Loading...
HomeMy WebLinkAbout20083778.tiff STATE OF COLORADO Bill Ritter,Jr.,Governor James B.Martin, Executive Director .0•cozo Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr.S. Laboratory Services Division * * Denver,Colorado 80246-1530 8100 Lowry Blvd. Phone(303)692-2000 Denver,Colorado 80230-6928 Isis 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 June 9, 2008 Mr. Steve Moreno Weld County Clerk 1402 N. 17th Ave. Greeley, CO 80631 Dear Mr. Moreno: The Air Pollution Control Division will publish a public notice for DCP Midstream. This public notice will be published in The Greeley Tribune on June 16, 2008. Thank you for assisting the Division by making the enclosed package (includes public notice, preliminary analysis, Air Pollutant Emission Notice(s) and draft permit(s)) available for public review and comment. It must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please forward any comment regarding this public notice to the address below. Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Attention: Jacquie Barela R ards, Jacq elfin N. Barela Public Notice Coordinator Stationary Sources Program Air Pollution Control Division NOTICE OF REQUEST FOR CONSTRUCTION PERMIT BY DCP Midstream, LP PERMIT NO. 07WE0988 TABLE OF CONTENTS 1. PUBLIC NOTICE 2. PRELIMINARY ANALYSIS 3. AIR POLLUTANT EMISSIONS NOTICE(S) 4. DRAFT PERMIT Prepared by: Geoffrey Drissel Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver CO 80246-1530 STATE OF COLORADO Bill Ritter,Jr.,Governor James B.Martin,Executive Director 0v•cozo Dedicated to protecting and improving the health and environment of the people of Colorado y� o 4300 Cherry Creek Dr.S. Laboratory Services Division Denver,Colorado 80246-1530 8100 Lowry Blvd. * Phone(303)692-2000 Denver,Colorado 80230-6928 1a7s 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 Released to: The Greeley Tribune on June 9,2008; published June 16,2008 PUBLIC NOTICE OF A PROPOSED PROJECT OR ACTIVITY WARRANTING PUBLIC COMMENT The Colorado Air Pollution Control Division has declared that the following proposed construction activity warrants public comment. Therefore, the Air Pollution Control Division of the Colorado Department of Public Health and Environment hereby gives NOTICE, pursuant to Section 25-7-114.5(5), C.R.S. of the Colorado Air Quality Control Act that an application to the Division has been received for an emission permit on the following proposed project and activity: DCP Midstream, LP has submitted an application to construct and operate one (1) additional natural gas fired reciprocating internal combustion engine at their Roggen Natural Gas Processing Plant. The engine will be used for residue gas compression. The engine is equipped with non-selective catalytic reduction and is permitted to operate at full load for 8,760 hours per year. With the controls on this engine, emissions from this engine will be below the significance level. This facility is located at 35409 Weld County Road 18 near Roggen, Colorado, which is located in Weld County. The existing facility is a major stationary source for purposes of non-attainment area new source review (NANSR) requirements. With the emission limits on the proposed new engine, this project is considered a synthetic minor modification to an existing major stationary source for purposes of NANSR(with respect to NOR, which is a precursor for ozone). The Division has determined that the engine will comply with all applicable standards and regulations. The Division therefore proposes to issue the applicant an initial approval permit for the one(1)proposed new engine. The Division hereby solicits and requests submission of public comment concerning the aforesaid proposed project and activity for a period of thirty(30)days from and after the date of this publication. Comments are solicited on the ability of the proposed project to comply with applicable standards and regulations. Any such comment must be in writing and be submitted to the following addressee: Geoffrey Drissel Colorado Department of Public Health and Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Within thirty (30)days following the said thirty(30)-day period for public comment,the Division shall consider comments and, pursuant to Section 25-7-114.5(7)(a), either grant,deny,or grant with conditions,the emission permit. Said public comment is solicited to enable consideration of approval of and objections to the proposed construction of the subject project and activity by affected persons. A copy of the application for the emission permits,the Preliminary Analysis of said application, and accompanying data concerning the proposed project and activity are available for inspection at the office of the Clerk and Recorder of Weld County, 1402 N. 17th Avenue, Greeley, CO during regular business hours and at the office of the Air Pollution Control Division, Colorado Department of Public Health and Environment,4300 Cherry Creek Drive South,Glendale, Colorado. Information is also available on the Division's website at: http://www.cdphe.state.co.us/ap/airpublicnotices.htm AIR POLLUTION CONTROL DIVISION PRELIMINARY ANALYSIS Applicant DCP Midstream, LP Permit No(s). 07WE0988 Facility Location Roggen Natural Gas Processing Plant Source No. 123/0049 35409 Weld County Road 18, Weld County Review Engineer Geoffrey D. Drissel, P.E. Date June 9, 2008 Control Engineer Roland Hea, P.E. Project DCP Midstream has proposed the following addition to the Roggen Gas Plant: Description • Installation of one new Waukesha L7042 GSI, Serial Number to be determined, natural gas-fired, four-cycle standard rich-burn, turbocharged, internal combustion reciprocating engine, site rated at 1,478 HP (AIRS ID 134). This unit will be equipped with air/fuel ratio controls and NSCR for control of emissions of VOC, CO, NOx and Formaldehyde. Potential emissions exceed the thresholds for a Major Modification under the nonattainment New Source Review (NANSR) rules. With the issuance of the proposed federally enforceable permits to limit the potential to emit to below the Major Modification thresholds, the addition of this unit will not be classified as a Major Modification under NANSR. Emission Engine: Combustion products, including Hazardous Air Pollutants (HAPs). Sources Requested Pollutant Controlled Potential Emissions from Emissions (tpy) Emissions (tpy) the New Oxides of Nitrogen 28.54 185.5 Equipment Volatile Organic Compounds 14.34 28.5 Carbon Monoxide 28.54 128.4 Formaldehyde 0.52 1 04 Total HAPs 0.73 1.42 Regulatory Status Major Source for Operating Permit Applicability: emissions of NOx, VOC and CO at the Roggen Gas Plant exceed the thresholds for operating permits. Ambient Impact Emissions are not expected to have an adverse impact on ambient air and formal Analysis modeling is not required. Public Comment Sources with projected controlled annual emissions exceeding 25 tons per year in Requirement a non-attainment area are subject to public comment. ° io N °p coy <) w w w ft > � CD c © CD •-o �, '3 5' Cr ° 0 C o O 0' ^. .. ° 5 [i7 0 w 0 O 7J �' o °' O w w w CD O o a o x o 0 a ti Cn 0 o CD w o •< Ctl o o C0 '-'i in' 'a O = w ,� O x w c� O ^C 0 < ry O O CD W 2 O ,�, Co co ti. d �," O O (' _o a' CD 0 = o • 5 N = C X CD CD CD .n-. A `G 7 0 CD UOQ W > n > Z CD Or Cp .G o CCDD H cn ro c, cn o 1 CCDD 0' o � W Cl) I a 0 a W 0 ZZ I d g O''' -0 -0 N CD O Cr Coo Coo C o ^•h c co `•" CD Co co p �' o 0 0 0 o coo CD 0 f.D - w 0 o 0 ry0 x m b m y o new ' o ^: w m �° • p i o a y ►'. 0 ^' C'' O �O �' CCU N 'u' P. MO y `c O Q. ° 'y"i m " O rte.. 0 00 COD O m C N CT . w P O-• O' 'J C K G CA C C O 0 p �' cn•�' O rt m O 'Kd VW O ,4 0.., a. s' = O� O C 0 m Q. 0 C 'Li •°-h CD b •O 0 O CD ` �' JQ to M a . `-S A w t.) m - N :y' aG y r m z co 0 oCD 97 o co 00 co 0 C .p - N xJ 0 "d o o •• y oo E CJ o °0 . d c' 0 o b cn °° a a t�7 '3 n f' 0 r' o b o o o Cr < CD ., N CD O. CA 41 04 O C () ° .. 'C W A CD'4' G CD 0 O 7' 0 !Cy Cp J W , 0 cot CD 0 P C/� o �' � an o O 7• fro Y W 0- CI R COD CD v l+ N O C_ m "O I-4 O z �./ .7 O 00 coco ^' A (0 AD 1. 0 0 — d p a. x 0 CO `/�' R ' 6• N N a .l' \1 (�+ ° LU CU Cb XI CD 0 0 CD A O o COEt M CD �c' o o b O n 'CI �• N N a .s C CD y Ny < n C ti o •d nA z v m 0 o' 0 o C M CD ti O C n9 0 CA W W l'i p `G CD co J ►+ •• 'b ti' G N W W C ti N C N O\ Q` 00 A t! w.. RD 00 O CC Ti' `"' .J E' Ill LA N CDC W CD CD R. IV ❑ TJ 'Ll �T.' t0 O N O C. pa p "0b b .0� `C J "0 CD 0 CD O. 9.. CD O 'CD O CD°D C '® ® ® off 0 P p. c z b N r. .9.2 _ "' C y �. �� ❑ ❑ ❑ CD ❑ ❑ ❑ ❑ a .n a N C• p o rt i--' CO) x c 7y W n n CD y y h CD I O : Z o Z 0 0 O S. Y a 0 ► Y o o f° 5. CCD C O' rTi CDD CDD C. CD �' C m Coo yy yy cn ha 7 `" 0 Z w ? O Cy CD ° MI O m R -, a o f 1 0 �' O a y• iD �' 90 LD CO m o p coo 0 Cho 04 i raw) ■K p �• .. O9. " 0 °0 co C K >< o S° 0 n CD C" rrf o O G ' n ° n m • ti I. n O O G O CD K Aen 0 h PCP 1 2- C) 0• 0 vi C17 0 p 0 O CD CD '~' O Cn PV N. Co o n4 U' C7o #. 2- 2 C' Z w 0 'p' tii m .ti °' 0 m rt c 0 �{ o p`e co m m H co to 5 x• = f° o' _ i-.+ o 0 OQ GA O 00 r+"a N y' 0 CD O ,., CD C7 K g' no 0 N o_ o ° g. A - .m'`. o `a 01. rl - w Co CD 4 0 w° v, ere, o C W O _ �,g� c, as ° Z a1 A b O , CD Crop o itJ '�+ ►ti o m` ° w ? c CD m Oy T n O is ❑ ❑ R b .d 'o-� >y O. N O O C<D z. 2 W O 2. m O CCD R. CD N' C g. r0 •' — o C n a • Co .+. cD O t° fCD o "a. Q�C.'' 'o O 00" LTI U.0 CCDD O ^ 0- y• M n e] '� a y 0 Wa. 0 CIVI• CD 0 0 K• ', W C`EL W' 0 C 00 0 CDCDD O 5 f~D Cn Cr Co a a 0'"' w -O"', ( o'2 0 a O 0 00 ti C� m 0 9 O bo CD w r''' p+ M I" Co d Cii S O .�"r p '.O 'C O. tri a o ti ° a 0 0 0 � .4 O .q 0. v) e0D = tai o O 0 tiv Z m �' Cr ro z R. o cD C °,—' ^' �. vm 0 oe * a CSJ I..:,.) 'O a< .. O� C Cr, .fl vNi .S. O r. 'O `< CCCD 0 iz m C A c ° y ? m o m o o CLOD W W W . p• 0"Ci o p- N < •• b• 9 E. 0 0 0 O d CD C� C 0 0 CD �yi fD t' b N 0 ��� o 5 R o w o as °, CA CD o s' b f, f3. N N .. ^* G w co (J7 O n O y N W `C '70 vy�' . IN CA o 00" B y O G O• u) (!i •P O 'O m 0 0 CD co �O O a. in' N 13 c 0 en CD 0 CD o Cr C7 n x0 w o ° S �C O `o o d CD co ', ti o �) w o c o © O o 0 " • m CD 0 oo C °�o ;� o� tit o' Uq � p*+ Y O. -- %,-;" I c �' '"` ?'a I OCD 0 C) I �, rpi, Fd �� spy' = n'I C ^�: N ry 's in �. ►iy oa n 0 K co o -C F.I. o -' � C xis; m d �e -r •- x o y ti U' o a o n 0 ›- o Q' �' $ i N D w o �. CD `� w IR-aa' x x 1-a C p �, 0 D o c n7 0 '- + O c n r° c 2v p /� O CA no 0 o �_ o' �' w e AD it � � '' � � 4 ofp " p 01 M -, Ca. o i--i d o Fzi b cY E' ^ti ►+ rn .1. 0 0 CO N o o m b CD p a q7 ,.., -ps VNi •-1°1 F '=cn n `t a o O =1., w a p C ^ A �-+ o -s ® CD a Y CA CD p o • r. y tsJ .C Cy 10 w ti 0 a r O O ca 0.0 ¢' g. d . O C C w w ` �..y 5 ,O_.. pp O oo . C o • C O �.I p a w-. O co. .0 p C C F�7 p l O PO N o-+ - O O C O C K ^• ^ a. ,y b t cs x ,9 tre •A in c a - co �• co n CD to C. C. ,mot PD 0�' `� fD 0 .. tows r+ CD w II _0 a r p,rn h, C tt ' ^3 Ca c n o� o v C .CC+ O C .0 �E O () CDerg VO w o Otr1 F. O F.+. N N ° C 0 0 •Dco '�(fq N W z o. ao o << co •o 'L r n CD coN co H Q. m trCOD ma SU O o. > o s0 0 O �. o CD P.: O to F'h CY O N O K `J' O O Vz] n a O ri rZ CD 0 wco a coD —• CD w n g' a: 0 04 n t, o °� °5. O .� O CD 0. O. S ? rt n p' p rn J N m ,'� �_ • n o a C C o tr CA e* Z-1. V' t. 0 CD o c a n CD w '� v.:2 t,1 o o -s c~Do ^ C a. o a.. 'a r .- n o cm o o a o a. CD d CCA DD c as ti o H O _ it O v �' 9 p p r n o " CD "n O N O nIA Q' CD et p ,n7' o oo �. CD O o o �.`� d 0 a w' o m CD C n o y C. w C M v a a tb �• P:i0' �. Q c II cD n a m 'a-'. x0 `t • ? ee-F ro �, m g 5--' 5. (0 o. h CD < �. CD O �' ' h� co n b [ m • o S ❑ °q Cs pl A O 0n Fff Z: p C� O10 CA 0 o IN""' o e ° o _ & O C] O O. m 01 CT ONO R. G y o ^ o o00 o A o � o w m a Fir q - O CM y [D fD pqq' 7 0 ..`•° <, O9 '-'-• ^ O N t I� CD ,1 .yy G l=J A d n CJ �' M by 'C y E. ci B53 Cr "°° CA 7 CD c. y rt O (7 me C C ® 0 II �% ODo L7 G C C O 1 A CD ¢ \ `J O W .{ r C O N O �' O H < C �' tD d m 't w (D W m q O' m O p n C0. E. O "u.'a C p' (,] J IV d MI x o v, -• 0 0 0 0 CD g ❑ O • �• P CD N O O 0 N tY C` a z n v y p' N V� OA CA G (n 0 ^.. O s �. C Q 00 w 0)5 5 o m� FC co o n CD `Ci v p•r�C O N < l-' b rn DRAFT PERMIT PERMIT NO: 07WE0988 Initial Approval DATE ISSUED: ISSUED TO: DCP Midstream, LP THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Natural Gas Compression facility,known as the Roggen Natural Gas Processing Plant,located at 35409 Weld County Road 18, in Weld County,Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: One(1)Waukesha L7042 GSI,Serial No.:TBD,rated at 1,478 horsepower @ 1,200 rpm,turbo-charged four- cycle standard rich burn,natural gas fired,internal reciprocating combustion engine designated as stack ID C- 179. This engine is used for Residue Gas Compression.This engine is equipped with air-fuel ratio control and NSCR. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7042 GSI engine in accordance with the permanent replacement provision of the Alternate Operating Scenario(AOS), included in this permit as Attachment A. This engine will be incorporated into Operating permit number 95OPWE055. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S.(25-7-101 et seq),TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: 1. 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. EPA Method 9 shall be used to measure opacity. (Reference:Regulation No. 1,Section II.A.1.&4.) 2. The permit number shall be marked on the subject equipment for easeof identification.(Reference: Regulation Number 3,Part B,III.E.)(State only enforceable) 3 Emissions of air pollutants shall not exceed the following limitations(as calculated in the Division's preliminary analysis): (Reference: Regulation No. 3,Part B, II.A.4) Pollutant Annual Limit(tpy) Monthly Limit(lb/month) Nitrogen Oxides 28.54 4848 Volatile Organic Compounds 14.27 2424 Carbon Monoxide 28.54 4848 Formaldehyde 0.52 88.3 Each Individual Hazardous Air Less than 8.0 Less than 1,358.9 Pollutant from the Facility Total Hazardous Air Pollutants Less than 20.0 Less than 3,397.3 from the facility Monthly limits are based on a 31-day month. During the first twelve (12) months of operation, compliance with both the monthly and yearly emission limitations shall be required. After the first twelve(12)months of operation, compliance with only the yearly limitation shall be required. Compliance with the annual limits shall be determined on a rolling(12)month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly emissions and keep a compliance record on site, or at a local field office with site responsibility for Division review. Compliance with the synthetic minor status of this facility shall be determined by recording the facility's annual permitted criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)from each emission unit,on a rolling(12)month total. By the end of each month a AIRS ID: 123/0049/134 Page 1 of 11 DCP Midstream,LP Colorado Department of Publi DRAFT Lent ' • Permit No.07WE0988 Air ion Initial Approval PERMIT new twelve-month total is calculated based on the previous twelve months'data. The permit holder shall calculate monthly emissions and keep a compliance record on site,or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all emission units, requiring an APEN,at this facility. 4. This source shall be limited to a maximum consumption rate as liaed below and all other activities, operational rates and numbers of equipment as stated in the application.Monthly and annual records of the actual consumption rate shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Consumption of natural gas as fuel shall not exceed 8.2 MMscf per month(31 days)and 97.10 MMscf per year. . During the first twelve (12) months of operation, compliance with both the monthly and yearly consumption limitations shall be required. After the first twelve(12)months of operation,compliance with only the yearly limitation shall be required. Compliance with the yearly consumption limits shall be determined on a rolling twelve(12)month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate monthly consumption of natural gas and keep a compliance record on site or at a local field office with site responsibility, for Division review. 5. A source compliance test shall be conducted during self-certification to measure the emission rate(s) for the pollutants listed below,using EPA approved methods. Oxygen shall also be measured using approved methods during the source compliance test. The test protocol must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. 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(1b/MIMBtu). 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. (Reference: Regulation No. 3, Part B.III.G.3) Oxides of Nitrogen Carbon Monoxide Volatile Organic Compounds Formaldehyde 6. This engine shall be equipped with a(n)NSCR capable of reducing uncontrolled emissions as follows: Pollutant Control Efficiency Oxides of Nitrogen At least 84.6% Carbon Monoxide At least 77.8% Volatile Organic Compounds At least 50.0% Operating parameters of the control equipment are identified in the operation and maintenance plan as specified in Attachment B. The identified operating parameters will replace the control efficiency requirement on the final permit. (Reference: Regulation No. 3,Part B,IV.E.) 7. Within one hundred and eighty days(180)after commencementof operation,the applicant shall adopt and follow the operating and maintenance plan and record keeping format as specified in Attachment B, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. (Reference: Regulation No.3,Part B, Section III.G.7.) 8 Prevention of Significant Deterioration(PSD)requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable PSD threshold will require a full PSD review of the source as though construction had not yet commenced on the source. The source shall not exceed the PSD threshold until a PSD permit is granted. Regulation No. 3 Part D,VI.B.4) AIRS ID: 123/0049/134 Page 2 of 11 • •DCP Midstream,LP Colorado Department of Publi tent DRAFT Permit No.07WE0988 Air ion Initial Approval PERMIT _ 9 MACT Subpart ZZZZ-National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Reference: Regulation No. 8,Part E) 10 This source shall be subject to the requirements of Regulation Number 7, Section XVI (Control of emissions from stationary and portable engines in the 8-hour Ozone Control Area). The owner or operator of any natural gas-fired stationary or portable reciprocating internal combustion engine with a manufacturer's design rate greater than 500 horsepower commencing operations in the 8- hour Ozone Control Area on or after June 1,2004 shall employ air pollution control technology to control emissions, as provided in Condition 11.a & 11.b (Colorado Regulation No. 7, Section XVI.A.1). a. For rich burn reciprocating internal combustion engines, a nonselective catalyst reduction and an air fuel controller shall be required. A rich burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of less than 2% by volume. (Colorado Regulation No. 7, Section XVI.B.1). b. The emission control equipment required by this Condition 11.a shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. (Colorado Regulation No. 7, Section XVI.B.3). 11. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3,Part A, II.C) a. Annually whenever a significant increase in emissions occurs as fillows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five(5)tons per year or more, above the level reported on the last APEN;or For any non-criteria reportable pollutant: If the emissions increase by 50%or five(5)tons per year,whichever is less,above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility,process,or activity;or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer,model and serial number and horsepower of the permanent replacement engine,the appropriate APEN filing fee and a cover letter explaining that the permittee is exercising an alternative-operating scenario and is installing a permanent replacement engine. 12. Within one hundred and eighty days (180) after commencement of operation, compliance with the conditions contained on this permit shall be demonstrated to the Division. It is the permittee's responsibility to self-certify compliance with the conditions.Failure to demonstrate compliance within 180 days may result in revocation of the permit.(Reference: Regulation No. 3, Part B,II.G.2). 13. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either,the date of issuance of this initial approval permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date(See General Condition No.6., AIRS ID: 123/0049/134 Page 3 of 11 . DCP Midstream,LP Colorado Department of Publi ient ' Permit No.07WE0988 Air DRAFT ion Initial Approval PERMIT Item 1.). The Division may grant extensions of the deadline per Regulation No. 3,Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) By: By: Geoffrey Drissel, P.E. Roland Hea, P.E. Permit Engineer Unit Leader Permit History Issuance Date Description AIRS ID: 123/0049/134 Page 4 of 11 - DCP Midstream,LP Colorado Department of Publi tent Permit No.07WE0988 Air DRAFT ion Initial Approval PERMIT Notes to Permit Holder: 1) The production or raw material processing limits and emission limits contained in this permit are based on the production/processing rates requested in the permit application. These limits may be revised upon request of the permittee providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice(APEN)and application form must be submitted with a request for a permit revision. 2) This source is subject to the Common Provisions Regulation Part II,Subpart E,Upset Conditions and Breakdowns. The permittee shall notify the Division of any upset condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than two(2) hours after the start of the next working day, followed by written notice to the Division explaining the cause of the occurrence and that proper action has been or is being taken to correct the conditions causing said violation and to prevent such excess emission in the future. 3) The following emissions of non-criteria air pollutants(NCRPs)are estimated based upon the site-rated horsepower and requested fuel consumption information as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds. CAS Pollutant Uncontrolled Controlled % Control Reporting Reportable Emissions Emissions Threshold ? (Ib/yr) (Ib/yr) (lb/yr) 50-00-0 Formaldehyde 2071 1036 50.0% 50 Yes 75-07-0 Acetaldehyde 282 141 50.0% 50 Yes 107-02-8 Acrolein 266 133 50.0% 50 Yes 71-43-2 Benzene 160 80 50.0% 50 Yes 4) The emission levels contained in this permit are based on the following emission factors: Emission Factors- Emission Factors— Uncontrolled Controlled CAS Pollutant lb/MMBtu g/bhp-hr lb/MMBtu g/bhp-hr NOx 3.6739 13.0000 0.5652 2.0000 CO 2.5434 9.0000 0.5652 2.0000 VOC 0.5652 2.0000 0.2826 1.0000 50-00-0 Formaldehyde 0.0205 0.0727 0.0103 0.0364 75-07-0 Acetaldehyde 0.00279 0.0099 0.0014 0.0045 107-02-8 Acrolein 0.00263 0.0093 0.0013 0.0047 71-43-2 Benzene 0.00158 0.0056 0.0008 0.0028 Emission factors are based on a Brake-Specific Fuel Consumption Factor of 7801.08 btu/hp-hr and a site-rated horsepower value of 1478. 5) This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits(Title V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit must be incorporated into the operating permit. The application for the modification to the Operating Permit is due within one year of commencement of the equipment or modification covered by this permit. 6) In accordance with C.R.S.25-7-114.1,the Air Pollutant Emission Notice(APEN)associated with this permit is valid for a term of five years. The five-year term for this APEN expires on October 12,2012. A revised APEN shall be submitted no later than 30 days before the five-year term expires. 7) This emission unit is classified as a: Synthetic Minor Source at a Major Facility This facility is classified as follows: Applicable Requirement Status Major for NOR,VOCs,and CO Operating Permit AIRS ID: 123/0049/134 Page 5 of 11 DCP Midstream, LP Colorado Department of Pubh DRAFT tent Permit No.07WE0988 Air ion Initial Approval PERMIT _ PSD Synthetic Minor for NO„and CO MACT ZZZZ Minor for HAPs AIRS ID: 123/0049/134 Page 6 of 11 -DCP Midstream,LP Colorado Department of Publi tent DRAFT Permit No.07WE0988 Air ion Initial Approval PERMIT GENERAL TERMS AND CONDITIONS: (IMPORTANT! READ ITEMS 5,6,7 AND 8) 1. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant and is conditioned upon conduct of the activity,or construction, installation and operation of the source, in accordance with this information and with representations made by the applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 2. Unless specifically stated otherwise,the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 3. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of, a condition hereof shall constitute a rejection of the entire permit and upon such occurrence,this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to final approval by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit,conditions imposed upon a permit are contested by the applicant,or the Division revokes a permit,the applicant or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 4. This permit and any required attachments must be retained and made available for inspection upon request at the location set forth herein. With respect to a portable source that is moved to a new location, a copy of the Relocation Notice (required by law to be submitted to the APCD whenever a portable source is relocated) should be attached to this permit. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation No.3,Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 5. Issuance(initial approval)of an emission permit does not provide"final"authority for this activity or operation of this source. Final approval of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final approval cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. If the APCD so determines, it will provide written documentation of such final approval,which does constitute"final"authority to operate.Compliance with the permit conditions must be demonstrated within 180 days after commencement of operation. 6. THIS PERMIT AUTOMATICALLY EXPIRES IF you (1) do not commence construction or operation within 18 months after either the date of issuance of this permit or the date on which such construction or activity was scheduled to commence as set forth in the permit,whichever is later;(2)discontinue construction for a period of 18 months or more;or(3)do not complete construction within a reasonable time of the estimated completion date. Extensions of the expiration date may be granted by the APCD upon a showing of good cause by the permittee prior to the expiration date. 7. YOU MUST notify the APCD at least thirty days (fifteen days for portable sources) prior to commencement of the permitted operation or activity. Failure to do so is a violation of Section 25-7- 114.5(12)(a),C.R.S.and AQCC Regulation No.3,Part B,Section III.G.1.,and can result in the revocation of the permit. You must demonstrate compliance with the permit conditions within 180 days after commencement of operation as stated in condition 5 8. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN)must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued,the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification,annual fee billing will terminate. 9. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and control Act or the regulations of the AQCC may result in administrative,civi or criminal enforcement actions under Sections 25-7-115 (enforcement),-121 (injunctions),-122(civil penalties),-122.1 (criminal penalties), C.R.S AIRS ID: 123/0049/134 Page 7 of 11 DCP Midstream, LP Colorado Department of Publi tent' • DRAFT Permit No.07WE0988 Air ion Initial Approval PERMIT ATTACHMENT A 1. Alternative Operating Scenarios The following Alternative Operating Scenario(AOS)Ix temporary and permanent engine replacement has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A,Operational Flexibility Alternative Operating Scenarios,and Regulation No. 3,Part B,Construction Permits, and Regulation No. 3,Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration,and has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 1.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any l2 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day,that day 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 montoring 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). Results of all tests and the associated calculations pursuant 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 seral number of the replacement engine. 1.1.1. The permittee may temporarily replace an existing 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 manifacturer, 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 1.2. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2. 1.1.2. The permittee may permanently replace the existing compressor engine that is subject to the emission limits set forth in this permit with an enginethat is of the same manufacturer,model and horsepower without modifying this permit so long as the emissions from the permanent replacement engine comply with the emission limitations for the existing permitted engine as determined in section 1.2. Measurement of emissions from the permanent replacement engine shall be made as set forth in section 1.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer,model and serial number and horsepower of the permanent replacement enghe shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee and a cover letter explaining that the peanittee is exercising an alternative operating scenario and is installing a permanent replacement engine. This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. AIRS ID: 123/0049/134 Page 8 of 1 l • -DCP Midstream,LP Colorado Department of Pubh tent Permit No.07WE0988 Air DRAFT ion Initial Approval PERMIT _ The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. If Subpart ZZZZ is newly triggered by a permanent replacement engine,the permittee must apply for a revision to their operating permit within 90 days of installation. 1.2 Portable Analyzer Testing The permittee shall measure nitrogen oxides(NOr)and carbon monoxide(CO)emissions in the exhaust from the replacement engine using a portable flue gas analyzerwithin seven(7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol(ver March 2006 or newer)as found on the Division's website at: http://www.cdphe.state.co.us/ap/down/portanalyzeproto.pdf Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit,the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies)in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760),whichever applies. If the portable analyzer results indicate compliance with both the NQ<and CO emission limitations,in the absence of credible evidence to the contrary,the source may certify that the engine is in compliance with both the NQ(and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S.25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations,the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicatcs compliance with both the NOx and CO emission limitations or until the engine is taken offline. 1.3 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit,not"routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission poirt and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction permitting process prior to installation. AIRS ID: 123/0049/134 Page 9 of 11 STATE OF COLORADO Bill Ritter,Jr,Governor James B.Martin, Executive Director pF co:� Dedicated to protecting and improving the health and environment of the people of Colorado ye�� o 4300 Cherry Creek Dr S Laboratory Services Division Denver,Colorado 80246-1530 8100 Lowry Blvd _4,3:y6 Phone(303)692-2000 Denver,Colorado 80230-6928 TDD Line(303)691-7700 (303)692-3090 Colorado Department Located in Glendale,Colorado Public Health http://www.cdphe state.co.us and Environment ATTACHMENT B: General Operating and Maintenance Plan for Reciprocating Internal Combustion Engines February 26,2007 The Colorado Department of Public Health and Environment,Air Pollution Control Division(the Division)has developed the following General Operating and Maintenance Plan(O&M Plan) for natural gas-fired Reciprocating Internal Combustion Engines(RICE)that reduce emissions below major source thresholds,thus becoming a synthetic minor source in the State of Colorado. The General O&M Plan shall become the default O&M Plan for natural gas-fired RICE unless the source chooses to submit a specific O&M Plan to the Division for review and approval through the Final Approval permitting process. The source shall maintain records to demonstrate compliance with either the General O&M Plan or another O&M Plan approved by the Divsion. The source shall provide documentation and recordkeeping to demonstrate compliance with the O&M Plan upon request by the Division. All engines shall comply with the following operating parameters and maintenance schedules: 1. The source shall follow the manufacturer's scheduled maintenance guide for the engine and document the date that activities were completed. If a company has established its own maintenance schedule then this schedule may be followed presuming it is consistent with good air polluion control practices for minimizing emissions as defined in the New Source Performance Standard(NSPS)general conditions. Determination of whether or not acceptable operating and maintenance procedures are being used will be based on information available to the Division,which may include,but is not limited to,monitoring results, opacity observations,review of operating and maintenance procedures, and inspection of the source. (Reference:Regulation No. 6, Part A. General Provisions from 40 CFR 60.11) Parameters 2 and 3 apply only to rich burn engines equipped with an air-fuel ratio controller. 2. The source shall maintain records to verify that the air-fuel ratio controller(AFRC) is operated per the manufacturer's recommendations. The oxygen sensa.millivolt(mV)reading of the AFRC shall be recorded per the schedule in Table 1. Additionally,the mV reading shall be tracked and recorded during each portable analyzer test. 3. The source shall follow the manufacturer's oxygen sensor replacement schedde if an oxygen sensor is utilized. If the equipment maintenance and replacement is dependent on the hours of operation then the hours shall be tracked and recorded and made available to the Division upon request. If the source is using a method other than hours of operation to track oxygen sensor replacement then tracking must be recorded and available to the Division upon request. Records of oxygen sensor replacement shall be made available to the Division upon request. 4. The source shall clean,recondition and replace the catalyst per the manufacturer's or packager's recommended schedule. A copy of this maintenance schedule shall be made available to the Division upon request. If maintenance activities or actions are dependent upon hours of operatim then engine operating hours shall be recorded and made available to the Division upon request. Records of the catalyst cleaning, reconditioning or replacement shall be documented and made available to the Division upon request. 5. The source shall record the inlet temperature into the catalyst per the schedule specified in Table 1. AIRS ID: 123/0049/134 Page 10 of 11 , ^DCP Midstream,LP Colorado Department of Publi Lent Permit No.07WE0988 Air DRAFT ion Initial Approval PER1VIIT _ • For a rich burn engine with non-selective catalytic reduction(NSCR)emission control equipment the temperature into the catalyst shall be operated between 750°F and 1250°F. • For a lean burn engine with an oxidation catalystemission control equipment,the temperature shall be operated between 450°F and 1350°F. If the temperature is outside this range then the appropriate maintenance activities shall be performed. 6. The source shall monitor and record the pressure drop across the catalyst monthly. The pressure differential shall not deviate by more than 2 inches of water column from the baseline value established by the source when the engine is operating at 90%- 110%load. Baseline pressure differential shall be established by the source and recorded during each portable analyzer test. If the pressure differential exceeds baseline values by more 2 inches water column then the appropriate maintenance shall be performed. Note: If the pressure differential is not within the parameters established during a baseline performance test, then the source may forgo maintenance activities and perform a portable analyzer test of the engine to establish new pressure differential baseline. The most recent baseline pressure differential established during portable analyzer testing shall be used to determine compliance. 7. Compliance demonstration: a. Existing Permitted Engines: i. Pressure differential across the control equipment shall be established within the first 100 hours of engine operations from the date that the catalyst is cleaned,reconditioned,or replaced. b. Newly Permitted Engines or Engines Associated with a Permit Modification: i. Pressure differential across the control equipment shall be established within 180 days from the date of equipment startup for newly permitted engines or within 180 days from the date of permit issuance for engines associated with a modified permit. 8. The source shall perform portable analyzer testing for NOx,CO and O2 per the schedule in Table 1. Portable analyzer testing shall follow the Division's approved protocol and shall include emissions testing at the outlet of the catalyst. The protocol can be found at the Division's web page at the following link: http://www.cdphe.state.co.us/apiclown/portanalyzeproto.pdf Table 1 Records of Record of Facility Permitted Emission Inlet AFRC milli- Portable Analyzer Testing Limits Temperature volt reading Engines at facilities with NOx or Quarterly Testing CO emissions greater than or If monitoring demonstrates compliance during equal to 80 tons per year. Dail Weekly four consecutive quarters then the source shall Including portable engines y be allowed to test semi-annually. If any of the moved to these facilities semi-annual tests fail then the source shall return to quarterly tests. Engines at facilities with NOx or Semi-annually Testing CO emissions less than 80 tons If monitoring demonstrates compliance during per year. Including portable Weekl Weekl two consecutive semi-annual tests then the engines moved to these facilities y y source shall be allowed to test annually. If any of the annual tests fail then the source shall return to semi-annual testing. All synthetic minor engines that do not have emission control equipment shall conduct portable exhaust gas analysis testing at least once per calendar year. AIRS ID: 123/0049/134 Page 11 of 11 Hello