA-AJRPOLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.605 2 23.46 Volatile organic compounds 0.605 2 23.46 Carbon monoxide 1.211 2 46.93 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist • Fluorides Units (U) should be entered as follows: = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 =gram/HP-hour 7 = lb/mmscf 8 =other(specify) 9=other(specify) 10 =other(specify) 158 Operating Permit Application EMISSION LJNITCR1TERrA AIR POLLUTANTS - FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 0.569 2 11.59 Volatile organic compounds 0.853 2 17.38 Carbon monoxide 0.284 2 5.79 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 8 =other(specify) 9 =other(specify) 10 =other(specify) 159 Operating Permit Application EMISSION-UNIT CRYFERIA-AIR POLLUTANTS - -FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) Neg. NA Neg. PM-10 Neg. NA Neg. Nitrogen oxides 1.12 2 22.9 Volatile organic compounds 0.225 2 4.6 Carbon monoxide 1.12 2 22.9 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/rnmscf 8 =other(specify) 9 =other(specify) 10 =other(specify) 160 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides Volatile organic compounds 4.57 1 20.0 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 =lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other(specify) 9 = other(specify) 10=other(specify) 162 Operating Permit Application - " EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S179 4. Unit identification code: P179 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) 13.7 7 NA PM-10 13.7 7 NA Nitrogen oxides 140 7 9.2 Volatile organic compounds 2.8 7 NA Carbon monoxide 35 7 2.3 Lead Sulfur dioxide 0.60 7 NA Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 =gram/HP-hour 7 = Ib/mmscf 8 =other(specify) 9 = other(specify) 10 =other(specify) 161 Operating Permit Application EMISSION UNIT ext_rERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181 4. Unit identification code: P181 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides Volatile organic compounds 0.57 1 2.5 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides • Units (U) should be entered as follows: l = lb/hr 2 = Ib/mmBTU 3 =grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = Ib/mmscf 8 =other(specify) 9=other(specify) 10 = other(specify) 163 Operating Permit Application EMISSION UNIT CRITERIA-AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Unit identification code: P181A 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides Volatile organic compounds 1.78 1 7.8 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: = lb/hr 2 = Ib/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 = gram/HP-hour 7 = lb/mmscf 8 = other(specify) 9 =other(specify) 10 =other(specify) 164 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S182 4. Unit identification code: P182 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides Volatile organic compounds 3.15 1 13.8 Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U) should be entered as follows: 1 = lb/hr 2 = lb/mmBTU 3 = grains/dscf 4 = lb/gallon 5 = ppmdv 6 =gram/HP-hour 7 = Ib/mmscf 8 =other(specify) 9=other(specify) 10=other(specify) 165 Operating Permit Application PLANT-WIDE HAZARDOUS AIR POLLUTANTS FORM 2000-602 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Attached Pollutant CAS Common or Generic Actual emtsstons Allowable OR Potential to emit Pollutant Name uau' _ Umts'�r� Quantity Units 71432 Benzene _ 7089 lb/yr 50000 Formaldehyde 10,710 lb/yr Y 75070 Acetaldehyde - #: 647.7 lb/yr 108883 Toluene 5689.4 lb/yr 1330207 Xylene 5093.8 lb/yr "Akste 1#-£ ��nFF tn i tx N x3`7.4} W k kn: • • R f�a ✓ NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. 165 Operating Permit Application PLANT-WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates (TSP) Neg. PM-10 Neg. Nitrogen oxides 370.51 Volatile organic compounds 170.53 Carbon monoxide 394.36 167 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. Pollutant 6. Colorado Air Quality 7. S. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds Compliance 10. Other requirements (e.g., malfunction reporting, special operating conditions from an State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual x **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 168 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: 5161 4. Unit identification code: P161 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 169 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds requirements e. Compliance 10. Other ( g., malfunction reporting, special operating conditions from an State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 170 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 171 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring — Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 172 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 173 Operating Permit Application APPLICABLEREQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 6. Colorado Air Quality 7 9. Compliance 5. Pollutant Reg ulations State 8. Limitation Status or Construction Permit Number Only IN OUT Nitrogen Oxides 97WE0287 39.6 tons/yr X Carbon Monoxide 97WE0287 39.6 tons/yr X Volatile Organic 97WE0287 9.7 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 174 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 6. Colorado Air Quality 7 9. Compliance 5. Pollutant Regulations State 8. Limitation Status or Construction Permit Number Only IN OUT Nitrogen Oxides 97WE0287 2.41 tons/yr X Carbon Monoxide 97WE0287 3.62 tons/yr X Volatile Organic 97WE0287 1.21 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping and Calculations X Portable Monitoring Semi-Annually X Opacity Restrictions X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 175 Operating Permit Application - APPLICA ILEREQUDtE-MENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 4.44 tons/yr X Carbon Monoxide 97WE0287 6.66 tons/yr X Volatile Organic 97WE0287 2.22 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual x **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 176 Operating Permit Application APPLICABLE-REQIIIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 6. Colorado Air Quality 7 9. Compliance 5. Pollutant Reg ulations State 8. Limitation Status or Construction Permit Number Only IN OUT Nitrogen Oxides 97WE0287 19.31 tons/yr X Carbon Monoxide 97WE0287 28.96 tons/yr X Volatile Organic 97WE0287 9.66 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Portable Monitoring Semi-Annually X Opacity Restrictions X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 177 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Stains or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 23.46 tons/yr X Carbon Monoxide 97WE0287 46.93 tons/yr X Volatile Organic Compounds 97WE0287 23.46 tons/yr X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 178 Operating Permit Application APPLICABLE REQUIREMENTS AND - FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 11.59 tons/yr X Carbon Monoxide 97WE0287 17.38 tons/yr X Volatile Organic 97WE0287 5.79 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Engine Portable Testing X Opacity Restrictions X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 179 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Nitrogen Oxides 97WE0287 22.9 tons/yr X Carbon Monoxide 97WE0287 22.9 tons/yr X Volatile Organic 97WE0287 4.6 tons/yr X Compounds y 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Fuel Consumption Limitations X Btu Content of Natural Gas Verification X Engine Recordkeeping X Opacity Restrictions X Portable Monitoring - Semi-annual x **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 180 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Volatile Organic 97WE0287 20.0 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Extended Gas Analysis X Emissions Calculations and GLYCaIc Model Runs X Dehydration Operational Parameters Recordkeeping X Natural Gas Throughput Recordkeeping X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 183 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S179 4. Unit identification code: P179 5. Pollutant 6. Colorado Air Quality 7. S. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Particulate Matter 97WE0287 0.25 Ibs/mmBtu X Opacity 97WE0287 <20% X Nitrogen Oxides 97WE0287 9.2 tons/yr X Carbon Monoxide 97WE0287 2.3 tons/yr X requirements (e.g., reporting, special operating conditions from an Compliance 10. Other malfunction State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Fuel Consumption Limitations X Heater Recordkeeping X Particulate Standard Limitations X Emissions Calculations and Recordkeeping X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 182 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181 4. Unit identification code: P181 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Volatile Organic 97WE0287 2.5 tons/yr X Compounds requirements e. Compliance 10. Other ( g., malfunction reporting, special operating conditions from an State Only Status existing permit such as material usage, hours of operation, etc.) IN OUT Component Count and Recordkeeping X Emissions Calculations and Recordkeeping X Inlet Gas Analysis Requirement X Maintenance Plan X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 184 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Unit identification code: P181A 6. Colorado Air Quality 7 9. Compliance 5. Pollutant Regulations State 8. Limitation Status or Only IN OUT Construction Permit Number Volatile Organic 97WE0287 7.8 tons/yr X Compounds 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Status IN OUT Physical Component Count Requirement X Emissions Calculations and Recordkeeping X Plant Inlet Gas Analysis X Maintenance Plan X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 185 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S182 4. Unit identification code: P182 5. Pollutant 6. Colorado Air Quality 7. 8. Limitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number Volatile Organic 97WE0287 Compounds 13.8 tons/yr X Condensate Loaded 97WE0287 4.47 million gals/yr X 10. Other requirements (e.g., malfunction reporting, special operating conditions from an Compliance existing permit such as material usage, hours of operation, etc.) State Only Stains IN OUT Emissions Calculations X Gallons Loaded Calculations X **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 181 APPLICABLE REQUIREMENTS AND STATUS OF EMISSIONS UNIT—Form 2000-604 Operating Permit Application PERMIT SHIELD PROTECTION FORM 2000-605 Colorado Department of Public Health and Environment IDENTIFICATION Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Specify Emission Source: P160-P171, CIG-S-2: 13 Internal Combustion Engines 4. Do not use 5. Pollutant, 6. Colorado Air Quality 7. Equipment, Regulations State or Only Process Internal Combustion Internal Combustion engines are Engines not considered fuel burning equipment for the applicable requirements of Regulation 1. 8. Other requirements (e.g., malfunction reporting, special operating conditions from an State Only existing permit such as material usage, operating hours, etc.) NOTE: REQUESTS FOR THE SHIELD MUST BE FOR A SPECIFIC REQUIREMENT IN THE REGULATIONS. USE FORM 2000-700 TO PROVIDE AN EXPLANATION OF WHY THE SHIELD IS REQUESTED 186 Operating Permit Application PERMIT SHIELD PROTECTION FORM 2000-605 Colorado Department of Public Health and Environment IDENTIFICATION Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Specify Emission Source: Facility Wide 4. Do not use 5. Pollutant, 6. Colorado Air Quality 7. Equipment, Regulations State or Only Process Reg. 3 B.IV.D.2 Facility Wide Non-attainment area X requirements Facility Wide Reg. 3 B.IV.D.3 X PSD Review requirements Facility Wide Reg. 3 B. X. X Air Quality Modeling Facility Wide Reg. 3 B. XI X Visibility requirements Facility Wide Reg. 4-Wood Burning Stoves X Reg. 6 Part A -Federal NSPS Facility Wide Requirements Facility Wide Reg. 6 Part B -State Only X NSPS Requirements Facility Wide Reg. 7 V.C X Facility Wide Reg. 7 VI.B.1 -Storage of X Petroleum Distillates Facility Wide Reg. 7 VI.B.2— Storage of X Petroleum Distillates Facility Wide Reg. 7 VII. C -Crude Oil X Storage Facility Wide Reg. 10 X NOTE: REQUESTS FOR THE SHIELD MUST BE FOR A SPECIFIC REQUIREMENT IN THE REGULATIONS. USE FORM 2000-700 TO PROVIDE AN EXPLANATION OF WHY THE SHIELD IS REQUESTED 187 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S160 4. Unit identification code: P160 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. /We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. • I - • 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 188 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S161 4. Unit identification code: P161 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. /We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six(6) months thereafter 189 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S162 4. Unit identification code: P162 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. /We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. - i 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 190 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S163 4. Unit identification code: P163 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. a 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 191 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S164 4. Unit identification code: P164 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. Ni We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 192 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S165 4. Unit identification code: P165 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 193 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S166 4. Unit identification code: P166 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. I Progress reports will be submitted: Start date: and every six(6) months thereafter 94 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S167 4. Unit identification code: P167 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirement3 of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 195 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S168 4. Unit identification code: P168 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We wilI achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline I1. - 2. 3. Progress reports will be submitted: Start date: and every six (6)months thereafter 196 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE L Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S169 4. Unit identification code: P169 5. For Units that are presently in compliance with ail applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 197 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S170 4. Unit identification code: P170 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 2. 3. Progress reports will be submitted: Start date: __and every six (6) months thereafter 198 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S171 4. Unit identification code: P171 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six(6) months thereafter 199 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: P002 4. Unit identification code: CIG-S-2 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Stan date: and every six (6) months thereafter 200 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S178 4. Unit identification code: P178 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 201 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: S179 4. Unit identification code: P179 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. ' These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. _ - • 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 202 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-91 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181 4. Unit identification code: P181 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline �` Progress reports will be submitted: Start date: and every six (6)months thereafter , Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS181A 4. Unit identification code: P181A 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. 3. Progress reports will be submitted: Start date: and every six(6) months thereafter 204 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: FS182 4. Unit identification code: P182 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ✓ We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Actions Deadline 1. 2. - 1 3. Progress reports will be submitted: Start date: and every six (6) months thereafter 205 Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. This form supplements Form 2000 - 102B for Emission Unit (e.g. B00I, P001, etc.) Additional Information, Diagrams Item Number Insignificant Activities Regen Gas Heater A Plant Regen Heater East Medium Heater West Medium Heater Gas Fired Heater Stabilizer Reboiler Heater Loveco Regenerator Reboiler TEG Dehydration Unit (drying regen gas) Storage Tank- TEG Emergency Flare Storage Tank- Condensate tank; CIG Tank-1 Product Storage Tank; T40 Storage Tank - Nutrient Mix Tank; T-90 Storage Tank - Surge Batch Tank; T-25 Storage Tank - Nutrient Mix Tank, T-90 Storage Tanks (4) - Condensate Storage Tanks (2) - Pressurized Y-Grade Condensate Loading Rack Permit Shield Protection Information - The pollutants, equipment, or regulations identified on forms 2000-605 are either in the permit shield of the current Title V permit or are activities that are not applicable to this facility at this time. 206 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Spindle Gas Processing Plant Facility Identification Code: CO 123-0015 I. ADMINISTRATION This application contains the following ✓ Form 2000-100, Facility Identification forms: ✓ Form 2000-101,Facility Plot Plan ✓ Forms 2000-102, -102A,and-102B, Source and Site Descriptions IL EMISSIONS SOURCE Total DESCRIPTION Number of This Form This application contains the following forms ✓ Form 2000-200,Stack Identification (one form for each facility boiler,printing 17 ✓ Form 2000-300,Boiler or Furnace Operation 1 Form 2000-301,Storage Tanks ✓ Form 2000-302, Internal Combustion Engine 13 Form 2000-303, Incineration Form 2000-304,Printing Operations Form 2000-305,Painting and Coating Operations ✓ Form 2000-306, Miscellaneous Processes 3 ✓ Form 2000-307,Glycol Dehydration Unit 1 III. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following ✓ Form 2000-400,Miscellaneous 12 forms: Form 2000-401,Condensers Form 2000-402,Adsorbers Form 2000403,Catalytic or Thermal Oxidation Form 2000-404,Cyclones/Settling Chambers Form 2000-405,Electrostatic Precipitators Form 2000-406,Wet Collection Systems Form 2000-407, Baghouses/Fabric Filters IV. COMPLIANCE DEMONSTRATION Total Number of This Form This application contains the following forms ✓ Form 2000-500,Compliance Certification-Monitoring and Reporting 18 (one for each facility boiler,printing Form 2000-501,Continuous Emission Monitoring ✓ Form 2000-502,Periodic Emission Monitoring Using Portable 3 Form 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 13 ✓ Form 2000-507, Recordkeeping 18 ✓ Form 2000-508,Other Methods 1 207 V. EMISSION SUMMARY ANI) COMPLIANCE CERTIFICATION Total Number of This Form This application contains the following forms ✓ Form 2000-600, Emission Unit Hazardous Air Pollutants quantifying emissions,certifying compliance 1 with applicable requirements,and developing a compliance plan ✓ Form 2000-601,Emission Unit Cr teria Air Pollutants 18 ✓ Form 2000-602,Facility Hazardous Air Pollutants ✓ Form 2000-603,Facility Criteria Air Pollutants ✓ Form 2000-604,Applicable Requirements and Status of Emission Unit 18 ✓ Form 2000-605,Permit Shield Protection Identification 2 ✓ Form 2000-606,Emission Unit Compliance Plan-Commitments and 18 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 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) 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 Title George Courcier General Manager of Operations—Rockies Region Signat Date Signed `7/707O3 Operating Pernsit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 Colorado Department or lealth 09-94 Air Pollution Control Division Facility Name: Spindle Gas Processing Plant Facility Identification Code: CO 123-0015 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) 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 Title George Courcier General Manager of Operations—Rockies Region Signat Date Signed Signat q/3o/0; SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B I 4300 CHERRY CREEK DRIVE SOUTH DENVER,CO 80246-1530 Appendix B Previously Submitted APENs a� ry Xi O 2c gJo _ do C V I _ry N i J Z = 0 a p '� �o " < a - = o .:51 - - a - • N < O ` y O w7 o, -- c ¢ - - 7, aE -1% _ - O L o < ry a r a" N v <.o< c V. V v m - - F- 2 on o _ < 3 o O = x�. 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J m m m E _ J Y ow > O —' cum E jq el m m Q. o Z o m m X o _ m 3 V V V o m CC Z w m m m m m m r Q m C L L v m > c 0 Q c m (7 r 'o 0 0 m Z o ¢ > D U 2 m Q . m C f a a m c a " d mC w Q C K a 'el m m MM U a cc o w c Q� Q w U a mZ N a u) m .m Um m o z w u t -E..9 Y ct ¢ U ao m a UN w — 2 LL 1 0 (n w❑ Appendix C Revised APENs submitted with this application - — - to CD c. t - - c, - _ = n u - - N Z r`+ f C J o _ `� Z Q = v G _— �- O N O Z o < ' c — ^ P. Z aL C - CID O c - o, .c o H v n a a< o o— < e:, o .t - 'frr V >u o LA N Q V x n g Q ,y _ W = _ - (, __ o w _ — v • 'F. �, 9) "2 .0 v m or u c - m O 0 C Li N z mr.t c+ 2��5 05c= 3 _ C s Cr H o toi. V Y c o o _ v v o m v -t '�. ti, < O < 0 < O v Cl W - � 5 3-T. To_ ,2a <Pe v is -= W CC NE.. F„ '�' p t a � 3oZ = cc _ W _ " = ch a < S_ a. o.� ueo - o< o n. a3 Q o u� 0 0 �._i ,_ a t.4 y Jf N O c" c ,•..s., i <XZ ay � vuf-'- cou oggg'r ° ° � o°x GN Oro co ro Z T X H° v 5-5v •w n v, v c o c o o- .o c--,4 o r .. 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( .o as < = co ` O O z c� ci.) s ro 4) E m OA x. ro U 3 v) 0 Z w 1"47—..iS - ' . \ f, 2 I r, a ECOM - AC+ e ' c , USER MANUAL el a • c; a c; a' set el0 es."J# q ECOM AMERICA, LTD. 1- 3075 Breckinridge Blvd., Suite 420 e, Duluth, Georgia 30136 C� • Tel (770) 886-0320• 8!/fl O 3 06 i Fax (770) 806-0120 1J WebSite: www.ecomusa.com • es t a Version 97-1 t o Ci • !' rJiw.v„e$•.1 kt lft u -...:Att .«w.. .,.-. 1. . b:. j �r- `i c 'r _ail - c 4! c,,r21 c' C~l c - i e+ F1 FF r..--, F' *7f i _ --1 Fe or la • 1..tli:,-ii.1 el w:. • Table of contents Section 1 -Introduction Introduction 1 List of Abbreviations 1 • Optimal Performance 2 Unpacking 2 Section 2-Operation &Front Panel Features } Getting Started on the ECOM-AC 3 Auto Zero/Auto Span 3 Fuel Selection 3 Contrast 4 Backlight 4 Zoom Feature 4 Printing 5 • • Draft Measurement 6 Smoke Measurement 6 Section 3-Program Settings Unit of Measurement 7 O,Correction (Undiluted) 7 Boiler Water Temp. • 7 Air Pressure 7 Pistol Grip Probe Heating 7 } Fuel Selection 7 Clock Settings 8 Fuel Type Upload<PC 8 RAM Card Time Settings 8 Datalogger On/Off 8 Section 4-RAM Card Operation Formatting 9 Datalogger On/Off 9 RAM Card Data Transfer to PC 10 Section 5-Turning the analyzer off 13 :S- : r, , ..'+! ,s..�u.' i!.• +§,,'•Pu an n ,,w a.A'a'luM1 : �a,G'-..�.ai _. Irakt"")..Allii,/,,j1,,.,... rSection 6-Calibration of the ECOM-AC 15Introduction 1S Calibration Principles 15 lj Auto Span and Auto Zero Calibration Methods 15 ` i4. 17rCalibration Gas 17 !'Y.Getting into Calibration Mode18 `cik Applying Calibration Gas 18r"Calibration Protocols �°�, 6AppendicesI. Front Display Features19 " Ji II. Technical Specifications19I 22 �.,.IIII. Trouble Shooting 23IV. Change Name on Printout '"�'24 �V. Factory Service Records .", 1.1 Ci41‘ �" 1r FF PA V Or fiji s t -iv- I j Ili ' 3 ii Section 1 INTRODUCTION11 r li 1.1 Introduction • The ECOM-AC is a microprocessor-based portable emission-analyzer that incorporates the latest technology 1.0 I for accurate stack gas analysis. p I The ECOM-AC is suited for a variety of applications:Boiler/Burner Flue Gas Analysis;Engine Emissions il Analysis;Source Testing;and Environmental Reporting of Stack Gas Parameters,among others. It also pro- e vides measurements for O,, CO low(0-4,000 ppm), CO high(0-40,000 ppm), NO,NO„ SO„and Combustibles,as well as Gas and Ambient Temperatures, Stack Draft,and Smoke. The calculated paame- f ters include CO„Efficiency, Excess Air,and Losses. An on-board printer allows for the memorization and a printing of vital stack parameters at the touch of a button,while an RS232 interface streamlines communi- cation between the ECOM-AC and the optional remote digital display or a computer. I One of the most reliable analyzers on the market, each ECOM-AC instrument is fully tested to strict quality control standards for performance and repeatability. i s' 1.2 List of Abbreviations Listed below are some abbreviations that are used throughout this manual. 1 O2 Oxygen 1 CO Carbon Monoxide CO2 Carbon Dioxide NO Nitric Oxide i NO2 Nitrogen Dioxide NO, . Nitrogen Oxides SO2 Sulfur Dioxide Temp Temperature EFF Efficiency 3 Batt Battery . T.Room Room Temperature 1 T.Gas Flue Gas Temperature { T.Boiler Boiler Water Temperature ) Losses Percent of Losses of Efficiency Lambda Excess Air in w.g. Inches of water gauge—for the draft sensor 1 % percent by volume ppm Parts Per Million 1 mg Milligrams • my Millivolts 1 V Volts CO,Max Maximum CO,Value NO-Limit Signal indicating that the battery voltage for the NO sensor is low 1 1- en�v�aevnot ,' te ONu Ge p,� :Y �t`i . 2 , a 1.3 Optimal Performance This section describes the general operation of the ECOM-AC and should h help you understand the basic operation of the unit. The ECOM-AC is a portable gas measurement analyzer that enables qualified erson- nel to collect accurate data for the servicing and maintenance of a variety of combustiqn sources. , . Designed as a portable analyzer only, the ECOM-AC is not recommended for continuous operation. Semi- continuous operation can be performed providing that all filters and the water trap receive general mainte- t .- nance on a consistent basis. it_s,a 1.4 Unpacking Upon receipt of your instrument,you should find the following components and accessory items contained - i within the carry case:I. t°-el 1. ECOM-AC analyzer with digital display,integral printer,and simple keypad control panel �, . 1 15 ft.AC power cord i 3. 12"coaxial probe assembly with connections for draft,gas,temperature gas, and slot for smoke test tdp,._ i filter(other probe lengths available upon request) j 4. 2 rolls of printer paper �• t S. 50 smoke paper test discs i. 6. 10 spare filters for in-line sample hose - 2 7. 15 ft sample hose with pistol grip probe connection e `2 8. single water trap assembly y 9. ambient thermocouple with magnet 10. 2 keys for case latches C + 11. carry strap2 12. user operational manual F3 13. rbr note pad 14. Quick Reference Guide �.4, rII cl ' 4. 0.12 sin- A, 4 -2 Y Section 2 OPERATION FRONT PANEL FEATURES 2.1 Getting Started To begin ECOM-AC operation,open the case by releasing the two latches located on the top panel next to the carry handle, making sure that the instrument is lying flat so that the top of the case opens upward to expose the internal components. Remove the water trap assembly and mount it on the slot provided on the top edge of the right side of the unit. The water trap(the bottle itself)should hang on the inside of the case with the tubing un-kinked and feeding directly into the instrument. Once the water trap is secured to the side of the unit, plug in the supplied power cord to an appropriate power outlet. To turn the instrument on,press the rocker switch marked I/O(for Instrument ON)until the display acknowledges power ON and reads: Fuel Type Function Confirm By <E> Calibrate. 3:00 I �For units with the optional RAM Card Data Processing Package,position the cursor on Gas Analysis and wait for the screen to read as follows: --> Press 13 to Select Gas Analysis Data Bank/RAM Service Card Then select-->N0<--at the next screen. --> NO <-- YES 2.2 Auto Zero/Auto Span Once the EC0M-AC reaches full power,the instrument begins its automatic calibration procedure. The analyzer should be in fresh air during this period. During this process,the Oxygen sensor is automatically calibrated to ambient air,while the other sensors are zeroed and checked for proper signal outputs. The ECOM-AC will require approximately 180 seconds to complete the Auto Zero/Auto Span warm up period. 2.3 Fuel Selection During the initial calibration and warm-up,you can select the type of fuel being used for this test_ By • pressing the up or down arrow keys,you can designate your desired fuel selection. The fuel selection only • affects calculated parameters. 3- ` } P 4 Ll Screen 1 r_ l ti pF Fuel Type Function, confirm by <E> �► I y Natural gas t" o; vY CO2 max = 11.7, Al/K = 0.35 �F,A,�� ‘', a, press button to enter. You may now insert the �..,A After you view your fuel selection on the display, the probe into,the stack. r y 2.4 Normal Measurement Mode evaltJeij After the instrument has completed its 180-second calibration cycle,the display will read real-time emission Hk, values. The parameters displayed on the digital read-out and their corresponding ranges are as follows: C Screen 2 r'',r;!.• % e 02 21.0% e.,„eri, CO2 -- Los% Losses -- S ' !.. CO 0 ppm Exc. air — S e- Irk' NO 0 ppm T. Gas 75 F . F NO2 0 ppm T. Air 75 F et.- < NOx 0 ppm Draft 0.09 i.w.9 SO2 0 ppm Dew p. .,-4: M1 rely' L; 15 Contrast `s Once the unit is up and running,you can adjust the contrast of the display by pressing and holding the . , button,on the keyboard until the desired contrast level is obtained. rt.y , The ECOM-AC is quipped with a backlit digital display for easy viewing. Simply press light M to illumi- raj nate the display. To tum off, press again and the light will go off. � : . �C 2.7 Zoom Feature The ro Key can double the display size. Pressing this key once changes the display from 8 lines to 4 lines. ,,t, (See Screen#3) You may scroll through the different values being displayed by pressing the arrow keys. The up arrow key will allow you to view values for the 3rd line of display. The down arrow key will allow you to view values for the 4th line of display. a Pressing the r] key again will change the display from 4 lines to 2 lines.(See Screen#4) You may scroll 0 throw h the values being displayed by again pressing the arrow keys. The up arrow key will allow you to 9 -45 rri 41 view values for the 1st line of the display. The down arrow key will allow you to view values for the 2n e#:" line of display. arti 41 '1,141 } T"i Y? ttl -4- • • Screen 2 02 21.0% Eff. — % CO2 — % Losses — % CO 0 ppm Exc. air — % NO 0 ppm T. Gas 75 F NO2 0 ppm T. Air 75 F NOx 0 ppm Draft 0.09 i.w.g SO2 0 ppm Dew p. — F Screen 3 02 21.0 % CO 0 ppm NOx 0 ppm T. Gas75 F • Screen 4 02 21 . 0 0 CO • 0 ppm Pressing again will return the display back to the initial 8 line display.(See Screen#2) 2.8 Printing t � To utilize the print facility of the ECOM-AC,you must press the tit key for the instrument to memorize a particular reading. When the memory function is activated, an will appear on the LCD Display. Screen 5 02 21.0% Eff. — % m CO2 — % Losses -- CO 0 ppm Exc. air % NO 0 ppm T. Gas 75 F NO2 0 ppm T. Air 75 F NOx 0 ppm Draft 0.09 i.w.g SO2 0 ppm Dew p. — F • -S- 'a .. .. . . . �, _:t..,..twx..v-+.x 1-.5.t : e6+-aa,. A. I. . ti C _ ,' After pressing the al button, press the a button located on the instrument key pad, then use the arrow t.. keys to select"Start Printing". Press the Oj key to print the memorized emission values. After printing is C-r,,_! complete,the display will again show real- time emission values. v. , Remember to press the 0 again to clear the memory for the next test(this will remove'the"m"from the c_ top right corner of the LCD Display.) It is important to clear the memory before you begin the next test to ensure that only new information is entered into the memory when the next printing is performed. 2.9 Draft Measurement 4rDP.: The ECOM-AC is equipped with a high quality piezoresistive sensor for differential pressure measurements ` iI that are used to measure stack draft. P r To perform this function during normal operation, press the D button on the front panel of the analyzer. ,. The pump will shut off and the display will read: rift-if I reset zero point: release draft hose «.t i then press model_ IS 4 At this point, remove the draft hose, then press E. The sensor will now auto-zero. ,g r Keep the probe in the stack for 15 seconds for reading to stabilize, then replace the draft hose. The display era rid will now show the exact value for draft in inches of water from 0 to+/-40.00 inches. Press the CI button tI r to memorize the number, then press frni, (Escape)to return to the normal test mode. The memory has now stored the Draft reading which can be printed on the next test. Once the display has returned to the normal operating mode,press the f button to confirm the next gas test;all parameters,including draft,will be printed when the i Di button is pressed. lf 2.10 Smoke Measurement E '. The ECOM-AC probe is equipped with the facility to utilize a smoke paper test When the trigger of the K, pistol grip handle is depressed,an opening in the sample line is exposed to allow for the insertion of the smoke test paper. . To begin the smoke measurement,press the B key,then depress the trigger and place a piece of the �' " supplied smoke test paper in the slot on the probe handle.To ensure a strong sample to be extracted for , proper gas analysis and smoke test measurements,allow the pump to draw for 30 seconds continuously a against the smoke test paper. To remove the smoke test paper,depress the trigger one more time and remove the paper from the slot in the probe. You can now determine the smoke level by comparing the -1' smoke spot number with any standard smoke chart(e.g., Bacharach).To determine the smoke test num- ber,find the corresponding number that best matches your results. V- :5 f,1 1 } 6 1 a Section 3 . 1 PROGRAM SETTINGS You may alter the calculated and measured values by changing certain options via the ECOM-.AC s default I settings. Press the El button when in the flue gas measurement mode to access the option menu,then move 3 the cursor to the relevant position and press,, . 1 Screen 6 1i Adjustments Units ppm Fuel Type Undiluted No Clock Set Ref. 02 3.0% Fuel Type,-PC a Boil.temp. i Air pres. 9.50psi .1 J Probe heat. • No The following settings are possible: Unit Factor for calculating gas concentration in: ppm=volume concentration(parts per million) mg/m,=mass concentration per volume #/mBtu=lbs.pollutant per mm/Btu Undiluted Calculation of gas concentration using reference oxygen. Undiluted:YES will correct toxic gas values(CO,NO,NO,)to a theoretical O, level(i.e., 3%) 0 selected below under the Reference O2 section. When Undiluted:YES is activated,a U will appear after the toxic readings on the display. Undiluted: NO will provide normal toxic readings to the actual O,concentration. Formula for calculation: I E rel=E meas`(21 -0, rel) 21 -O,meas Reference O, Reference oxygen value for O2 correction(i.e., 3%). this will only calculate if Undiluted:YES is activated. Boiler temp Boiler feed water temperature as reference value i tAir pressure Barometric air pressure used in the dew point calculation I Probe heating Probe heating on/off for Smoke Test 1 Fuel Change fuel types without turning unit off I 11 I 7 z' x rn:R_.r o d*M";Y,i epn g,;^� .tvs .�ggfrn ,, 4 r:'.1.•. ';'^ • r:r. �W` �<- h-tiA'S,3 y"!ci"�.". ti.R a '.rye O < ry. i • :. • ♦ .. .n. • ., iEY .. .:TXi.:+?t4 Rdt'tlu `Yi�+1'Z��9�N'NWA2�'i'�M�?.v n}.:hntarM1�i+n x4.'. .A •. �.. C4 t; Clock Set the internal clock Fuel type<PC Upload fuel program from software r 4 Times Set the memory and output options for sending data to: RAM Card (set time intervals for storage, i.e., .02 to store every 2 seconds to the RAM Card): Data logger must be YES to r .d store.Centronics Port(direct parallel printer output) C Data logger Press D key to change YES/NO for Storage of data to RAM Card C 2 [' ,ca r :G et-'2., r,k2{ r 4 e i2. f= acir.4 era i e, 8 . - - 1 I Section 4 I • RAM CARD OPERATION 4.1 Formatting the RAM Card(Optional) To format the RAM Card,erasing old data from RAM Card after downloading to a PC, follow this proce- dure: 1 1. Insert RAM Card into RAM Card slot. � 2. From Normal Gas Measurement Mode, Press An (See Screen #2) 3. Position cursor on Data Bank/RAM. A _ 6'_�Press� Fel to select. (See Screen #7) ' I 4. Position cursor on RAM Card. Press to select. (See Screen #8) 1 S. Position cursor on Format. Press Ql, to select. (See Screen#9) 6. The display will read, Are you sure? (See Screen #9a) Position cursor on <Yes>. Press C to select(kB counts down). a 7. Formatting is now complete. Old data has been erased. 8. Press EiF twice and position cursor on Gas Analysis(See Screen #7) A l i 9. Press to return to Normal Gas Measurement Mode. (See Screen #2) 4.2 Datalogger On/Off To turn the RAM Card datalogger on/off, follow this procedure: 1. From the Normal Gas Measurement Mode(See Screen#2), Press Prog (Program from the front panel of the unit. i 2. Position cursor on Times and Press CI to select. (See Screen #6) 3. Position cursor on RAM Card and Press CI to select. (See Screen #10) 4. Enter the desired data storage interval(e.g., .02 to store every 2 seconds). (See Screen#10a) 7 S. Press El (Escape)to return to Program screen. (See Screen #6) / 6. Position cursor on Datalogger. NO. Press ID to change to Datalogger. YES 7. Press S (Escape)to return to Normal Gas Measurement Mode. (See Screen #2) i 8. Unit is now storing data to the RAM Card. • 9. To turn off the RAM Card datalogger,from Normal Gas Measurement Mode, press -0- . (See Screen#6) 10. Position cursor on Datalogger:YES and Press 1©1 to switch to Datalogger: NO NOTE:Each time Datalogger.YES/NO is switched on,a new storage file is stacked on top of any other data storage files until the RAM Card is reformatted,as described above. The number of data storage files will appear on screen as General Data. t _9_ 4.3 RAM Card Data Transfer to PC To transfer RAM Card data to your PC, follow this procedure: 1. Make sure that the datalogger is switched off(Datalogger. NO) before beginning (from Section 2.11). 2. From Normal Measurement Mode(See Screen #2), Press El and position cursor on Select Data Bank/RAM. Press El to select. (See Screen#7) C`_' 3. Position cursor on Communication,and Press[41), to select. (See Screen #8) 4. Position cursor on Send General Data, and press 4 to select (See Screen#11) r 5. Display will read: Get your PC ready for reception.Start the transmission by<E>. (See Screen #11a) �4+ , • When using the ECOM Software package, go to the Main Menu of the ECOM Software program on your 4'i PC and select RAM Card Data Transfer to prepare it for the transmission of data from the RAM Card. C'it Follow the instructions for PC Data Retrieval. 6. Once the PC is ready, return to the ECOM-A+, and press .0 to send data to PC. rt :, 7. PC screen will count upward for information received, and ECOM-A+screen will count downward for t!°` information downloading. cal} Return to Data Processing on the ECOM Software program to set up a new file and to import from rbr rikt- into the Data Processing(ECOMX)format Follow the instructions for Data Processing. C_`r-Li' �l Screen 1 Screen 4 f': ° 02 21.0 % ......,0b.,Fuel Type Function, confirm by <E> CO 0 ppm riey . Natural gas Pte' CO2 max = 11.7, Al/K = 0.35 Screen 5 r 02 21.0% Eff. — % m yr Screen 2 CO2 -- % Losses -- % 02 21.0% Eff. — 8 CO 0 ppm Exc. air — % CO2 — % Losses — I NO 0 ppm T. Gas 75 F NO2 0 ppm T. Air 75 F CO 0 ppm Tx. sir % NOx 0 ppm Draft 0.09 i.w.g NO 0 ppm T. Gas 75 F SO2 0 ppm Dew p. -- F NO2 0 ppm T. Air 75 F NOx 0 ppm Draft 0.09 i.w.g Screen 6 ' F.17S� SO2 0 ppm Dew p. F is — — Adjustmentserrs 1.) Screen 3 Onits ppm Fuel Type li Undiluted No Clock Set ��rr,, ._t CO 21.0 8 /_,{ lc., CO 0 ppm Ref. 02 3.08 Fuel Type,-PC k Boil.temp. NO 0 ppm T. Gas 75 F Air pres. 9.50psi Probe heat. No -10- 1/4.1. • • Screen 7 Screen 11 Gas analysis Communication Data bank/RAM — ;4 Service card Load data bank Y Select function, confirm by <E>! ! Send data bank Send general data 4 Screen 8 •d Screen lla Select Visualize/Print Send general data 41 Communication y RAM Card Get your PC ready for reception and s start the transmission by <E>! '• Screen 9 Terminate by <ESC>! Format .r Cancer Files Screen 12 Configurate Control V1.3 41 Capacity: 512kB General data: 0 02 i8256mV Run time 20.28 hrs Reserved: 64kB Free: 448kB CO -17 mV d NO -21 mV Serial no.AC 7722 1 Screen 9a NO2 -6 mV yf Format SO2 3 mV Service tel. <0770>806-0220 4 are you sure? -4 Screen 13 NO > YES <— Y4.. CO 0 ppm T.Gas 75.0 F + NO 0 ppm T.Air 75.0 F - Screen 10 NO2 0 ppm Draft 0.00 i.w.g. - A Times SO2 0 ppm Soot Measurement - CO-% -- ppm 02 21.0 % T Ram card .r 30 sec. Screen 14 .. CO 100 ppm Screen 10a Input: ppm 'v RAM Card eg. 0.05 = 5 sec., 1.00 = 1 min. Input: — + A ._ f -1 1 - ., ....< °�i+St!+3'..�s:`•t':'. ?. ••'f,')%i"?, '\S H✓•':eiYi4i 6i.a4`S�:SY,': . , - it, y t I tF�i k "�� v.e`�tiicMarlbr 4L iff'L,Y"`,a�,'9.At+v'a`� .VE - '@i` • r2"-€. r. r t,-k rf r, C. , r r<; r rr.Y� 5 C .rV ett r , e"' i pRr• I r`i r C , : r Cill edri 1 , r2 r • • Section S TURNING THE INSTRUMENT OFF 5.1 Turning the Instrument Off When turning the instrument off, remove the probe from the stack and allow any moisture that has gath- ered to drain into the water trap. Allow all toxic readings to return to zero and 0,to 20.9%before switch- ing the ECOM-AC off. Upon being switched off,the instrument will automatically start a purging cycle that continues until the gas values reach zero,a process that prevents the instrument from being stored with gas in the line. The unit will not shut off until readings fall below 15 ppm. Replace the probe and hose into the supplied compartments. Make sure the water bottle is placed back in the supplied compartment for storage. Plug in the instrument and let it charge overnight. (The instrument must be turned off for the best charge to take place.) If the instrument is to be stored in excess of 1 month,it must be fully charged before storage and charged again for approximately 24 hours when taken out of storage. 4 1 • f � ti 1 -1 3 re- el" ,a x r , i �.lCx tiesr l r l Arlo' Ii, yJn eijIc cit er r�4 rteicit. tin -14- 4l ._ ..__ rt. w: . Section 6 CALIBRATION OF THE ECOM-AC ( 6.1 Introduction i Calibration is a distinctive feature of the ECOM-AC. To guarantee accurate performance of the analyzer, the instrument uses microprocessor technology and quality sources of gas. The ECOM-AC automatically calibrates to ambient Oxygen at 20.9%,and zeroes the appropriate toxic gas scales during its initial calibra- tion and warm-up phase. To guarantee accuracy,it is imperative that the instrument is turned on in clean air only prior to placing the probe in the stack. Span calibration for the sensors is described below. ) To calibrate the ECOM-AC,you will need a Calibration Kit accessory, available separately from ECOM AMERICA, Ltd. You will also need Certified Calibration gas for CO,NO, NO„and SO„ depending upon the type of sensors your analyzer is equipped with. Although the toxic sensors are linear within their respective nominal ranges,the recommended calibrations levels should be as close to the expected readings as possi- ble to achieve best results. 1 IT IS VERY IMPORTANT THAT THE SENSORS ARE NOT OVER-OR UNDER-PRESSURIZED. THE FLOW OF THE GAS MUST EQUAL THE PULL OF THE PUMP, OR THE PUMP MUST BE ALLOWED TO PULL THE GAS AT ITS OWN RATE. 3 The ECOM-AC may be configured with 4-6 electrochemical sensors including Oxygen(0,),Carbon I Monoxide(CO),Nitric Oxide(NO),Nitrogen Dioxide(NO,), Sulfur Dioxide(SO), and Combustibles(C„1-0. Note:There are two sensors available for CO with ranges of 0-4,000 ppm(1 ppm resolution)and 0-40,000 ppm(5 ppm resolution). I 6.2 Calibration Principles Calibration of the sensors in the ECOM-AC is a quick and simple process. The analyzer is configured with an individual sensor for each specific gas to be measured. Sensors indude O„ CO,with optional sensors for NO,NO„SO„and Combustibles. If you have any question as to the configuration of your instrument, check the printout or LCD to confirm the actual sensors found in the analyzer. Note:There are no sensors for CO,or NO,as they are calculated values. 6.3 Auto Span and Auto Zero When the ECOM-AC is switched on, it will perform a three-minute auto-zero of the toxic sensors(CO, NO, NO„SO,and Combustibles)and auto-span for the O,sensor. The auto-spanning of the Oxygen sensor sets the calibration/span for the sensor. No calibration gas is used for calibrating the O,sensor. The auto- zero function sets the baseline or zero point for the toxic sensors. 1 6.4 Calibration Methods i There are three recommended methods of calibration for the ECOM-AC. In each method, the gas line should be connected to the instrument by placing the tubing over the end of the probe or by connecting it I to the gas inlet of the instrument (Fittings for calibration are supplied in the ECOM calibration accessory ) kit.) When checking for air leaks, it is best to connect the gas line to the probe. i -15- %� VA.q, '1,,f�,t: k:,:ii i$ itca• d".rt�!b'V'de7,011,:..,S 'la? 7Jr.11...-'' tr'R$Tv.K,-' .. l P 1. The first and most common method employs a'regulated flow meter that is used as a vent in the gas line to ensure that the sensors are not over-or under-pressurized. This process connects the c' ^ instrument, the gas cylinder and the flow meter using a 'T" connector. ► i liens gas is vented Nrwgh Step 1: the hOw mete. Open the pas now {; until the how meta l reads t lfM. — I I I. k, ® 0 �". t. �T feting Sten . The pnlow metes vents a small amain(ei Ws heeh Fr."- NITT to air volt enlemu Ue Sys-Roland tea stows e to control all mnrun<m v mmma prmae Sas ...man � ; 2. The second method uses a regulated flow meter that is attached to the probe using an appropriately et sized section of tubing. By connecting one end of the flow meter to the EC0M-AC, and leaving the ' other end open,you can first measure the flow rate of the pump, then connect the other end of the p.1=Z flow meter to the gas cylinder with the regulator opened to match the pull of the pump. 1± 1 i t I I h_ Sep:: t Cornea gas Minaee,m ® floe fle regubate,unfit now ...0 rechannelsale as Puma teleSKTMal W mw I es ppmo.i Mewl Connecter 1 ono to taw met r to measure w of tW. ; M pu I CET a. 3. A gas calibration bag can be used to draw gas into the instrument for calibration. By allowing gas to } be drawn from the bag, rather than a cylinder, this method ensures the maintenance of the correct v flow rate. We recommend that you use a gas bag 15-liter or larger to ensure that enough gas is pre sent for the instrument to stabilize. Alj; CA ItI tl C. i it i -1 6- C. 1 • -ml 1)yI Y . i.✓... a Yun'�.-.... . -. ...............-Sep 1 '�- il t Fill he es bag being weed not to oboe ail to leak info toe bat • 0 1 it Step 7It as tern eam Ile bMrvmtnl to draw the bb Bantle WOYdM'taboos lo settee 4 6.5 Calibration Gas 1 During calibration, use a different calibration gas for each sensor(O,excluded)to ensure accuracy for each parameter,keeping in mind that accuracy standards for calibration gases can vary depending on the type or classification of the gas. Individual cylinders or certain blends can also be used for instrument calibra- tion. Some types include: a) Small disposable cylinders b) .Larger refillable cylinders—NIST traceable c) Larger refillable cylinders—EPA Protocol Gas Your application or instrument requirements may dictate which type of calibration gas to use,and your gas sup plier lier can recommend which type to use for the balance of the gas(generally Nitrogen). Non-absorbing `1. 4 materials such as stainless steel regulators and non-absorbing tubing should be used to eliminate the loss of the gas sample—primarily NO, NO„or SO,. ys For best results,the gas concentration should be as close to the expected levels of emissions as possible. Because each sensor is linear through a nominal range,one calibration gas concentration can often be used ;t- for a reasonably wide range of emission levels. For applications with extremely low or extremely high levels a of emissions,with respect to the sensors operating range,the sensors should be calibrated as close as pos- sible to the desired levels to be measured. Ti 6.6 Getting into Calibration Mode From the normal measurement screen,press the CONTR button B and the display will show the milli- . volt signals for the sensors,as well as other instrument data. Take the magnet portion of the Ambient Temperature Thermocouple and place it just above the CAL HERE label on the analyzer. The unit will beep Ii and enter into calibration mode. Screen 12 Control V1.3 ;44 02 18256mV Run.time 20.28 hrs vY CO -17 mV 1 NO -21 mV Serial no.AC 7722 '- NO2 -6 mV , SO2 3 mV Service tel. <0770>806-0220 1.41 1 7_ .".i t y ,a�•. ,+ hS r.., t. L. ws rr.cto 6.7 Applying Calibration Gas C Position the cursor on the gas you wish to calibrate first and apply the gas at the correct flow rate by using r any of the three methods mentioned earlier. Allow the reading to stabilize for a short period of time. Response time will vary depending on the sensor being calibrated. Generally, the reading will reach 90- -- k 95%of full span very quickly,and the remaining 5-10%will then level off and stabilize. r . E: Screen 13 CO 0 ppm T.Gas 75.0 F C ` NO 0 ppm T.Air 75.0 F r, NO2 0 ppm Draft 0.00 i.w.q. t , S02 0 ppm Soot Measurement C0-% — ppm 02 21.0 % r"" ., Once the reading has stabilized, press E to select the gas,and a new display will appear with the reading C- for the gas to be calibrated. Input the correct numerical value of the calibration gas via the analyzers key- pad. The sensor may be calibrated up or down. Cci Screen 14 c_.-.k co 100 ppm C,g Input: - ppm C`t, Press E to confirm and the unit will return to the previous screen. That sensor has now been calibrated. C Position the cursor on the next sensor to be calibrated,and repeat these steps with the appropriate calibra- tion gas for each sensor. Cl Note:The O,level should fall to near 0.0%when applying a gas with a Nitrogen balance as the O,is being c--, displaced by the N,. An excellent method for checking air leaks and calibration is to apply the gas throughout the entire sampling system,including the probe and sample line. After calibration of each sen- sor is completed,press ESC (Escape)twice to return to normal measurement mode. 6.8 Calibration Protocol Verification of the portable analyzer for calibration,drift,span,interference,and other parameters,before and after an emissions compliance test may be required by the local regulatory agency. You can ensure accurate and repeatable results by following an established protocol. Check with the agency for any exist- ing protocols they may prefer or acknowledge. . f. ci cg.. ,„' el -18- t,tf: • Appendix 1 , 1- FRONT PANEL DISPLAY FEATURES tr., Select Printer Contrast Zoom Control D¢ptay Pnp Program Special Cursor Optonsnt Advance Mode CO Mode Up Escape fft pm «Z00M PAINT 4k>. 'PR00l CMO0E`tT �. f.-H {* C0 ® M0KEe jCONiN m,ifP Illuminate CO Pressure Soot Control memory Cursor y Display Bypass (Inches Measurement ModeMeasurement far OOwn Enter Ord Jp Printing Appendix 11 TECHNICAL SPECIFICATIONS iit PHYSICAL Instrument: 19"x 16"x 6.5"Aluminum Carry Case with locks A Probe: 13" length x 3/8" OD Inconel Probe with aluminum handle, pistol grip handle with threaded quick disconnect probe connection Hose: 15'high temperature flex hose with thermocouple wire. Additional lengths available. Weight 28 lbs. ELECTRICAL AC: 110 V 60 Hz/220V 50 Hz Standard. User selectable on panel. 1 Amp. Batteries: Lead acid rechargeable—life 1.5-2.0 hours i MISCELLANEOUS: Pump Draw: Flow rate 2.5 LPM(approximately) : y Display: 24 Character,full line backlit display with adjustable display contrast and zoom. Displays all parameters simultaneously. OPERATING TEMPERATURE Instrument: 20 F to 122 F acry 10- Probe: 0 F to 1800 F c: MEASURED PARAMETERS: 1. OXYGEN Range- 0-21% v :C I v, -19- i Sensor Type- Electrochemical C . Sensor Life- 2 years Accuracy- 2%of reading ?k Resolution- .1% f 2k CARBON MONOXIDE Cs Range-Range- 0-4000 ppm ►v. Sensor Type- Electrochemical C Sensor Life- 3 years* Accuracy- 4%of reading r Resolution- 1 ppm ` 2B. CARBON MONOXIDE ; II Range- 0-40,000 ppm Sensor Type- Electrochemical Sensor Life- 3 years* Accuracy- 4%of reading Resolution- 5 ppm 3. NITRIC OXIDE c. Range- 0-4000 ppm Sensor Type- Electrochemical Sensor Life- 3 years* �* Accuracy- 4%of reading Resolution- 1 ppm C. ; 4. NITROGEN DIOXIDE Range- 0-500 ppm Sensor Type- Electrochemical Sensor Life- 3 years* Accuracy- 4%of reading Resolution- 1 ppm 5. SULFUR DIOXIDE Range- 0-5000 ppm Sensor Type- Electrochemical Sensor Life- 3 years* Accuracy- 4%of reading Resolution- 1 ppm , Cici -2O- e • 1,,_.max.. . ..._.� _. I 6. COMBUSTIBLES , +;p Range- 0-6% Sensor Type- Pellister 14 Sensor Life- 3 years :c Resolution- .01% 7. AMBIENT TEMPERATURE I Range- 0-250 Degrees F Sensor Type- IC Sensor Sensor Life- 10 years Accuracy- 3 F Resolution- 1 F 8. STACK TEMPERATURE Range- 0-1800 F Sensor Type- Type K Thermocouple ly Sensor Life- 10 years T' Accuracy- 3 F - Resolution- 1 F 9. STACK DRAFT ',re Range- 0-40.00" H2O Sensor Type- Piezoresistive Electronic Sensor Sensor Life- 10 years rAccuracy- 2%of Reading Resolution- .01I-I,0 10. SMOKE MEASUREMENT g Scale- 0-9 spot method 11. TIME/DATE-Time in hours, minutes,and seconds Date in day,month,year Depends on usage and gas concentration CALCULATED PARAMETERS: 1. CARBON DIOXIDE(CO) Range- 0-40% Resolution- .1% Formula: CO,=CO, max*(1 -O,meas.) 21 C It 21 tah'tiA^dwer i . .k r%ii .. .: wq .4x.'v:.. 4 L - "4.7.-t-.!::,4,4 2. COMBUSTION EFFICIENCY • Range- 0-100% rY Resolution- 1% r' Formula: ETA= 100-q, ' 3. EXCESS AIR (LAMBDA) ei" Range- 0-50% Resolution- .01% esr-E Formula: Lambda= 1 +O, t'.Ti 21-O, 4. LOSSES Range- 0-100% . Resolution- 1% Formula: q, = (A2+B) *(T gas -T air) 21 O Appendix III r TROUBLE SHOOTING 1. Purple beads are for removal of NQ/SO,for the CO sensor only. When replacement is necessary, they will r turn brown,then white. 2. A high Oxygen reading could be the result of an air leak somewhere in the sampling system. Check all tubing,connections, O rings,water trap assembly,sample line, and probe. . y 3. By using a calibration gas with a Nitrogen balance,the O,will be displaced or purged to a reading of near 0.0%. This serves as an excellent method of checking the integrity of the sampling system for leaks. 4. A low or high reading on calibration gas could be the result of improper flow. Be sure not to over/under _ pressurize the sensors.Follow all calibration instructions for applying gas. S. The filter on top of the water trap can be saturated with water. Be sure to check this periodically as it will cause the pump to work against this blockage. 6. After a printout has finished, be sure to press m again to remove the prior test from the short term memory. 7. When connecting a unit to a PC via an RS232 cable,the pins of the cable must be modified or a null modem used in order for the two to be compatible. 8. Use the trigger on the pistol grip probe only for inserting the smoke dot paper. Pulling the trigger during a r� normal emission test will result in an air leak causing diluted toxic readings and high 0,. -22- ( • r :a r cill 9. A small magnet used for accessing calibration is located at the end of the Ambient Thermocouple. 10. A proper pre-calibration test will result in correct emission readings. An improper pre-test calibration will t' • ,a result in incorrect stack/exhaust readings and may invalidate any subsequent testing. `a Appendix IV r • a `, CHANGING NAME ON PRINTOUT Equipment required: C .a 1. ECOM-AC+analyzer C I? 2. Computer(PC) I. c 3. RS232 cable w/null modem or modify pin connections 2-3,3-2,5-5 4. ECOM Software r la r ICJ Instructions: C I7 1. Connect the RS232 cable to the PC and to the ECOM analyzer ` 2. Install the ECOM Software to the PC C La 3. Start the ECOM Software program and go to Main Menu �� 4. Position cursor on Name to Printout and stop. C ', 5. Turn the ECOM-AC+analyzer on. ley will C .a 6. Before 10 seconds has elapsed, place magnet on "Cal Here"label(same as calibration position). C �- 7. The analyzer will read Gas Analysis. 8. Return to PC and select Name to Printout k all C .. 9. PC screen will read: Zeile 1: (enter information) -� Zeile 2: C of near r ,i. or 2 Zeile 8: under fir''J r 17 Note: If only two lines of information are needed, use the first two lines(Zeile 1&2),and"Return"through the , other lines leaving them blank. sitwill Cl� 10. Once"return"is entered on Zeile 8,the PC will show"OK"in a few seconds. C n Ca � 11. To test the name, turn the ECOM-AC+off and then back on, allowing the unit to complete its 3-minute � calibration cycle. Print out as usual. C? ull C 1-3 during a G ) L) 7 -23- Appendix E Facility Map and Plot Plan ,ii/ .- " a� � . 1- --0:55—r . _ ) �7. ";1 t'14891 V. ' �I/r 1.�' den • I 1,,- '/\— - �`70 L \/"'4 -4 t ] Ro¢edakl i �0 • rr } • ^ '--. -' w`� 11-r- 1-;�=-�r !li& - , 64 _ 11 n , o �t t � �f ,, t' 1414 dowef j'-- _ I -• SO I • y9y I fi� ,.{ - �� 4916 1 �N't`lw"sC ( �yto , Ol r7 I It I, , lnr.l tikd *• �I I 4 �C ,..I '- (., i OUth 7a�v w,. _ 1 -i4 --1- �. h-,- 871 i ,/. lrtc �.<' t' I—_, • �i :• ` �' 7J . ( 1/C- • J ti a4 IH-C Jas ey , O r R A wcsTc r Mjy Ilkert } - i47DB _—.j . $ Si . / Y It 1141_ On { 1, 1 . I PeCiI Y P JIYJll' i I � I eta? 1 �i f �9 s. ,� ,'N` i�p7(si�� f 1 6797;1- i—'-- --C, __ ' j i (I)It St // j `� 1 i , _ 14]Al'.1-fr ,n j •:.1., I 4 5'0 i14` � 2 �� I ' ` � 1!•. � ea. oa I 1 f�rm 1 %i ��' L. icli o1,CN.trig. I?2 I I A 1 Wi$milui , ' � �? r.4,q is I �as� E .r �PIattSJJJ ' I ee1� :Na tmn� g r- Gc,lld:lda mil , / I 14: 4 1 • _ • ' -1 r $ -{- -JI 116111./x c c tl '�' ; ndm ill`, �t l� nCh t I__ I 'n,/15.1147- __ _ �` t �x ! -e Drivinr Directions: 125 N to Exit 235 talk! c M e . I r-1 • I i oo l 4 Ca�I_ r. 0, 'I ..(CR 52). Go East on 52-5 mi.to Cr 19. ----- 6: 1C3• ----II Turn left Spindle is on the right side-'1/2 '._ •. _� --- _ ._ ' - Lake r _ i mile.9101 W.CR14,Ft.Lupton, cI 485 7 y— _ -•I, y , > e nm CG.g0621 B7 I I -I �f ‘ • N I i J _ __ • �86 I.ne� 1- --- I i ( )` Vc m 1 i_ T 1 _ .., Fa ., i a �5c• I „\ ' 1tre.dP I a I ,i _I � V� �1°� . u ...8:- 1� 5195 1 • i` -a. _ } X8581 7 I( c., - Lo , — / HE SAND Hi( � / ' ^ • _ �_r '• - __ .� U7-1- I ,,/ , \ It� k�/ I q Finn I t T -_.. aeon �,_ _ 1J P _ 69/4 • Y. y. ' Nr ��I J �y In ' i twit,_, I_ r1 C/ {i'.' o i/ o � I, L I I "x15 n n- }� r 6 t t `t% I50d11 ,,T2-"c..,,,, f f x a l� �� `^C` r 1 I �1;' , at Vralrl4 ,-,7--'r-'—'. -- ; ,1 ` 1 4� 4:80I �_ /' J jr � � .. 1 t f� 1 i� I 4 dl el erg ✓. •. . C,01 -, r._ I 502E • a 1,,', 1- 19bt •- T` 0jpl -` 151 i ' -'�- F rm•� / y�r� 1 .{ -_.I- ' L. I i`-1 513.5 f/'"� I_ ,L 1- v ,1' (J s Id • 1 111 — �A_?l J• )_�. ;). .. .��j — iI —rte= _ �....\ �..+---- o� �snoa o s so.o,.P.,, rsim¢. Spindle Gas Plant is 40104A1 Greeley Soma:USGS 0 wale Duke Weld County,Colorado in Dawn yy:y_1MW V; !1@ Zone 13 UTMH 509828m UTMV 4437358m Revised by:Dice Field services. ENVIRONMENTAL s A Duke Emmy Cmgmy AFFAIRS DEPARTMENT , , •,n W � -.i I • 2 g@1 : 1 R NWag O c, a • 6 t :Fa a gigz -4 b I I _ a o ' L._. Ii. r_..I is 1.i .M N N iiii � '_a J¢ , m I 1 I I t 324 ��4I I I ,.. 't iE0YB3r -a —t i t!, II v " " 1" --- .P tt � SilI ! l�. i��L � p ? 5�0 IIds il I l a u �r .X !4 4 u_ e� )�(,- ' ] o III - pp _a III II4 ,I -t..., I_.. a .� ! ! m — �p », F. � 11 a u " wnI "" �..I “1t�• LI= •fell F r — ! _ al R C • lEmmm • li KC i L1 , a , ��..au I ® l„ wH,; x IMII _e i al— = — � - . _,- I,o a i i .-_ ��d II J_I ll i__¢° a j f] 8 1— I 4. x1 :„ ^ ir x • it I i . ,p $ e 0 j8 iI x -- I--- ---ii------ -- --- • -- - I ------ I a ' -N is I I 0 Aid x 9 . I r A N, N 1' I I i - Q • x y . x 9 x x ! J p ! _ ! p ° •,e se u N n—u -- " ! is I I I p'Ix : — I � x i 'UM xI _e gg 2 I �'. 4- I —TT _ I - Ix -. 4 o-.rr % llI1 II i� .4 ,O I(J! j X h 4 [so x -N x N I I """ • • C > 4 4 4 C 4 6, 4 Z 4 ' 4 4 " 1 " ' 4 4 1 4 " 4 ' 4 ' 4 < Appendix F Compliance Assurance Monitoring Plan Compliance Assurance Monitoring Plan Spindle Gas Processing Plant 1 Background This portion of the operating permit application is included to meet the requirements of the compliance assurance monitoring (CAM) regulation (40 CFR Part 64) as it applies to pollutant-specific emission snits (PSEU) at the Spindle Gas Processing Plant. To be subject to the CAM regulations, a PSEU nust meet the following three criteria: (1) it is subject to a federally-enforceable limitation on a egulated air pollutant or pollutant surrogate; (2) it uses an emission control device to comply with the mitation or standard; and (3) its potential pre-control device emissions of the pollutant are "major" as efined by 40 CFR Part 70. )uke Energy Field Services (DEFS) operates thirteen I/C compressor engines at the Spindle Gas 'rocessing Plant. The engines are subject to limits on emissions of nitrogen oxides (NOr) and carbon tonoxide (CO). Twelve engines are equipped with nonselective catalytic reduction (NSCR) units that wer NO., CO and hydrocarbon emissions, and one engine has no pollution control device. Eight of e engines, the 1000-horsepower Waukesha L-7042 (engines P160, P161, P162, P163, P164, P165, 166 and P169), have pre-control device potential emissions that are "major" as defined by Part 70. ve of the engines, however, qualify for exemption from CAM by any of the criteria listed at 40 CFR Year t.2(b).(P167, P168, P170, P171 and P002) Hence, these eight engines are subject to CAM quirements and are addressed by this monitoring plan. ie CAM regulation specifies the information that an owner/operator must submit with a Part 70 6 plication for subject PSEUs. The basic elements required of a source subject to CAM are listed 6 low. 6 Proposed indicators of performance relevant to compliance; g Indicator ranges or conditions, or the process by which such indicators will be established; 6 Performance criteria that satisfy 40 CFR 64.3(b); .6 Indicator ranges and performance criteria for any CEM, COM or predictive emission monitoring .6 96 (PEM). minimum, the rule requires a source to select for monitoring at least one indicator of performance control device and to make at least one observation per 24 hours of the relevant parameter. A rce is required to submit information that justifies its proposed monitoring for compliance. ns of portion of the operating permit application identifies the subject emission units and the federally- 'rceable emission limits applicable to each unit. Table 1 presents the CAM that DEFS will perform he NSCR/Catalyst units on the eight engines as required by 40 CFR 64. DEFS also presents 9cation for the proposed elements of its monitoring, as required by section 64.4(b).-ent Operating Permit Number: 95OPWE039 )le 1 on ind one and AFR rig Table a) s c -o d C V C(o pa) m T C w O C. 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C V r _ C cO Q m .- m a 0 W al j V O a 0 C O m p- C O w't CO m cC O m O U lL 0 a a m E m a c E a m co C a O O E m o a C O 0 C (6 rt co m co co O 0 U O O w m 02 O) Zc2 ` a 0 > 0) 0.0l 0cm) Q o ai ao 660 uia i • w Monitoring Approach Justification Rationale for Using Temperature as a Performance Indicator The temperature into the NSCR unit is measured because the catalytic reactions that destroy the three pollutants are temperature-dependent. The reduction reactions occur favorably if the engine exhaust gas temperature into the catalyst is greater than 650 °F (per the manufacturer's specification), but begin to decrease significantly if that temperature drops below 650 °F. Exhaust temperature typically exceeds 650°F if the engine is operating properly. Catalyst damage will occur if the inlet temperature is too high. Deterioration of the catalyst would reduce emission destruction efficiency. To protect the catalyst, the engine is equipped with an automatic shutdown that will stop engine operation if the exhaust gas temperature exceeds 1350°F (as specified by the manufacturer). Either excessive or inadequate temperature indicates possible problems with engine operation that may be correctable after investigation. Monitoring of the temperature-sensing device (thermocouple) of the inlet exhaust gas into the catalyst will ensure the presence of optimum conditions for the catalytic reaction. Rationale for Using Oxygen Content as a Performance Indicator The oxygen content of the exhaust gas was selected as a performance indicator because the exhaust gas into the catalyst must have sufficient oxygen to promote the oxidation of carbon monoxide and hydrocarbons. However, if exhaust gas oxygen concentration is too high it will interfere with the catalytic reaction of the nitrogen oxides. Thus, percent oxygen in the NSCR inlet must be kept within a range for optimal destruction of all three pollutants. CAM Implementation Temperature Monitoring The control panel on each engine has a digital readout that displays the engine exhaust temperature at the NSCR unit inlet. A data logger will record the temperature indicator at least once daily and record the displayed temperature. To ensure ongoing catalyst integrity, the control panel is programmed to automatically shutdown the engine if the exhaust gas temperature exceeds 1350°F. The control panel will be programmed to notify an operator if the exhaust gas temperature at the NSCR inlet is less than 650°F. If no shutdowns or notifications occur, compliance with the emission limits is presumed based on the known optimal conditions for performance of the catalyst unit. DEFS will investigate all compressor engine shutdowns and alarms and will record whatever corrective action is taken to return the engine exhaust temperature to its normal range. DEFS will investigate all notification and will record whatever corrective action is taken to return the engine exhaust temperature to its normal range. Oxygen Content Monitoring DEFS uses an air/fuel ratio (AFR) controller to promote and maintain slightly rich to stoichiometric combustion mixtures both to facilitate combustion and to allow a certain amount of oxygen carryover into the exhaust gas stream for catalytic reaction. The AFR oxygen sensor displays a signal on a digital readout in terms of volts. DEFS initially fixes the AFR at a "setpoint," which is a voltage value that the AFR will automatically work to maintain by adjusting the fuel intake into the engine. During engine operation, the voltage (surrogate for O2) reading of the exhaust gas prompts the AFR to increase or decrease fuel for the combustion mixture depending on the direction of drift from the setpoint. As the engine adjusts to variations in the operating load and the Btu content of the fuel gas, the AFR continually checks exhaust oxygen content and adjusts the air/fuel combustion mixtures to maintain the assigned set point in volts (and, therefore, the appropriate amount of residual oxygen in the exhaust). However, the process of responding to changing engine operating conditions creates a natural fluctuation in the voltage reading, which means the oxygen sensor indicator inevitably will display a range of voltage values over time. DEFS initially establishes the setpoint of each 02 sensor (in volts)while measuring both NOx and CO emissions with portable analyzers when exhaust gas temperature is within the range for proper operation of the catalytic converter. Thus, the setpoint is established at an air/fuel ratio that corresponds to compliant emission rates for NOx and CO measured in real-time by the analyzers. For CAM, DEFS will monitor 02 in the inlet to the catalytic converter daily using a data logger for the voltage reading on a dedicated voltage meter. The voltage reading will be recorded with date and time of reading. DEFS personnel will compare the observed voltage to the range that that is listed in Table 1. The delay of the AFR in responding to changing operating conditions creates a fluctuation in the voltage of the oxygen sensor and therefore may require averaging. An excursion is defined as two consecutive daily average readings outside the range stated in Table 1. Corrective action following the recorded excursion will include inspection of the 02 sensor, documentation of the inspection results and replacement of the sensor if needed. DEFS will then check emission rates using a portable analyzer. In the event that testing shows compliance with the emission limits when the voltage reading is outside the range defined in Table 1, DEFS will submit an amendment to the Title V Operating Permit to adjust the acceptable indicator ranges as necessary. The set points for the AFRs will be verified during the tri-annual stack emissions testing. The 02 sensors will be replaced when found to be defective. Establishing the Temperature and Oxygen Sensor Indicator Range The indicator ranges in Table 1 for the temperature and the oxygen voltage into the catalyst was selected based on available operational data from compliance tests, observation, and manufacturer data for rich burn engines equipped with AFR and catalytic control. The values at either end of the indicator range, therefore, do not necessarily represent a point beyond which the engine is emitting NOx or CO at rates that would exceed their respective emission limits. Hello