HomeMy WebLinkAbout20083812.tiff 02/it/- /US — �c Weld County Planning Department
GREELEY OFFICE
c, ' rzA 6,+r,,,v MAR 2 8 2008
rm ECEB '�=" '
STATE OF COLORADO
Bill Ritter,Jr.,Governor
James B.Martin,Executive Director °F•cozo.P
Dedicated to protecting and improving the health and environment of the people of Colorado
y � o
4300 Cherry Creek Dr.S. Laboratory Services Division * G°'
Denver,Colorado 80246-1530 8100 Lowry Blvd.
•
Phone(303)692-2000 Denver,Colorado 80230-6928 1876
TDD Line(303)691-7700 (303)692-3090 Colorado Department
Located in Glendale,Colorado of Public Health
http://www.cdphe.state.co.us and Environment
March 13,2008
Mr. Steve Moreno
Weld County Clerk
1402 N. 17th Ave.
Greeley,CO 80631
Dear Mr.Moreno:
On March 19,2008,the Air Pollution Control Division will publish a public notice foiDCP 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 byColorado 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 blow.
Colorado Dept. of Public Health&Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Jacquie N. Barela
Re ds,
Jacq eline . Barela
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
g' 0 r. (3L / L0 3
2a3S3a12
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 17th Street, Suite 2500
Denver, CO 80202
Facility: Kersey/Mewbourn Gas Processing Plant
Junction of Weld County Road 35 and Weld Coutty Road 38
Gilcrest, CO 80623
DCP Midstream, LP, has applied for an Renewal Operating Permit for their facility in Weld County, CO.Natural gas
liquids processing and gathering. A copy of the applications, including supplemental information, the Division
analysis, and a draft of the Renewal Operating Permit 95OPWE062 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 Lisa Clarke at the Division at 303-692-3117 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: March 19, 2008
March 13, 2008
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
OPERATING PERMIT RENEWAL SUMMARY
PERMIT NUMBER: 95OPWE062 AIRS ID#: 1230090 DATE: March 13, 2008
APPLICANT: DC Midstream, LP—Kersey/Mewbourn Gas Processing Plant REVIEW ENGINEER: Lisa Clarke
SOURCE DESCRIPTION
DCP Midstream has applied for renewal of their Operating Permit issued for the Kersey/Mewbourn Gas Processing Plant
located at the junction of Weld County 35 and Weld County Road 38 in Lucerne in Weld County. This facility is located in
an area designated as attainment for all criteria pollutants except ozone. This area is classified as non-attainment for
ozone and is part of the 8-Hour Ozone Control Area as defined in Regulation No. 7, Section II.A.16. This source is a
synthetic minor source with respect to Prevention of Significant Deterioration (PSD). This facility is located within 50 miles
of Wyoming, which is an affected state. This facility is located within 100 kilometers of Rocky Mountain National Park,
which is a Federal Class I designated areas. This source is subject to the Accidental Release provisions of section 112(r)
of the Federal Clean Air Act and the required Risk Management Plan was submitted to the appropriate authority by June
20,1999. Eight(8) engines (C-105, C-106, C-107, C-108, C-109, C-110, C112, C-113, and C-178) are signification
emission units equipped with air pollution control devices subject to the Compliance Assurance Monitoring (CAM)
requirements in 40 CFR Part 64. The facility is a true minor source of HAPS and is not subject to the requirements of
MACT ZZZZ or MACT HHH. The facility is subject to the area source requirements of MACT HH due to the presence of a
triethylene glycol dehydrator at this facility, although all emissions from this unit are recycled to the inlet stream.
FACILITY EMISSION SUMMARY
Potential to Emit(tons/yr)
Emission Unit
NOx I CO I VOC I Formaldehyde Total HAPS
Four(4) 1232 HP Engines 76.0 76.0 47.6 1.7 2.3
Two(2) 1100 HP Engines 34.0 34.0 21.2 0.8 1.0
C167 1680 HP Engine 24.3 24.3 16.2 0.6 0.8
C181 1478 HP Engine 21.4 21.4 16.2 0.5 0.7
Three(3) 711 HP Engines 33.0 33.0 20.7 0.7 0.9
C134 750 HP Engine 11.6 11.6 7.2 0.2 0.3
C211 330 HP Engine 5.1 5.1 3.2 0.1 0.1
C132 450 HP Engine 7.0 7.0 4.4 0.1 0.1
C243 380 HP Engine 5.9 5.9 3.7 0.1 0.1
C210 84 HP Engine 1.7 1.7 0.8 0.0 0.0
P016 Hot Oil Heater 6.3 5.3 0.3 0.0 0.0
F017 Fugitive Leaks 0.0 0.0 9.2 0.0 0.0
P019 Tank Loadout 0.0 0.0 20.5 0.0 0.4
P024 Stab.Tanks 0.0 0.0 7.1 0.0 0.1
Total 226.3 225.3 172.3 4.8 6.8
EMISSION SOURCES
The following discussion identifies some of the noteworthy changes that were made in the renewal permit.
Compressor Engines—The Division replaced one engine in the permit and modified twelve of the engines to the correct
specifications. The Division also incorporated two other engines into this permit. All of the engines at this facility are
controlled with non-selective catalytic reduction systems.
Equipment Leaks—The Division added fugitive emissions from equipment leaks of both plants to the Operating Permit.
This facility is subject to the requirements of the NSPS KKK.
Miscellaneous—The Division modified the hot oil heater to the correct specifications, increased the condensate truck tank
loadout throughput, and incorporated four(4) stabilized condensate tanks into the permit.
Facility Wide Changes—The language was updated throughout the permit to reflect current Division-Approved language.
Language revisions made to: Alternative Operating Scenarios, Portable Monitoring, Ozone Nonattainment Area
Requirements, and Appendix B &C.
Tech Review Summary—Kersey/Mewbourn Gas Processing Plant Title V Renewal Page 1
TECHNICAL REVIEW DOCUMENT
For
Renewal
of
OPERATING PERMIT 95OPWE103
to be issued to:
DCP Midstream, LP.
Kersey/Mewbourn Gas Processing Plant
Weld County
Source ID 1230090
Prepared by Lisa Clarke
November—December 2007
I. PURPOSE
This document will establish 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 proposed for this site. The original Operating Permit was issued June
1, 1999, and expired on June 1, 2004. 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 May
30, 2003; additional information received February 24 and October 20, 2004; August 24, 2005;
May 9 and July 12, 2006; June 8 and November 15, 16, 2007; previous inspection reports, and
various e-mail correspondence, as well as telephone conversations with the applicant. Please
note that copies of the Technical Review Document for the original permit and any Technical
Review Documents associated with subsequent modifications of the original Operating Permit
may be found in the Division files as well as on the Division website at
http://www.cdphe.state.co.us/ap/Titlev.html.
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.
In addition to the changes requested by DCP Midstream in the renewal application,the Division has
included changes to make the permit consistent with recently issued permits, including comments
made by EPA on other Operating Permits,as well as to correct errors or omissions identified during
inspections and/or discrepancies identified during review of this renewal.
Tech Review Summary—Kersey/Mewboum Gas Processing Plant Title V Renewal Page 3
' MACT Applicability
HHH—Natural Gas Transmission and Storage
This facility is a natural gas transmission and storage facility as described in 40 CFR Part
63 Subpart HHH, "National Emission Standards for Hazardous Air Pollutants From
Natural Gas Transmission and Storage". However, this facility is a true minor source of
Hazardous Air Pollutants (HAPs). Therefore, this facility is not subject to this MACT.
HH—Oil and Natural Gas Production Facilities
Although this facility is a true minor of HAPs, there are two dehydrators present.
However, one of the dehydrators is an ethylene glycol dehydrator (Plant A—point 064)
and not subject to the MACT HH. The other dehydrator, a triethylene glycol dehydrator
at Plant B (AIRS Point 065) runs through a vapor recovery unit, which is inherent to the
process, and only has safety relief devices for venting. The MACT HH defines this
system as a"closed-vent system," or a system that is not open to the atmosphere and is
composed of piping, ductwork, connections, and if necessary, flow inducing devices that
transport gas or vapor from an emission point to one or more control devices. Since the
standards for the MACT HH are for the process vents (i.e. the dehydration unit reboiler
vent and the vent from the GCG separator (flash tank), if present), this particular unit is
not subject to the MACT HH requirements. The facility has been designed as an inherent
closed-loop system from start-up.
ZZZZ—Stationary Reciprocating Internal Combustion Engines
The final rule for RICE was published in the Federal Register on June 15, 2004. Under
the rule, for production field facilities, only emissions from glycol dehydrators, storage
vessels with the potential for flash emissions, reciprocating internal combustion engines
and combustion turbines need to be aggregated to determine if the facility is a major
source for HAPS. An analysis was conducted to determine HAP emissions from the
equipment at this facility. Total HAP emissions based on permitted production were
calculated to be 6.98 TPY, with no single HAP exceeding 5 TPY. This facility is a true
minor source of HAPs. Therefore, the RICE MACT does not apply to the
Kersey/Mewbourn gas processing plant.
Compliance Assurance Monitoring(CAM)
The following emission points at this facility use a control device to achieve compliance with an
emission limitation or standard to which they are subject and have pre-control emissions that exceed
or are equivalent to the major source threshold(100 tons per year). They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado
Regulation No. 3, Part C, Section XIV:
C126, C133, C149, C130, C125, C131, C181 —Waukesha Model L-7042GSI ICE
C167—Waukesha Model L-7044GSI ICE
The primary purpose of the CAM program is to supplement or enhance the Operating Permit
Tech Review Summary—Kersey/Mewboum Gas Processing Plant Title V Renewal Page 5
II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of
the PSD review requirements.
Emission Sources
The following sources are specifically regulated under terms and conditions of the Operating Permit
for this plant:
Internal Combustion Engines
C133, C149, C125, C131 —Waukesha 1,232 HP Engines
C126, C130 —Waukesha 1,100 HP Engines
C167— Waukesha 1,680 HP Engine
C181 —Waukesha 1,478 HP Engine
C127, C129, C128 —Waukesha 711 HP Engines
C134—Waukesha 750 HP Engine
C211 —Caterpillar 300 HP Engine
C132—Waukesha 450 HP Engine
C243 —Cummins 380 HP Engine
C210— Cummins 84 HP Engine
Natural Gas Fired 12 MMBtu/Hr Hot Oil Heater(P016)
Fugitive Emissions of Volatile Organic Compounds from Equipment Leaks (Plants A & B)
(F017)
Condensate Tank Truck Loadout Rack (P019)
Stabilized Condensate Tanks (P024)
Accidental Release Program (112(r))
Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical
accidents. Sources subject to these provisions must develop and implement risk management
programs that include hazard assessment, a prevention program, and an emergency response
program. They must prepare and implement a Risk Management Plan (RMP) as specified in the
Rule.
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). The Risk
Management Plan required by the Act was submitted to the appropriate authority and/or a designated
central location by June 20, 1999 and revised accordingly.
Emission Factors
From time to time published emission factors are changed based on new or improved data. A logical
concern is what happens if the use of the new emission factor in a calculation results in a source
being out of compliance with a permit limit. For this operating permit, the emission factors or
emission factor equations included in the permit are considered to be fixed until changed by the
permit. Obviously,factors dependent on the fuel sulfur content or heat content cannot be fixed and
will vary with the test results. The formula for determining the emission factors is, however,fixed.
It is the responsibility of the permittee to be aware of changes in the factors, and to notify the
Tech Review Summary—Kersey/Mewbourn Gas Processing Plant Title V Renewal Page 7
factor. The fuel consumption of each engine at the facility is determined by
allocating fuel use to each of the engines based on monthly hours of operation and
total engine fuel use.
The Division's current (6/1/2006) portable monitoring language has been included
in the permit. This requires the source to measure NO„ and CO emissions
quarterly.
The Btu content of the natural gas fuel shall be measured semi-annually (twice per
year) using appropriate methods. DCP is also required to monitor the air fuel ratio
controller monthly.
• Internal Combustion Engine—Construction Permit 97WE0304/Permit Exempt
07WE1091
DCP applied for the removal of engine 210, the 100 HP Minneapolis Moline, to be
replaced with the APEN required permit exempt Cummins G5.9 84 HP engine, on
November 16, 2007. Although this engine was permit exempt at the time of submittal,
this engine is no longer permit exempt due to the location in the nonattainment ozone
area. This new engine will have the same label—C210 —as the previous engine. The
AIRS Point is new—the ID is 123/0090/077.
1. Applicable Requirements—
• Monthly recordkeeping and calculation of NOx, CO, and VOC
• Plant fuel meter tracking of natural gas consumption
• Hours of Operation annually
• Semi-annual Btu heat content analysis
• 20% opacity
• Good operation&maintenance
• Serial Number Certification
2. Emission Factors—Emissions are determined using manufacturer's
specifications for the engine and the catalyst. AP-42 factors were used to
determine uncontrolled HAP emissions. The catalyst manufacturer guaranteed
50% destruction of all Hazardous Air Pollutants. The emission factors are
detailed in the table below:
Pollutant Reported Emission Fuel Based Factor
Factor
NO„ 2.0 grams/hp-hr 0.54 lbs/MMBtu
CO 2.0 grams/hp-hr 0.54 lbs/MMBtu
VOC 1.0 grams/hp-hr 0.28 lbs/MMBtu
3. Monitoring Plan—The source must monitor the air fuel ratio (AFR) millivolt
reading and the catalytic converter(NSCR) inlet and outlet temperature and
pressure measured once per month and recorded.
• Internal Combustion Engine—Construction Permit 05WE0631
DCP requested the addition of this engine, a Cummins KTA19GC 380 HP engine
equipped with NSCR and an AFR, to the Operating Permit. This Construction Permit
was issued on January 31, 2006 and a modification issued on December 3, 2007. This
Tech Review Summary—Kersey/Mewboum Gas Processing Plant Title V Renewal Page 9
Permit 97WE0304. Emissions will be emitted from component leaks. A revised APEN
was received August 24, 2005 to request a more appropriate VOC limit.
1. Applicable Requirements—
• 9.20 TPY VOC emissions.
• Compliance with NSPS KKK
• The source must submit a NSPS KKK report detailing the specific
applicable and non-applicable requirements of NSPS KKK within 6
months of permit issuance. This report will be reviewed and used by
the inspector to determine compliance.
2. Emission Factors- Emissions are determined using appropriate emission
factors from the EPA document: Protocol for Equipment Leak Emission
Estimates, EPA-453/R-95-017).
3. Monitoring Plan—The source must conduct a component count within 90
days of permit issuance. Records of component changes shall be maintained
and a physical hard count shall be conducted at least every five years.
• Condensate truck loadout—Construction permit 97WE0553
DCP requested that the condensate truck loadout be increased based on actual throughput,
with a revised APEN received March 27, 2007, which has been incorporated into the
Operating Permit.
1. Applicable Requirements—Compliance limit of 20.45 tons of volatile organic
compounds per year and 7.1 million gallons of condensate to be loaded per year.
The loadout emissions report only the NonMethane,NonEthane VOC
(NMEVOC) as reported in the most recent analysis of the product. The Division
requires a copy of the analysis to be kept on-site.
2. Emission Factors—The truck loadout emissions are calculated using the
appropriate equation and emission factors from AP-42.
3. Monitoring Plan—The emissions of each pollutant and the gallons of condensate
loaded on trucks shall be calculated by the end of the subsequent calendar month.
A twelve (12) month rolling total of emissions shall be maintained to verify
compliance with the long-term emission limitation. By the end of the new
calendar month, a total shall be calculated for the previous 12 calendar months,
and compliance determined and recorded. All calculations and compliance
determinations shall be made available for Division review upon request.
• Stabilized Condensate Tanks—Incorporated into Operating Permit Only
Pursuant to Regulation No. 3, Part A, Section II.D.1.eeee, DCP applied for the addition of
these four (4) vertical fixed condensate tanks first on December 27, 2002 and then with
updated technical information, on October 20, 2004. On July 12, 2006, DCP requested
an increase in the emissions from the tanks based on EPA TANKS 4.0. These four tanks
have been incorporated into the Operating Permit.
1. Applicable Requirements—Compliance limit of 7.1 tons of volatile organic
compounds per year. These tanks would be subject to Regulation No. 7, except that
Tech Review Summary—Kersey/Mewboum Gas Processing Plant Title V Renewal Page 11
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).
• Added language specifying that the semi-annual reports and compliance certifications
are due in the Division's office and that postmarks cannot be used for purposes of
determining the timely receipt of such reports/certifications.
Section I—General Activities and Summary
• The description of the source was updated to reflect the current status of the facility.
• The attainment status of Weld County was updated to reflect the current ozone
nonattainment status of this area.
• Condition 1.3 was updated to reflect all of the correct incorporated Construction
Permits.
• Conditions 13 and 17 in Condition 1.4 were renumbered to 14 and 18 and Condition
21 in Condition 1.5 was renumbered to 22. The renumbering changes were necessary
due to the addition of the Common Provisions requirements in the General Conditions
of the permit.
• In Condition 1.4, General Condition 3.g (new general condition for general
provisions) was added as a State-only requirement.
• The language for the alternative operating scenario for temporary engine replacement
was updated to reflect current language (2/27/2008 version). The AOS table was also
updated to reflect the engines at the facility that are applicable.
• Added a"new" Section 5 for CAM.
• The previous Section 5, outlining the applicability and description of Subpart KKK
requirements, was deleted due to repetition.
• Summary table 6.1 has been updated.
Section II- Specific Permit Terms
• This section was completely revised. Section II.1 was split up into different engine
categories—engines subject to CAM (now Section II.1), engines subject to Regulation
7 (now Section II.2), and permit required engines (now Section II.3). The natural gas
fired heater, fugitives, condensate loadout, the addition of the condensate tanks,
MACT HH requirements, CAM conditions, updated portable monitoring, general
operation, and calculations were all revised, added, and/or reorganized.
Tech Review Summary—Kersey/Mewboum Gas Processing Plant Title V Renewal Page 13
• Condition 2.5 -Required source to record operating hours.
• Condition 2.6—Inserted good operation and maintenance requirement.
• Condition 2.7—Required source to monitor air/fuel ratio controller.
• Inserted NSCR monitoring requirement (Section I1.13).
• Condition 2.8—Added the Control of Emissions from Stationary and Portable engines
in the 8-hour Ozone Control (Nonattainment) Area.
Section II.3 -Internal Combustion Engines—Under 500 Horsepower
• This section was added for organizational purposes to differentiate between engine
categories.
o Engines in the section are: C211, C132, C210, and C243.
• Condition 3.1 - Added emission limits & calculation.
• Condition 3.2—Put in fuel use limitations
• Added portable monitoring requirement (Section II.10).
• Condition 3.3 —Added verification of natural gas Btu content.
• Condition 3.4—Included opacity requirement.
• Condition 3.5 —Inserted good operation and maintenance requirement.
• Condition 3.6 - Required source to record operating hours.
• Condition 3.7—Required source to monitor air/fuel ratio controller.
• Inserted NSCR monitoring requirement (Section I1.13).
• Condition 3.8—Added compliance testing for engine C243 only.
• Condition 3.9—Put in serial number submission for engine C243 only.
• Condition 3.10-Inserted engine statewide control requirement for engine C243 only.
Section 11.4-P016—Natural Gas Fired 12 MMBtu/hr Hot Oil Heater
• This section (previously Section I1.3) was not changed except to correct the emission
factors in the summary table and update language.
Section 11.5 -F017—Fugitive VOC Emissions from Equipment Leaks (Plant A & B)
• This section (previously Section II.4) was moved for organizational purposes.
Tech Review Summary—Kersey/Mewbourn Gas Processing Plant Title V Renewal Page 15
• Updated plot plan submittal date.
• Updated list of insignificant activities, detailing specific units as well as the generic
list. Removed all condensate tanks as those are covered in Condition 7.
Appendices B & C
• Updated to 2/2/2007 version.
• Updated report tables to current facility units.
Appendix D
• Updated EPA address.
Appendix G—"new appendix
• Added Compliance Assurance Monitoring Plan.
: C°.
O •
k; - A ' 4), ,
T / E / -: b
F-i. ,, ,
Arita►IkrTl��
''� 1 g 7 6 �`
Colorado Department
of Public Health
and Environment
OPERATING PERMIT
DCP Midstream, LP -
Kersey/Mewbourn Gas Processing Plant
Issued June 1, 1999
Last Revised: April 15, 2003
Renewal Proposed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME: Kersey/Mewbourn OPERATING PERMIT NUMBER
Gas Processing Plant
FACILITY ID: 1230090 95OPWE062
ISSUE DATE:
EXPIRATION DATE:
MODIFICATIONS: See Appendix F of Permit
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act,
25-7-101 et se . (1989 & 1995 Supp.) and applicable rules and regulations.
ISSUED TO: PLANT SITE LOCATION:
DCP Midstream, LP SE '/4 Sec 35, T4N, R66W
370 17th Street, Suite 2500 Junction of WCR 35 & WCR 38
Denver, CO 80202 Weld County
INFORMATION RELIED UPON
Operating Permit Application Received: May 30, 2003
And Additional Information Received: February 24 and October 20, 2004; August 24, 2005;
May 9 and July 12, 2006; June 8 and November 15, 16, 2007; February 15, 2008
Nature of Business: Natural Gas Liquids Processing and Gathering
Primary SIC: 1321
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name: Paul Brewer Name: Rusty Frishmuth
Title: Vice President—North Asset Title: Manager of Air Quality
Operations Programs
Phone: (918) 523-1122 Phone: (303) 605-1725
SUBMITTAL DEADLINES
Semi -Annual Monitoring Period: January 1 —June 30, July 1 —December 31
Semi -Annual Monitoring Report: August 1, 2008 and February 1, 2008 and subsequent years
Annual Compliance Period: January 1 —December 31
Annual Compliance Certification: February 1, 2008 and subsequent years
NOTE: The Semi-Annual Monitoring reports and the Annual Compliance report must be received at the
Division office by 5:00 PM 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 7
1. Permitted Activities 7
2. Alternative Operating Scenarios (ver 2/27/2008) 8
2.1 Engine Replacement 8
2.2 Portable Analyzer Testing 9
3. Prevention of Significant Deterioration/New Source Review(PSD/NSR) 12
4. Accidental Release Program (112(r)) 12
5. Compliance Assurance Monitoring (CAM) 13
6. Summary of Emission Units 13
SECTION II - Specific Permit Terms 17
1. Internal Combustion Engines— Subject to CAM 17
2. Internal Combustion Engines— Subject to Regulation 7 22
3. Internal Combustion Engines—Under 500 Horsepower 25
4. P016—Natural Gas Fired 12 MMBtu/Hr Hot Oil Heater 29
5. F017 - Fugitive VOC Emissions from Equipment Leaks (Plants A & B) 31
6. P019 - Condensate Tank Truck Loadout Rack 34
7. P024-Stabilized Condensate Tanks 35
8. Compliance Assurance Monitoring 36
9. Portable Monitoring (version 6/1/2006) 42
10. General Operation 44
11. Calculations 44
12. Catalytic Converter Monitoring 46
SECTION III - Permit Shield 47
1. Specific Conditions 47
2. General Conditions 48
3. Streamlined Conditions 49
General Permit Conditions (Ver.02/20/07) 50
1. Administrative Changes 50
2. Certification Requirements 50
3. Common Provisions 50
4. Compliance Requirements 54
5. Emergency Provisions 55
6. Emission Standards for Asbestos 56
7. Emissions Trading,Marketable Permits,Economic Incentives 56
8. Fee Payment 56
9. Fugitive Particulate Emissions 56
10. Inspection and Entry 56
11. Minor Permit Modifications 56
12. New Source Review 57
13. No Property Rights Conveyed 57
14. Odor 57
15. Off-Permit Changes to the Source 57
16. Opacity 57
17. Open Burning 57
18. Ozone Depleting Compounds 57
19. Permit Expiration and Renewal 58
20. Portable Sources 58
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 950PWE062 Page 7
SECTION I - General Activities and Summary
1. Permitted Activities
1.1 The Kersey/Mewbourn Gas Processing plant is classified as a natural gas
processing plant as set forth under Standard Industrial Classification 1321. Natural gas is
delivered to the plant by pipeline. After condensate is removed from the gas by the inlet
scrubbers, the inlet gas is subsequently compressed to processing pressures. The inlet gas is then
chilled by the propane refrigerant to remove a natural gas liquid (NGL) product from the stream.
The closed loop refrigeration process also acts to stabilize the NGL product. The gas plant
consists of two (2) gas processing skids, identified as Plant A and Plant B, to separate ethane,
propane, and heavier NGL products from the incoming natural gas stream. All NGL products
are transported off-site by pipeline.
The site consists of sixteen (16) engines powering natural gas compressors, two (2) natural gas
processing skids, one triethylene glycol (TEG) dehydration system, one ethylene glycol (EG)
natural gas dehydration, a 12 MMBtu/hr hot oil heater, a condensate truck load-out rack, and
four (4) 400 barrel (16,921 gallon) stabilized condensate storage tanks.
The TEG skid is designed to dehydrate the inlet gas feeding to Plant B. The Plant B TEG
dehydration system operates with a closed loop Vapor Recovery Unit (VRU) that is inherent to
the process. The vapors collected in the VRU are recompressed and routed to the inlet gas
stream, making this unit a closed-vent system.
The EG dehydration system is used to dehydrate the inlet gas feeding to Plant A. The EG unit is
under APEN thresholds and considered to be an insignificant activity for the purposes of this
permit.
Condensate is first collected in a 60,000 gallon pressurized bullet tank. The pressure in the tank
is maintained at about 38 PSIG by a vapor recovery unit. Condensate is manually transferred
from the bullet tank to each of the 400-barrel stabilized condensate storage tanks. The
condensate in the 400-barrel tanks is transported off-site by tanker truck.
The Kersey/Mewbourn Gas Processing Plant is located southeast of Gilcrest, Colorado at the
intersection of Weld County Roads (WCR) 35 and 38. The area in which the plant operates is
classified as attainment for all pollutants except ozone. It is classified as non-attainment for
ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.16.
Wyoming is an affected state within 50 miles of the plant. Rocky Mountain National Park is a
Federal Class I designated area within 100 kilometers of the plant.
Operating Permit Number: 950PWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant Permit# 95OPWE062 Page 9 _
engine is in operation. If the engine operates only part of a day, that day counts towards the 90
day total. Note that 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.
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. 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 to contemporaneously record the start and stop date of
any engine replacement, the manufacturer, 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.
2.1.1. The permittee may temporarily replace an existing compressor engine that is subject to
the emission limits set forth in this permit with an engine that is of the same
manufacturer, model, and horsepower or a different manufacturer, model, or horsepower
as the existing engine without modifying this permit, so long as the emissions from the
temporary replacement engine comply with the emission limitations for the existing
permitted engine as determined in section 2.2. 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 NOX and CO from the temporary replacement
engine must be less than or equal to the potential annual emissions of NO„ and CO from
the original grandfathered or permit exempt engine or for the engine that is not subject to
emission limits, as determined by applying appropriate emission factors (e.g. AP-42 or
manufacturer's emission factors)
2.2 Portable Analyzer Testing
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)
operating days of commencing operation of the replacement engine. The seven days is the total
number of days that the engine is in operation. If the engine operates only part of a day, that day
counts towards the seven day total.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 11
C211 Caterpillar Model G379 4-Cycle Rich Burn Portable No N/A No
Internal Combustion Engine, Rated at 330 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C132 Waukesha Model F3521 4-Cycle Rich Bum Portable No N/A No
Internal Combustion Engine, Rated at 450 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR.
C126 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A Yes
Internal Combustion Engine,Rated at 1,100 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C133 Waukesha Model L7042GSI 4-Cycle Rich Bum Portable No N/A Yes
Internal Combustion Engine,Rated at 1,232 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C127 Waukesha Model L7042GSI 4-Cycle Rich Bum Portable No N/A No
Internal Combustion Engine, Rated at 711 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C129 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A No
Internal Combustion Engine, Rated at 711 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C128 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A No
Internal Combustion Engine, Rated at 711 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR ,
C149 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A Yes
Internal Combustion Engine,Rated at 1,232 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C130 Waukesha Model L7042GS1 4-Cycle Rich Burn Portable No N/A Yes
Internal Combustion Engine, Rated at 1,100 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C134 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A No
Internal Combustion Engine, Rated at 750 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C125 Waukesha Model L7042GSI 4-Cycle Rich Burn Portable No N/A Yes
Internal Combustion Engine,Rated at 1,232 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C131 Waukesha Model L7042GSI 4-Cycle Rich Bum Portable No N/A Yes
Internal Combustion Engine,Rated at 1,232 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
and AFR
C167 Waukesha Model L7044GSI 4-Cycle Rich Burn Portable No N/A Yes
Internal Combustion Engine,Rated at 1,680 HP Monitoring
(Site),Natural Gas Fired Equipped with NSCR Quarterly
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant ,
Permit# 95OPWE062 Page 13
authority and/or a designated central location. Such certification shall be signed by the
Responsible Official.
5. Compliance Assurance Monitoring (CAM)
5.1 The following emission points at this facility use a control device to achieve compliance
with an emission limitation or standard to which they are subject and have pre-control emissions
that exceed or are equivalent to the major source threshold. They are therefore subject to the
provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV:
C126, C133, C149, C130, C125, C131, C181 —Waukesha Model L-7042GSI ICE
C167 —Waukesha Model L-7044GSI ICE
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 C211 Caterpillar Model G379 SI-NA 330 HP* Non-Selective
Natural Gas Fired Internal Catalytic
Combustion Reciprocating Reduction
Engine,4-cycle,Standard Rich 97WE0304
Burn w/air/fuel ratio
controller; Serial No 72B641,
powering a natural gas
compressor
052 C132 Waukesha Model F-3521 GU 450 HP* Non-Selective
Natural Gas Fired Internal Catalytic
Combustion Reciprocating Reduction
Engine 4-cycle,Standard Rich
Burn w/air/fuel ratio
controller; Serial No 289683,
powering a natural gas
compressor
053 C126 Waukesha Model L-7042 GSI 1100 HP* Non-Selective
Natural Gas Fired Internal Catalytic
Combustion Reciprocating Reduction
Engine,4-cycle,Standard Rich
Burn wl air/fuel ratio
controller; Serial No 353224,
powering a natural gas
compressor
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
, Permit# 95OPWE062 Page 15
AIRS Plant Description Size Pollution Construction
Stack Identifier Control Device Permit
Number
060 C134 Waukesha Model L-7042 GU 750 HP* Non-Selective
Natural Gas Fired Internal Catalytic
Combustion Reciprocating Reduction
Engine,4-cycle, Standard Rich
Burn w/air/fuel ratio
controller; Serial No.285300
powering a natural gas
compressor
062 C125 Waukesha L-7042 GSI Natural 1232 HP* Non-Selective
Gas Fired Internal Combustion Catalytic
Reciprocating Engine,4-cycle, Reduction
Standard Rich Burn;equipped
w/air/fuel ratio controller,
Serial No 232481;powering a
natural gas compressor
063 C131 Waukesha L-7042 GSI Natural 1232 HP* Non-Selective
Gas Fired Internal Combustion Catalytic
Reciprocating Engine,4-cycle, Reduction
Standard Rich Burn;equipped
w/air/fuel ratio controller;
Serial No 394541;powering a
natural gas compressor
066 P016 Natural gas fired heater for 10 None
heating hot oil MMBtu/I-Ir
067 F017 Plant A&B Gas Plant Fugitive N/A None
Emissions
069 P019 Condensate Truck Load-out N/A None
070 P024 4 vertical fixed roof condensate 400 bbl each None
tanks
071 C167 Waukesha L-7044 GSI Natural 1680 HP* Non-Selective 01WE0495
Gas Fired Internal Combustion Catalytic
Reciprocating Engine,4-cycle, Reduction
Standard Rich Burn;equipped
w/air/fuel ratio controller,
Serial No C13853/1;powering
a natural gas compressor
075 C181 Waukesha L-7042 GSI Natural 1478 HP* Non-Selective 05WE0630
Gas Fired Internal Combustion Catalytic
Reciprocating Engine,4-cycle, Reduction
Standard Rich Burn,equipped
w/air/fuel ratio controller;
Serial No. TBD,powering a
natural gas compressor
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 17
SECTION II - Specific Permit Terms
1. Internal Combustion Engines—Subject to CAM
C133, C149, C125, C131 Waukesha 1,232 HP Engines
C126, C130 Waukesha 1,100 HP Engines
C167 Waukesha 1,680 HP Engine
C181 Waukesha 1,478 HP Engine
NOTE: The following terms and conditions apply to each engine individually
Parameter Permit Compliance Limits Compliance Monitoring
Condition (for each individual Emission Factor Method Interval
Number engine)
C133-Waukesha 1232 HP Compressor Engine
C149-Waukesha 1232 HP Compressor Engine
C125-Waukesha 1232 HP Compressor Engine
C131-Waukesha 1232 HP Compressor Engine
NOx 1 1 19.03 tons/year 0.467 lb/MMBtu Record keeping and Monthly
Calculation
CO 19 03 tons/year 0 467 lb/MMBtu
12 month rolling total
VOC 11.90 tons/year 0.292 lb/MMBtu
Natural Gas 1 2 96 98 MMscf/year Plant Fuel Meter
Consumption 12 month rolling total
C126-Waukesha 1100 HP Compressor Engine
C130-Waukesha 1100 HP Compressor Engine
NOx 1 1 16.99 tons/year 0 466 lb/MMBtu Record keeping and Monthly
Calculation
CO 16 99 tons/year 0 466 lb/MMBtu
12 month rolling total
VOC 10.62 tons/year 0.292 lb/MMBtu
Natural Gas 1.2 86 77 MMscf/year Plant Fuel Meter
Consumption 12 month rolling total
C167—Waukesha 1680 HP Compressor Engine
NOx 1.1 24 33 tons/year 0 432 lb/MMBtu Recordkeeping and Monthly
CO 24.33 tons/year 0 432 lb/MMBtu Calculation
VOC 12.17 tons/year 0.217 lb/MMBtu 12 month rolling total
Natural Gas 1.2 134 02 MMscf/year Plant Fuel Meter 12
Consumption month rolling total
C181—Waukesha 1478 HP Compressor Engine
NOx 1 1 21 41 tons/year 0 422 lb/MMBtu Recordkeeping and Monthly
CO 21 41 tons/year 0 422 lb/MMBtu Calculation
VOC 14 27 tons/year 0.281 lb/MMBtu 12 month rolling total
Natural Gas 1 2 120.59 MMscf/year Plant Fuel Meter 12
Consumption month rolling total
Portable Monitoring 11 Flue Gas Analyzer Quarterly
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 19
Tons/mo=CEF(lbs/MMBtu)x Monthly Fuel Use(MMscf/mo)x Heat Content of Fuel(MMBTU/MMscf)
2000 lbs/ton
A twelve-month rolling total of emissions will be maintained in order to monitor
compliance with the annual emission limitation. 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 Section II,
Condition 11 show that either the NOx or CO emission rates/factors are greater than
those 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.
1.2 Fuel consumption for each engine shall not exceed the limitation established by
Attachment A to Construction Permit 97WE0304, Condition 4 of Construction Permit
01WE0495, and Condition 4 of Construction Permit 05WE0630 as modified by the provisions of
Section I, Condition 1.3. The plant fuel meter reading shall be recorded on the first day of each
new month. The fuel use for a calendar month shall be determined by the end of the subsequent
calendar month. Allocation of fuel use to each engine shall be made as set forth in Condition 13.
A twelve (12) month rolling total shall be maintained to determine compliance with annual fuel
use limitation. By the end of each new calendar month a total shall be calculated for the
previous twelve (12) calendar months, and compliance determined. Records of the calculations
and compliance determinations shall be maintained. The calculation and compliance
determination records shall be made available to the Division for review upon request.
1.3 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 higher heating value (HHV) of
the fuel. Calculations of monthly emissions shall be made using the heat content derived from
the most recent required analysis. The Btu value used by the Division in determining emission
limits was 840 Btu per standard cubic foot of natural gas. The Btu value was provided by the
APENs submitted on February 24, 2004 and thereafter.
1.4 Opacity of emissions from the engine shall not exceed 20% (Condition 2 of Construction
Permit 97WE0304, Condition 1 of Construction Permit 01WE0495, and Condition 1 of
Construction Permit 05WE0630). In the absence of evidence to the contrary, compliance with
the 20% opacity limit shall be presumed whenever natural gas is used as fuel for the engine.
1.5 These engines shall be operated and maintained in accordance with manufacturer's
recommendations at all times, including periods of start-up, shutdown, and malfunction.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 21
completion of the tests. The test protocol must be in accordance with the requirements of
the Air Pollution Control Division Compliance Test Manual and shall be submitted to the
Division for review and approval at least thirty (30) calendar days prior to testing.
Engine operating parameters will be included in the analysis with emissions reported in
parts per million dry volume and grams per actual horsepower-hour (g/BHP-Hr.) or
pounds per million BTU (lb/MMBtu). No test shall be conducted without prior approval
from the Division. Any stack test conducted to show compliance with a monthly or
annual emission limitation shall have the results projected up to the monthly or annual
averaging time by multiplying the test results by the allowable number of operating hours
for that averaging time. (Condition 5 of Construction Permit 01 WE0495 and Condition 9
of Construction Permit 05WE0630, modified under the provisions of Section I, Condition
1.3)
1.11 The source shall submit the serial number of engine C181 to the Division within one
hundred and eighty days (180) after commencement of operation (Construction Permit
01WE0495, Condition 10 and Construction Permit 05WE0630, Condition 8)
1.12 Engine C181 is subject to the statewide requirements for control of emissions from new
and relocated natural gas fired reciprocating internal combustion engines under
Regulation No. 7, Section XVII.E. Specifically, the following standards apply to engines
greater than 500 horsepower (State only enforceable) (Construction Permit 05WE0630,
as modified under the provisions of Section I, Condition 1.3):
Construction or Emission Standard(g/hp-hr)
Relocation Date NO„ CO VOC
July 1,2007 2.0 4.0 1.0
July 1,2010 1.0 2.0 0 7
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 23
2.1 Nitrogen Oxide (NOx), Carbon Monoxide (CO), and Volatile Organic Compound (VOC)
emissions from these individual engines shall not exceed the limitations stated in Summary
Table 1 above (Colorado Construction Permit 97WE0304, as modified under the provisions of
Section I, Condition 1.3). Except as provided for below, the emission factors listed above have
been approved by the Division and shall be used to calculate emissions from these engines, as
follows:
Monthly emissions of each pollutant shall be calculated by the end of the subsequent
month using the above Compliance Emission Factors (CEF), the monthly natural gas
consumption and the heating value, 840 MMBTU/MMscf, of the fuel in the equation
below:
Tons/mo=CEF(lbs/MMBtu)x Monthly Fuel Use(MMscf/mo)x Heat Content of Fuel(MMBTU/MMscf)
2000 lbs/ton
A twelve-month rolling total of emissions will be maintained in order to monitor
compliance with the annual emission limitation. 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 Section II,
Condition 11 show that either the NOx or CO emission rates/factors are greater than
those 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.
2.2 Fuel consumption for each engine shall not exceed the limitation established by
Attachment A to Construction Permit 97WE0304 as modified by the provisions of Section I,
Condition 1.3. The plant fuel meter reading shall be recorded on the first day of each new
month. The fuel use for a calendar month shall be determined by the end of the subsequent
calendar month. Allocation of fuel use to each engine shall be made as set forth in Condition 13.
A twelve (12) month rolling total shall be maintained to determine compliance with annual fuel
use limitation. By the end of each new calendar month a total shall be calculated for the
previous twelve (12) calendar months, and compliance determined. Records of the calculations
and compliance determinations shall be maintained. The calculation and compliance
determination records shall be made available to the Division for review upon request.
2.3 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 higher heating value (HHV) of
the fuel. Calculations of monthly emissions shall be made using the heat content derived from
the most recent required analysis. The Btu value used by the Division in determining emission
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant ,
Permit# 95OPWE062 Page 25
3. Internal Combustion Engines—Under 500 Horsepower
C211 —Caterpillar 330 HP Engine
C132—Waukesha 450 HP Engine
C243 —Cummins 380 HP Engine
NOTE: The following terms and conditions apply to each engine individually
Parameter Permit Compliance Limits Compliance Monitoring
Condition (for each individual Emission Factor
Number engine) Method Interval
C211-Caterpillar 330 HP Compressor Engine
NOx 3 1 5 10 tons/year 0 448 lb/MMBtu Record keeping and Monthly
Calculation
CO 5.10 tons/year 0.448 lb/MMBtu
12 month rolling
VOC 3.19 tons/year 0 280 lb/MMBtu
total
Natural Gas 3 2 27 11 MMscf/year Plant Fuel Meter
Consumption 12 month rolling
total
C132-Waukesha 450 HP Compressor Engine
NOx 3 1 6 95 tons/year 0 490 lb/MMBtu Record keeping and Monthly
Calculation
CO 6 95 tons/year 0.490 lb/MMBtu
12 month rolling total
VOC 4 35 tons/year 0 306 lb/MMBtu
Natural Gas 3 2 33 74 MMscf/year Plant Fuel Meter
Consumption 12 month rolling total
C243—Cummins KTA 19GC 380 HP Compressor Engine
NOx 3 1 5 87 tons/year 0 436 lb/MMBtu Record keeping and Monthly
Calculation
CO 5 87 tons/year 0.436 lb/MMBtu
VOC 0 97 tons/year 0 272 lb/MMBtu 12 month rolling
total
Natural Gas 3 2 32.10 MMscf/year Plant Fuel Meter
Consumption 12 month rolling total
C210 Cummins G5.9 84 HP Compressor Engine
NOx 3.1 1 67 tons/year 0 538 lb/MMBtu Record keeping and Monthly
Calculation
CO 1.67 tons/year 0 538 lb/MMBtu
12 month rolling total
VOC 0 64 tons/year 0.269 lb/MMBtu
Natural Gas 3 2 5.70 MMscf/year Plant Fuel Meter
Consumption 12 month rolling total
Portable Monitoring 11 Flue Gas Analyzer Quarterly
Btu Heat Content 3 3 ASTM or other Semi-
Division-Approved Annually
Method
Opacity 3 4 Not to Exceed 20% Fuel Restriction Only Natural
Gas is Used
as Fuel
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 27
reflect, at a minimum, the higher emission rates/factors within 60 days of the completion
of the test.
3.2 Fuel consumption for each engine shall not exceed the limitation established by
Attachment A to Construction Permit 97WE0304 and Condition 3 of Permit 05WE0631 and
Permit 07WE1091 as modified by the provisions of Section I, Condition 1.3. The plant fuel
meter reading shall be recorded on the first day of each new month. The fuel use for a calendar
month shall be determined by the end of the subsequent calendar month. Allocation of fuel use
to each engine shall be made as set forth in Condition 13. A twelve (12) month rolling total
shall be maintained to determine compliance with annual fuel use limitation. By the end of each
new calendar month a total shall be calculated for the previous twelve (12) calendar months, and
compliance determined. Records of the calculations and compliance determinations shall be
maintained. The calculation and compliance determination records shall be made available to
the Division for review upon request.
3.3 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 higher heating value (HHV) of
the fuel. Calculations of monthly emissions shall be made using the heat content derived from
the most recent required analysis. The Btu value used by the Division in determining emission
limits was 840 Btu per standard cubic foot of natural gas. The Btu value was provided by the
APENs submitted on February 24, 2004 and thereafter.
3.4 Opacity of emissions from each engine shall not exceed 20% (Condition 2 of
Construction Permit 97WE0304 and Condition 1 of Construction Permit 05WE0631 and Permit
07WE1091, as modified by the provisions of Section I, Condition 1.3). In the absence of
evidence to the contrary, compliance with the 20% opacity limit shall be presumed whenever
natural gas is used as fuel for the engine.
3.5 These engines shall be operated and maintained in accordance with manufacturer's
recommendations at all times, including periods of start-up, shutdown, and malfunction.
3.6 The number of operating hours for each individual engine shall be recorded for each
calendar month. The records shall be made available for Division review upon request.
3.7 The Air Fuel Ratio (AFR) millivolt reading on 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.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 29
4. P016—Natural Gas Fired 12 MMBtu/Hr Hot Oil Heater
Parameter Permit Limitations Compliance Monitoring
Condition Factors Method Interval
Number
Fuel Usage 4.1 125 15 MM cubic feet Vendor receipts and flow Monthly
per year meter readings
12 month rolling total
PM 4 4 7.6 lb/MMscf Record keeping and Monthly
Mio
7 6 lb/MMscf calculation
P
Opacity 4 3 Not to exceed 20% Fuel Restriction- Annual
Natural Gas Certification
NOx 4 2 6 26 tons per year 100 lb/MMscf Record keeping and Monthly
calculation
12 month rolling total
SO2 4 4 0.6 lb/MMscf Record keeping and Annually
calculation
VOC 4 4 5.5 lb/MMscf
CO 5 26 tons per year 84 lb/MMscf
40 CFR Part 60 4 5 Record keeping As necessary
Subpart Dc 4 6
4.1 The terms and conditions of this permit are based on the heater burning natural gas. The
use of any other fuel may require the permit to be re-opened prior to any use of the fuel. The
fuel use limits were set by Attachment A to Construction Permit 97WE0304, modified under the
provisions of Section I, Condition 1.3.
4.2 The emission limits were set by Attachment A to Construction Permit 97WE0304,
modified under the provisions of Section I, Condition 1.3. Compliance with the emission limits
and fuel use shall be determined on a calendar month basis. By the end of each new calendar
month the emissions and fuel use for the previous twelve (12) calendar months shall be
calculated and compliance determined. A record of the calculations and the compliance
determination shall be kept on-site and made available for Division review upon request.
4.3 Opacity of emissions from the heater shall not exceed 20% (Construction Permit
97WE0304, Condition 2). In the absence of evidence to the contrary, compliance with the 20%
opacity limit shall be presumed whenever natural gas is used as fuel.
4.4 The estimated actual annual emissions of the pollutant for the previous calendar year
shall be calculated by April 30 of each new calendar year. The calculations shall be kept on file
and available for Division review upon request. A revised APEN shall be submitted whenever
there is a significant change in the actual annual emissions of this pollutant. (Regulation 3, Part
A, §II.C.2). For sources emitting less than 100 tons per year, a significant change is defined as a
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 31
5. F017 - Fugitive VOC Emissions from Equipment Leaks (Plants A & B)
Parameter Permit Compliance Compliance Monitoring
Condition Limits Emission Factor Method Interval
Number Report Interval
VOC 5.1 9.2 tons per year By Component- Initial Component Count, Within 90 days, Annual
EPA Protocol for Recordkeeping,and Ongoing Tally,
Equipment Leak Emission Calculations Annually
Estimates
Leak 5.2 Per Subpart KKK Maintenance Plan
Detection 5 3
and Repair
5.1 VOC emissions shall not exceed the limitations stated. Emissions shall be calculated
using the emission factors and equations listed below. An actual physical count of the existing
components shall be performed within ninety (90) calendar days of the issuance of this operating
permit. The count of the various components shall be recorded and used to establish the start of
a hardware inventory. Records shall be kept of all component additions and deletions and a
running tally maintained. An actual physical hard count of the existing components shall be
performed at least once every five (5) calendar years. The records shall be kept at the site and
made available for Division review upon request.
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.
The below factors are for gas service only.
Valves 0.00992 Connectors 0.00044
Relief Valves 0.01940 Open-ended Lines... 0.00441
Compressor Seals 0 .01940 Pump Seals 0.00529
Flanges 0.00086
Calculation of annual emissions of VOC per component:
(Component count) X (8760 hrs/year) X (Weight %VOC in organic portion of gas stream) X
(Emission factor for component being evaluated) X (Control Factor)
The total fugitive VOC emissions shall be the sum of emissions for each component.
The most recent inlet gas analysis as required under Condition 9 shall be used for emission
calculation purposes. An annual inlet gas analysis shall be used for emission calculation
purposes. The maximum Weight-%VOC used in the above equation will be 35.00% as
submitted accordingly and approved by the Division on November 15, 2007.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 33
5.3.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required
under 40 CFR Part 60 §60.7.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 35
7. P024—Stabilized Condensate Tanks
Permit Monitoring
Condition Compliance Compliance Emission
Parameter Number Limits Factor Method Interval
VOC 7 1 7 08 tons/yr 1.995 lbs per 1000 Recordkeeping and Monthly
gallons calculation
12 month rolling total
Condensate 7.10 million
Throughput gallons per year
Opacity 7 2 Not to exceed 20% Annually Annual
7.1 VOC emissions shall not exceed the limitations stated in the table above. The VOC
emissions shall be calculated by the end of each subsequent month. 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 monthly tank emissions using the following equation:
Tons per month= gallons per month x 1.995 lbs/ 1000 gallons 12000 lbs per ton
All calculations and compliance determinations shall be made available for Division
review upon request.
7.2 Visible emissions shall not exceed twenty percent (20%) opacity during normal operation
of the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty
consecutive minutes. Since this a VOC source, due to lack of evidence to the contrary,
compliance with the opacity limits shall be presumed.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 37
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).
8.1.2.4 After approval of the monitoring required under the CAM requirements, if
the owner or operator identifies a failure to achieve compliance with an
emission limitation or standard for which the approved monitoring did not
provide an indication of an excursion or exceedance while providing valid
data, or the results of compliance or performance testing document a need
to modify the existing indicator ranges or designated conditions, the owner
or operator shall promptly notify the Division and, if necessary submit a
proposed modification for this permit to address the necessary monitoring
changes. Such a modification may include, but is not limited to,
reestablishing indicator ranges or designated conditions, modifying the
frequency of conducting monitoring and collecting data, or the monitoring
of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
8.1.3 Quality Improvement Plan (QIP) Requirements
8.1.3.1 Based on the results of a determination made under the provisions of
Condition 10.1.2.3.b, the Division may require the owner or operator to
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 39
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).
8.1.3.6 Implementation of a QIP shall not excuse the owner or operator of a
source from compliance with any existing emission limitation or standard,
or any existing monitoring, testing, reporting or recordkeeping
requirement that may apply under federal, state, or local law, or any other
applicable requirements under the federal clean air act (40 CFR Part 64 §
64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
8.2 Reporting and Recordkeeping Requirements
8.2.1 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 10.1.3 of this permit. Upon completion of a QIP, the owner
or operator shall include in the next summary report documentation that
the implementation of the plan has been completed and reduced the
likelihood of similar levels of excursions or exceedances occurring (40
CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant ,
Permit# 95OPWE062 Page 41
applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in
Colorado Regulation No. 3, Part C, Section XIV).
8.2.2.3 Nothing in these CAM requirements shall restrict or abrogate the authority
of the U.S. EPA or the Division to take any enforcement action under the
federal clean air act for any violation of an applicable requirement or of
any person to take action under section 304 of the federal clean air act (40
CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV)
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 43
Results of all tests conducted shall be kept on site and made available to the
Division upon request.
9.1.1 The outlet oxygen content of the exhaust stream shall be measured during
portable monitoring when measurement of the outlet CO content is being
conducted.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 45 '
C210 84 2 0 2.0 1.0 8000 0.55
B) FUEL ALLOCATION TO INDIVIDUAL FUEL BURNING EQUIPMENT
lbs _ grams hp-hr pounds X 106
Emission Factor( )— X X
MMBtu hp-hr Btu 453.6 grams MM
Individual Fuel Consumption=
(Design Heat Rate X Hours of Operation X Site Rated Horsepower )for engine X Total Monthly Fuel Use
N
E (Design Heat Rate X Hours of Operation X Site Rated Horsepower )for all engines
i=1
C) EMISSIONS CALCULATION
Tons Fuel Use Ton
Emissions( )_( )X(Fuel Heat Content)X(Emission Factor)X (2000 lbs)
Month month
CALCULATIONS OF EMISSIONS FROM FLUE GAS PORTABLE MONITOR
MEASUREMENTS
The methods outlined will be used to calculate the nitrogen oxide and carbon monoxide
criteria pollutant emissions from internal combustion engines from the values measured by
the portable flue gas monitors.
Stack flow data will be based on EPA Method 19 UFO factors for natural gas combustion. The
portable monitor values are presented as ppmv dry. From Method 19, Table 19-1 Fd for natural
gas equals 8710 dry standard cubic feet per million Btu(8710 scf/MMBtu)
Tons MMscf X Btu X pounds X Ton
Emissions( )_
Month month scf MMBtu 2000 pounds
scf scf 20.95%
MMBtu
Exhaust Flow Rate, =8710 X Fuel consumption,
X
hour MMBtu hour 20.95%-O2%
O2 = Oxygen measured in stack at time of testing.
Fuel consumption will be from the measured total fuel use data collected for the plant and
apportioned to each compressor engine as described in the previous section. The standard cubic
feet per hour (scf/hour) will be converted to million Btu per hour (MMBtu/hour) utilizing the
following equation:
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 47
SECTION III - Permit Shield
Colorado Regulation No. 3, 5 CCR 1001-5, Part A, §I.B.44; Part C, §§V.C.I.b. & V.D., XIII.B;
.§25-7-111(2)(I), 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
Description&Number
C211 Caterpillar G379 Reg 1.III.A.1.b—Particulate Internal combustion engines are not considered fuel burning
SI-NA 330 HP emissions from fuel-burning equipment for the applicable requirements of Regulation 1
C132 Waukesha F-3521 equipment Reg 1.III.A l.b-
GU 450 HP Particulate emissions from
fuel-burning equipment
C I26 Waukesha L-7042
GSI 1100 HP
C133 Waukesha L-7042 Reg 1 VI B 5.a-Sulfur
GSI 1232 HP dioxide emissions from fuel-
burning equipment
C127 Waukesha L-7042
GU711HP
C129 Waukesha L-7042
GU 711 HP
C128 Waukesha L-7042
GU711HP
C149 Waukesha L-7042
GSI 1232 HP
C130 Waukesha L-7042
GSI 1100 HP
C134 Waukesha L-7042
GU 750 HP
C125 Waukesha L-7042 Reg 1.III.A Lb-Particulate Internal combustion engines are not considered fuel burning
GSI 1232 HP emissions from fuel-burning equipment for the applicable requirements of Regulation 1
C131 Waukesha L-7042 equipment Reg 1 III A.1.b-
GSI 1232 HP Particulate emissions from
fuel-burning equipment
C 167 Waukesha L-7044
GSI 1680 HP
Reg 1 VI.B 5.a-Sulfur
C181 Waukesha L-7042 dioxide emissions from fuel-
1478 HP
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant ,
Permit# 95OPWE062 Page 49
2.4 The ability of the Air Pollution Control Division to obtain information from a source
pursuant to § 25-7-111(2)(I), 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. Streamlined 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. No applicable
requirements were streamlined out of this permit.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 51
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
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
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant -
Permit# 95OPWE062 Page 53
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
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,
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 55
notification of planned changes or anticipated noncompliance does not stay any permit condition,except as
provided in§§X and XI of Regulation No.3,Part C
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.
5. Emergency Provisions
Regulation No 3,5 CCR 1001-5,Part C,'VII
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
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant .
Permit# 95OPWE062 Page 57
Regulation No.3,5 CCR 1001-5,Part C,"X &Xl.
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 11 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 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,I1.
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 Section I, II.C, II.D., III, IV, and V of Regulation No 15 shall be enforced as a matter of state law
only
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant
Permit# 95OPWE062 Page 59
"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,
(iii) the company or entity that performed the analysis;
(iv) the analytical techniques or methods used,
(v) the results of such analysis;and
(vi) the operating conditions at the time of sampling or measurement
b. The permittee shall retain records of all required monitoring data and support information for a period of at
least five(5)years from the date of the monitoring sample,measurement,report or application. Support
information, for this purpose, Includes all calibration and maintenance records and all original strip-chart
recordings for continuous monitoring instrumentation,and copies of all reports required by the Operating
Permit With prior approval of the Air Pollution Control Division,the permittee may maintain any of the
above records in a computerized form
c Permittees must retain records of all required monitoring data and support information for the most recent
twelve(12)month period,as well as compliance certifications for the past five(5)years on-site at all times
A permittee shall make available for the Air Pollution Control Division's review all other records of required
monitoring data and support information required to be retained by the permittee upon 48 hours advance
notice by the Division.
d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at
least every six(6)months,unless an applicable requirement,the compliance assurance monitoring rule,or the
Division requires submission on a more frequent basis. All instances of deviations from any permit
requirements must be clearly identified in such reports
e The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or
altering any facility,process,activity which constitutes a stationary source from which air pollutants are or
are to be emitted,unless such source is exempt from the APEN filing requirements of Regulation No.3,Part
A,'II.D A revised APEN shall be filed annually whenever a significant change in emissions,as defined in
Regulation No 3,Part A,'II C.2.,occurs,whenever there is a change in owner or operator of any facility,
process,or activity;whenever new control equipment is installed;whenever a different type of control
equipment replaces an existing type of control equipment,whenever a permit limitation must be modified,or
before the APEN expires An APEN is valid for a period of 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
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division DCP Midstream, LP
Colorado Operating Permit Kersey/Mewbourn Gas Processing Plant .
Permit# 95OPWE062 Page 61
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
a For sources located in an ozone non-attainment area or the Denver Metro Attainment Maintenance Area,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
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
b. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology(RACT)is utilized
c 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.
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.
END OF PERMIT REQUIREMENTS
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix A
Inspection Information Page 63
APPENDIX A - Inspection Information
Directions to Plant:
The facility is located in the southeast quarter of Section 35, T4N, R66W. The plant is
bounded by Weld County Road (WCR) 35 on the east and WCR 38 on the south.
Safety Equipment Required:
Hard Hat Safety Shoes Ear Protection Eye Protection
Facility Plot Plan:
Figure 1 shows the plot plan as submitted on November 28, 2007 with the source's Title
V Operating Permit Application.
List of Insignificant Activities:
The following generic list of insignificant activities was provided in the Title V
application:
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 H25 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.
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.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix A.
Inspection Information Page 65
Kerosene tank
Solvent tank
Heat medium oil tank
Refrigeration propane 5,000-gallon tank
Vehicle propane tank
One smokeless emergency flare
At Kersey/Mewbourn-CIG site:
D014 - Plant A Natural Gas Hydration Inhibition System w/ flash tank using ethylene
glycol; 25 MMscf/day
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 67
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.
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:
(1) 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
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division B
Colorado Operating Permit Appendix
Monitoring and Permit Deviation Report Page B
9
1.5.5 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.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 71
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 on a semi-annual basis unless otherwise noted in the permit.
The Table below must be completed for all equipment or processes for which specific
Operating Permit terms exist.
2. Part II of this Appendix B shows the format and information the Division will require for
describing periods of monitoring and permit deviations, or upset 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 Upsets) may be referenced and
the form need not be filled out in its entirety.
FACILITY NAME: DCP Midstream, LP - Kersey/Mewbourn Gas Plant
OPERATING PERMIT NO: 95OPWE062
REPORTING PERIOD: (see first page of the permit for specific reporting
period and dates)
Deviations noted Deviation Code 2 Malfunction/Emergency
Operating During Period?' Condition Reported
Permit Unit
ed
During Period
ID Unit Description YES NO YES NO
C21 I Caterpillar Model G379 SI-NA
Compressor Engine;330 HP
C132 Waukesha Model F-3521 GU
Compressor Engine;450 HP
C126 Waukesha Model L-7042 GSI
Compressor Engine; 1 100 HP
C133 Waukesha Model L-7042 GSI
Compressor Engine; 1232 HP
C127 Waukesha Model L-7042 GU
Compressor Engine;711 HP
C129 Waukesha Model L-7042 GU
Compressor Engine; 711 HIP
C128 Waukesha Model L-7042 GU
Compressor Engine, 711 HP
C149 Waukesha Model L-7042 GSI
Compressor Engine, 1232 HP
C130 Waukesha Model L-7042 GSI
Compressor Engine, 1100 HP
C134 Waukesha Model L-7042 GU
Compressor Engine, 750 HP
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 73
Monitoring and Permit Deviation Report - Part II
FACILITY NAME: DCP Midstream, LP -Kersey/Mewbourn Gas Plant
OPERATING PERMIT NO: 95OPWE062
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: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix B
Monitoring and Permit Deviation Report Page 75
Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: DCP Midstream, LP - Kersery/Mewbourn Gas Plant
FACILITY IDENTIFICATION NUMBER: 123/0090
PERMIT NUMBER: 95OPWE062
REPORTING PERIOD: (see first page of the permit for specific reporting period and
dates)
All information for the Title V Semi-Annual Deviation Reports must be certified by a
responsible official. The responsible official signing this certification must be pre-approved by
the Division in accordance with Colorado Regulation No. 3, Part A, Section I.B.54. This signed
certification document must be packaged with the documents being submitted.
STATEMENT OF COMPLETENESS
I have reviewed the information being submitted in its entirety and, based on information
and belief formed after reasonable inquiry, I certify that the statements and information
contained in this submittal are true, accurate and complete.
Please note that the Colorado Statutes state that any person who knowingly, as defined in
Sub-Section 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: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 77
Operating Unit Description Deviations Monitoring Was compliance
Permit Unit Reported I Method per continuous or
ID Permit"2 intermittent?3
Previous Current YES NO Continuous I Intermittent
C133 Waukesha Model
L-7042 GSI
Compressor
Engine, 1232 HP
C127 Waukesha Model
L-7042 GU
Compressor
Engine,711 HP
C129 Waukesha Model
L-7042 GU
Compressor
Engine,711 HP
C128 Waukesha Model
L-7042 GU
Compressor
Engine; 711 HP
C149 Waukesha Model
L-7042 GSI
Compressor
Engine, 1232 HP
C130 Waukesha Model
L-7042 GSI
Compressor
Engine, 1100 HP
C134 Waukesha Model
L-7042 GU
Compressor
Engine;750 HP
C210 Waukesha Model
L-7042 GU
Compressor
Engine;750 HP
C125 Waukesha Model
L-7042 GSI
Compressor
Engine, 1232 HP
C131 Waukesha Model
L-7042 GSI
Compressor
Engine; 1232 HP
P016 10 MMBtu/Hr
Natural gas fired
heater for heating
hot oil
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix C
Compliance Certification Report Page 79
in continuous compliance for the duration of the reporting period. Therefore, if a source 1) 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.
4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information.
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Colorado Operating Permit Appendix D ,
Notification Addresses Page 81
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
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Permit Modifications, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Mail Stop 8P-AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Air Pollution Control Division
Cglorado Operating Permit Appendix E
Permit Acronyms Page 83
RACT - Reasonably Available Control Technology
SCC - Source Classification Code
SIC - Standard Industrial Code
SO2 - Sulfur Dioxide
TPY - Tons Per Year
TSP - Total Suspended Particulate
VOC - Volatile Organic Compounds
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
r
Air Pollution Control Division
Colorado Operating Permit Appendix 6
Compliance Assurance Monitoring Page 85
APPENDIX G - Compliance Assurance Monitoring Plan
I. Background
a. Emission Unit Description:
Four Waukesha Model L-7042 GSI Internal Combustion Engines, 1,232 HP each
Two Waukesha Model L-7042 GSI Internal Combustion Engines, 1,100 HP each
One Waukesha Model L-7044 GSI Internal Combustion Engines, 1,680 HP
One Waukesha Model L-7042 GSI Internal Combustion Engine, 1,478 HP
b. Applicable Regulation, Emission Limit, Monitoring Requirements:
Regulations: Operating Permit Section II, Condition 1.1
Emission Limitations: 1.1 - NO„ 19.00 tons/yr(1,232 HP engines)
CO 19.00 tons/yr (1,232 HP engines)
1.1 - NO„ 17.00 tons/yr(1,100 HP engines)
CO 17.00 tons/yr(1,100 HP engines)
1.1 - NO„ 24.30 tons/yr (1,680 HP engine)
CO 24.30 tons/yr(1,680 HP engine)
1.1 NO), 21.40 tons/yr(1,478 HP engine)
CO 21.40 tons/yr(1,478 HP engine)
c. Control Technology:
Non-Selective Catalytic Reduction
Operating Permit Number: 95OPWE062 ISSUED: June 1, 1999
LAST REVISED: April 15, 2003
DRAFT RENEWAL
Hello