The URL can be used to link to this page

Browse Search

Home My WebLink About20202130.tiff xr COLORADO troDepartment of Public Health&Environment Weld County - Clerk to the Board 1150 O St RECEIVED PO Box 758 Greeley, CO 80632 JUN 1 5 2020 June 10, 2020 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On June 11, 2020, the Air Pollution Control Division will begin a 30-day public notice period for DCP Operating Company, LP - Spindle Natural Gas Processing Plant. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health >:t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator Enclosure 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.govicdphe I o, Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director „ * Publ;c. Rev:e. ,•) cc: PLO'P))FIL(DS),PW(iM/ER/cH/cK), OC(JM) 2020-2130 0$/19/20 °s/13r20 CMM,: Air Pollution Control Division "'!P-- Notice of a Proposed Title V Operating Permit CDPHE Modification Warranting Public Comment Website Title: DCP Operating Company, LP - Spindle Natural Gas Processing Plant - Weld County Notice Period Begins: June 11, 2020 NOTICE is hereby given that an application to modify 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 Operating Company, LP 370 17th Street Suite 2500 Denver, CO 80202 Facility: Spindle Natural Gas Processing Plant Section 34, T2N, R67W Fort Lupton, CO 80621 DCP Operating Company, LP has requested to modify their Operating Permit for the Spindle Natural Gas Processing Plant in Weld County, CO. This facility is a natural gas processing plant. This operating permit modification includes the following: reduction of the emission limitations for three natural gas fired engines and reduction in the facility fugitive VOC emission limitation. Regulatory updates have been made for the three engines and the fugitive emissions included in this modification. This modification results in a reduction of NOx emissions from all three affected engines, a reduction in CO and VOC emissions from one of the affected engines and a reduction in VOC emissions from the facility fugitive emissions point. A copy of the application, including supplemental information, the Division's analysis, and a draft of the modified Operating Permit 95OPWE039 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.govtpacific/cdphe/air-permit-public-notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft modified operating permit for approval. Any interested person may contact Elie Chavez of the Division at 303-692-6332 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. Only those portions of the permit affected by the modification are subject to Public Comment. Those portions of the permit affected by the modification are summarized in Appendix F of the permit. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately COLORADO Departm 1 I Health l Enventofironme Publicnt represented. The Division wilt receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Elie Chavez Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Hearing requests may be submitted to the email address or the mailing address noted above. COLORADO Department of Public 2 I ""E Health It Environment ov 6,c0t04, f 'iTc) %Colorado Department of Public Health and Environment OPERATING PERMIT DCP Operating Company, LP Spindle Natural Gas Processing Plant First Issued: May 1 , 1999 Renewed: July 1 , 2012 Last Revised: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: DCP Operating OPERATING PERMIT NUMBER Company, LP — Spindle Natural Gas Processing Plant FACILITY ID: 123/0015 95OPWE039 RENEWED: July 1, 2012 EXPIRATION DATE: July 1, 2017 MODIFICATIONS: See Appendix G of Permit Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et seq. and applicable rules and regulations. ISSUED TO: PLANT SITE LOCATION: DCP Operating Company, LP DCP Operating Company, LP Spindle Natural Gas Processing Plant 370 17th Street Sec 34, T2N, R67W Suite 2500 '/4 mile north of Highway 52, 3'/2 miles west of Ft Lupton Denver, CO 80202 Weld County, CO INFORMATION RELIED UPON Operating Permit Renewal Application Received: May 1, 2003 And Additional Information Received: April 4, 2003, June 23, 2003, October 20, 2004, November 22, 2004, March 25, 2005, April 28, 2005, August 24, 2005, July 10, 2006, March 27, 2007, April 2, 2008,April 30, 2008,April 21,2009,April 24,2009,July 31, 2009, June 21, 2010, July 19, 2010, August 19, 2010 and March 17, 2011 Nature of Business: Natural Gas Liquids Processing and Gathering Primary SIC: 1321 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Charles A. Job Name: Roshini Shankaran Title: General Manager, North Area Title: Senior Environmental Engineer Operations Phone: (303) 605-1964 Phone: (303) 605-2039 SUBMITTAL DEADLINES First Semi-Annual Monitoring Period: July 1 —December 31,2012 Subsequent Semi-Annual Monitoring Periods: January 1—June 30&July 1 —December 31 Semi-Annual Monitoring Reports: Due February 1,2013&August 1,2013 &subsequent years First Annual Compliance Period: July 1,2012—June 30,2013 Subsequent Annual Compliance Periods: July 1—June 30 Annual Compliance Certification: Due August 1,2013 &subsequent years Note that the Semi-Annual Monitoring Reports and Annual Compliance report must be received at the Division office by 5:00 p.m.on the due date.Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports. Table of Contents: First Issued: May 1, 1999 1 Renewed: July 1, 2012 1 95OPWE039 3 SECTION I- General Activities and Summary 1 1. Permitted Activities 1 2. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration(PSD) 2 3. Accidental Release Program (112(r)) 2 4. Alternative Operating Scenarios (ver 10/1/2011) 2 5. Compliance Assurance Monitoring (CAM) 8 6. Summary of Emission Units 9 SECTION II -Specific Permit Terms 11 1. Natural Gas Fired Internal Combustion Engines with AFR and NSCR> 500 HP 11 C-136—Waukesha 1232 HP Compressor Engine 11 C-137—Waukesha 1232 HP Compressor Engine 11 C-141 —Waukesha 1232 HP Compressor Engine 11 C-138—Waukesha 1232 HP Compressor Engine 13 C-147—Waukesha 1232 HP Compressor Engine 14 C-139—Waukesha 1232 HP Compressor Engine 15 C-140—Waukesha 1232 HP Compressor Engine 16 C-153 —Waukesha 1000 HP Compressor Engine 17 C-212—Superior 600 HP Compressor Engine 18 2. Natural Gas Fired Internal Combustion Engines Equipped with AFR and NSCR<500 HP 32 C-221 —Superior 474 HP Compressor Engine 32 C-217—Caterpillar 230 HP Compressor Engine 33 3. Natural Gas Fired Internal Combustion Engines with Oxidation Catalyst 39 C-215 —Superior Ajax 1215 HP Compressor Engine 39 4. P178 -Triethylene Glycol Regeneration Unit 46 5. P179 - 15 MMBtu/Hr Natural Gas Fired Hot Oil Heater 49 6. P181 - Fugitive VOC Emissions from Equipment Leaks 51 7. P182 - Condensate Tank Truck Loadout 55 8. Portable Monitoring(ver 6/1/06) 56 SECTION III-Permit Shield 57 1. Specific Conditions 57 2. General Conditions 57 3. Stream-lined Conditions 58 SECTION IV- General Permit Conditions (ver 5/22/2012) 59 1. Administrative Changes 59 2. Certification Requirements 59 3. Common Provisions 59 4. Compliance Requirements 63 5. Emergency Provisions 64 6. Emission Controls for Asbestos 64 7. Emissions Trading, Marketable Permits, Economic Incentives 64 8. Fee Payment 64 9. Fugitive Particulate Emissions 65 10. Inspection and Entry 65 11. Minor Permit Modifications 65 Table of Contents: 12. New Source Review 65 13. No Property Rights Conveyed 65 14. Odor 65 15. Off-Permit Changes to the Source 65 16. Opacity 66 17. Open Burning 66 18. Ozone Depleting Compounds 66 19. Permit Expiration and Renewal 66 20. Portable Sources 66 21. Prompt Deviation Reporting 66 22. Record Keeping and Reporting Requirements 67 23. Reopenings for Cause 68 24. Section 502(b)(10) Changes 68 25. Severability Clause 68 26. Significant Permit Modifications 69 27. Special Provisions Concerning the Acid Rain Program 69 28. Transfer or Assignment of Ownership 69 29. Volatile Organic Compounds 69 30. Wood Stoves and Wood burning Appliances 70 APPENDIX A-Inspection Information 1 1. Directions to Plant: 1 2. Safety Equipment Required: 1 3. Facility Plot Plan• 1 4. List of Insignificant Activities: 1 APPENDIX B 1 Reporting Requirements and Definitions 1 Monitoring and Permit Deviation Report- Part I 5 Monitoring and Permit Deviation Report - Part II 7 Monitoring and Permit Deviation Report- Part III 9 APPENDIX C 1 Required Format for Annual Compliance Certification Reports 1 APPENDIX D Notification Addresses 1 APPENDIX E Permit Acronyms 1 APPENDIX F NSPS KKK Example Report Format 1 APPENDIX G Permit Modifications 1 APPENDIX H Engine AOS Applicability Reports 1 APPENDIX I Compliance Assurance Monitoring Plan 1 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 1 SECTION I - General Activities and Summary 1. Permitted Activities 1.1 This plant is classified as a natural gas processing plant as set forth under Standard Industrial Classification 1321. The Spindle Natural Gas Processing Plant consists of a gas processing skid and a fractionation assembly. The gas processing skid utilizes straight refrigeration coupled with a cryogenic expander process to recover natural gas liquid (NGL) mixtures from the inlet gas stream. The NGL stream is sent to the fractionation assembly to make various fuel products. A high Btu content methane/ethane residue gas stream is created by the removal of the NGL. The residue gas stream is recompressed and routed to the sales pipeline. A triethylene glycol (TEG) dehydration system operates to dehydrate a slip stream of the residue gas used to regenerate the mole sieves. The mole sieves function to dehydrate the inlet gas. The fractionation assembly separates the NGL product from the gas plant into pure streams consisting of ethane, propane, and butane/gasoline mix (BG Mix). The ethane is recompressed and routed to a pipeline. The propane and BG mix are each stored in pressurized bullet tanks for transport off-site by truck and/or pipeline. There are twelve (12) engines powering natural gas compressors operating in inlet, residue or refrigeration service. As noted previously,one TEG dehydration unit operates to remove the water from the residue gas used to regenerate the mole sieves. The site also operates with a 15 million Btu per hour hot oil heater and one condensate loadout rack. Fugitive VOC emissions from the entire facility are subject to the leak control provisions of NSPS Subpart KKK. The plant is located west of Fort Lupton in Weld County, Colorado. This facility is located in an Area classified as attainment for all pollutants except ozone. It is classified as non-attainment for ozone and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. Rocky Mountain National Park is a Federal Class I designated area within 100 kilometers of the plant. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this plant in accordance with the requirements, limitations, and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permit(s): 09WE0195. 1.4 All conditions in this permit are enforceable by the US Environmental Protection Agency (EPA), Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 2 otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II,Condition 1.11.1,Condition 4.6 and Section IV, Conditions 3.g(last paragraph), 14 and 18 (as noted). 1.5 All information gathered pursuant to the requirements of this permit is subject to the Record keeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. 2. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC and NOx≥ 100 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) for VOC or NOx or a modification which is major by itself(Potential to Emit of≥ 100 TPY of either VOC or NOx)may result in the application of the NANSR review requirements. This facility is categorized as a PSD major stationary source (Potential to Emit≥250 Tons/Year for CO. Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.26 and 42) or a modification which is major by itself(Potential to Emit of>250 TPY) for any pollutant listed in Regulation No. 3,Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 2.2 There are no other Operating Permits associated with this plant for the purposes of determining the applicability of the PSD regulations. 3. Accidental Release Program (112(r)) 3.1 Based on the information provided by the applicant, this facility is subject to the provisions of the Accidental Release Prevention Program (Section 112 (r) of the Federal Clean Air Act). 4. Alternative Operating Scenarios (ver 10/1/2011) The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios,Regulation No. 3,Part B,Construction Permits,and Regulation No.3,Part D,Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 4.1 Engine Replacement Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 3 The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping), and shall be subject to any shield afforded by this permit The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log,the permittee shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 4.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of 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) 4.1.2 The permittee may permanently replace the existing compressor engine for the emission points specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table 1 without modifying this permit so long as the permanent replacement engine Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 4 complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice(APEN)that includes the specific manufacturer,model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found in Appendix A. This submittal shall be accompanied by a certification from the Responsible Official indicating that"based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 4.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer). Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 5 For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760),whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp- hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the engine is taken offline 4.3 Applicable Regulations for Permanent Engine Replacements 4.3.1 Reasonably Available Control Technology(RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOx are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40 tons/yr. For purposes of this AOS,the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOx: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM to: Use of natural gas as fuel Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 6 As defined in 40 CFR Part 60 Subparts GG(§ 60.331)and 40 CFR Part 72 (§ 72.2),natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 4.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E(State-Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non- selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards:Section XVII.E—State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine Construction or Emission Standards in G/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 4.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 7 A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, §LB (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 4.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 4.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not"routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 8 Table 1 Internal Combustion Engine Information for the AOS Emission Replacement Engine Periodic Subject Point Monitoring? to CAM? C-136 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-137 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-138 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-147 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-139 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-140 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-141 Waukesha Model L-7042 1232 HP GSI Natural Gas Fired Engine,turbocharged,4- Quarterly Yes cycle,Standard Rich Burn w/AFR controller C-217 Caterpillar Model G-342 NA, 230 HP, standard rich bum, turbocharged, low Quarterly No emission design,natural gas fired engine w/AFR C-153 Waukesha Model L-7042 GU, 1000 HP,standard rich bum,turbocharged,4-cycle, Semi-annually Yes natural gas fired engine w/AFR C-215 Superior Ajax Model 8SGTB, 1215 HP,lean bum,turbocharged,natural gas fired Quarterly No engine w/oxidation catalyst and AFR C-212 Superior Model 6G825,600 HP,standard rich burn,turbocharged,natural gas fired Semi-annually No engine w/AFR&NSCR C-221 Superior Model 6G825,474 HP,standard rich burn,natural gas fired engine w/AFR Quarterly No 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: Pre-controlled NOx emissions from eight (8) of the Waukesha Model L-7042 GSI engines are above the major source level. The control devices on the engines are used to meet their NOx emission limitations,therefore CAM applies to these units. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 9 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: AIRS Plant Description Size* Pollution Construction Stack Identifier Control Device Permit Number 051 C-136 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective None Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 360657 052 C-137 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 240602 053 C-138 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 327101 081 C-147 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective 09WE0195 Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 397541 055 C-139 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective None Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 286440 056 C-140 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 263183 057 C-141 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 144345 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 10 AIRS Plant Description Size* Pollution .Construction Stack Identifier. Control Device Permit Number 059 C-217 Caterpillar Model G-342 NA Natural Gas Fired 230 HP Non-Selective None Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn;low Reduction emissions design;equipped w/air/fuel ratio controller;powering a residue gas compressor. SN 71B03385 060 C-153 Waukesha Model L-7042 GU Natural Gas Fired 1000 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 361158 061 C-215 Superior Ajax Model 8SGTB Natural Gas Fired 1215 HP Oxidation Internal Combustion Reciprocating Engine, Catalyst turbocharged,4-cycle,Lean Burn,low NOx design; equipped w/oxidation catalyst and air/fuel ratio controller;powering a low pressure residue gas compressor.SN 314879 062 C-212 Superior Model 6G825 Natural Gas Fired Internal 600 HP Non-Selective Combustion Reciprocating Engine,turbocharged,4- Catalytic cycle,Standard Rich Burn;equipped w/air/fuel ratio Reduction controller;powering a low pressure residue gas compressor.SN 19941 063 P178 Weatherford Natural Gas Dehydration System using 10 Condenser triethylene glycol.SN 34418 MMscf/day Reboiler/Flare 064 P179 OPF-HMO natural gas fired heater for heating hot oil; 15 None Serial No.J87426 MMBtu/Hr 034 P181 Gas Plant Fugitive Emissions N/A None 066 P182 Condensate Truck Load-out N/A None 075 C-221 Superior Model 6G825 Natural Gas Fired Internal 474 HP Non-Selective Combustion Reciprocating Engine,4-cycle,Standard Catalytic Rich Burn;powering a natural gas compressor. Reduction SN 18653 * All horsepower(I-IP)values are site rated values as reported in APEN submittals Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page 11 SECTION II - Specific Permit Terms 1. Natural Gas Fired Internal Combustion Engines with AFR and NSCR>500 HP C-136—Waukesha 1232 HP Compressor Engine C-137—Waukesha 1232 HP Compressor Engine C-141 —Waukesha 1232 HP Compressor Engine Note:These limitations apply to each engine individually. Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval Emission&Consumption Limits 051 —C-136,Waukesha 1,232 HP Natural Gas Fired Internal Combustion Engine NOx 1.1 11.9 TPY 0.291 Recordkeeping& Monthly CO 23.8 TPY 0.582 Calculation 12 month rolling VOC 1.2 8.3 TPY 0.204 Natural Gas 1.3 78.7 MMscf/yr Consumption Emission&Consumption Limits 052/057—C-137/141,Two(2)Waukesha 1,232 HP Natural Gas Fired Internal Combustion Engines NOx 1.1 24.0 TPY 0.588 Recordkeeping& Monthly CO 39.6 TPY 0.968 Calculation 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.7 MMscf/yr Consumption Other Requirements Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page 12 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 13 C-138—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter. Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 23.8 TPY 0.582 Recordkeeping& Monthly Calculation CO 39.6 TPY 0.968 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.7 IVIMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 14 C-147—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 1.1 23.8 TPY 0.473 Recordkeeping& Monthly Calculation CO 23.8 TPY 0.473 12 month rolling VOC 1.2 6.0 TPY 0.119 Natural Gas 1.3 96.9 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 15 C-139—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number` (lb/MMBtu) Method Interval NOx 1.1 23.8 TPY 0.472 Recordkeeping& Monthly Calculation CO 47.6 TPY 0.945 12 month rolling VOC 1.2 11.9 TPY 0.236 Natural Gas 1.3 96.9 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page 16 C-140—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (1b/MMBtu) Method Interval NOx 1.1 11.9 TPY 0.236 Recordkeeping& Monthly CO 23.8 TPY 0.472 Calculation 12 month rolling VOC 1.2 8.3 TPY 0.165 Natural Gas 1.3 96.9 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page 17 C-153—Waukesha 1000 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (Ib/MMBtu) Method Interval NOx 1.1 19.3 TPY 0.472 Recordkeeping& Monthly Calculation CO 29.0 TPY 0.708 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.6 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 18 C-212—Superior 600 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MIMBtu) Method Interval NOx 1.1 11.6 TPY 0.569 Recordkeeping& Monthly Calculation CO 17.4 TPY 0.853 12 month rolling VOC 1.2 5.8 TPY 0.284 Natural Gas 1.3 39.2 MMscf/yr Consumption Btu Content of 1.4 ASTM.EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 Statewide Controls 1.11 See Condition 1.11 for Oil and Gas Operations 1.1.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations stated in the tables above (Compliance Order On Consent Case Nos. 2009-007, Colorado Construction Permit 09WE0195 for engine C-147 and as provided for under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X based on requested emissions identified on the APENs submitted on 7/2/2018 for C-139 and C-140 and 1/31/2020 for C-136, and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested emissions identified on the APENs submitted on 1/31/2020 for C-137 and C- 141). Compliance with the emission limitations shall be monitored as follows: Except as Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 19 provided below,the emission factors listed above have been approved by the Division and shall be used to calculate emissions from these engines. Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the natural gas consumption (as required by Condition 1.3) and the Btu content of the natural gas (as required by Condition 1.4) in the equation below: tons/mo= [EF(lb/MMBtu)x fuel use(MMscf/mo)x heat content of fuel(MMBtu/MMscf)1 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If the results of the portable analyzer testing conducted under the provisions of Condition 1.1.2 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division),the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 1.1.2 Portable monitoring shall be conducted for semi-annually engines C-153 and C-212 and quarterly for all other engines as required by Condition 8. 1.2 Volatile Organic Compounds (VOC) emissions from each engine shall not exceed the annual emission limitation stated in the tables above (Colorado Construction Permit 09WE0195 for engine C-147 and as provided for under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X based on requested emissions identified on the APENs submitted on 7/2/2018 for C-139 and C-140 and 1/31/2020 for C-136). Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor the monthly natural gas consumption (as required by Condition 1.3) and the Btu content of the natural gas (as required by Condition 1.4) in the equation below: tons/mo= [EF(lb/MMBtu)x fuel use(MMscf/mo)x heat content of fuel (MMBtu/MMscf)1 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.3 Natural gas consumption from each engine shall not exceed the above limitation (Colorado Construction Permit 09WE0195 for engine C-147 and as provided for under the provisions of Section 1,Condition 1.3 and Colorado Regulation No.3,Part B, Section II.A.6 and Part C, Section X based on requested limitations identified on the APENs submitted on 7/2/2018 for C-139 and Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 20 C-140). Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured on the same day that run time hours have been recorded in accordance with Condition 1.5. Allocation of natural gas to each engine will be calculated using the following calculation: Btu \ MMSCF HREngine(month) MMSCF FCEngine month Btu Btu Btu x FCFatiiity month HREngine(month)+ HRHeater(month)+ HRother(month Where: HREngine (month)= BSFC (hp t hr)x Hours of Operation (month) x Site Rated hp(hp) Btu Btu hr HRHeater (month) = Design Heat Rating (Btu x Hours of Operation (month) And: FCEngine = Individual Engine Fuel Consumption,MMSCF/Month HREngine =Individual Engine Heat Requirement,Btu/Month HRHeater=Individual Heater Heat Requirement,Btu/Month HRother= Other Users Heat Requirement,Btu/Month FCFaciiity= Facility Wide Fuel Consumption(metered),MMSCF/Month BSFC=Brake Specific Fuel Consumption,Btu/hp•hr Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly natural gas consumption from each engine shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 1.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually, or once every six months,using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 1.5 Hours of operation of each engine shall be recorded monthly. Records shall be made available for Division review upon request. 1.6 Visible emissions shall not exceed 20% opacity (Colorado Construction Permit 09WE0195 for engine C-147 and Colorado Regulation No. 1, Section II.A.1) except during periods of startup when visible emissions shall not exceed 30%opacity for a period or periods aggregating more than six(6)minutes in any sixty(60)consecutive minutes(Colorado Regulation No. 1, Section II.A.4). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 21 This opacity standard applies to each engine. In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for these engines. 1.7 Each engine is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including, but not limited to,the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date,the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. Note that as of the date of revised permit issuance October 15, 2018,the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 and later have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements, they will become both state and federally enforceable. General Requirements 1.7.1 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times (§63.6605(a)). 1.7.2 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to,monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.6605(b)). Emission Limitations, Operating Limitations and Work Practices 1.7.3 If you own or operate an existing stationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d (Condition 1.7.3.1)to this subpart that apply to you (§63.6603(a)). 1.7.3.1 Table 2d Item 11 for non-emergency, non-black start 4SRB remote stationary RICE> 500 HP: a. Change oil and filter every 2,160 hours of operation or annually,whichever comes first(Table 2d, Item 11.a). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit - Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 22 b. Inspect spark plugs every 2,160 hours of operation or annually, whichever comes first, and replace as necessary (Table 2d, Item 11.b). c. Inspect all hoses and belts every 2,160 hours of operation or annually, whichever comes first, and replace as necessary(Table 2d, Item 11.c). 1.7.3.2 Sources have the option to .utilize an oil analysis program as described in §63.6625(j) (Condition 1.7.6) in order to extend the specified oil change requirement in Table 2d (Condition 1.7.3.1a) of this subpart (Table 2d, Footnote 1). 1.7.4 An existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP must meet the definition of remote stationary RICE in §63.6675 of this subpart on the initial compliance date for the engine,October 19, 2013, in order to be considered a remote stationary RICE under this subpart. Owners and operators of existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP that meet the definition of remote stationary RICE in §63.6675 of this subpart as of October 19,2013 must evaluate the status of their stationary RICE every 12 months. Owners and operators must keep records of the initial and annual evaluation of the status of the engine. If the evaluation indicates that the stationary RICE no longer meets the definition of remote stationary RICE in §63.6675 of this subpart, the owner or operator must comply with all of the requirements for existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP that are not remote stationary RICE within 1 year of the evaluation (§63.6603(f)). Testing and Initial Compliance Requirements 1.7.5 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine,not to exceed 30 minutes,after which time the emission standards applicable to all times other than startup in Table 2d(Condition 1.7.3.1)to this subpart apply (§63.6625(h)). 1.7.6 You have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Tables 2d(Condition 1.7.3.1a)to this subpart. The oil analysis must be performed at the same frequency specified for changing the oil in Table 2d (Condition 1.7.3.1a) to this subpart. The analysis program must at a minimum analyze the following three parameters: Total Acid Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Acid Number increases by more than 3.0 milligrams of potassium hydroxide (KOH) per gram from Total Acid Number of the oil when new;viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content(by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 23 engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine (§63.6625(j)). Continuous Compliance Requirements 1.7.7 You must demonstrate continuous compliance with each emission limitation, operating limitation,and other requirements in Table 2d(Condition 1.7.3.1)to this subpart that apply to you according to methods specified in Table 6 (Condition 1.7.7.1) to this subpart (§63.6640(a)). 1.7.7.1 Table 6 Item 9 for existing non-emergency 4SLB and 4SRB stationary RICE>500 HP located at an area source of HAP that are remote stationary RICE: a. Work or Management practices (i) Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6, Item 9.a.i); or (ii) Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (Table 6, Item 9.a.ii). 1.7.8 You must report each instance in which you did not meet each emission limitation or operating limitation in Table 2d(Condition 1.7.3.1)to this subpart that apply to you. These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650 (Condition 1.7.10). If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE (§63.6640(b)). 1.7.9 You must also report each instance in which you did not meet the requirements in Table 8 (Condition 1.8)to this subpart that apply to you (§63.6640(e)). Reporting Requirements 1.7.10 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart (Condition 1.7.8) in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A) (§63.6650(f)). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 24 Recordkeeping Requirements 1.7.11 If you must comply with the emission and operating limitations (Condition 1.7.3.1), you must keep the records described in paragraphs §63.6655(a)(1)through(a)(5)of this subpart (§63.6655(a)). 1.7.12 You must keep the records required in Table 6 (Condition 1.7.7.1) of this subpart to show continuous compliance with each emission or operating limitation that applies to you (§63.6655(d)). 1.7.13 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan (§63.6655(e)). 1.7.14 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). (Condition 1.8.2) (§63.6660(a)). 1.7.15 As specified in §63.10(b)(1), (Condition 1.8.2), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.6660(b)). 1.7.16 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1) (Condition 1.8.2) (§63.6660(c)). 1.8 Each engine is subject to the requirements in 40 CFR Part 63 Subpart A"General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to,the following: 1.8.1 Prohibited activities and circumvention (§63.4) 1.8.2 Recordkeeping and reporting requirements (§63.10) 1.9 Each engine shall be equipped with both a non-selective catalytic reduction system and an air fuel controller(Colorado Regulation No. 7 Section XVI.B.3). 1.9.1 For engine C-212 only, the pressure drop across the catalyst and the catalyst inlet temperature shall be monitored and recorded monthly. The catalyst inlet temperature shall be kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. When portable monitoring is scheduled,the above parameters shall be recorded during the portable monitoring event. 1.9.2 The millivolt reading (AFR) for each engine will be monitored and recorded monthly to assess the air to fuel ratio controller operating condition. During those months when Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 25 portable monitoring is scheduled the millivolt reading shall be monitored and recorded during the portable monitoring event. Recording of the millivolt reading shall be used to verify that the AFR controlled is operated in accordance with the manufacturer's recommendations. 1.9.3 The oxygen concentration in the engine exhaust gas shall be measured and recorded for each engine during each portable monitoring event required by Condition 1.1.2. 1.10 These engines,except engine C-212,are subject to the Compliance Assurance Monitoring(CAM) requirements with respect to the NOx emission limitations in Condition 1.1. The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV,apply to eight(8)Waukesha compressor engines, C-136, C-137, C-138, C-147, C-139, C-140, C-141, and C-153. 1.10.1 Excursions, for purposes of reporting are as follows: 1.10.1.1 The permittee shall follow the CAM Plan provided in Appendix I and excursions for purposes of reporting are as follows: a. Any monthly pressure drop across the catalyst that is not within +2 inches of water from the baseline value established by the source when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during the first portable analyzer test, required by Condition 1.1.2, conducted after this revised permit issuance [July 1, 2012]. For a new, cleaned or reconditioned catalyst the new pressure drop baseline must be established by the operator within the first 7 days of engine/catalyst operation. b. Any daily engine exhaust (catalyst inlet) temperature reading that is less than 750°F or greater than 1250°F Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 1.10.2 Operation of Approved Monitoring 1.10.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.2.2Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 26 required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent,not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.2.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the pollutant-specific emissions unit (including the control device and associated capture system)to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.2.4After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Division and,if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 27 monitoring of additional parameters (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3 Quality Improvement Plan (QIP) Requirements 1.10.3.1 Based on the results of a determination made under the provisions of Condition 1.11.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3.2The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 1.11.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3.4If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 1.11.2.3.b, the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 28 a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.3.6Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.4 Reporting and Recordkeeping Requirements 1.10.4.1 Reporting Requirements: The reports required by Section IV, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary,a description of the actions taken to implement a QIP during the reporting period as specified in Condition 1.11.3 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring(40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.4.2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section IV, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 1.11.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring,or records of monitoring maintenance or corrective actions)(40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 29 b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.5 Savings Provisions 1.10.5.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard,or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.10.5.2Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2),as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 1.10.5.3Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.11 Each engine is subject to the following requirements of Colorado Regulation No. 7, Part E, Section I.D."Control of Emissions from New,Modified,Existing and Relocated Natural Gas Fired Reciprocating Internal Combustion Engines": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No.7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 30 1.11.1 Engines C-136 and C-139 only: [State-Only Enforceable]New,Modified and Relocated Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.2.). 1.11.1.1 Except as provided in Section I.D.2.b. (Condition 1.11.1.2 below), the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in Table 1 shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in Section I.D.2.b. Table 1 Condition 1.11.1.2 below) (Colorado Regulation No. 7, Part E, Section I.D.2.a.). 1.11.1.2Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in Table 1 as expressed in units of grams per horsepower-hour(g/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b.): Table 1 Maximum Emission Standard in g/hp-hr Engine HP Construction or Relocation Date NOx CO VOC On or after July 1, 2007 2.0 4.0 1.0 >500 HP On or after July 1,2010 1.0 2.0 0.7 L - [Compliance Demonstration: Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly, as specified in Condition 1.1.2. For comparison with the short—term limits in this Condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition 1.11.1.2.] [Compliance Demonstration:In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition 1.11.1.2.] 1.11.2 All Engines: Existing Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.3.). 1.11.2.1 Except as provided in Sections I.D.3.a.(i)(B) and (C) and I.D.3.a.(ii), all rich burn reciprocating internal combustion engines with a manufacturer's name plate design rate greater than 500 horsepower,constructed or modified before February 1,2009 shall install and operate both a non-selective catalytic reduction system and an air fuel controller by July 1, 2010. A rich burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of less than 2% by Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 31 volume (Colorado Regulation No. 7, Part E, Section I.D.3.a.(i)). a. All control equipment required by this Section I.D.3.a. (Condition 1.11.2.1) shall be operated and maintained pursuant to manufacturer specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator shall keep manufacturer specifications or equivalent on file (Colorado Regulation No. 7, Part E, Section I.D.3.a.(i)(A)). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 32 2. Natural Gas Fired Internal Combustion Engines Equipped with AFR and NSCR<500 HP C-221 -Superior 474 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (Ib/MMBtu) Method Interval NOx 2.1 22.9 TPY 1.12 Recordkeeping& Monthly Calculation CO 22.9 TPY 1.12 12 month rolling VOC 2.2 4.6 TPY 0.225 Natural Gas 2.3 39.2 MMscf/yr Consumption Btu Content of 2.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 2.5 Recordkeeping Monthly Opacity 2.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 2.7 Change filters and inspect spark See Condition 2.7 ZZZZ plugs,hoses and belts NESHAP Subpart A 2.8 See Condition 2.8 Parametric 2.9 See Condition 2.9 Monitoring Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 33 C-217—Caterpillar 230 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (lb/MMBtu) Method Interval NOx 2.1 5.0 TPY 0.672 Recordkeeping& Monthly Calculation CO 5.0 TPY 0.672 12 month rolling VOC 2.2 2.2 TPY 0.299 Natural Gas 2.3 14.3 MMscf/yr Consumption Btu Content of 2.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 2.5 Recordkeeping Monthly Opacity 2.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 2.7 Change filters and inspect spark See Condition 2.7 ZZZZ plugs,hoses and belts NESHAP Subpart A 2.8 See Condition 2.8 Parametric 2.9 See Condition 2.9 Monitoring 2.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations stated in the tables above. Compliance with the emission limitations shall be monitored as follows: 2.1.1 Except as provided below, the emission factors listed above have been approved by the Division and shall be used to calculate emissions from these engines. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 34 Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the natural gas consumption (as required by Condition 2.3) and the Btu content of the natural gas (as required by Condition 2.4) in the equation below: tons/mo= [EF(Ib/MMBtu)x fuel use(MMscf/mo)x heat content of fuel (MMBtu/MMscf)1 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If the results of the portable analyzer testing conducted under the provisions of Condition 2.1.2 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division),the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 2.1.2 Portable monitoring shall be conducted quarterly as required by Condition 8. 2.2 Volatile Organic Compounds (VOC) emissions from each engine shall not exceed the annual emission limitation stated in the tables above. Monthly emissions shall be calculated by the end of the subsequent month using the above emission the monthly natural gas consumption (as required by Condition 2.3) and the Btu content of the natural gas(as required by Condition 2.4) in the equation below: tons/mo= [EF(lb/MMBtu)x fuel use(MMscf/mo)x heat content of fuel(MMBtu/MMscf)l 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 2.3 Natural gas consumption from each engine shall not exceed the above limitation. Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured on the same day that run time hours have been recorded in accordance with Condition 2.5. Allocation of natural gas to each engine will be calculated using the following calculation: Btu l MMSCFI HREngine(month) MMSCF FCEngine(month J HREnine( Btu 1+ HR Heater Btu + HR Other Btu \X FCFacility (month 1 g month) L. Heater(month) Other month) Where: HREngine ( Btu l ( Btu l hr month/ = BSFC \hp•hr/x Hours of Operation (month) x Site Rated hp(hp) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 35 Btu l Btul hr HRHeater (month/ = Design Heat Rating (hr/x Hours of Operation (month) And: FCEngine =Individual Engine Fuel Consumption,MMSCF/Month HREngine =Individual Engine Heat Requirement,Btu/Month HRHeater=Individual Heater Heat Requirement,Btu/Month HRother=Other Users Heat Requirement,Btu/Month FCFaciiity=Facility Wide Fuel Consumption(metered),MMSCF/Month BSFC=Brake Specific Fuel Consumption,Btu/hp•hr Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly natural gas consumption from each engine shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 2.4 The Btu content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 2.5 Hours of operation of each engine shall be recorded monthly. Records shall be made available for Division review upon request. 2.6 Visible emissions shall not exceed 20%opacity(Colorado Regulation No. 1,Section II.A.1)except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). This opacity standard applies to each engine. In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for these engines. 2.7 Each engine is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including, but not limited to,the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date,the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 36 Note that as of the date of revised permit issuance October 15, 2018, the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 and later have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements, they will become both state and federally enforceable. General Requirements 2.7.1 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times (§63.6605(a)). 2.7.2 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.6605(b)). Emission Limitations, Operating Limitations and Work Practices 2.7.3 If you own or operate an existing stationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d to this subpart that apply to you (§63.6603(a)): 2.7.3.1 Non-emergency, non-black start 4SRB stationary RICE <500 HP shall: a. Change oil and filter every 1,440 hours of operation or annually,whichever comes first (Table 2d, Item 10.a) b. Inspect spark plugs every 1,440 hours of operation or annually, whichever comes first, and replace as necessary (Table 2d, Item 10.b); and c. Inspect all hoses and belts every 1,440 hours of operation or annually, whichever comes first, and replace as necessary (Table 2d, Item 10.c). Monitoring, Installation, Collection, Operation and Maintenance Requirements 2.7.4 You must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (§63.6625(e)). 2.7.5 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 37 needed for appropriate and safe loading of the engine,not to exceed 30 minutes,after which time the emission standards applicable to all times other than startup in Table 2d(Condition 2.7.3.1)to this subpart apply (§63.6625(h)). Continuous Compliance Demonstration 2.7.6 You must demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Table 2d to this subpart that apply to you according to methods specified in Table 6 to this subpart(§63.6640(a)): 2.7.6.1 Existing 4SRB stationary RICE<500 HP located at an area source of HAP shall: a. Operate and maintain the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6, Item 9.a.i); or b. Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (Table 6, Item 9.a.ii). 2.7.7 You must report each instance in which you did not meet each emission limitation or operating limitation in Table 2d(Condition 2.7.3.1)to this subpart that apply to you.These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650 (Condition 2.7.9). If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE (§63.6640(b)). 2.7.8 You must also report each instance in which you did not meet the requirements in Table 8 (Condition 2.8)to this subpart that apply to you (§63.6640(e)). Reporting Requirements 2.7.9 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart (Condition 2.7.7) in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A) (§63.6650(f)). Recordkeeping Requirements 2.7.10 If you must comply with the emission and operating limitations (Condition 2.7.3.1), you must keep the records described in paragraphs §63.6655(a)(1)through(a)(5)of this subpart (§63.6655(a)). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 38 2.7.11 You must keep the records required in Table 6 (Condition 2.7.6.1) of this subpart to show continuous compliance with each emission or operating limitation that applies to you (§63.6655(d)). 2.7.12 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan (§63.6655(e)). 2.7.13 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1) (Condition 2.8.2) (§63.6660(a)). 2.7.14 As specified in §63.10(b)(1) (Condition 2.8.2), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.6660(b)). 2.7.15 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1) (Condition 2.8.2) (§63.6660(c)). 2.8 Each engine is subject to the requirements in 40 CFR Part 63 Subpart A"General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to the following: 2.8.1 Prohibited Activities and Circumvention (§63.4) 2.8.2 Recordkeeping and Reporting Requirements (§63.10) 2.9 Parameters associated with the air-to-fuel ratio controller (AFR) and non-selective catalyst reduction unit shall be monitored as follows: 2.9.1 The millivolt reading (AFR) will be monitored and recorded monthly to assess the air to fuel ratio controller operating condition. Recording of the millivolt reading shall be used to verify that the AFR controller is operated in accordance with the manufacturer's recommendations. 2.9.2 The pressure drop across the catalyst shall be monitored and recorded monthly. 2.9.3 The catalyst inlet temperature shall be monitored and recorded monthly and kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. 2.9.4 When portable monitoring is scheduled, the above parameters in Conditions 2.9.1 through 2.9.3 shall be recorded during the portable monitoring event. 2.9.5 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 2.1.2. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 39 3. Natural Gas Fired Internal Combustion Engines with Oxidation Catalyst C-215—Superior Ajax 1215 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (Ib/MMBtu) Method Interval NOx 3.1 11.7 TPY 0.303 Recordkeeping& Monthly Calculation CO 23.5 TPY 0.605 12 month rolling VOC 3.2 8.2 TPY 0.212 Natural Gas 3.3 74.5 MMscf/yr Consumption Btu Content of 3.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 3.5 Recordkeeping Monthly Opacity 3.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 3.7 See Condition 3.7 ZZZZ NESHAP Subpart A 3.8 See Condition 3.8 Control Device 3.9 See Condition 3.9 3.1 Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) shall not exceed the limitations stated above (as provided for under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X based on requested emissions identified on the APEN submitted on 5/11/2015). Compliance with the emission limitations shall be monitored as follows: 3.1.1 Except as provided below, the emission factors listed have been approved by the Division and shall be used to calculate emissions. Monthly emissions shall be calculated by the end of the subsequent month using the above emission factor, the natural gas consumption (as required by Condition 3.3) and the Btu content of the natural gas (as required by Condition 3.4) in the equation below: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 40 ton/mo= 1EF(lb/MMBtu)x fuel use(MMscf/mo)x heat content of fuel (MMBtu/MMscf)1 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. If the results of the portable analyzer testing conducted under the provisions of Condition 3.1.2 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division),the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within 60 days of the completion of the test. 3.1.2 Portable monitoring shall be conducted quarterly as required by Condition 8. 3.2 Volatile Organic Compounds (VOC) emissions shall not exceed the annual emi`ssion limitation stated above (as provided for under the provisions of Section 1, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X based on requested emissions identified on the APEN submitted on 5/11/2015). Monthly emissions shall be calculated by the end of the subsequent month using the above emission the monthly natural gas consumption (as required by Condition 3.3) and the Btu content of the natural gas (as required by Condition 3.4) in the equation below: tons/mo= [EF(lb/MMBtu)x fuel use(MMscf/mo)x heat content of fuel (MMBtu/MMscf)1 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.3 Natural gas consumption shall not exceed the above limitation. Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas use shall be measured no on the same day that run time hours have been recorded in accordance with Condition 3.5. Allocation of natural gas will be calculated using the following calculation: Btu 1 MMSCF — HREngine(month) MMSCF FCEngine month Btu l Btu Btu X FCFaciiiry t l HREngine(month)+ HRHeater(month)+E HRother(month \month/ Where: Btu HREngine (month/ u = BSFC (hp t•hr)x Hours of Operation hr (month) x Site Rated hp(hp) Btu Btu hr HRHeater (month)l = Design Heat Rating (hr)x Hours of Operation (month) And: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 41 FCEngine =Individual Engine Fuel Consumption,MMSCF/Month HREngine =Individual Engine Heat Requirement,Btu/Month HRHeater=Individual Heater Heat Requirement,Btu/Month HRother=Other Users Heat Requirement,Btu/Month • FCFacility= Facility Wide Fuel Consumption(metered),MMSCF/Month BSFC=Brake Specific Fuel Consumption,Btu/hp•hr Records of calculations shall be kept in a log to be made available to the Division upon request. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months data. 3.4 The Btu content of the natural gas used to fuel the engine shall be verified semi-annually using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. The Btu content of the natural gas shall be based on the higher heating value of the fuel. Calculation of monthly emissions shall be made using the heat content derived from the most recent required analysis. 3.5 Hours of operation shall be recorded monthly.Records shall be made available for Division review upon request. 3.6 Visible emissions shall not exceed 20% opacity except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty(60)consecutive minutes(Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for this engine. 3.7 This engine is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including,but not limited to,the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date,the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. Note that as of the date of revised permit issuance October 15, 2018, the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 and later have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements, they will become both state and federally enforceable. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 42 General Requirements 3.7.1 You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times (§63.6605(a)). 3.7.2 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.6605(b)). Emission Limitations, Operating Limitations and Work Practices 3.7.3 If you own or operate an existing stationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d (Condition 3.7.3.1) to this subpart that apply to you (§63.6603(a)). 3.7.3.1 Table 2d Item 8 for non-emergency, non-black start 4SLB remote stationary RICE > 500 HP: a. Change oil and filter every 2,160 hours of operation or annually,whichever comes first(Table 2d, Item 8.a). b. Inspect spark plugs every 2,160 hours of operation or annually, whichever comes first, and replace as necessary(Table 2d, Item 8.b). c. Inspect all hoses and belts every 2,160 hours of operation or annually, whichever comes first, and replace as necessary (Table 2d, Item 8.c). 3.7.3.2 Sources have the option to utilize an oil analysis program as described in §63.6625(j) (Condition 3.7.6) in order to extend the specified oil change requirement in Table 2d (Condition 3.7.3.1a) of this subpart (Table 2d, Footnote 1). 3.7.4 An existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP must meet the definition of remote stationary RICE in §63.6675 of this subpart on the initial compliance date for the engine, October 19, 2013, in order to be considered a remote stationary RICE under this subpart. Owners and operators of existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP that meet the definition of remote stationary RICE in §63.6675 of this subpart as of October 19,2013 must evaluate the status of their stationary RICE every 12 months. Owners and operators must keep records of the initial and annual evaluation of the status of the engine. If the evaluation indicates that the stationary RICE no longer meets the definition of remote stationary RICE in §63.6675 of Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 43 this subpart, the owner or operator must comply with all of the requirements for existing non-emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP located at area sources of HAP that are not remote stationary RICE within 1 year of the evaluation (§63.6603(f)). Testing and Initial Compliance Requirements 3.7.5 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine,not to exceed 30 minutes,after which time the emission standards applicable to all times other than startup in Table 2d(Condition 3.7.3.1)to this subpart apply (§63.6625(h)). 3.7.6 °You have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Tables 2d(Condition 3.7.3.1a)to this subpart.The oil analysis must be performed at the same frequency specified for changing the oil in Table 2d (Condition 3.7.3.1a) to this subpart. The analysis program must at a minimum analyze the following three parameters: Total Acid Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Acid Number increases by more than 3.0 milligrams of potassium hydroxide (KOH) per gram from Total Acid Number of the oil when new;viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content(by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine (§63.6625(j)). Continuous Compliance Requirements 3.7.7 You must demonstrate continuous compliance with each emission limitation, operating limitation,and other requirements in Table 2d (Condition 3.7.3.1)to this subpart that apply to you according to methods specified in Table 6 (Condition 3.7.7.1) to this subpart (§63.6640(a)). 3.7.7.1 Table 6 Item 9 for existing non-emergency 4SLB and 4SRB stationary RICE>500 HP located at an area source of HAP that are remote stationary RICE: a. Work or Management practices Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 44 (i) Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions (Table 6, Item 9.a.i); or (ii) Develop and follow your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (Table 6, Item 9.a.ii). 3.7.8 You must report each instance in which you did not meet each emission limitation or operating limitation in Table 2d(Condition 3.7.3.1)to this subpart that apply to you.These instances are deviations from the emission and operating limitations in this subpart. These deviations must be reported according to the requirements in §63.6650 (Condition 3.7.10). If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE (§63.6640(b)). 3.7.9 You must also report each instance in which you did not meet the requirements in Table 8 (Condition 3.8)to this subpart that apply to you (§63.6640(e)). Reporting Requirements 3.7.10 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart (Condition 3.7.8) in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A) (§63.6650(f)). Recordkeeping Requirements 3.7.11 If you must comply with the emission and operating limitations (Condition 3.7.3.1), you must keep the records described in paragraphs §63.6655(a)(1)through(a)(5)of this subpart (§63.6655(a)). 3.7.12 You must keep the records required in Table 6 (Condition 3.7.7.1) of this subpart to show continuous compliance with each emission or operating limitation that applies to you (§63.6655(d)). 3.7.13 You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan(§63.6655(e)). 3.7.14 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1). (Condition 3.8.2) (§63.6660(a)). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 45 3.7.15 As specified in §63.10(b)(1), (Condition 3.8.2), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.6660(b)). 3.7.16 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1) (Condition 3.8.2) (§63.6660(c)). 3.8 This engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to, the following: 3.8.1 Prohibited activities and circumvention (§63.4) 3.8.2 Recordkeeping and reporting requirements (§63.10) 3.9 This engine shall be equipped with oxidation catalyst (Colorado Regulation No. 7, XVI.B.2). Upon compliance with the requirements of Condition 3.7, the following monitoring requirements shall no longer apply. Parameters associated with the catalyst shall be monitored as follows: 3.9.1 The pressure drop across the catalyst shall be monitored and recorded monthly. 3.9.2 The catalyst inlet temperature shall be monitored and recorded monthly and kept within the manufacturer's specified range. The manufacturer's recommendations on the catalyst inlet temperature shall be made available to the Division upon request. 3.9.3 When portable monitoring is scheduled,the above parameters in Condition 3.9.1 and 3.9.2 shall be recorded during the portable monitoring event. 3.9.4 The oxygen concentration in the engine exhaust gas shall be measured and recorded during each portable monitoring event required by Condition 3.1.2. 3.9.5 All control equipment required by Condition 3.9 shall be operated and maintained pursuant to manufacturer specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. Manufacturer specifications or equivalent shall be kept on file. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 46 4. P178 -Triethylene Glycol Regeneration Unit Parameter Permit Limitations Emission Factor Monitoring Condition Number Method Interval VOC 4.1 21.3 tons per year GLYCalc 4.0 or Parametric Monthly higher 12 month rolling Gas Processed 4.2 3,650.0 MMscf per year Recordkeeping& Monthly Caclulation 12 month rolling Lean Glycol Pumping 4.3 0.7 gallons per minute Recordkeeping Monthly Rate Extended Gas 4.4 EPA/Division Annually Analysis Approved Methods Days/Hours of 4.5 Recordkeeping See Condition 4.5 Operation [State-Only] Control 4.6 See Condition 4.6 Device NESHAP Subpart HE 4.7 < 1984 lb/yr benzene or See Condition 4.7 <3MMscf/day 4.1 VOC emissions shall not exceed the annual emission limitation stated above. Emissions of VOC and HAPs will be calculated monthly using the Gas Research Institute's GLYCalc (Version 4.0 or higher)Model. Parametric monitoring of triethylene glycol circulation rate, inlet gas pressure and inlet gas temperature for the dehydrator shall be performed to verify input to this model. Values recorded shall be representative of how the unit operated during the period. Recording interval for all parameters shall be on a monthly basis. Monthly calculation of emissions using GLYCaIc will be conducted by the end of the subsequent month utilizing the gas data from the last analysis conducted as required by Condition 4.4 and the average monthly value of the monitored parameters. Monthly VOC emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.2 The gas processed by the glycol dehydration unit shall not exceed the limitations listed above. The gas throughput to the dehydration unit shall be recorded monthly using the existing flow meter. A twelve month rolling total will be maintained to monitor compliance with annual limitations. Records of throughput shall be kept in a log to be made available to the Division upon request. An average daily gas throughput rate shall be determined by dividing the monthly gas throughput by the number of operating days in the previous month. This average daily gas throughput rate shall be used in the monthly GLYCaic runs required by Condition 4.1. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 47 4.3 The maximum pumping rate of lean glycol shall not exceed 0.7 gallons per minute (a pump stroke correlation can be used). Monthly records of the actual pumping rate shall be maintained by the permittee and made available to the Division for inspection upon request. 4.4 Samples of inlet gas shall be collected and analyzed(extended gas analysis) annually to determine C1 to C6, n-hexane, benzene,toluene, ethyl benzene and total xylene (BTEX) composition. If any of the analyses indicates the BTEX constituent concentrations exceed the values listed in the table below,frequency of extended gas analyses will become quarterly. The first quarterly sample shall be taken three months after the sample that indicated a BTEX constituent exceeded the parameters in the table was taken. Frequency of sampling and analysis will move to semi-annually after four (4) subsequent analyses and to annually after two (2) subsequent semi-annual analyses indicate that the BTEX constituents remain at or below the values in the table below. Constituent Value Units Criteria Benzene 465 parts per million At or Below Toluene 212 parts per million At or Below Ethyl Benzene 3 parts per million Must Not Exceed Xylene 20 parts per million At or Below 4.5 Days and hours of operation shall be monitored and recorded monthly in a log that is to be made available to the Division upon request. Days of operation shall be used to calculate an average daily gas throughput as specified in Condition 4.2. Hours of operation for the month shall be used in the GLYCaIc runs required by Condition 4.1. 4.6 [State-Only] Any still vent and flash separator or flash tank shall reduce uncontrolled actual emissions of VOCs by an average of at least 90 percent through the use of air pollution control equipment. (Colorado Regulation No. 7, Section XVII.D) 4.7 The glycol dehydration units are subject to the requirements in 40 CFR Part 63 Subpart HH, "National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", as adopted by reference in Colorado Regulation No. 8, Part E, Section III, including, but not limited to the following: 4.7.1 These dehydrators are exempt from all requirements, save recordkeeping in §63.774(d)(1), provided the criteria in Condition 4.7.1.1 or Condition 4.7.1.2 below is met: (§63.764(e)(1)) 4.7.1.1 The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere shall be less than 0.90 megagram per year, or 1984 lbs per year, as determined by the procedures specified in Condition 4.7.3 (§63.764 (e)(1)(ii)). OR 4.7.1.2 The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day (3.0 MMSCF/day), as determined by the procedures specified in Condition 4.7.4 (§63.764(e)(1)(i).) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 48 4.7.2 Records shall be kept of the actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with Condition 4.7.3 §63.772(b)(2) (§63.774(d)(1)(ii)). 4.7.3 The determination of actual average benzene emissions from this glycol dehydration unit shall be made using the procedure described in Condition 4.7.3.1 below. Emissions shall be determined with federally enforceable controls in place. 4.7.3.1 The actual average benzene emissions shall be determined using the model GRI- GLYCalc, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc, Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric. Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1) (§63.772(b)(2)(i)). 4.7.4 The determination of actual flowrate of natural gas to the glycol dehydration unit shall be made using the procedure described in Condition 4.7.3.1 below. 4.7.4.1 The facility shall install and operate a monitoring instrument that directly measures natural gas flowrate to the glycol dehydration unit with an accuracy of plus or minus 2 percent or better. The source shall convert annual natural gas flowrate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processed natural gas. (§63.722(b)(1)(i)) Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 49 5. P179 - 15 MMBtu/Hr Natural Gas Fired Hot Oil Heater Parameter Permit Limitations Emission Monitoring Condition Factors Number (Ib/MMscf) Method Interval PM 5.1 0.25 lb per MMBtu Fuel Restriction Only Natural Gas is Used As Fuel NOx 5.2 6.3 tons per year 100 Recordkeeping& Monthly Calculation CO 5.3 tons per year 84 12 month rolling total Natural Gas 5.3 126.4 MMscf per year Fuel Meter Monthly Consumption Recordkeeping Opacity 5.4 Not to Exceed 20%Except Fuel Restriction Only Natural Gas is as Provided Below Used As Fuel For Startup-Not to Exceed 30%,for a Period or Periods Aggregating More than Six(6)Minutes in any 60 Consecutive Minutes NSPS General 5.5 As Required by NSPS General Provisions Provisions 5.1 Particulate Matter (PM) emissions shall not exceed the above limitations (Colorado Regulation No. 1, Section III.A.1). In the absence of credible evidence to the contrary, compliance with the particulate matter emission limits is presumed since only natural gas is permitted to be used as fuel in the heater. The numeric PM standards were determined using the design heat input for the heater (15 MMBtu/hr) in the following equation: PE=0.5 x(FD-0 26, where: PE=particulate standard in lb/MMBtu FI=fuel input in MMBtu/hr 5.2 Emissions of NOx, and CO shall not exceed the limitations listed above. Monthly emissions shall be calculated by the end of the subsequent month using the above emission factors (EF) (from "EPA's Compilation of Emission Factors (AP-42)", Section 1.4 (dated 3/98)) and the monthly natural gas consumption, as required by Condition 5.3 in the following equation: ton/mo= [EF(lb/MMscf)x monthly natural gas consumption(MMscf/mo)l 2000 lb/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XS X/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 50 5.3 Natural gas consumption shall not exceed the limitations stated above. Natural gas consumed in the heater shall be recorded monthly (40 CFR Part 60 Subpart Dc §60.48c(g), as adopted by reference in Colorado Regulation No. 6, Part A). Natural gas use shall be recorded monthly using the fuel meter. Monthly natural gas consumption shall be used to calculate annual emission as required by Condition 5.2. A twelve month rolling total shall be maintained to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of consumption shall be kept on site and made available for Division review upon request. 5.4 Visible emissions shall not exceed 20%opacity(Colorado Regulation No. 1,Section II.A.1)except during periods of startup when visible emissions shall not exceed 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for this unit. 5.5 The hot oil heater is subject to the requirements in 40 CFR Part 60,Subpart A—General Provisions, as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A as follows: 5.5.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses discharged to the atmosphere. (40 CFR 60 Subpart A §60.12, as adopted by reference in Colorado Regulation No. 6, Parts A, Subpart A and B, Section I.A). 5.5.2 At all times, including periods of startup, shutdown,and malfunction,owners and operators shall to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (40 CFR Subpart A §60.11(d), as adopted by reference in Colorado Regulation No. 6, Parts A, Subparts A and B, Section I.A). 5.5.3 Records shall be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the source; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative (40 CFR Part 60 Subpart A §60.7(b), as adopted by reference in Colorado Regulation No. 6, Parts A, Subparts A and B, Section I.A). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 51 6. P181 - Fugitive VOC Emissions from Equipment Leaks Parameter Permit Limitation Emission Factor Monitoring Condition Number r Method Interval VOC 6.1 9.9 tons per By Component- EPA Method 21 Annually year EPA Protocol for Recordkeeping& Equipment Leak Calculation Estimates Statewide Controls for Oil Complies by meeting 40 CFR 60 Subpart OOOO NSPS 6.2 and Gas See Condition 6.2 Operations 40 CFR Part 60 Subpart KKK 6.3 See Condition 6.3 NSPS 40 CFR Part 60 Subpart OOOO 6.4 See Condition 6.4 NSPS NSPS General 6.5 See Condition 6.5 Provisions 6.1 Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lbs/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017. These emission factors are fixed until changed by established permit modification procedures. • C t ponent mission F4,c jlb/component hr l ' Gas Service light Liquid Heavy Liqui Valves 9.92 x 10-3 5.51 x 10"3 1.85 x 10-5 Connectors 4.41 x 10-4 4.63 x 10-4 1.65 x 10-5 Flanges 8.60 x 10-4 2.43 x 10-4 8.60 x 10-' Pump Seals 5.29 x 10-3 2.87 x 10-2 N/A Other* 1.94 x 10-2 1.65 x 10-2 7.05 x 10-5 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches,instruments,meters,polished rods,and vents. Calculation of annual emissions of VOC per component: Component count x 8760 hrs/year x VOC content(wt%) x Emission Factor x Control Factor The total fugitive VOC emissions shall be the sum of emissions for each component. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 52 A plant inlet gas analysis shall be performed according to appropriate ASTM or EPA approved methods at least once per calendar year.The dates of the annual inlet gas analysis shall be separated by at least two (2) calendar months. The most recent inlet gas analysis shall be used to determine the appropriate %VOC to use in the above equation. For determining compliance the Division accepted the following control factors: Control Factor Component Gas Light Liquid Heavy Liquid Connectors 81% 8P/0 30% Flanges 81% 81% 30% Open-Ends N/A N/A N/A Pump Seals N/A 88% 75% Valves 96% 95% 75% Other* 75% 75% 75% *Other equipment type includes compressors,pressure relief valves,relief valves,diaphragms,drains,dump arms, hatches, instruments, meters,polished rods,and vents. 6.1.1 The annual emission limit was based on the following component count,which includes a 20% buffer: Component Component Count Gas Service Light Liquid Heavy Liquid Service Service Valves 1,542 2,753 24 Connectors 6,547 6,740 241 Flanges 1,643 1,208 0 Pumps 46 0 Other* 127 40 0 VOC Content(wt%) 25.64 100 100 *Other equipment type includes compressors,pressure relief valves,relief valves,diaphragms,drains,dump arms,hatches,instruments,meters,polished rods,pumps and vents. A running total shall then be kept of all additions and subtractions to the component count. A manual component count shall be performed at least once every five (5) calendar years as a check against the running total. The most recent running total shall be used for emission calculation purposes. The records shall be kept at the site and made available for Division review upon request. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page 53 6.2 This facility is subject to the following requirements for gas-processing plants located in the 8- hour Ozone Control Area of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations": 6.2.1 For fugitive volatile organic compound emissions from leaking equipment, the leak detection and repair(LDAR)program as provided at 40 CFR Part 60, Subpart OOOO(July 1, 2017; Condition 6.4) applies, regardless of the date of construction of the affected facility,unless subject to the LDAR program provided at 40 CFR Part 60, Subpart 0000a (July 1, 2017). (Colorado Regulation No. 7, Part D, Section I.G.1.). 6.2.2 Natural gas processing plants within the 8-hour Ozone Control Area constructed before January 1, 2018 must comply with the requirements of Section I.G. (Condition 6.2.1) beginning January 1, 2019 (Colorado Regulation No. 7, Part D, Section I.G.3.). 6.3 This facility, with respect to fugitive emissions, is subject to the New Source Performance Standards requirements of Colorado Regulation No. 6, Part A, Subpart KKK (40 CFR Part 60, Subpart KKK) "Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction,Reconstruction or Modification Commenced After January 20, 1984,and on or Before August 23, 2011", including, but not limited to,the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart KKK published in the Federal Register on 8/16/2012. However, if revisions to this Subpart are published at a later date, the owner or operator is required to comply with the requirements contained in the revised version of 40 CFR Part 60 Subpart KKK. 6.3.1 For all equipment types, except for affected compressors only, compliance with NSPS KKK is presumed, provided the requirements of NSPS OOOO (Condition 6.4) are met. 6.3.2 Affected compressors only are subject to the following applicable requirements: 6.3.2.1 Standards, as required by §60.632 6.3.2.2 Exceptions, as required by §60.633 6.3.2.3 Recordkeeping Requirements, as required by §60.635 6.3.2.4 Reporting Requirements, as required by §60.636 6.4 This facility, with respect to fugitive emissions, is required to comply with the New Source Performance Standards requirements of Colorado Regulation No. 6, Part A, Subpart OOOO (40 CFR Part 60, Subpart OOOO) "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced After August 23, 2011, and on or before September 18, 2015", as required by Condition 6.2.1, including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart OOOO published in the Federal Register on 6/3/2016. However, if revisions to this Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 54 Subpart are published at a later date, the owner or operator is required to comply with the requirements contained in the revised version of 40 CFR Part 60 Subpart OOOO. This facility is subject to the following applicable requirements: 6.4.1 At all times, including periods of startup, shutdown,and malfunction,owners and operators shall maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source (§60.5370(b)). 6.4.2 Equipment leak standards applicable to affected facilities at an onshore natural gas processing plant(§60.5400). 6.4.3 Exceptions to the equipment leak standards for affected facilities at an onshore natural gas processing plant(§60.5401). 6.4.4 Alternative emission limitations for equipment leaks from onshore natural gas processing plants (§60.5402). 6.4.5 Continuous compliance demonstration with the standards for affected facilities at onshore natural gas processing plants (§60.5415(f)). 6.4.6 Recordkeeping Requirements for affected facilities subject to VOC requirements for onshore natural gas processing plants (§60.5421). 6.4.7 Reporting Requirements for affected facilities subject to VOC requirements for onshore natural gas processing plants (§60.5422). 6.5 This facility, with respect to fugitive emissions, is subject to the requirements in 40 CFR Part 60 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A as specified in 40 CFR Part 60 Subpart KKK and Subpart OOOO. These requirements include, but are not limited to the following: 6.5.1 §60.7—Notification and recordkeeping 6.5.2 §60.12—Circumvention 6.5.3 §60.17-Incorporations by reference 6.5.4 §60.19—General notification and reporting requirements Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 55 7. P182 - Condensate Tank Truck Loadout IParameter Permit Limitations Emission Monitoring Condition Factor Number Method Interval VOC 7.1 43.3 tons per year 4.81 lb/1000 Record keeping and Monthly gallons calculation 12 month rolling total Condensate 7.2 18 million gallons Throughput per year 7.1 VOC emissions from condensate truck loading shall not exceed the limitations stated above. VOC emissions shall be calculated monthly using the compliance emission factor above (calculated from methodology in AP 42 Chapter 5-2) in the following equation: tons/mo =EF (lb/Mgallons)x Condensate Throughput(gallon/mo) 1000 gallons x 2000 (lb/ton) The parameters used to determine the emissions factor are as follows. The Division shall be notified should there be any change in these parameters that would result in a higher emission factor. Truck Loadout Emissions (lb/1000 gallons loaded) =(12.46 x S x P x M)/(T x CF) where: S = Saturation Factor 0.6 Submerged loading, dedicated normal service P =Ave Vapor Pressure 5.0 psi M= Molecular Weight 66.0 lb/lb mole T=Average Temperature 512.45 degrees R(based on 52.45° F) CF = Control Efficiency 1 Monthly emissions of VOC will be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 7.2 The quantity of condensate loaded into trucks shall not exceed the limitations stated above. The quantity of condensate loaded into trucks shall be monitored and recorded monthly and used to calculate emissions as required by Condition 7.1. Monthly condensate throughput shall be the sum of all loading activities within that month. This sum will be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. Records of condensate throughput shall be kept in a log to be made available to the Division upon request. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 56 8. Portable Monitoring (ver 6/1/06) Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted semi- annually for engines C-153 and C-212 and quarterly for all other engines using a portable flue gas analyzer. At least one calendar month shall separate the quarterly tests and at least two months quarter for semi-annual tests. Note that if the engine is operated for less than 100 hrs in any quarterly or semi- annual period, then the portable monitoring requirements do not apply. An EPA Reference Method test can replace a required portable analyzer test if conducted within the same test period as the portable analyzer test it replaces. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: https://wym.colorado.t;ov/pacific/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit,the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the engine is taken offline. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request.. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 57 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, ,S§ I.A.4, V.D. &XIII.B; ,§ 25-7-114.4(3)(a), C.R.S. 1. Specific Conditions Based upon the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition,this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Applicable Requirement Justification C-136 Waukesha 1232 HP Engine Reg 1.III.A.1.b—Particulate Internal combustion engines are not considered fuel C-137 Waukesha 1232 HP Engine emissions from fuel-burning burning equipment for the applicable requirements of equipment Regulation 1. C-138 Waukesha 1232 HP Engine Reg 1.VI.B.5.a I.B.5.a—Sulfur dioxide C-147 Waukesha 1232 HP Engine emissions from fuel-burning equipment C-139 Waukesha 1232 HP Engine C-140 Waukesha 1232 HP Engine C-141 Waukesha 1232 HP Engine C-217 Caterpillar 230 HP Engine C-153 Waukesha 1000 HP Engine C-215 Superior Ajax 1215 HP Engine C-212 Superior 600 HP Engine C-221 Superior 474 HP Engine Plant-wide Reg 3.B.IV.D.3-PSD Review Activities at this site have not yet required Prevention Requirements of Significant Deterioration(PSD)review or permitting. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 58 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance. 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(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. Stream-lined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition I Streamlined(Subsumed)Requirements Section II,Condition Colorado Regulation No.7,XVII.E.3.b.(i)[install control equipment]—State Only Requirement 1.9 Section II, Colorado Regulation No. 7,Section XVI.B.3 [operation and maintenance] Conditions 1.10.1 and 3.10.4 Section II,Condition Colorado Regulation No.7,XVII.E.3.b.(i)[install control equipment]—State Only Requirement 3.9 Section II,Condition Colorado Regulation No. 6, Part B, Section II.C.2 [fuel burning equipment particulate matter 5.1 requirement]—State Only Requirement Section II,Condition Colorado Regulation No. 6, Part B, Section II.C.3 [opacity of emission shall not exceed 20%] — 5.4 State Only Requirement Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 59 SECTION IV- General Permit Conditions (ver 5/22/2012) 1, Administrative Changes Regulation No.3,5 CCR 1001-5,Part A, & III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No.3,Part A, § I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No.3,5 CCR 1001-5,Part C, III.B.9.,V.C.16.a.&e.and V.C.17. a. Any application,report,document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the truth,accuracy and completeness of such form,report or certification stating that,based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s)used for determining the compliance status of the source,currently and over the reporting period;and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act,the permittee shall certify its compliance with that requirement;the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2&&II.A.,II.B.,II.C.,II.E.,II.F.,II.I,and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install,maintain,and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 60 c. Performance Testing The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s) and furnish the Division a written report of the results of such test(s)in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves,in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes,Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s).Operations during period of startup,shutdown,and malfunction shall not constitute representative conditions of performance test(s)unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided,performance testing facilities as follows: (I) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s);and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown,failure of an irreplaceable portion of the sample train,extreme meteorological conditions,or other circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 61 An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden,unavoidable breakdown of equipment,or a sudden, unavoidable failure of a process to operate in the normal or usual manner,beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass)were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design,operation,or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement;and (x) During the period of excess emissions,there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible,but no later than noon of the Division's next working day,and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits,including,but not limited to,new source performance standards and national emission standards for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip) limits or permit limits that have been set taking into account potential emissions during malfunctions,including,but not necessarily limited to,certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. e. Circumvention Clause A person shall not build,erect, install,or use any article,machine,equipment,condition,or any contrivance,the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 62 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; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum • extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed,contemporaneous operating logs or other relevant evidence;and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions.The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants,or Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 63 any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition,an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration(PSD)increments. In making any determination whether a source established an affirmative defense,the Division shall consider the information within the notification required above and any other information the Division deems necessary,which may include,but is not limited to,physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3,5 CCR 1001-5,Part C, §§ III.C.9.,V.C.11.& 16.d.and§25-7-122.1(2),C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act,as well as the state act and Regulation No.3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No.3,shall be enforceable pursuant to state law,and shall not be enforceable by citizens under§304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action,for permit termination,revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked,reopened, and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification,revocation and reissuance,or termination,or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in§§X.and 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. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 64 5. Emergency Provisions Regulation No. 3,5 CCR 1001-5,Part C,& VII.E An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source,including acts of God,which situation requires immediate corrective action to restore normal operation,and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency"does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance,careless or improper operation,or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the permit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency,and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency,any steps taken to mitigate emissions,and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8,5 CCR 1001-10,Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8,Part B,"asbestos control." 7. Emissions Trading,Marketable Permits,Economic Incentives Regulation No. 3,5 CCR 1001-5,Part C,§ V.C.13. No permit revision shall be required under any approved economic incentives,marketable permits,emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S §§ 25-7-114.1(6)and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice,unless a permittee has filed a timely protest to the invoice amount. b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. §25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25-7-114.1(6)for each APEN or revised APEN filed. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 65 9. Fugitive Particulate Emissions Regulation No. 1,5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, §III.D.1. 10. Inspection and Entry Regulation No.3,5 CCR 1001-5,Part C,$V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or any authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located,or emissions-related activity is conducted,or where records must be kept under the terms of the permit; b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities,equipment(including monitoring and air pollution control equipment), practices,or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or applicable requirements,any substances or parameters. 11. Minor Permit Modifications Regulation No.3,5 CCR 1001-5,Part C, §§X.&XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3,5 CCR 1001-5,Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No.3,Part B,without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3,5 CCR 1001-5,Part C, V.C.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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 66 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.,II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§I.-II. 17. Open Burning Regulation No. 9,5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No.9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I.,II.C.,II.D.,III.IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No.3,5 CCR 1001-5,Part C, §§III.B.6.,IV.C.,V.C.2. a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No.3,5 CCR 1001-5,Part C, §II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No.3,5 CCR 1001-5,Part C,& V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit,the probable cause of such deviations,and any corrective actions or preventive measures taken. "Prompt" is defined as follows: a. Any definition of"prompt"or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit;or Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 67 b. Where the underlying applicable requirement fails to address the time frame for reporting deviations,reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements,the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements,the report shall be made within 48 hours;and (iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months, except as otherwise specified by the Division in the permit in accordance with paragraph 22.d.below. c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone (303-692-3155)or facsimile(303-782-0278)based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit.] A written notice,certified consistent with General Condition 2.a. above(Certification Requirements),shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required above. "Prompt reporting"does not constitute an exception to the requirements of"Emergency Provisions"for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No.3,5 CCR 1001-5,Part A,§II.;Part C, &$ V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit,the permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (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 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 68 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 Regulation No.3,5 CCR 1001-5,Part C,§ XIII. a. The Air Pollution Control Division shall reopen,revise,and reissue Operating Permits;permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No.3,Part C, §III.,except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years,unless the effective date of the requirements is later than the date on which the permit expires,or unless a general permit is obtained to address the new requirements; whenever additional requirements(including excess emissions requirements)become applicable to an affected source under the acid rain program;whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit,except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10)Changes Regulation No.3,5 CCR 1001-5,Part C, XII.A. The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No.3,5 CCR 1001-5,Part C,§ V.C.10. In the event of a challenge to any portion of the permit,all emissions limits,specific and general conditions,monitoring, record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 69 26. Significant Permit Modifications Regulation No.3,5 CCR 1001-5,Part C, § III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No.3,Part B ("Construction Permit" requirements)without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation,to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the"Combined Construction/Operating Permit"application procedures of Regulation No.3,Part C,then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No.3,5 CCR 1001-5,Part C, $$ V.C.1.b.&8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3,5 CCR 1001-5,Part C, § II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms,for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7,5 CCR 1001-9,§&III&V. The requirements in paragraphs a,b and e apply to sources located in an ozone non-attainment area or the Denver 1-hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. All storage tank gauging devices,anti-rotation devices,accesses,seals,hatches,roof drainage systems,support structures,and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually,by touch,by presence of odor,or using a portable hydrocarbon analyzer. When an analyzer is used,detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. b. Except when otherwise provided by Regulation No.7,all volatile organic compounds,excluding petroleum liquids, transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons),shall be transferred using submerged or bottom filling equipment. For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology(RACT)is utilized. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 70 d. No owner or operator of a bulk gasoline terminal,bulk gasoline plant,or gasoline dispensing facility as defined in Colorado Regulation No.7,Section VI,shall permit gasoline to be intentionally spilled,discarded in sewers,stored in open containers,or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No.4,5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No.4 concerning the advertisement, sale,installation,and use of wood stoves and wood burning appliances. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - NSPS KKK EXAMPLE REPORT FORMAT G - PERMIT MODIFICATIONS H - ENGINE AOS APPLICABILITY REPORTS I - COMPLIANCE ASSURANCE MONITORING *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise stated in this permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/3000( Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A-Inspection Information 1. Directions to Plant: The facility is located in Section 34, T2N, R67W, which is a '/4 mile north of State Highway 52, 3% miles west of Fort Lupton, Colorado. From I-25 North take Exit 235 (CR 52) and go east on 52 —5 miles. Turn left at CR 19 and Spindle is—1/2 mile on the right. 2. Safety Equipment Required: Hard Hat, Safety Shoes, Ear Protection, Eye Protection, and Fire Retardant Clothing. 3. Facility Plot Plan: Figure 1 shows the plot plan as submitted on April 27, 2020. 4. List of Insignificant Activities: The following generic list of insignificant activities was provided in the Title V application: 2.2 MMBtu/hr, Heater S-175 1.75 MMBtu/hr, Reboiler S-178 2 MMBtu/hr, Heater S-179 1.97 MMBtu/hr, Regen Heater S-174 1.5 MMBtu/hr, Regen Heater S-172 Two (2) 1.6 MMBtu/hr, Heaters, S-173 & S-176 Twelve (12) Compressor Blowdown Vents East Condensate Loading and Unloading West Propane Loading Rack East BG Loading Rack • West Y-Grade Loading and Unloading Emergency Flare 500 gal, Kerosene tank 210-bbl, Lube Oil tank 6,000 gal, Lube Oil tank Two (2) 500 gal, Lube Oil tanks 470 gal, Lube Oil tank 300 gal, Lube Oil 4,512 gal, Used Oil tank 500 gal,portable Used Oil Tank Three (3)225 gal, Used Oil Tanks 500 gal, Diesel tank 500 gal, Dyed Diesel tank 30 bbl, Slop Oil Tank Two (2) 80 bbl, Slop Oil Tanks Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 2 210 bbl, Slop Oil Tank Two (2) 10 bbl, Slop Oil Tanks 220 gal, Slop Oil tank Four(4) 30,000 gal Pressurized NGL Storage Tanks Four(4) 80 bbl, Produced Water Tanks 80 bbl, Stormwater Tank 80 bbl, Wastewater Tank 10 bbl, Dehy water tank 1,000 gal, Methanol tank Four(4) 500 gal, Methanol tanks Two (2) 1,000 gal,Norkool tanks Two (2) 24 bbl,Norkool tanks 500 gal, TEG tank Two (2) 80,000 gal Pressurized Butane Storage Tanks 30,000 gal Pressurized Propane Storage Tank 18,000 gal Pressurized Methanol Storage Tank Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX '1Ov� O rs' c' . O. cm ��y , V --. Y •. '.. j I t ANT 0L4IAJSLf..SKIR 1 .1 �• Z " • �. lug. RA-' t' II,r -.N, ., o- % cL cpl_.BECE ty ' ,i. I ;41 'FiiC _ TX •d A u 17- Il ;lc wnoN can k ul� n d ..t f ix j[ _ .. I b._,. f ,e4.:rrefX4-7 11 1..I,'. ..»u~r NA hLc - '� ,tee.. ��.. ....) —_1 W4O1I / V f t i. ( _...— -I' ', t-—'-' 1 �.' 1 ' •' I1 I I r�,,x,,!'4n1 rwntr . EQUIPMENT IOc NIIEICATION PK.EI%E5 r o } 7' E}I CP r.PcE r Y ,i; I : M a^2n �1 w i j iT �. I' Ir ,. r1 \\ 1 (] le ja .r�$ a ax } _i, .r. I '"--+- I_ r 1- 1 ---;714 1 r «N i r � .. • 1 �a i r 4 1 ,1;,-; i 1 PLAN!A ... _ .4 1 " ! I A, I �� s " __ 1. x'io- �- l _-_— - i-- i. 6^uxarV"rF"'1,. P NF A EXPAMLEA_SYA ' 'CJ IIH ?aft_ ELAN�_I2EyyP 0 1 _ ti . ,,I __ r I N .� w w WELD 4(MY.COLORADO 'o 'a�o yl`INlrIF PLOT AND 0000100 PACE ' �l ,t. ' N o- r t mn E n.,. '' 1153 lt...,,, wi _ CMG NO 0,w,u� )h CA H m E+��Jyy U] C rri l , C li co DD XHi IN) w > Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 1 APPENDIX B Reporting Requirements and Definitions with codes ver 2/20/07 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained(whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph,the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report(due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report#2: Permit Deviation Report(must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix,the probable cause of Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 2 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 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually,as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 3 Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include,at a minimum,the methods and means required in the permit. If necessary,the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject,to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. 1 For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 4 Startup, Shutdown, Malfunctions and Emergencies Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown,and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP)means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 Monitoring and Permit Deviation Report- Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: DCP Operating Company, LP— Spindle Natural Gas Processing Plant OPERATING PERMIT NO: 95OPWE039 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Devi ons X Ma�3ctton/Eme ertc3 DeviationndiIion P t Cod Unit ID unit Descriptor YES7,51'1 iii} C-136 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-137 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-138 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 IIP C-147 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-139 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-140 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-141 Waukesha Model L-7042 GSI NG Compressor Engine, 1232 HP C-217 Caterpillar Model G-342 Residue Gas Compressor Engine,230 HP C-153 Waukesha Model L-7042 GU NG Compressor Engine, 1000 HP C-215 Superior Ajax 8SGTB Residue Gas Compressor Engine, 1215 HP C-212 Superior Model 6G825 Residue Gas Compressor Engine,600 HP P178 Natural Gas Dehydration System;using triethylene glycol Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 .,,:Deviations Matmetimenc 4-6104.004-i34, Durt -. Z erio[I _ ode i Yom ' . F Umt nit ertption S P179 Natural Gas Fired Heater for heating hot oil;Serial No.J87426 P181 Gas Plant Fugitive Emission P182 Condensate Truck Load-out C-221 Superior Model 6G825 NG Compressor Engine,474 1-IP General Conditions Insignificant Activities 'See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries,as appropriate 1 = Standard: When the requirement is an emission limit or standard 2 =Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 Monitoring and Permit Deviation Report - Part II FACILITY NAME: DCP Operating Company, LP— Spindle Natural Gas Processing Plant OPERATING PERMIT NO: 95OPWE039 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date &time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported(if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT)Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to J. Garcia, APCD Deviation Code Division Code QA: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Monitoring and Permit Deviation Report-Part III REPORT CERTIFICATION SOURCE NAME: DCP Operating Company, LP—Spindle Natural Gas Processing Plant FACILITY IDENTIFICATION NUMBER: 123/0015 PERMIT NUMBER: 95OPWE039 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18- 1-501(6), C.R.S., makes any false material statement, representation,or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page 1 APPENDIX C Required Format for Annual Compliance Certification Reports Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: DCP Operating Company, LP—Spindle Natural Gas Processing Plant OPERATING PERMIT NO: 95OPWE039 REPORTING PERIOD: I. Facility Status During the entire reporting period,this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Deviations Monitoring was cotttpliance Urttt Ott Des ption �P°Reported � Previous I Current Continuo s C-136 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-137 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-138 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-147 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-139 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-140 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-141 Waukesha L-7042 GSI NG Compressor Engine, 1232 HP C-217 Caterpillar G-342 Residue Gas Compressor Engine,230 HP C-153 Waukesha L-7042 GU NG Compressor Engine, 1000 HP C-215 Superior Ajax 8SGTB Residue Gas Compressor Engine, 1215 HP Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page 2 Monttotxng W np1ta I3ev1at S Method Per Cantfttu{FU 3Jtt IU Ilurt3escriPtt = rtt 2 petx� � mt#�ent2� 1'r vtaus • turettt S �O .; tntto � t 'tt tt; C-212 Superior 6G825 Residue Gas Compressor Engine,600 HP P178 Natural Gas Dehydration System;using triethylene glycol P179 Natural Gas Fired Heater for heating hot oil P181 Gas Plant Fugitive Emissions P182 Condensate Truck Load-out C-221 Superior 6G825 NG Compressor Engine,474 HP General Conditions Insignificant Activities If deviations were noted in a previous deviation report,put an"X"under"previous". If deviations were noted in the current deviation report(i.e.for the last six months of the annual reporting period),put an"X"under"current". Mark both columns if both apply. 2 Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark "no"and attach additional information/explanation. 'Note whether the compliance status with each term and condition provided was continuous or intermittent. "Intermittent Compliance"can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to.provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore,if a source 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. Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix C Required Format for Annual Compliance Certification Report Page 3 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r)of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 1 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP-42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act(CAAA= Clean Air Act Amendments) CCR- Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet(SCF = Standard Cubic Feet) CFR- Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate (MMBtu/hr) FR- Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HP - Horsepower HP-HR- Horsepower Hour(G/HP-HR=Grams per Horsepower Hour) LAER- Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf- Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx- Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PM 10 - Particulate Matter Under 10 Microns Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms _ Page 2 PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT- Reasonably Available Control Technology SCC - Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 1 APPENDIX F NSPS KKK Example Report Format DISCLAIMER: This is only an example report and does not cover all possible KKK requirements. NSPS SUBPART KKK STANDARDS OF PERFORMANCE FOR EQUIPMENT LEAKS OF VOC FROM ONSHORE NATURAL GAS PROCESSING PLANTS Acme Gas Processing FID: 9991234 Permit#: 93OPXX999 September 1, 1996 Determination of reporting requirements for 93OPXX999 under Subpart KKK Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. Note that any non-applicability determinations under the provisions of 60.630 must be accompanied by a detailed explanation including copies of any relevant test results or any other supporting documentation. Determination of NSPS KKK requirements: 60.630 (a) (1) Applies to Acme plant since it is an onshore natural gas processing plant. (2) Applies to Acme plant since compressors are in VOC service and wet gas service. (3) Applies to Acme Plant since the group of equipment, excluding compressors, is in wet gas service. (b) Applies to Acme since the plant was placed into operation after January 20, 1984. (e) Applies to the compressor station and glycol dehydration units since they are located at the plant. 60.632 (a) Subject to the provisions of this subpart and shall comply as soon as practical, but no later than 180 days after initial startup. 60.482-1 Subject to parts (a) and (b) requiring that compliance be demonstrated within 180 days of equipment initial startup. This compliance shall be determined by a review of records and reports, performance test results, and inspection Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 2 methods and procedures of 60.485. Part (d) applies but ACME has no equipment in vacuum service. 60.482-2 Exempt under 60.633 (d). 60.482-3 Exempt under 60.633(f). 60.482-4 Applies but superseded by 60.633 (b). 60.482-5 Exempt under 60.633(c). 60.482-6 Does Not Apply. ACME does not have any open-ended lines. 60.582-7 Applies to this facility. Valves shall be monitored monthly by methods in 485(b)-(e). An instrument reading of 10,000 ppm or greater indicates a leak. Any valve for which a leak hasn't been detected for 2 successive months will be monitored the first month of every quarter until a leak is detected. After detection of a leak, the valve shall be monitored monthly until a leak is not detected for 2 successive months. When a leak is detected, it shall be repaired as soon as practical but no later than 15 calendar days after detection. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. 60.482-8 Does Not Apply. ACME has no equipment in heavy liquid service or pressure relief devices in light liquid service. 60.482-9 Applies to this facility. Delays of equipment repair allowed as specified under this subpart. 60.482-10 Does Not Apply. ACME has no closed vent systems or control devices. 60.483 Alternative Standards Acme has elected not to use the provisions of 60.483-1 which allows alternative standards for valves by complying with an allowable percentage of leaking valves of equal to or less than 2.0 percent. Acme has elected not to use the provisions of 60.483-2 which allows alternative standards for valves by skipping period(s) of leak detection and repair. 60.633 Exceptions (b) (1) Each pressure relief device shall be monitored quarterly and within 5 days after each pressure relief to detect leaks as per 60.485(b). (2) An instrument reading of 10,000 ppm or greater is a leak. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 3 (3) (i) When a leak is detected, it shall be repaired as soon as practical, but no later than 15 calendar days after detection. (ii) A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. (4) Does Not Apply. Facility is staffed full-time. (c) Applies to this facility. As previously stated, ACME is exempt from the requirements of 60.482-5. (d) Applies, ACME has a design capacity to process 5 million standard cubic feet per day of field gas (less than the 10 mmscf/day limit). As such, ACME is exempt from the routine monitoring requirements of 60.482-2(a)(1) and 60.482-7(a), and paragraph (b)(1) of this section. (e) Does Not Apply. Facility not in the Alaskan North Slope. (f) Applies to this facility. All compressors are in wet gas service and are therefore exempt from the requirements of 60.482-3. (g) Does Not Apply. ACME has no flaring equipment. (h) Does Not Apply. ACME has no equipment in heavy liquid service. 60.634 Alternative Means of Emission Limitation Acme has not elected to use the provisions of 60.634 which allows an alternative means of emission limitation if approved by the Administrator and published in the Federal Register. 60.635 Record keeping requirements (a) Applies to this facility. Subject to the requirements of 60.486. 60.486 Record keeping requirements 60.482-7 - When each leak is detected as specified this provisions, the requirements of 60.486(b) and 60.486(c) apply. 60.482-1 to 60.482-10 - All equipment subject to these provisions are subject to the provisions of 60.486(e). 60.482-7(g), (h)- All valves subject to these provisions are subject to the requirements of 60.486(f). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 4 60.486(j)- Information and data used to demonstrate that a piece of equipment is not in VOC service shall be recorded in a log that is kept in a readily accessible location. 60.635(b)(1) When a leak has been detected a weatherproof marker shall be placed on the pressure relief device. (b)(2) When each leak is detected, the following information shall be kept for at least 2 years in the operational log (i) the identification number of the instrument used to identify the leak the operator identification number and the identification number of the equipment responsible for the leak. (ii) the date the leak was detected and the dates of repair (iii) the repair methods used to repair the leak (iv) if the leak was above 10,000 ppm (v) if the repair was delayed and how many days (vi) signature of the owner or operator identifying and repairing the leak (vii) was the leak repaired in less than 15 days after the discovery of the leak and if it was not the reason for the delay. (viii) the dates of process unit shutdown that occurred to repair the leak (ix) the date of successful repair of the leak (x) the list of equipment identification numbers for no detectable emissions 60.636 Reporting requirements (a) Applies to this facility. Subject to the reporting requirements of 60.487. (b) Operator shall include the following information on a semi annual report: (1)-(4) Number of pressure relief devices subject to the requirements of 60.636(b) (e) (1) Number of pressure relief devices for which leaks were detected (c) (2) Number of pressure relief devices for which leaks were not repaired Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 5 60.487 Reporting requirements (a) Each owner or operator subject to the provisions of Subpart VV shall submit semiannual reports beginning 6 months after the initial startup date. (b) The initial report to the administrator shall include the process unit identification and the number of equipment subject to 60.482-7, 60.482-2, 60.482-3. (c) All semiannual reports shall include the following information: (1) Process unit identification (2) For each month: (i) Number of valves for which leaks were detected under 60.482-7. (ii) Number of valves for which leaks were not repaired as required under 60.482-7. (iii-vi) Exempt under various provisions above (vii) The facts that explain each delay and repair and, where appropriate, why a process unit shutdown was technically infeasible. (3) Dates of process unit shutdowns within the semiannual reporting period. (4) Any new items not included in the initial list of subject equipment. (d) If electing to comply with alternative monitoring, the administrator shall be notified of the standard selected 90 days prior to implementation. (e) All performance tests shall be reported. The administrator shall be notified of any initial performance tests 30 days prior to testing. CONCLUSION OF FINDINGS In general,ACME is subject to the general monitoring for valves in gas/vapor service and pressure relief devices. Valves will be monitored monthly for leaks(readings above 10,000 ppm)except that 2 successive months without leaks shall allow the monitoring to be quarterly. Pressure relief devices will be monitored quarterly for leaks (readings above 10,000 ppm)and within 5 days after each pressure release. All leaking equipment will be marked with a weatherproof tag. All leaks will be repaired no later than 15 days after detection. A first attempt at repair shall be made no later than 5 calendar days after leak detection. Any changes in equipment which triggers additional requirements will be reported no later than the semi-annual report. Records shall be maintained on site with the information as described under 60.635 and 60.486, above. Reports shall contain the information described under 60.636 and 60.487, above. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix F NSPS KKK Example Report Format Page 6 Therefore the following forms shall be submitted on a semi annual basis beginning September 1, 1997 for compliance under NSPS KKK. The form shall also report an estimated volume of VOC emissions which were associated with the leak, or failure of any pressure relief device reported on the log books, or in the reporting form as attached. Acme does keep records of the testing and replacement of all pressure relief valves and a copy of these records is attached for review. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 1 APPENDIX G Permit Modifications SECTION DATE OF NUMBER, DESCRIPTION OF REVISION REVISION CONDITION NUMBER 01/22/2018 Cover Page Changed company name per request received 3/2/2017 Page Before Table Changed company name,RO contact information and facility contact information per request of Contents received 3/2/2017 Section I,Condition Removed reference to condensate storage tanks(AIRS 067)per cancellation request received 1.1 5/4/2015,removed reference to Spindle CIG Booster Station and updated permitted activities per source correspondence received 1/17/2018 Updated CAM applicability to NOx emissions only for all Waukesha L7042 GSI engines.Based on Section I,Condition the minor modification submitted on 11/13/2017 and source correspondence received 1/17/2018, 5 emissions of NOx only for these engines are above the major source threshold.CAM is not applicable to emissions of CO,which are below the major source threshold for each engine Updated engine serial numbers for C-138(AIRS 053),C-141 (AIRS 057),C-153(AIRS 060),C- Section I,Condition 215(AIRS 061)and C-147(AIRS 081)replaced via AOS provisions,removed condensate storage 6.1 Table tank entry(AIRS 067)per cancellation request received 5/4/2015,removed dehydration unit pressure and temperature references since these are not permitted limitations,pursuant to source correspondence received 1/17/2018 Section II, Created new table identifying new VOC,NOx and CO emission limitations and emission factors Condition 1 Table for C-140(AIRS 056)per 11/13/2017 minor modification Updated CAM applicability to NOx emissions only for all Waukesha L7042 GSI engines.Based on Section II, the minor modification submitted on 11/13/2017 and source correspondence received 1/17/2018, Condition 1.10 emissions of NOx only for these engines are above the major source threshold.CAM is not applicable to emissions of CO,which are below the major source threshold for each engine Section II, Updated table with new VOC,NOx and CO emission limitations and emission factors for C-215 Condition 3 Table (AIRS 061)per 11/13/2017 minor modification Section II,Previous Condition 8 Removed condensate storage tank(AIRS 067)condition per cancellation request received 5/4/2015 Appendix B Changed company name per request received 3/2/2017,removed condensate storage tank(AIRS 067)entry per cancellation request received 5/4/2015 Appendix C Changed company name per request received 3/2/2017,removed condensate storage tank(AIRS 067)entry per cancellation request received 5/4/2015 Updated CAM applicability to NOx emissions only for all Waukesha L7042 GSI engines.Based on Appendix I the minor modification submitted on 11/13/2017 and source correspondence received 1/17/2018, emissions of NOx only for these engines are above the major source threshold.CAM is not applicable to emissions of CO,which are below the major source threshold for each engine Throughout Updated all engine identifiers to C-XXX,updated emission calculations to reflect fuel gas consumption on a monthly basis per source correspondence received 1/17/2018 10/15/2018 Section I,Condition 4 AOS Table Updated horsepower of engines C-139 and C-140 per minor modification received 7/2/2018. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 2 SECTION DATE OF NUMBER, DESCRIPTION OF REVISION REVISION CONDITION NUMBER Section I,Condition Updated serial number for engine C-139 and horsepower of engines C-139 and C-140 per minor 6.1 Table modification received 7/2/2018. Section II, Updated horsepower,throughput limitations and NOx,CO and VOC emission limitations for Condition 1 Table engines C-139 and C-140 per minor modification received 7/2/2018.Updated MACT ZZZZ condition description in tables for all Condition 1 engines. Section II, Updated MACT ZZZZ requirements to reflect the remote status of these engines per minor Conditions 1.7& modification received 7/2/2018.Re-formatted condition to achieve consistency across Conditions 1.8 1-3 MACT ZZZZ requirements for engines. Section II, Updated MACT ZZZZ requirements to reflect updated rule citations per minor modification Conditions 2.7& received 7/2/2018.Re-formatted condition to achieve consistency across Conditions 1-3 MACT 2.8 ZZZZ requirements for engines. Section II, Condition 3 Table Updated MACT ZZZZ condition description in table for engine. Section II, Updated MACT ZZZZ requirements to reflect the remote status of this engine per minor Conditions 3.7& modification received 7/2/2018.Re-formatted condition to achieve consistency across Conditions 3.8 1-3 MACT ZZZZ requirements for engines. Section III Permit Updated horsepower of engines C-139 and C-140 per minor modification received 7/2/2018. Shield Table Updated horsepower of engine C-147 per source correspondence received 8/23/2018. Appendix B Point Summary Table Updated horsepower of engines C-139 and C-140 per minor modification received 7/2/2018. Appendix C Point Summary Table Updated horsepower of engines C-139 and C-140 per minor modification received 7/2/2018. Appendix I CAM Updated horsepower and NOx emission limitations for engines C-139 and C-140 per minor Plan modification received 7/2/2018. XX/XX/XXXX Page After Cover Updated responsible official contact information,pursuant to source comments received 6/3/2020. Page Updated list of state-only enforceable requirements to include reference to the Colorado Regulation Section I,Condition No.7,Part E,Section I.D.2.engine requirements,which are state-only enforceable and were 1.4 included in the operating permit as requested in the permit modification applications received 1/31/2020 and 4/27/2020,and source comments received 6/3/2020. Updated Prevention of Significant Deterioration(PSD)language to remove NOx.Pursuant to the Section I,Condition changes requested in the permit modification applications received 1/31/2020 and 4/27/2020,this 2.1 facility no longer has the potential to emit NOx in excess of 250 tons/year.As such,this facility is no longer considered to be a major stationary source of NOx emissions.Note,however,this facility is still classified as a major stationary source with respect to CO emissions. Updated serial number for engines C-136,C-137 and C-140,pursuant to the most recent alternative Section I,Condition operating scenarios(AOS)executed on 1/26/2020,6/25/2019 and 5/8/2020 respectively,as 6 Table requested in the permit modification applications received 1/31/2020 and 4/27/2020,and the permanent AOS application received 5/22/2020. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 3 SECTION DATE OF NUMBER, DESCRIPTION OF REVISION REVISION CONDITION NUMBER Updated NOx,CO and VOC emission limitations and factors for engine C-136 and the NOx Section II, emission limitations and factors for engines C-137 and C-141,based on the permit modification Condition 1 Tables applications received on 1/31/2020 and 4/27/2020.Included row to reference the Colorado Regulation No.7 requirements applicable to all engines,as requested in the permit modification applications received 1/31/2020 and 4/27/2020,and source comments received 6/3/2020. Section II, Updated fuel allocation calculation to reflect that a facility-wide fuel meter is used to allocate fuel, Conditions 1.3,2.3 as requested in source comments received 6/3/2020.As such,the denominator of this equation must and 3.3 take into account all other fuel users at the facility(e.g.,the hot oil heater,pilot gas,etc.)to properly allocate fuel among the engines. Section II, Updated Btu content verification condition to require that the higher heating value,instead of the Conditions 1.4,2.4 lower heating value,be used to calculate emissions,as requested in source comments received and 3.4 6/3/2020. Created new condition to include the applicable Colorado Regulation No.7 requirements for engines operating in the state of Colorado,as requested in the permit modification applications received 1/31/2020 and 4/27/2020,and source comments received 6/3/2020. These new Section II, requirements include emission standards for NOx,CO and VOC(Reg.7,Part E,Section I.D.2.)and Condition 1.11 control device installation(Reg.7,Part E,Section I.D.3.).Note that each engine is required to conduct portable analyzer testing in accordance with the previous version of the operating permit (which may be used to monitor compliance against the emission standards)and is equipped with an NSCR and AFR pursuant Reg.7 standards previously included in the operating permit. Updated VOC emission limit and monitoring frequency pursuant to minor permit modification Section II, application received on 1/31/2020 and source comments received 6/3/2020.Updated table to refer Condition 6 Table to new Colorado Regulation No.7 requirements for fugitive emissions at natural gas processing plants located in the 8 hour ozone control area,NSPS KKK and NSPS OOOO requirements.The NSPS OOOO requirements are applicable to this facility pursuant to Colorado Regulation No.7. Added heavy liquid emission factors from EPA-453/R-95-017 1995 Protocol for Equipment Leak Emissions Estimates,updated control factors to reflect the increased LDAR monitoring frequency pursuant to NSPS OOOO,as set forth under EPA-453/R-95-017,and updated component count Section II, table pursuant to hard count conducted June 2019,which includes a 20%buffer,and an updated Condition 6.1 extended gas analysis,as requested in the minor permit modification application received 1/31/2020.Note that control factors for heavy liquid components were not assessed in EPA-453/R- 95-017.As such,the previously approved control factors for the Spindle Natural Gas Processing Plant were retained for the heavy liquid components only. Incorporated Colorado Regulation No.7,Part D,Section I.G.fugitive emissions requirements for natural gas processing plants operating in the 8 hour ozone control area.This section requires the facility to comply with NSPS OOOO LDAR requirements,regardless of facility date of Section II, construction(Reg.7,Part D,Section I.G.1.).Because the Spindle Natural Gas Processing Plant was Condition 6.2 constructed prior to 1/1/2018,this facility is required to comply with these requirements as of 1/1/2019(Reg.7,Part D,Section I.G.3.).Note that this requirement was not yet promulgated at the time of the operating permit renewal on 7/1/2012,but is now being incorporated as requested in the minor permit modification application received 1/31/2020. Updated NSPS KKK language as requested in the minor permit modification application received 1/31/2020.Because this facility must now comply with NSPS OOOO,compliance with NSPS KKK Section II, may be presumed for all components except for compressors,provided the requirements of NSPS Condition 6.3 OOOO are met.The NSPS KKK and NSPS OOOO requirements for compressors are very different and as such,one set of requirements is not obviously more stringent than the other.Therefore,for compressors,compliance with NSPS KKK cannot be presumed. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix G Permit Modifications Page 4 SECTION DATE OF NUMBER, DESCRIPTION OF REVISION REVISION CONDITION NUMBER Incorporated NSPS OOOO fugitive emissions requirements at natural gas processing plants,as required by Colorado Regulation No.7,Part D,Section I.G.,and as requested in the minor permit modification application received 1/31/2020.Note that the Spindle Natural Gas Processing Plant Section II. has not undergone construction,modification or reconstruction between 8/23/2011 and 9/18/2015 Condition 6.4 such that the requirements of NSPS OOOO have been triggered,thereby subjecting the facility to this regulation outright.This facility is only subject to the requirements of NSPS OOOO pursuant to Colorado Regulation No.7,Part D,Section I.G.,which mandates compliance with the LDAR requirements of this rule. Updated the NSPS Subpart A general provisions to include references to notification and Section II, recordkeeping(§60.7,as requested in the minor permit modification application received Condition 6.5 1/31/2020),incorporations by reference(§60.17)and general notifications and reporting requirements(§60.19),as these sections are applicable to the NSPS fugitive emissions rules,but were not included in the previous version of the operating permit. Appendix A, Updated facility plot plan to the version submitted with the permit modification application Condition 3 received 4/27/2020. Appendix I, Updated the CAM-applicable emission limitations for engines C-136,C-137 and C-141 to reflect Condition I.b. the newly permitted NOx emission limitations for each of these engines,as requested in the permit modification applications received 1/31/2020 and 4/27/2020. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 1 APPENDIX H Engine AOS Applicability Reports ver 12/10/08 Note: A MS Word version of this Appendix can be found at: https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting-forms DISCLAIMER: These are only example reports and do not cover all possible requirements. Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 2 Engine AOS Applicability Report Certification Language All information for the Applicability Reports must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. or 2) for Construction and General Permits, the person legally authorized to act on behalf of the source. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s) shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, section I.B.9., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s) referenced in the Report(s) until such time as the Permit is revised to reflect the new requirements. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1- 501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX • Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 3 Colorado Regulation No. 7 Sections XVI and )(VILE DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Acme Gas Processing Source ID: 999/1234/001 Permit#: 93OPXX999 Date: October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Construction date: July 1, 2007 Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, § XVI ❑ Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. ❑ Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, §XVII.E ❑ Does not apply to this engine. Engine does not have a maximum horsepower greater than 100 or the construction or relocation date precedes the applicability dates. ❑ Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): 2.0 CO (g/hp-hr): 4.0 VOC (g/hp-hr): 1.0 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 4 Max Engine Construction or Emission Standards in g/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 5 NSPS JJJJ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible JJJJ requirements. Note that as of September 1, 2008 that the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6,Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source,subject to the requirements of NSPS JJJJ. NSPS Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Company: Acme Gas Processing Source ID: 999/1234/001 Permit#: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. ❑ NSPS JJJJ does not apply to this engine. ❑ NSPS JJJJ does apply to this engine. Note:Using the format below,the source must submit to the Division an analysis of all of the NSPS JJJJ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical engine that is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 6 Determination of NSPS JJJJ requirements: 60.4230 Applicability (a)(4)(i) Applies to this engine since it is a rich burn engine,greater than 500 HP,with a manufacture date after July 1, 2007. 60.4233 Emission Standards for Owners and Operators (e) Owners and operators of stationary SI ICE with a maximum engine power greater than 100 HP must comply with the standards in Table 1. Non-Emergency SI,Natural Gas, HP>500, Manufactured after 7/1/2007 NOX 2.0 g/HP-hr or 160 ppmvd@15% O2 CO 4.0 g/HP-hr or 540 ppmvd@15% O2 VOC 1.0 g/HP-hr or 86 ppmvd@l5% O2 Other Requirements for Owners and Operators 60.4234 Emission standards must be met for the lifetime of the engine. 60.4235 N/A - Sulfur content of gasoline. 60.4236 N/A (for now) - After July 1, 2009 owners and operators may not install engines with a power rating > 500HP that do not meet the emissions standards in 60.4230. 60.4237 N/A - Emergency Engines. 60.4238- 60.4242 Compliance Requirements for Manufacturers—(Not Applicable) 60.4243 Compliance Requirements for Owners and Operators (b)(2)(ii) To maintain compliance with the emission limits in 60.4233, owners of SI ICE> 500HP must: • Keep a maintenance plan; • Keep records of conducted maintenance; • Maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions; • Conduct an initial performance test; and • Conduct subsequent performance tests every 8,760 hours or every three years, which ever comes first, in order to demonstrate compliance with the emission limits. (g) Air to fuel ratio controllers (AFRCs) must be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. 60.4244 Testing Requirements for Owners and Operators Operating Permit Number: 950PWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 7 (a) Each performance test must be conducted within 10% of the highest achievable load and must comply with the testing requirements listed in 60.8 and Table 2 of NSPS JJJJ. (b) Performance tests may not be conducted during periods of startup,shutdown, or malfunction,as specified in 60.8(c). If the engine is non-operational when a performance test is due, the engine does not need to be started up just to test it, but will need to be tested immediately upon startup. (c) Three separate test runs must be conducted for each performance test as specified by 60.8(f). Each run must be within 10% of max load and be at least 1 hour in duration. (d) To determine compliance with the NOR, CO, and VOC mass per unit output emission limitations, the measured concentration must be converted using the equations outlined in this section of NSPS JJJJ. 60.4245 Notification, Reports, and Records for Owners and Operators (a) Owners of all stationary SI ICE must keep records of the following: (1) All notifications submitted to comply with this subpart; (2) Maintenance conducted on the engine; (3) N/A -Manufacturer information for certified engines, and (4) Documentation that shows non-certified engines are in compliance with the emission standards. (b) N/A—For emergency engines only. (c) Owners of non-certified engines> 500HP must submit an initial notification as required in 60.7(a)(1) which includes the following information: (1) Name and address of the owner or operator; (2) The address of the affected source; (3) Engine information including make, model, engine family, serial number, model year, maximum engine power, and engine displacement; (4) Emission control equipment; and (5) Fuel used. CONCLUSION OF FINDINGS (EXAMPLE ONLY) In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non-selective catalytic converter(NSCR). These emission rates will be met throughout the Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 8 life of the engine. A maintenance plan will be kept and all maintenance activities will be recorded. Compliance with the emission limits will be confirmed by the initial performance tests,which shall be conducted following the procedures outlined in 60.4244. Copies of performance test results will be submitted within 60 days of the completion of each test. Since this is an uncertified engine, an initial notification will be submitted including all of the requested information in 40.4245 within 30 days of startup. ACME will keep records of all compliance related materials. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 9 MACT ZZZZ Area Source Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 999/1234/001 Permit#: 93OPXX999 Date: October 1, 2008 Manufacturer: Best Engine Company Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. ❑ MACT ZZZZ does not apply to this engine. ❑ MACT ZZZZ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the area source MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at an area source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at an area source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? (c) A new or reconstructed stationary RICE located at an area source of HAP emissions that is subject to 40 CFR Part 60, must meet the requirements of this part by meeting the requirements of 40 CFR Part 60 subpart JJJJ. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to NSPS JJJJ, no additional requirements apply under MACT ZZZZ. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 10 MACT ZZZZ Major Source Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 999/1234/001 Permit#: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Rich Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. ❑ MACT ZZZZ does not apply to this engine. ❑ MACT ZZZZ does apply to this engine. Note: Using the format below,the source must submit to the Division an analysis of all of the major source MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at a major source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at a major source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? This subpart covers Acme's new stationary reciprocating internal combustion engine. 63.6595 When do I have to comply with this Subpart? (a)(5) The engine must comply with the applicable emission limitations and operating limitations upon startup. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 11 63.6600 Emission and operating limitations for RICE site rated at more than 500 hp (a) The engine is subject to the emission limits in table la and the operating limits in table lb. ACME will meet the emission limitations by reducing formaldehyde emissions by 76 percent and will maintain the catalyst such that the pressure drop does not change by more than 2 inches of H2O at 100 % load plus or minus 10 percent from the pressure drop measured during the initial performance test and will maintain the temperature of the engine exhaust so that the catalyst inlet temperature is greater than or equal to 750°F and less than or equal to 1250 °F. The engine will be equipped with non-selective catalytic reduction and an air fuel controller to meet the emission limitations. 63.6601 & 63.6611 Requirements for 4SLB engines between 250 and 200 hp These requirements do not apply. 63.6605 General Requirements (a) The engine will comply with the emission and operating limitations at all times, except during periods of startup, shutdown and malfunction (SSM) (b) The engine, including air pollution control and monitoring equipment shall be operating in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during SSM. 63.6610 Initial performance test (a) the performance tests specified in Table 4 (select sampling port and measure O2, moisture and formaldehyde at inlet and outlet of the control device) shall be conducted within 180 days of startup. (b) & (c) not applicable construction did not commence between 12/19/02 and 6/15/04. (d) previous performance tests have not been conducted on this unit within two years,therefore, this provision does not apply. 63.6615 Subsequent performance tests Subsequent tests will be conducted as specified in Table 3. No additional testing is required for 4SRB engines meeting the formaldehyde percent reduction requirements. 63.6620 Performance test procedures (b) tests must be conducted at 100 % load plus or minus 10% (c) tests may not be conducted during periods of SSM. (d) must conduct three 1-hr test runs (e) equation (e)(1) shall be used to determine compliance with the percent reduction requirement. (f), (g) & (h) Not applicable (i) engine load during test shall be determined as specified in this paragraph. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 12 63.6625 Monitoring, installation, operation and maintenance requirements (a), (c) & (d) Not applicable (b) a continuous parameter monitoring system(CPMS)shall be installed to measure the catalyst inlet temperature. The CPMS will meet the requirements in § 63.8 63.6630 Demonstrating initial compliance (a) initial compliance shall be determined in accordance with table 5 (initial performance test must indicate formaldehyde reduction of 76 percent or more, a CPMS must be installed to measure inlet temperature of the catalyst and the pressure drop and catalyst inlet temperature must be recorded during the initial performance test). (b) pressure differential will be established during the initial performance test. (c) Notification of compliance status will be submitted and will contain the results of the initial compliance demonstration. 63.6635 Monitoring to demonstrate continuous compliance (b) except for monitor malfunctions, associated repairs, and required QA/QC activities monitoring must be continuous at all time the engine is operating. (c) data recorded during monitoring malfunctions, associated repairs and required QA/QC activities must not be used in data averages and calculations to report operating levels, however, all the valid data collected during other periods shall be used. 63.6640 Demonstrating continuous compliance (a) continuous compliance will be demonstrated as specified in table 6 (collect catalyst inlet temperature data, reduce that data to 4-hr rolling average and maintain the 4-hr rolling averages to within the operating limitation and measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop meets the operating limitation. (b) deviations from the emission and operating limitations must be reported per § 63.6550. If catalyst is changed the operating parameters established during the initial performance test must be re-established. When operating parameters re-established a performance test must also be conducted. 63.6645 Notifications (a) Submit notifications in §§ 63.7(b) & (c), 63.8(e), (0(4) and (0(6), 63.9(b) thru (e) & (g) & (h)that apply by dates specified. (b) Not applicable. Acme unit started after effective dated for Subpart ZZZZ. (c) Submit initial notification within 120 days after becoming subject to Subpart ZZZZ. (d)thru (0 Not applicable. Acme engine greater than 500 hp and subject to requirements in Subpart ZZZZ. (g) & (h) Submit notification of intent to conduct performance test and notification of compliance status. 63.6650 Reports Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 13 (a) Submit reports required by table 7 (compliance report and SSM reports (if actions inconsistent with SSM plan) (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with title v reports (c) Compliance reports to contain the following information: company name and address, statement by responsible official certifying accuracy, date of report and beginning and end of reporting period, if SSM the information in 63.10(d)(5)(i), if no deviations a statement saying that, if no periods when CPMS out of control a statement saying that. (d) Not applicable, using CPMS (e) For each deviation the information in (e)(1)thru(e)(12) shall be provided. (f) Applicable. Compliance reports are submitted with title v reports. Compliance reports under Subpart ZZZZ include all necessary info for title v deviation report with respect to Subpart ZZZZ requirements. (g) Not applicable. Acme engine not firing landfill or digester gas. 63.6655 Recordkeeping (a) Retain records as follows: copy of each notification and report(including all documentation supporting any initial notification or notification of compliance status), records in 63.6(e)(iii)thru (v) related to SSM, and records of performance tests and evaluations. (b) CPMS records including records in 63.10(b)(2)(vi) thru (xi), previous versions of the performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the relative accuracy test for CPMS as required by 63.8(f)(6)(i). (c) Not applicable. Acme engine not firing landfill or digester gas. (d) Will keep records required in Table 6 (monthly pressure drop readings, 4-hr averages of catalyst inlet temperature) to show continuous compliance with emission and operating limits. 63.6660 Form and length of records (a) records must be in a form suitable and readily available for expeditions review (b) records must be retained for five years (c) records must be retained on-site for first 2 years, may be retained off-site for the remaining 3 years 63.6665 General Provisions This engine must comply with the general provisions as indicated in Table 8. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to the requirements of MACT Subpart ZZZZ. The engine will be installed with a non-selective catalyst to meet the formaldehyde reduction requirement of 76% or more. An initial performance test will be conducted within 180 days of startup to demonstrate compliance with the formaldehyde percent reduction requirement. During the initial performance test,the pressure drop across the catalyst will be measured. A CPMS will be installed to measure the catalyst inlet temperature. Continuous compliance will be demonstrated Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix H Engine AOS Applicability Reports Page 14 by keeping the 4-hr rolling averages of catalyst inlet temperature within the operating limitations and recording the pressure drop across the catalyst monthly and demonstrating that the pressure drop is within the operating limitation. Records, notifications and reports will be submitted as required. To that end required reports and notifications include initial notification, notice of intent to conduct performance test, notification of compliance status, SSM reports (if required) and semi-annual compliance reports. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 1 APPENDIX I Compliance Assurance Monitoring Plan Background a. Emission Unit Description: Eight(8) Waukesha Model L-7042 GSI Natural Gas Fired Internal Combustion Engines, turbocharged, 4-cycle, Standard Rich Burn, powering a natural gas compressor. Engine ratings for each engine are as follows: Facility ID AIRS ID Site Rating C-I36 051 1232 HP C-137 052 1232 HP C-138 053 1232 HP C-147 081 1232 HP C-139 055 1232 HP C-140 056 1232 HP C-141 057 1232 HP C-153 060 1000 HP b. Applicable Regulation, Emission Limit, Monitoring Requirements: Engine C-136 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 11.9 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engines C-137, C-141 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 24.0 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 2 Engine C-140 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 11.9 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine C-138 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 23.8 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine C-147 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 23.8 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine C-139 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 23.8 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engine C-153 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 19.3 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature c. Control Technology: Each engine is equipped with an Air/Fuel Ratio controller and Non-Selective Catalytic Reduction (NSCR)to control NOx emissions. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 3 IL Monitoring Approach Indicator 1 r Indicator 2 I. Indicator Pressure Drop Across the Catalyst Catalyst Inlet Temperature Measurement Approach Pressure drop across the catalyst beds is The temperature of the exhaust gas into the measured using a differential pressure catalyst will be measured using an in line gauge. thermocouple. II. Indicator Range Pressure drop shall be within+2 inches of The exhaust gas into the catalyst shall be water from the pressure drop baseline value greater than or equal to 750°F and less than established as specified Condition or equal to 1250°F. 1.10.1.1.a. Excursions trigger the permitee to Excursions trigger the permittee to investigate the engine performance and investigate the catalyst performance and make any repairs or adjustments necessary. make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded Any adjustments or repairs shall be recorded in the log to be made available to the in the log to be made available to the Division upon request. Division upon request. III. Performance Criteria a. Data The pressure drop across the catalyst is The catalyst inlet temperature is measured Representativeness measured at the catalyst inlet and outlet. upstream of the catalyst. The minimum accuracy is+/-5°F b. Verification of N/A Guarantee from the thermocouple Operational Status manufacturer. c. QA/QC Practices and Pressure gauges shall be calibrated and Thermocouples shall be calibrated and Criteria replaced in accordance with manufacturer's replaced in accordance with manufacturer's recommendations. recommendations. d. Monitoring Frequency Monthly Daily. e. Data Collection The pressure drop shall be recorded monthly The catalyst inlet temperature shall be Procedures in a log to be made available to the Division recorded daily in a log to be made available upon request. to the Division upon request. f. Averaging Period None None III. Justification a. Background: The pollutant specific emission units are eight (8) internal combustion engines used to drive compressors. Each engine is equipped with a non-selective catalytic reduction unit to control NOx emissions. The non-selective reduction catalyst reduces NOx emissions to nitrogen and water. b. Rational for Selection of Performance Indicators: Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page 4 The Division selected the pressure drop across the catalyst as it is an indicator of the catalyst performance. A change in the pressure drop across the catalyst can indicate if the catalyst is damaged or fouled, which would decrease catalyst performance. The inlet temperature to the catalyst was approved as an indicator since the temperature is important for the proper activation of the catalyst. The final RICE MACT requires monitoring of inlet temperature to the catalyst and the pressure drop across the catalyst. The CAM rule specifies that monitoring required for a MACT standard is presumptively acceptable monitoring,provided the monitoring is applicable to the performance of the control device (40 CFR Part 64 § 64.4(b)(4)). Since the MACT monitoring is for the same control device, the Division considers that the indicators are presumptively acceptable. c. Rational for Selection of Indicator Ranges: The indicator range for the catalyst inlet temperature and the pressure drop cross the catalyst are the same ranges as specified in the final RICE MACT. Since the monitoring is presumptively acceptable,the Division considers that the indicator range is also presumptively acceptable. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: XX/XX/XXXX DCP Midstream C:16.27—=1 370 17th St.,Suite 2500 Denver,CO 80202 (303)605-2029 Midstream.. awwv.dcpmidstream.com January 31, 2020 Hand Delivered Colorado Department of Public Health and Environment Air Pollution Control Division ATTN: Elie 4300 Cherry Creek Drive South JAN 3 2020 Denver, CO 80246-1530 Re: Spindle Natural Gas Processing Plant Title V Modification: 95OPWE039 AIRS ID 123/0015 Dear Mrs. Chavez: DCP Operating Company,LP(DCP) is submitting the attached minor modification application for the Spindle Natural Gas Processing Plant(Spindle), located at SW Section 34,Range 67W, Township 2N in Weld County, Colorado. This facility currently operates under Title V permit 95OPWE039 originally issued on May 1, 1999 and last revised on October 15,2018. Summary of Changes Fugitive Emissions(AIRS ID 034) Spindle is required to conduct periodic hard counts of components that may leak VOCs. The estimation of fugitive VOCs has been updated based on the most recent hard count plus a 20% buffer,combined with the most recent Extended Gas Analysis(EGA). All emission units at the facility are subject to the Leak Detection and Repair(LDAR)program in New Source Performance Standard(NSPS) Subpart OOOO,as required by Regulation No. 7, Section XII.G.The Division has specified control efficiencies that can be assumed for monthly monitoring in accordance with LDAR per Subpart OOOO,as enumerated in Section 7 of the Fugitive Component Leak Emissions APEN Form APCD-203 (Rev. 3/2019).These control efficiencies differ from those specified in 95OPWE039,Condition 2.1 for some types of components. DCP is requesting an update to Condition 2.1 to reflect the use of the control efficiencies associated with the required NSPS Subpart OOOO LDAR program,which is being performed across the Spindle facility. Where a specific type of component is not listed in Section 7 of Form APCD-203,the control efficiencies for similar components were used in recalculating plantwide fugitive VOC and organic HAP emissions from equipment leaks. DCP is also requesting a change in the allowable VOC emissions from this source based on the revised emission estimate. Finally,the most recent revision to the operating permit occurred prior to Regulation No.7, Section XII.G was revised to specify that all natural gas processing plants in the 8-Hour Ozone Control Area would be subject to the LDAR program of NSPS Subpart OOOO. DCP is proposing changes to Condition 2 to add these requirements.The specific language of the suggested revisions has been taken from recent revisions to the operating permit for a similar gas plant. For a summary of these requested changes, please see the proposed revisions to Permit 95OPWE039 in Attachment F. Waukesha L-7042 GSI Compressor Engine C136(AIRS 051) Engine C-136 was replaced under Title V Alternate Operating Scenario(AOS)provisions on January 26,2020.The replacement unit is subject to reduced Regulation 7 criteria emission limits for NOx,CO,and VOC. The replacement unit was tested against these reduced limits on January 29,2020. The results of that test are included with the pending AOS application to be submitted for this unit within the 14 day timeframe provided under AOS provisions. DCP is requesting a reduction in the permitted emission limits for this unit to match these reduced Reg 7 limits as part of this application. DCP has redlined the TV permit to reflect these new emission limits,as well as the new SN for this replacement unit. Waukesha L-7042 GSI Compressor Engines C137 and C141 (AIRS 052,057) DCP is requesting a decrease in the NO,;emission limits and corresponding compliance emission factors for the above two compressor engines. DCP has included summaries of 2019 quarterly portable analyzer results in support of the requested emission limit decreases.DCP is requesting these reduced emission limits to ensure that NOx emissions from each unit are permitted below NA-NSR Major Modification significance levels,and that this facility can continue to perform permanent engine replacements under the Alternative Operating Scenarios(AOS)provisions detailed in Section 1.0,Condition 4.0 of Title V Operating Permit 95OPWE039 after the reclassification of the Colorado ozone non-attainment area from moderate to serious. Additionally, DCP is requesting that the serial number listed for engine C137(AIRS 052)be updated to reflect a permanent engine replacement that occurred on June 25, 2019. Regulatory Analysis There are no changes in regulatory applicability for the fugitive VOC emissions from the facility other than the addition of Regulation No. 7, Section XII.G LDAR requirements(NSPS Subpart OOOO LDAR program). Subpart KKK still applies facility-wide but the Division has previously found that for most components,compliance with NSPS Subpart OOOO LDAR satisfies the LDAR requirements of Subpart KKK. The primary change will be to update the LDAR program control efficiencies to reflect the implementation of NSPS Subpart OOOO LDAR for all components at the facility and to revise the VOC permit limit from this source. The only regulatory change for compressor engine C-136 is the new applicability of the criteria pollutant emission standards under Colorado Regulation 7 Section XVII.E(Part E, Section I.D. under the pending revisions.)DCP will continue to comply with all other applicable state and federal requirements for this engine. There are no changes in regulatory applicability for compressor engines C-137 or C-141 based on the requested decreased emission limits.DCP will continue to comply with all applicable state and federal requirements for these engines. Attachments The following attachments needed to make the requested changes to operating permit 95OPWE055 have been included: • Attachment A: Responsible Official Certification • Attachment B:APEN Fee • Attachment C: Updated APEN Forms • Attachment D: Emission Calculations and Supporting Documentation • Attachment E: Form APCD-102: Facility Emissions Inventory • Attachment F: Proposed Revisions to Permit 95WEOP039 If you have any questions or require any additional information about this submittal,please contact me at (303)605-2029 or MECameron@dcpmidstream.com. Sincerely, DCP Operating Company, LP 4ze, Marie Cameron Senior Environmental Engineer Attachment A: Responsible Official Certification Spindle Natural Gas Processing Plant I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and,based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures by used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). Tauna Rignall General Manager, North Area Operations Printed or Typed Name Title Signature of Responsible Official Date Attachment B: APEN Fees $191.13—Fugitive VOC Emissions (AIRS ID 034) $573.39—Waukesha L-7042 GS1 Compressor Engines (AIRS ID 051, 052, 057) Spindle Natural Gas Processing Plant Attachment C: Updated APEN Forms Fugitive VOC Emissions AIRS ID 034 Waukesha L-7042 GS1 Compressor Engines (AIRS ID 051, 052, 057) Spindle Natural Gas Processing Plant • Attachment D: Emission Calculations and Supporting Documentation Fugitive VOC Emissions AIRS 1D 034 Waukesha L-7042 GSI Compressor Engines (AIRS ID 051, 052, 057) Spindle Natural Gas Processing Plant Spindle Gas Processing Plant Fugitive Emissions From Equipment Leaks Uncontrolled Emissions Controlled Emissions Total MC Total VOC Total HC Total VOC Emission Factor' Component Count2 Percent VOC' Hours of Operation Control Factor Emission Rate Emission Rate Emission Rate Emission Rate lb/hr/source hr/yr % lb/hr lb/hr tpy tpy Valves-GasNapor 9.92E-03 1,542 25.63% 8,760 96.00% 15.30 3.92 2.68 0.69 Valves-Light Liquids 5.51E-03 2,753 100.00% 8,760 95.00% 15.17 15.17 3.32 3.32 Valves-Heavy Liquids 1.90E-05 24 100.00% 8,760 95.00% 0.0005 0.0005 0.00010 0.00010 ReliefValves-GasNapor 1.94E-02 113 25.63% 8,760 75.00% 2.19 0.56 2.40 0.62 Relief Valves-Liquid 1.65E-02 40 100.00% 8,760 75.00% 0.66 0.66 0.72 0.72 Compressor Seals 1.94E-02 14 25.63% 8,760 75.00% 0.27 0.07 0.30 0.08 Pump Seals-Light Liquids 2.87E-02 46 100.00% 8,760 88.00% 1.32 1.32 0.69 0.69 Connectors-GasNapor 4.41E-04 6,547 25.63% 8,760 81.00% 2.89 0.74 2.40 0.62 Connectors-Light Liquids 4.63E-04 6,740 100.00% 8,760 81.00% 3.12 3.12 2.60 2.60 Connectors-Heavy Liquids 1.65E-05 241 100.00% 8,760 81.00% 0.004 0.004 0.003 0.003 Flanges-GasNapor 8.60E-04 1,643 25.63% 8,760 81.00% 1.41 0.36 1.18 0,30 Flanges-Light Liquids 2.43E-04 1,208 100.00% 8,760 81.00% 0.29 0.29 0.24 0.24 GasNapor Totals 22.06 5.65 8.96 2.30 Liquid Totals 20.57 20.57 7.58 7.58 Totals 20,911 42.63 26.22 16.54 9.88 ' Emission Factors from EPA-453-R-95-017,Table 2-4 Uncontrolled tons per year: 114.85 2 Component count from June 2019+20% 3 Gas analysis based inlet gas analysis dated 8/12/2019 Spindle Gas Plant EGA 8/12/2019 Corrected VOC Liquid Service HAP Constituent weight% for HC weight% weight% He 0.0000 - Hydrogen 0.0000 - - CO2 3.7600 - - Nitrogen 0.5700 - - - Methane 52.8357 55.2270 - Ethane 18.3145 19.1434 Propane 13.3217 13.9246 13.925% - Isobutane 2.2566 • 2.3587 2.359% n-Butane 5.3793 5.6228 5.623% - Isopentane 1.2661 1.3234 1.323% - n-Pentane 1.3267 1.3867 1.387% - Cyclopentane 0.0583 0.0609 0.061% n-Hexane 0.2086 0.2180 0.218% 0.851% Cyclohexane 0.0465 0.0486 0.049% - Other Hexanes 0.3893 0.4069 0.407% Heptanes 0.1028 0.1075 0.107% - Methlycyclohexane 0.0296 0.0309 0.031% - 2,2,4-Trimethylpentane 0.0005 0.0005 0.001% 0.002% Benzene 0.0252 0.0263 0.026% 0.103% Toluene 0.0124 0.0130 0.013% 0.051% Ethylbenzene 0.0005 0.0005 0.0005% 0.002% Xylenes 0.0024 0.0025 0.003% 0.010% C8+Heavies 0.0231 0.0241 0.024% O2/Argon 0.0000 - - Alcohols' 0.0702 0.0734 0.073% 0.286% Total 100 100 0.2563 2.67% 4 Assumed to be 100%methanol Spindle Gas Plant HAP Calculations-Gas Components Uncontrolled HAP Controlled HAP Uncontrolled HAP Controlled HAP Emissions Emissions Emissions Emissions Rate(lb/yr) Rate(lb/yr) (tpy) (tpy) n-Hexane 421.4 171.1 0.211 • 0.086 2,2,4-Trimethylpentane 1.0 0.4 0.001 0.000 Benzene 50.9 20.7 0.025 0.010 Toluene 25.0 10.2 0.013 0.005 Ethylbenzene 1.0 0.4 0.001 0.000 Xylene 4.8 2.0 0.002 0.001 Methanol 141.8 57.6 0.071 0.029 HAP Calculations-Liquid Components Uncontrolled HAP Controlled HAP Uncontrolled HAP Controlled HAP Emissions Emissions Emissions Emissions Rate(lb/yr) Rate(lb/yr) (tpy) (tpy) n-Hexane 1,532.8 565.2 0.766 0.283 2,2,4-Trimethylpentane 3.7 1.4 0.002 0.001 Benzene 185.2 68.3 0.093 0.034 Toluene 91.1 33.6 0.046 0.017 Ethylbenzene 3.7 1.4 0.002 0.001 Xylene 17.6 6.5 0.009 0.003 Methanol 515.8 190.2 0.258 0.095 HAP Calculations-Total Emissions Uncontrolled HAP Controlled HAP Uncontrolled HAP Controlled HAP Emissions Emissions Emissions Emissions Rate(lb/yr) Rate(lb/yr) (tpy) (tpy) n-Hexane 1,954.1 736.2 0.977 0.368 2,2,4-Trimethylpentane 4.7 1.8 0.002 0.001 Benzene 236.1 88.9 0.118 - 0.044 Toluene 116.2 43.8 0.058 0.022 Ethylbenzene 4.7 1.8 0.002 0.001 Xylene 22.5 8.5 0.011 0.004 Methanol 657.6 247.8 _ 0.329 0.124 2019 Actual Emissions Uncontrolled Controlled Uncontrolled Controlled Emissions Emissions Emissions Emissions Rate(lb/yr) Rate(lb/yr) (tpy) (tpy) voc - - 91.0 28.7 Benzene - - - - Toluene - - - - Ethylbenzene - - - - Xylenes - - - - n-Hexane 1,490.8 467.0 0.75 0.23 Methanol - - - - 2,2,4-Trimethylpentane - - - - EMPACT EXTENDED NATURAL GAS ANALYSIS(*DHA) GLYCALC INFORMATION PROJECT NO. : 201908081 ANALYSIS NO.: 03 COMPANY NAME: DCP MIDSTREAM ANALYSIS DATE: AUGUST 14,2019 13:36 ACCOUNT NO. : PO 0000481483 RC-G010 SAMPLE DATE : AUGUST 12,2019 14:05 PRODUCER . CYLINDER NO.: 1222 LEASE NO. : SAMPLED BY : CHANDLER COLE NAME/DESCRIP. SPINDLE GAS PLANT SPINDLE INLET *"FIELD DATA*** SAMPLE TEMP.: 80 SAMPLE PRES. 700 AMBIENT TEMP.: H2S BY STAIN TUBE: - ppm COMMENTS SPOT Possible moisture in sample. Componet Mole°/0 Wt% Helium 0.01 0.00 Hydrogen 0.02 0.00 Carbon Dioxide 1.90 3.76 Nitrogen 0.45 0.57 Methane 73.32790 52.83570 Ethane 13.5609 18.3145 Propane 6.7263 13.3217 Isobutane 0.8644 2.2566 n-Butane 2.0606 5.3793 Isopentane 0.3907 1.2661 n-Pentane 0.4094 1.3267 Cyclopentane 0.0185 0.0583 n-Hexane 0.0539 0.2086 Cyclohexane 0.0123 0.0465 Other Hexanes 0.1011 0.3893 Heptanes 0.0231 0.1028 Methylcyclohexane 0.0067 0.0296 2,2,4 Trimethylpentane 0.0001 0.0005 Benzene 0.0072 0.0252 Toluene 0.0030 0.0124 Ethylbenzene 0.0001 0.0005 Xylenes 0.0005 0.0024 C8+Heavies 0.0045 0.0231 Subtotal 99.95120 99.92980 Oxygen/Argon 0.00 0.00 Alcohols 0.0488 0.0702 Total 100.00000 100.00000 BD!.-Below Detection Limit. The IIlS LOS has a detection limit of 0.25 ppm.A (at uderscore)indicates there was no tube pulled for HIS. The data presented herein ha,been acquired by mean,fcnrrcnl analytical technlgnes mu!repre,enn the j,ul,,ions ennclu.ion E tlPACT:,,ah-,/cal Sr,tems.htr. Res s!,,of the atud}a.can he affected by the soup/ing condition,(herd ore.are only warranted through proper lob protocol. Et/P It T,e,atands ua re,pnnsihilirr for intopreta,im,or a,,r,vnr,egn,m•,from application of the reported infnnnutinn duna is the sole l,ahilin of the use The reprodoetinu i,,ally media of IN, reported information nut,,not he made.in portion or n a I h o/e,without the rrinen permission r f F t/P:1 t I Inal,th al.S,vetns-her. EMPACT Analytical Systems Inc. 365 S Main St Brighton,CO 80601 303-637-0150 Go ogle Maps DCP Midstream-Spindle Gas Plant Topographic Map - . ,d, '�.s il ^: O Kelorn G.3 ...A � t / � . , ,Y 1 Loveland - .," r+ y 4D .r ", Ai Camp an 1 'A .ulmstoav Adna ..sd( 1 Ijo ,..444 a,t C'l � CO M�uiken ;,t a r ' !1 r 14A?Q� 7,----, ,, ,,- ,- t - ,;. . , i - • '''' , :-.1.1' ' j r i ae R r+g r } ,. i v. x IV s Sr y •' C Mead Y, .. %l • " 1 Pfattes J }� • Y{ a . ;‘t 4' e . -. , Longmont it _ 7. S' ° t * i .• .f.7, _. I3 t j .... t{ lJ Firestone tosdt Frederick azy Act 3 t �-, tSprnde Gas Want n g ® C.COCKI Fa 9. T is • Gu barrel, W v.44; � Leyner Er" ii# }l ' Go= �gle� Jl qSchadd Spindle Co Mc s x ,_� 1* Boulder CI) 0 Engine Emission Calculations Spindle Gas Processing Plant DCP Operating Company,LP Waukesha L7042 GSt Engine C-136 123/00167051 4 Stroke,Rich Bunt Updated:January 2020 Ur,R Rolirg 1232�hp 8SFC. '58C,55,77.0. Maximum Heat Input 9,34 mmbtu7nr Poten0al Mours of Operation. 8 760 hriyr Potential FtR'. 1 040 Misled __ ,Maximum Potential fuel Use 78 7.nnscl;yr 89805017.0 Actuel Parameters Mont, fuel Use Meat Value lfilMst-fimonifil p1lu80.7'_ January _.... _.. ... 5,7 1081.7 Fsbwry 4.6 1014.3 March 5.9 1074.3 April 55 1077,6 4,i_ay_ 5.6 1082.7 J,re, — 5.4 10930 _ July 5.4 1069.7 August _ 55 1071.6 member 49 1070.8 October 56 1064.5 J November. 5.5 _ 1089.7 Cemmber 5,4 1069.7 2016 652 10750 Glaris Pollutant Emission Calculations Uncontrolled Controlled I Potential CompPance Emission Factors Potential Emissions Cempilanes Factors Actual Emissions Emission Factors Emissions Factors Actual Emissions Pollutant 1000881) (IWMM8O,) Itdn54) it9Nyri 0bIMMBWL_ ([00081) NO4e' 11.0 gbhpAr 130.9 3.20_ 112.1 1,00 gibhp-hr 11.9 0.29 34.0 CO.' 8.0 515hpJv 56.2 2.33 41.5 200 gbhphr 23,8 0.58 34.0 000 a' 1.5 gbhp4u 17.8 0.44 15.3 970 gbhphr 8.3 020 DA PM° 194E-021b/'mn80, 0.79 1.94E-02 _ 0.64 1,94E-02 Ibimm8n, 0.79 1.94E-02 0.68 _ 8O2' 588E-04 Ib/mm0tu 0.024 5.88E-04 0.021 5.88E-04 b nonDtu 0.024 5.88E-04 0.021 e Wnoleclurers emsabns Acton 0 Urcanb4444 4%4440 lac6va.3m 400062 947404//4538 404,44 nom 60.43 CWp4e,3 Tanta 32-3(7,00,. r Rem Cabnde P.agWton 547.Pan E 5sc50.1.0.22 Non-Criteria Reportable Pollutant Calculations Contolled Controlled Actual Unconeaissi Potential Uncontrole0 Acba1 Control Potential Emissions Ac Emissions Emissions Efficiency Emissions Pollutant NAP Emission factors a Oda Source pb/yr) (ib/yr) % 0054) (Iblyr) I12.2-Taear4em0tiurn _ 2.53E-05IblmmBN EPA 207 1.77 50% 103 0.89 11.2-T,ichlometnane _ <1.539-05150,0n857 EPA 1.25 _ 1.07 5016 0.63 054 110ihloroethane <1.13E-05150rrm95, EPA 038 0.79 5096 0.18 040 1,20ihlorcethane <1.13E-O5 Iblmm8N EPA 0.36 0,79 50% _ 018 0.40 1.2 0,hloropropane 01,30E-95 Ibin'mBtu EPA 040 0.91 50% 0.20 0.46 1343utadiene 663E-O41bimm88, EPA 54.24 46.45 5O% 27.12 23.23 1.3-Ochloropropna 0127E.05570008tu EPA 1.04 0.89 50% 0.52 044 _ Acetaldehyde 270E-039s'*r+8w EPA 228,25 _ 195,48 50% 114,12 97,74 /31,00.00 2.63E-03 lb/mm(3N EPA 21518 184.27 5O% 107,58 9214 Benzene 1.58E-03 Ibimm85, _ EPA _ 129.26 11070 5O% 84.63 55.35 Carton Tetrachloride 01.779.05 Wmmew EPA 145 1.24 50% 372 __ 0.52 Cliorobenzene 01.29E-051b0.mm8w EPA 105 0.90 50% 0.51 0.45 Chloroform 0137E-05 IINnmBtu EPA 1.12 0.96 50% 0.56 0.48 Ethylbanaene 02.48E-052_ EPA 2.03 1.74 50% 1.01 087 Ethylene Oibmmde 0 2.13E-05 157,3031_ EPA _ 1 74 1X19 50% 387 0 75 _-_ __ £mmatd•hyd4- 2.06E412 BMrmmBlu EPA ,.077.18 1,47435 72% 402.11 34417 Methanol _ 306E-031Nnxn8tu EPA 25934 214.40 50% 125.17 107,20 Methylene CMonde 412E-05 m(mrn81u EPA 337 289 5O% 199 1,44 NapMhakne 09.71E-05 lb/rnmEitu EPA 794 6.80 50% 3.97 3.40 PAH 1,41E-041b,mm850 EPA 11.54 9.88 50% 5.77 4.94 Styrene --- _--- 01.19E-05101mm0b, EPA 0.97 0.83 50% 0.49 0.42 Tel.. 5.58E-04 G:mnOtu EPA 45.65 39.10 50% 2282 19.55 ._...0___...___.._._...._...____ Vinyl CN%Me <7.18E-06 I0/0301B87EOp 059 0.50 50% 0.28 _ 0.25 0910 eArn,p,ol 1.55E-04 6483.35., EPA 1595 1366 5O°6 7.58 6.83 TOTAL 0.0324037 153emnetu — 42633 <2274 <491 0763 '61030501.4.3.o,91050100010300 4ntraea.Rr5-0um 145P5,anginas nom AP,.5lu0e03.Tad%32-3.17/00). 1/3172020 Engine Emission Calculations Spindle Gas Processing Plant DCP Operating Company,LP Waukesha L 7042 GSI Engine C-137 12210015/052 4 Stroke,Rich Bum Updated:January 2020 Unit Ra0ng 1 232 hp 85FC. 7 5800N010-hr Msunum Head __„ 934 mmbtuao Potential Hours of Op.4801 for 2013 a Too Sly, Potential F1112 1.040 Mudd Msdmmt Potential Fuel Use. 78.7 nrrncf/yr 8,980 scl3 Actual Parameters Month Fuel Use Heat Value (MMscflmon0h) (B0640._. January 5.6 1081.7 53 10743 March, 58 1074.3 .pn1 _ 57 10776 ._ 5,6 1082.7 June 50 1093.0 July 5.5 1069.7 - . 9t 5.5 1071.6 _September 5.0 1070.8 October 5.6 10645 November 5,5 1089.7 Number 55 1089.7 2089 65.7 1075.0 Criteria Pollutant Emission Calculations Uncontrolled Controlled Potential Complbnce ' Emission Factors Potential Emissions Compilance Facture Actual Emissions Emission Factors Emissions Factors Actual Emissions Pollutant don/84 (lbiMMBtu) turned (t00hr) (N41MBtu) (00015.) NO." 11090040 130.9 320 _ 113.0 2029Ahp4u 24.0 _ 059 34.3 CO'` 8.0 g5hp-hr 95.2 2 33 02.2 3.33 gAhp4b 39.9 0.97 341 _ _193/114_2e. 17.8 0.44 15.4 082 9Ahp-hr 9.8 0.24 8.4 PM' 1 94E-02 lblmn8tu 0.79 1.540.72 _ 099 1.94E-021b/mr9W 0.79 1.94E-02 0.89 SOo` 5.83E-04INmrew 0.024 5.86E-04 0.021 5.86E-0a IbhmBw 0.024 5.88E-0a 0.021 •lloismaers ema0ns factors •llc0r8ro4ed emsnon rect.Ran 4aboke,Ron-burn(45801 engnes horn AP-42 Chapter 3 Table 3.2-3.l7/031 •From Colorado Itrpb5on tb.7.Part E Section 002.6 00.Cditoria Reportable Pollutant Calculations Controlled Controlled Actual Uncontrolled Potential UncontrolledActual Coned Potential Emissions ETlsalon, Emission, Efficiency Emissions Pollutant HAP Emission factors• Date Sour.. )Ibiyr) 0NYr) % (ib/yr) QW50) 1.1.2.2-TebacNoroemane -__ 2.53ED5lNrm8m EPA _ 2.07 1.79 50% 1.03 0.89 1.1,2-Tnchioroelrane <1,53E-051Nnn43w EPA 1,25 1.08 50% 0.83 0.54 t,f Dichbroa0wro <1.13E-0<INnrt43w EPA 0.36 _ 0.80 50% 0.18 0.40 1.2 Ditl±broe0lane <1.13E-05 IbAnOso EPA 0.38 080 50% 0.18 040 1,2 DicNcropropane 4130E-05lbhmr8w EPA 041 092 50% 0.20 0.46 1,3-Buddiane 6.83E-04Ibhnr8ho EPA 51.24 46.(14 50% 27.12 2342 13-Diddomprepene _ 41.27E-051bhmAN EPA 1.04 0,90 50% 052 0.45 Acetaldehyde 2.79E-0315hm81u EPA 228.25 197.12 50% 114.12 98.56 Aaolsln 263E-03IMrrt8w EPA 21516 185.81 50% 107.58 9291 Benzene 158E-03I6hm8w EPA 129.28 111.83 50% 64.63 55.81 Carbon Tobachbnde <1.77E-05INnn43w EPA 1.45 1.25 50% 0.72 0.63 -< CNorobenana <1,29E-05Ibhm8w _ EPA 1.05 0.91 50% 0.53 0.06 Chloroform <137E-05 IntorriBtu EPA 1.12 0.97 50% 0.56 0.48__ Ethylbenzen. 42.48E-05 ibhmEw EPA 2.03 1.75 50% 1.01 088 Ethylene dbromde 42.13E-05 lNnndw EPA 1.74 1.50 50% 0.87 0.75 FeeuaM.9yde 2950432 Iwamoto: EPA 1.977.10 1,445.35 74%. 402.35 54714 Methanol 306003 bMn,w EPA 250.34 218.19 _ 50% 125.17 108.10 9p( to CNonde 412E-05 tern*.tern*. EPA 3.37 2.91 50% 1,69 I 1.46 NC0,ukne 4871 E-OS bh,vedw EPA )94 6.86 50% 3.97 3.43 PAH _--_ 1.41E-0a tNrtsrBtu EPA 1154 9.98 50% •---5.77 —_.. 4.98 Styrene --_-- 41.19E-05 N,nr6w EPA 097 0.84 50% 0.49 0.42 T duens 5,58E-04 0/,45, EPA 45.65 _ 39.42 50% 22.82 1971 Vmyl Chloride <7.18E-08 NmrBw EPA 0.59 0.51 0 50% 0.29 025 Xybnssimp.o) 1,95004 MmBtu EPA 1595 13,781 50% 798 6.89 , TOTAL 0.0324537 bhnmBtu 42653 <3283 4891 4770 '1acortrokd enslnn tattoos I,om 4a*oke,1ecRtan(4508i ergots from AP-42 Chadds 3.Tate 3.2-3,i7,Ob. 1/272020 Engine Emission Calculations Spindle Gas Processing Plant DCP Operating Company,LP Wauke9ha L 7042 GSI Engine C-141 123100151057 4 Stroke,Rich Bum Updated:January 2020 UMRahg. 1.232 tm 0500- 7 530 btnlplr Manrtun Heal Input 9.34 mmblu97 Potential Hays of Operation for 2015 3.'W hlyr 002001al F115. I GOO b61001 Werra.Poten0al Fuel Use 78.7 mmdlyr 8.980'clay Actual Parameters Month Fuel Use Heat Value (MMs<flnront) (B4dsc5) January 57 10617 February 5 2 10743 March 58 1074.3 AMA 5.8 1077.6 May 5 6 10827 June 53 10930 July 5.5 1069.7 Au91nt 5 4 10718 September 46 1070.8 October 5.8 1084.5 November 5.6 1089.7 Oe<em5er 5,6 1069.7 2015 6571 1075.0 I Criteria Pollutant Emission Calculations Uncontrolled ContmM4 Petendal Compliance Emission Factors Potential Emissions Compliance Factors Actual Emissions Emission Factors Emissions Factors Actual Emissions Pollutant 181741) 1010101074) (1auy1) (tonlyrl__ (5WMM814) 1806yr) NO," 118gclptr 130.9 320 1t3.0 2029DIp4r 24.0 059 34.3 CO" 60 ofolp-le 05.2 2.33 62.2 3.33,.511pdr 39.6 0.97 34.2 VOC" t89M,Plr 17.9 044 15.4 0.829/olp41 9.6 024 54 PM° 1.94E-0'2 bl1m8W 0.79 194E-02 • , 0.69 1.94E-02 Wmm5tu 0.79 194E-02 0.69 SO10 5.60E-04 DlmmBtu 0.024 5.88E-04 0.021 5.68004 10!0064 0.024 588E-04 0.021 e M4whaa.fl am ton s a 0,80.094.4.mevm raaooa hem 4~004.8ianb.m:4SR8).58°75011'35 80.42.051858 3,,0.4.32317.1 ;7001 1 Sean Comm.R.moM0n No.7.01c E.5.0,091.0.2.6 Non-Criteria Reportable Pollutant Cakul4tions 0;07°Z Actual Potential Uncontr d aN Acluel Control Pontrol.4 Emltsbns EmIstkint Emissions EMcienCy Emissions POWtant HAPEMssbn factors° Data Source (9885) QW)r) % QWyr) Qbryr) 1.122-Tetachoroemere 2.53E-05dmm8W EPA 207 1.79 50% 103 0.89 112Tnchbroadune 4153E-05dmm8tu EPA 125 108 50% 063 0.54 1.1 3KNoroeerene 6 1.13E-05 bhnm8W EPA 0.36 0,80 50% 011!1 0,40 1.13E-0SdmmBtlr �.____ EPA --_..- 0.36 0.00_. 50% 0.19__....._..—._.640 1.2 DeuloroelhaM--- 1,2DIcllbroprupane 61.30E-05dmm8W EPA 9.41 0.92 50% 0.20 0.46 1,3-Butadane 663E-04.+mmBW EPA 54.24 46,83 50% 2712 23.42 1.3{ldioropropene 6127E-05 dnen84 EPA 1.04 0.90 50% 0.52 0.45 Acatabohyde 2,79E-03bimmBh EPA 22825 19109 50% 114.12 9854 Aerobe, 2.63E-03 brmm9W EPA 21516 185.78 50% 10758 9289 Bemela 1.58E-03dmmBW EPA 129.26 11181 50% 54.63 55.80 Canteen T.9act4ond. e 1,77E-05bl,9mBW EPA 1.45 1.25 50% 0.72 0,63 CHombevene 4129E-056lmmBW EPA 1.06 091 50% 0.53 048 CNomform 4137E-05dmmBW EPA 1.12 0.97 50% 055 0.40 Eehy4Eevene <249E-05 b/mmoso EPA 2.03 1.75 50% 1.01 0.88 Ethylene D5Omd1 62.13E-05DhnmBW EPA 1.74 1.50 50% 087 0.75 EoeMetWatlyde 2.059:020018810 EPA 1.617:99. 1.44401 .76% 409559 • 347.41 Methanol 308E-03 blmn184 EPA 250.36 218.15 50% 12517 108.08 58051,4..CNorde 4,120056Imm86< EPA 3.37 - 2.91 50% 1.69 1.46 Nna YUubre .89.71E-056imm55, EPA 7.94 6.86 50% 3.97 3.43 I PAN 141E-04bhrmBW EPA 11.54 9.96 50% 5.77 4.98 Styrene 41.19E-056lmmBW 50% 049 0.42 0.97 0.84 _ I Toluene 5.58E-04dmmBW EPAEPA 45.85 39.42 50% 2282 971 Vinyl CFbnde 4].180-06 dmm85, EPA 059 0.51 50% 029 0.25 I Xyieres(m.Po) 1-95E-04drm11BW EPA 15.95 13.77 50% 7.90 689 TOTAL 0.0324537 1°/,9,8074 - <2653 12292 <S91 4770 1<.800,601.4.98980<00710194-0,0<..585-Corn 14998).5800010980.42.0MP8,1 9*72-3.(]vl,n • 127(2020 Supporting underlying portable analyzer test data available upon request. Portable Analyzer Test Results 1st Quarter 2019 Spindle Gas Plant Exhaust Flow Rate scf/hr=8710 scf/MMBtu* Fuel Consumption MMBtu/hr*20.95°, Fuel Consumption MMBtu/hr = Fuel Consumption(scf/hr)* Fuel Heating Value(Bti Emissions(lb/hr)=measured ppmv/ 1,000,000* Exhaust Flow(scf/hr)* mol.w t. (lb/1 where: molecular weight CO 28.00 molecular weight NO: 46.07 Test Data Results(see attached): Source ID No. P-161 P-166 Site ID No. C-137 C-141 Serial Number 350086 144345 Engine Stack Test Date 01'14/19 01/14/19 Meas.Conc. O2% = 0 0 Meas. Post-Converter CO ppmv = 206.35 177.22 Meas.Post-Convert.NOx ppmv = 21 '' i . Normal Fuel Heat Value Btu/scf = 1077.0)' 1077 OS Max.Fuel Consumption(scf/hr) = 8976 8976 Max.Fuel Consump. (MMBtu/hr)= 9.67 9.67 Max.Exhaust Flow Rate(scf/hr) = 84204.8 84204.8 Max.Meas.CO Emiss. Rate(lb/hr)= 1.3 1.1 Permited CO Emiss.Limit(lb/hr) = 9.1 9.1 Compliance with Hrly CO Limit YES YES Max. Meas.CO Emiss. Rate(tpy) = 5.5 4.7 Permited CO Emiss.Limit(tpy) = 39.6 39.6 Compliance with Yrly CO Limit YES YES Max.Meas. NOx Emiss.Rate(Ib/hr)= 0.2 0.2 Permited NOx Emiss. Limit(lb/hr)= 9.1 9.1 Compliance with Hrly NOx Limit YES YES Max. Meas.NOx Emiss.Rate(tpy)= 0.9 0.7 Permited NOx Emiss. Limit(tpy) = 39.6 39.6 Compliance with Yrly NOx Limit YES YES Supporting under(:ing portable anal,°zer test data available upon request. Portable Analyzer Test Results 2nd Quarter 2019 Spindle Gas Plant Exhaust Flow Rate scf/hr=8710 scfMMBtu* Fuel Consumption MMBtu/hr * 20.95°, Fuel Consumption MMBtu/hr = Fuel Consumption(scl hr) * Fuel Heating Value(Bti Emissions(lb/hr)=measured ppmv/ 1,000,000 *Exhaust Flow(scf/hr)*mol.wt.(Ib/I where: molecular weight CO 28.00 molecular weight NO: 46.07 Test Data Results(see attached): Source ID No. P-161 P-166 Site ID No. C-137 C-141 Serial Number 350086 144345 Engine Stack Test Date 04'03/19 04 04'19 Meas.Conc. O2% = 0 0 Meas.Post-Converter CO ppmv = 159.1 7 76.65 Meas. Post-Convert.NOx ppmv = 2;8 s l Normal Fuel Heat Value Btu/scf = l0?4_?6 10-4 '6 Max.Fuel Consumption(scf/hr) — 8976 8976 Max. Fuel Consump.(MMBtu/hr)= 9.64 9.64 Max. Exhaust Flow Rate(scf/hr) = 83986.7 83986.7 Max. Meas.CO Emiss. Rate(Ib/hr)= 1.0 0.5 Permited CO Emiss.Limit(Ib/hr) = 9.1 9.1 Compliance with Hrly CO Limit YES YES Max.Meas.CO Emiss.Rate(tpy) = 4.3 2.0 Permited CO Emiss.Limit(tpy) = 39.6 39.6 Compliance with Yrly CO Limit YES YES Max.Meas.NOx Emiss.Rate(lb/hr)= 2.4 0.1 Permited NOx Emiss. Limit(lb/hr)= 9.1 9.1 Compliance with Hrly NOx Limit YES YES Max. Meas.NOx Emiss.Rate(tpy)= 10.5 0.2 Permited NOx Emiss.Limit(tpy) = 39.6 39.6 Compliance with Yrly NOx Limit YES YES Supporting underlying portable analyzer test data available upon request. Portable Analyzer Test Results 3rd Quarter 2019 Spindle Gas Plant Exhaust Flow Rate scf/hr=8710 scf7MMBtu* Fuel Consumption MMBM/hr* 20.95°, Fuel Consumption MMBtu/hr = Fuel Consumption(scf/hr)* Fuel Heating Value(Bti Emissions(lb/hr)=measured ppmv/ 1,000,000 * Exhaust Flow(scf/hr)* mol. wt.(lb/I where: molecular weight CO 28.00 molecular weight NO: 46.07 Test Data Results(see attached): Source ID No. P-161 P-166 Site ID No. C-137 C-141 Serial Number 350086 144345 Engine Stack Test Date 06!26/19 07/18/19 Meas.Conc. O2% = I.2 0 Meas. Post-Converter CO ppmv = 361.364 16.74 Meas. Post-Convert.NOx ppmv = 507.0-45 50 16 Normal Fuel Heat Value Btu/scf = 19O.67 106).67 Max.Fuel Consumption(scf/hr) = 8976 8976 Max.Fuel Consump.(MMBtu/hr)= 9.60 9.60 Max. Exhaust Flow Rate(scf/hr) = 88709.0 83627.8 Max. Meas.CO Emiss. Rate(lb/hr)= 2.3 0.1 Permited CO Emiss. Limit(lb/hr) = 9.1 9.1 Compliance with Hrly CO Limit YES YES Max. Meas.CO Emiss. Rate(tpy) = 10.2 0.4 Permited CO Emiss. Limit(tpy) = 39.6 39.6 Compliance with Yrly CO Limit YES YES Max. Meas.NOx Emiss. Rate(Ib/hr)= 3.3 0.5 Permited NOx Emiss. Limit(lb/hr)= 9.1 9.1 Compliance with Hrly NOx Limit YES YES Max.Meas.NOx Emiss. Rate(tpy)= 14.3 2.2 Permited NOx Emiss. Limit(tpy) = 39.6 39.6 Compliance with Yrly NOx Limit YES YES Supporting underl)mg portable analyzer test data a‘tillable upon request. Portable Analyzer Test Results 4th Quarter 2019 Spindle Gas Plant Exhaust Flow Rate scf/hr=8710 scf/MMBtu* Fuel Consumption MMBtu/hr* 20.950, Fuel Consumption MMBtu/hr = Fuel Consumption(scf/hr) * Fuel Heating Value(BU Emissions(lb/hr)=measured ppmv/ 1,000,000*Exhaust Flow(scfrhr)* mol.wt.(lb/1 where: molecular weight CO 28.00 molecular weight Na 46.07 Test Data Results(see attached): Source ID No. P-161 P-166 Site ID No. C-137 C-141 Serial Number 240602 144345 Engine Stack Test Date 10/23/19 10'22%19 Meas.Conc. O2% = 0 0 Meas.Post-Converter CO ppmv = 642.22 140.39 Meas. Post-Convert.NOx ppmv = 496.57 Normal Fuel Heat Value Btu/scf = 106-1,3 I I06-t.,4 Max. Fuel Consumption(scf/hr) = 8976 8976 Max. Fuel Consump.(MMBtu/hr)= 9.56 9.56 Max. Exhaust Flow Rate(scf/hr) = 83226.8 83226.8 Max.Meas.CO Emiss.Rate(Ib/hr)= 3.9 0.8 Permited CO Emiss.Limit(lb/hr) = 9.1 9.1 Compliance with Hrly CO Limit YES YES Max. Meas.CO Emiss.Rate(tpy) = 17.0 3.7 Permited CO Emiss.Limit(tpy) = 39.6 39.6 Compliance with Yrly CO Limit YES YES Max. Meas.NOx Emiss.Rate(Ib/hr)= 4.9 0.5 Permited NOx Emiss. Limit(Ib/hr)= 9.1 9.1 Compliance with Hrly NOx Limit YES YES Max. Meas.NOx Emiss.Rate(tpy)= 21.6 2.1 Permited NOx Emiss. Limit(tpy) = 39.6 39.6 Compliance with Yrly NOx Limit YES YES Attachment E: Form APCD-102: Facility Emissions Inventory Spindle Natural Gas Processing Plant • • • Colorado Department of Public Health and Environment Form APC D-102 J Air Pollution Control Division41/4 C D P H E LIFacility Wide Emissions Inventory Form der April 21119 CO ,,,�..1./ Cnntl y Name:IX.1(3i.rating.CCmpoov,1..R lir 41� Source Name,Spindle 631.Flans 1M Source AIRS ID:123,001; tbmnvulled Ye1286.i w 1201111111E1 curt o90ed P642.1031.emit 11111811111181 el) I 119114 OW.) Crlm,i61TPV) I 11A1141110/,1AIRS In 2 600.81n4.4ri71,46 1711 76110 1,172,5 001 NOS COO. CO 1114110 Metal Acre a! Tel 68 5,71 n-1111 Mrib 214461P ISP P7110 P511,( 002 Nut VIII' CO 1 At HO 9.121 4044 ar. 101 86 7491 n-1142 Ale. 224-TMle 1±1'10]5,024 1006ne 0.7 0 14 014 11.14 0 tot 1805 4 00 10.13 505 42 29 24 8 1 3 0 411 014 014 01J 0 00 500 -12 500 1 71 21 2,1 12 `4 23 I nzools.om FuEtt9a _ 000 004 0 O 0.ti0 000 11485 000 0 0 216 116 5 22 1954. 658 000 000 000 COO 400. 9.88 0.00 1 0 0 0 S0 44 76 248 12910015,051 Blet.e1:110 074 079 079 002 10086 1784 9517 1772 228 15 129 46 2 16 0 ±50 079 079 0.14 002 1240 8.11 23 79 1 401 114 III 65 70 125. 123:0015;0.52 En86te C-137 1.79 079 019 002 11086 IT 81 9517 1,677 225 215 129 44 2 16 0 250 079 079 .070 002 24.01 9.76 10.62 I 401 114 108 05 13 125 1x1,00154;1 lu,re1,18 0.19 0.7V 0.01 11086 u,,,7 .011 , _U. 62 1 401 114 1,1r 05 11 ' 111 1,0015,015 r,r1C C-114 _ 098 _ 1148! 1784 9517 2,006 102 t 098_ 09x 105 217 11,90 4759 1 111 80 :,8 1 154 12511015;050 rte 7.140 0508 00tl 003 I7 e4 45.17 2006 281 156 56 0 308 09% 119p 2779 1 4. I 154 toe, 09A l0.tlb a5 � IU 8 0.98 101 X 1 10 lEi 12310015,1151 Ontui0 C-141 0711 079 0.19 0.02'. 11086 1784I 9 21 95.1> t,671 228. ?IS IEY 40 3 1U 0 .250 11.14 079 :0.>9 003 IJ 113 916 39.62401 ::114. 108 04 ±3 :125 121N015N611 toru,C-155 6 1_1,677 I6 6 OW 1931 4 tr., 28.911 401114 1114 65 21 t 125 1.2.1.014.061 11,68 00, 0 19 0 36-039- 0 07 123 14 0 164 - 1 002 6 1 6 , 121,0150? Engler C-2,1,11.'7, 000 010 0208 , 0.00 OW 0.00 11 011 000 121,0017201 P-18'1110neb2drotue 000 2111 677 085 I + , 1 2 11.0 n ., ±.5411 r 4. r0015!Oti4 1-17015 10702010 Hot Oi0Neur, 0.48 0 41 0.44 004 68E 0 17 511 s 0 00 221 o 0.12 048 048 004 611 0 15 5 II I ` 0 4 21 121!0015..000 4(0040odl'1nder28h Tan.211 , 0 0 0 0 000 000 2It, 000 I 0 t , 121,0015.075 - -221 019 40 0 O 001 87 —45111 835— 1,3 04 -3 1 _ 040 04 1740 011 1289 4.58 22894 200 5] 4 65 II - 113.01v081 Eng.,C-141 098 098 098 003 11006 1784— 06 a "•5 ' 159 50 , 098 098 098 -003 1119 11.191 107 - 141 Ill 40 18 I ti15,052 PI Plate 0011 0017 110 215 712.79 - '0 101 0 4w 5 40 000 00 000 0 1 215 f9.4 7 0 1.4 0 , 12198314/2120 112(31,4'F 0000 000 0,0 OW Uql 18 000 1 1 1 1 . _ 0 0 < 0 , UC 0(71 Ow uC5 OW 11,1116 000 I U 0 u — 0 V 11 10 P8704484 Suomi Su6404n1 8.71 8Ji 2.31 0.20 4,149.76 1.087._4 881,03 19.828 2.788 1,416 4,717 8,088 709 5,346 6,016 3,109 5 8,35 8.31 +8.01 0.30 210.79 129.66 334.021 3,004 1,394 1,208 419 780 5e 415 5,111 2,.548 2 ¢N only-Penne 1:.9em71 Source. I.3T055/r80 )W TANK, 00 00 40 00 C0 14 01. ' 0 0 _ 5 72 0 0 0 229 0 0 011 00 00 _ 4 00 . 0 0 1. 71 0 u 2_ U 0 _ f - — — I- . I 1 _ I 1 t -1 APPS:0Ny S0140441- 1.0 0.0 0.9 0.0 0.0 IA 0.0 : 0 0 n 3 0 0 0 119 a 0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 I 0 0 0 73 0 u 0 219 0 0 Ar.Exe P/Imtemann7wu,ee p,,41olns,BnlGum 07991,18 00 00 00 00 511 27 •II 0 11 a 11 4 O 0 101 1-I 0 411 4.) 111 O0 56 Il 40 0 u 0 0 0 0 201 324 0 F- F- - _ 1 _ _ _ I 18 812.112 ant 5861..1 0.0 0.0 _0. I 0,0 ..0 1.3 4.7 U V 0 0 _ 0 0 0 201 324 u 0.0 0.0 0A 0.0 5,6 1.3 4.7 2 0 0 U U 0 n 0 xnl 124 0 - Total,5P946.24.=i 8.7 I 82 I 6 1 0.3 I 1145.3 I 1090.2 1 666.3 !19,47.111 2,786 I 2,16 J 4.010 IL., I 719 I 5,346 I 6,446 I 3,511 I 5 18.3 I to J 8.3 J 11.3 I 116.4 1 142.4 1 3187: 3,904 I 1,394 I 1,206 1 1,700 I 750 1 56 I 412 1 1,5901 1.841 I 2 8ereetr6115d 0Ae,Sant.,.,.(1 PI)1 9.0 I 2.4 I 1.2 J 2:5 I 4.3 1 04 I 2.7 1 3.2 1 I.8 1 0.0 I 1606441eduAP.S..6.4,(rPv)1 2.8 I 0.7 I 1.6 I es J 0 4 1 uu 10.2 I 0.8 1 04 I 0.0 Umoo0911ed Tn141,All OAPs(1PVI-1 21,2 I 4'.00trolled 0001,All l0AP3(975)-I_ 0,1 I POUtnO2es: I This form should he completed to include both e.9151mg sources and all proposed new or modifications to existing 00)10610;1*5021700* 2 It the emissions source is new then 111107"proposed"under the Permit No and AIRS I[3 data columns 3 ]HAP 455100i001ns lm:ludc R$ Benzene 2241 NIP-2,2,4-1lmethylpenrdne T01-Toluene Aerial Acetaldehyde PR-I':lhylben9.enc Aeru Acrvlem 541-Xylem 0-1108-n-Hexane 11(:110=Formaldehyde Meth-Methanol 4 APIN Exompl'2ns16ni0cant Sources should be included when warranted 001 Op500802 company.lP 1131/2020 Pagel of 1 Attachment F: Proposed Revisions to Permit 95OPWE039 Spindle Natural Gas Processing Plant Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 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 C-136 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective None Internal Combustion Reciprocating Engine, Catalytic turbocharged.4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 210113360657 052 C-137 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle.Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 350086240602 053 C-138 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 327101 081 C-147 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective 09WE0195 Internal Combustion Reciprocating Engine, Catalytic turbocharged.4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller.powering a natural gas compressor. SN 397541 055 C-139 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective None Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 286440 056 C-140 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged.4-cycle,Standard Rich Burn w/air/fuel Reduction ratio controller,powering a natural gas compressor. SN 288108 057 C-141 Waukesha Model L-7042 GSI Natural Gas Fired 1232 HP Non-Selective Internal Combustion Reciprocating Engine, Catalytic turbocharged,4-cycle,Standard Rich Burn wl air/fuel Reduction ratio controller,powering a natural gas compressor. SN 144345 * All horsepower(HP)values are site rated values as reported in APEN submittals Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1,2012 LAST REVISED: October 15,2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page SECTION I - Specific Permit Terms 1. Natural Gas Fired Internal Combustion Engines with AFR and NSCR> 500 HP C-136—Waukesha 1232 HP Compressor Engine Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (Ib/MMBtu) Method Interval Nt3\ 1.1 11.9 TPY 0.291 Recordkeeping& Monthly CO 23.8 TPY 0.582 Calculation 12 month rolling VOC 1.2 8.3 TPY 0.204 Natural Gas i_3 78.7 MMscf'vr Consumption Btu Content of L4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation L55 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Statewide 1.11 See Condition 1.11 Controls for Oil and Gas Operations Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: October 15, 2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page C-137—Waukesha 1232 HP Compressor Engine C-141 —Waukesha 1232 HP Compressor Engine Note:These limitations apply to each engine. Permit Controlled Monitoring Parameter Condition Limitations Emission Factor Number (1b/MMBtu) Method Interval NOx 1.1 324.0 TPY 0.9680.588 Recordkeeping& Monthly CO 39.6 TPY 0.968 Calculation 12 month rolling VOC 1.2 9.7 TPY 0.236 Natural Gas 1.3 78.7 MMscf/yr Consumption Btu Content of 1.4 ASTM,EPA or Semi-Annually Natural Gas other Division Approved Methods Hours of Operation 1.5 Recordkeeping Monthly Opacity 1.6 Not to Exceed 20%Except as Fuel Restriction Only Natural Gas Provided for Below is Used a Fuel For Startup—Not to Exceed 30%, for a Period or Periods Aggregating More than Six(6) Minutes in any 60 Consecutive Minutes NESHAP Subpart 1.7 See Condition 1.7 ZZZZ NESHAP Subpart A 1.8 See Condition 1.8 Control Device 1.9 See Condition 1.9 CAM 1.10 See Condition 1.10 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: October 15, 2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 1.10 Statewide Controls for Oil and Gas Operations 1.10.1 Colorado Regulation No. 7, Section XVII Requirements: Engine C-136 only is subject to the following requirements of Colorado Regulation No. 7. Section XVII. "Statewide Controls for Oil and Gas Operations and Natural Gas-Fired Reciprocating Internal Combustion Engines": 1.10.1.1 lState-Only Enforceable]: Except as provided in Section XVII.E.2.b..the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state.on or after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below (Colorado Regulation No. 7. Section XVII.E.2.a.). 1.10.1.2 jState-Only Enforceable]: Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in the table below as expressed in units of grams per horsepower-hour(g/hp-hr)(Colorado Regulation No. 7, Section XVII.E.2.b.). Maximum Construction or Emission Standard in g/hp-hr Eneine Hp Relocation Date NOx CO VOC On or after July I.2007 2_0 4.0 1.0 >500 HP On or after July 1, 2010 1.0 2_0 03 1.10.1.3 Except as provided in Sections XVl1.E.3.a.(i)(B)and (C)and XVII.E.3.a.(ii). all rich burn reciprocating internal combustion engines with a manufacturer's name plate design rate greater than 500 horsepower.constructed or modified before February' 1. 2009 shall install and operate both a non-selective catalytic reduction system and an air fuel controller by July 1. 2010. 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 XVII.E.3.a.(i)). All control equipment required by Section XVII.E.3.a. shall be operated and maintained pursuant to manufacturer specifications or equivalent to the extentpracticable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator shall keep manufacturer specifications or equivalent on file. (Colorado Regulation No. 7. Section XVII.E.3.a.(i)(A)). Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: October 15, 2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 6. P181 -Fugitive VOC Emissions from Equipment Leaks Parameter Permit Limitation Emission Factor Monitoring Condition Number Method Interval VOC 6.1 9.92-8,4 4 tons By Component- EPA Method 21 Semi-annually per year EPA Protocol for Recordkeeping& Equipment Leak Calculation Estimates Statewide b!2 Complies by meeting 40 CFR 60,Subpart OOOO NSPS Controls of Oil See Condition 6.2 and Gas Operations 40 CFR 60. 6.3 See Condition 6.3 Subpart KKK NSPS Regulation No. 6A See Condition 6.4 7,Section X1].G (40 CFR 60, Subpart OOOO NSPS) Leak Detection Fri As defined by approved plan per Subpart KKK and Repair NSPS General 6.53 See Condition 6.53 Provisions 6.1 Emissions shall be calculated using the emission factors and equations listed below. Emission Factors for individual types of components in lbs/component-hr from the reference Protocol for Equipment Leak Emission Estimates, EPA, November 1995, EPA-453/R-95-017. These emission factors are fixeuidt until changed by established permit modification procedures. "*�" 3F "F}'[' .ar Y d p-... ',. a cj,y. ✓Y t tl C� i r� - dam'§ �,c Aar "d W. �{ -D zz,. .�.s" r_`$ Valves 9.92 x 10-3 5.51 x 10-3 1.85 x 10-5 Connectors 4.41 x 10-4 4.63 x 10-4 1.65 x 10` Flanges 8.60 x 10-4 2.43 x 10-4 8.60 x 10-' Pump Seals 5.29 x 10-3 2.87 x 10-2 N/A Other* 1.94 x 10-2 1.65 x 10-2 7.05 x 10"` Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1,2012 LAST REVISED: October 15,2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches,instrument meters,polish rods,and vents. Calculation of annual emissions of VOC per component: Component count x 8760 hrs/year x VOC content(wt%) x Emission Factor x Control Factor The total fugitive VOC emissions shall be the sum of emissions for each component. A plant inlet gas analysis shall be performed according to appropriate ASTM or EPA approved methods at least once per calendar year. The dates of the annual inlet gas analysis shall be separated by at least two (2) calendar months. The most recent inlet gas analysis shall be used to determine the appropriate %VOC to use in the above equation. For determining compliance,the Division has accepted the following control factors:accepted the use of a 75 percent (%) control factor for all components except the flanges/connectors. For the flanges/connectors the Division accepted the-use of a 30 percent(%) control factor. Component Gas Control Factor Liquid Control Factor Connectors 81% 81% Flanges 81% 81% Pump Seals N/A 88% Valves 96% 95% Compressors/Relief Valves 75% 75% 6.1.1 The annual emission limit was based on the following component count,which includes a 2-1_0% buffer: Component Component Count Gas Service Light Liquid Heavy Liquid Service Service Valves 1.5431715 2.7532660 24 Connectors 6.5471275 6.7403549 241 Flanges 1,643464 1.208904 0 Pumps 0 46 0 Other* 127132 4027 0 VOC Content(wt%) 25.6422.5 100 100 Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: October 15,2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit#95OPWE039 Page *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms,hatches,instrument meters,polish rods,pumps and vents. A running total shall then be kept of all additions and subtractions to the component count. A manual component count shall be performed at least once every five (5) calendar years as a check against the running total. The most recent running total shall be used for emission calculation purposes. The records shall be kept at the site and made available for Division review upon request. 6.2 Statewide Controls for Statewide Oil and Gas Operations 6.2.1 Colorado Regulation No. 7, Section Xl1.G Requirements: This facility is subject to the following State-Only Enforceable requirements for gas-processing plants located in the 8-hour Ozone Control Area of Colorado Regulation No. 7, Section XII, `'Volatile Organic Compound Emissions from Oil and Gas Operations": 6.2.1.1 For fugitive volatile organic compound emissions from leaking equipment, the leak detection and repair (LDAR) program as provided at 40 CFR Part 60. Subpart OOOO (July 1. 2017; Condition 1.4) applies, regardless of the date of construction of the affected facility, unless subject to the LDAR program provided at 40 CFR Part 60, Subpart 0000a (July I, 2017). (Colorado Regulation No. 7. Section XII.G.I.). 6.2.1.2 Natural gas processing plants within the 8-hour Ozone Control Area constructed before January 1. 2018 must comply with the requirements of Section XII.G. (See Condition 1.4) beginning January 1, 2019 (Colorado Regulation No. 7. Section XII.G.3.). 6.32. This source is subject to 40 CFR Part 60, Subpart KKK, New Source Performance Standards (NSPS) (Adopted into Colorado Regulation No. 6, Subpart KKK): Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants. The following items apply: 6.32.1 For all equipment types except for affected compressors only, compliance with NSPS KKK is presumed, provided the requirements of NSPS OOOO (Condition 6.2) are met.Inspection and maintenance requirements as stated in §60.632. §60.633. and §60.634. 6.3?.2 Affected compressors only are subject to the following applicable requirements:Record keeping requirements as stated in §60.635. 6.3.2.1 Standards, as required by §60.632 6.3.2.2 Exceptions, as required by §60.633 6.3.2.3 Record keeping requirements. as required by §60.635. 6.3.2.4 Reporting requirements. as required by §60.636. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1,2012 LAST REVISED: October 15, 2018 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Spindle Natural Gas Processing Plant Permit# 95OPWE039 Page 6.2.3 Reporting requirements as stated in §60.636. Reporting under this section is to be fulfilled concurrently with Appendix B compliance monitoring reporting and shall be submitted to the Division. In addition. the document shall detail procedures for leak detection and leak repair for the equipment and piping subject to Subpart KKK. Any changes to the document required as a result of the Division review of the document shall be accomplished as directed in writing by the Division. The document shall be retained at the plant and reviewed at least annually by the permittee and revised as necessary. The document shall be made available for Division inspection upon request. The document may be used in a compliance evaluation and determination. The requirements of Subpart KKK include a number of options and alternatives. As a minimum the document shall detail all the applicable requirements, alternatives and options to be followed, the procedures and equipment used for the testing, the instrumentation calibration and performance requirements, action levels, actions to be taken, time frames for performing the actions, reporting requirements, and provide any additional information as might be needed to fully and completely demonstrate compliance with the Subpart KKK and Regulation No. 6, Part A, General Provisions. 6.4 Regulation No. 7, Section XII.G (40 CFR Part 60, Subpart OOOO NSPS) This facility is subject to the LDAR requirements of Colorado Regulation No. 6, Part A. New Source Performance Standards, Subpart OOOO (40 CFR Part 60, Subpart OOOO) "Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution for which Construction. Modification or Reconstruction Commenced After August 23. 2011, and on or before September 18. 2015." This facility is subject to the following applicable requirements: 6.4.1 Equipment leak standards applicable to affected facilities at an onshore natural gas processing plant(§60.5400) 6.4.2 Exceptions to the equipment leak standards for affected facilities at an onshore natural gas processing plant(§60.5401) 6.4.3 Recordkeeping requirements for affected facilities subject to VOC requirements for onshore natural gas processing plants (00.5421) 6.53 Regulation No. 6, Part A, General Provisions applies as follows: 6.53.1 No article, machine, equipment or process shall be used to conceal an emission which would otherwise constitute a violation of an applicable standard. Such concealment includes,but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentrations of a pollutant in the gasses discharged to the atmosphere (§60.12) 6.5.2 Records of startups, shutdowns, and malfunctions shall be maintained, as required under 40 CFR Part 60 §60.7. Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1, 2012 LAST REVISED: October 15, 2018 Air Pollution Control Division Colorado Operating Permit Appendix I Compliance Assurance Monitoring Plan Page APPENDIX I Compliance Assurance Monitoring Plan Background a. Emission Unit Description: Eight(8) Waukesha Model L-7042 GS'Natural Gas Fired Internal Combustion Engines, turbocharged, 4-cycle, Standard Rich Burn, powering a natural gas compressor. Engine ratings for each engine are as follows: Facility ID AIRS ID Site Rating C-136 051 1232 HP C-137 052 1232 HP C-138 053 1232 HP C-I47 081 1232 HP C-139 055 1232 HP C-140 056 1232 HP C-141 057 1232 HP C-153 060 1000 HP b. Applicable Regulation, Emission Limit, Monitoring Requirements: Engine C-136 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 11.9 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Engines C 136, C-137, C-141 Regulations: Operating Permit Condition 1.1 Emission Limitations: NOx 24.03.9-6 tons/yr Monitoring Requirements: Pressure drop and catalyst inlet temperature Operating Permit Number: 95OPWE039 FIRST ISSUED: May 1, 1999 RENEWED: July 1,2012 LAST REVISED: October 15, 2018 SAN 31 'Mt Fugitive Component Leak Emissions APEN Form APCD-203 GDP; Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for fugitive component teak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 / 0015 /034 [Leave blank unless APED has already assigned a pmmit g and AIRS ID] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Spindle Gas Processing Plant SW Sec 34 T2N R67W Site Location Weld Site Location: , County: NAICS or SIC Code: 1321 Mailing ddress: 370 17th Street, Suite 2500 (Includp Code) Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E-Mail Address2: rshankaran@dcpmidstream.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. 424972 (COLOADO Form AP(..J 203 Fu;i;lvc Compo^nnt tcai� , APEN E t 12;2\1c 1 I ®, It: Permit Number: 95OPWE039 AIRS ID Number: 123 /m15/034 Section 2 - Requested Action D NEW permit OR newly-reported emission source(check one below) -OR- ✓❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change process or equipment ❑ Change company name3 ❑ Add point to existing permit Change permit limit ❑ Transfer of ownership' ✓❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: New component count& EGA: Change fugitives VOC limit, update LDAR control factors, and add NSPS Subpart 0000 LDAR (Reg 7, Section XII.G) requirements 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 'For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information Company equipment Identification No. (optional): P-181 For existing sources,operation began on: 2000 For new or reconstructed sources, the projected start-up date is: El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Facility Types: ❑Well Production Facility ❑Natural Gas Compressor Station 0 Natural Gas Processing Plant ❑Other(describe): 5 When selecting the facility type,refer to definitions in Colorado Regulation No.7,Section XVII. n,- f COLORADO !Min?Arl_.�-2L�3 F gle'V Cy!i11;)t) Er. Leak�� Et l≥'?„ � t-, '{_�� 'l l;!: I} IliLts< 2 Health°�"sm Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/034 Section 4 - Regulatory Information What is the date that the equipment commenced construction? 2000 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Will this equipment be located at a stationary source that is considered a ❑Yes 0 No Major Source of Hazardous Air Pollutant(HAP)emissions? Are there wet seal centrifugal compressors or reciprocating compressors Yes No located at this facility? ❑ ❑ Is this equipment subject to 40 CFR Part 60, Subpart KKK? El Yes ❑ No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? O Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? ❑Yes 0 No EJC per Is this equipment subject to 40 CFR Part 63, Subpart HH? laYes X N° 6/5/2020 Is this equipment subject to Colorado Regulation No. 7, Section XII.G? 0 Yes O No email Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? O Yes 0 No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? O Yes 0 No Section 5 - Stream Constituents 0 The required representative gas and liquid extended analysis(including BTEX)to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight%content of each applicable stream. VOC Benzene Toluene Ethytbenzene Xylene n-Hexane 2'2'4 Stream (wt%) (wt%) (wt%) (wt%) (wt%) (wt%) Trimethytpentane fwt%) Gas 25.64 0.026 0.013 0.0005 0.002 0.218 0.00 Heavy Oil (or Heavy Liquid) 100 0.103 0.051 0.002 0.010 0.851 0.002 Light Oil (or Light Liquid) 100 0.103 0.051 0.002 0.010 0.851 0.002 Water/Oil Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.7 Attach a topographic site map showing location COLORADO Form AP�.D-20, FugItiv tr(;1 i' « ,,,,�� t �_ '�.�, R-`�1�1 i/'L±;19 3 - (xw rt.rde. `r.0 Permit Number: 95OPWE039 AIRS ID Number: 123 /00151034 [Leave . C) aErady as.ogneciaper it and AIRSig] Section 7 - Leak Detection and Repair (LDAR)and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: 0 LDAR per 40 CFR Part 60, Subpart KKK ❑Monthly Monitoring- Control: 88%gas valve, 76%light liquid valve, 68%light liquid pump 0 Quarterly Monitoring- Control: 70%gas valve, 61%light liquid valve, 45%light liquid pump ✓❑ LDAR per 40 CFR Part 60, Subpart 0000/0000a 0 Monthly Monitoring- Control: 96%gas valve, 95%light liquid valve, 88% light liquid pump,81% connectors 0 LDAR per Colorado Regulation No. 7,Section XVII.F ❑Other6: ❑No LDAR Program 6 Attach other supplemental plan to APEN form if needed. COLORADO Forme`k1� t f i Leak W t" r<-fir � a�i"` � 12/2019 uepwavaanNe �= t� tt�s - F,.,I.°v_ Component,s „ _w�. .�_� _ . s v E 4 Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/034 Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. Table 2-4 was used to estimate emissions7. ❑Table 2-8(< 10,000ppmv)was used to estimate emissions7. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑ Estimated Component Count Actual Component Count conducted on the following date: June 2019 + 20% Buffer Equipment Type Service Open-Ended y Connectors Flanges Pump Seals Valves Other Lines Gas Count8 6,547 1,643 0 0 1,542 127 Emission Factor 4.41 E-04 8.60E-04 - -- 9.92E-03 1.94E-02 Units lb/hr/component lb/hr/component — -- lb/hr/component lb/hr/component Heavy Oil(or Heavy Liquid) Counts 241 0 0 0 24 0 Emission Factor 1.65E-05 -- -- -- 1.90E-05 — Units lb/hr/component -- — -- lb/hr/component — Light Oil(or Light Liquid) Counts 6,740 1,208 0 46 2,753 40 Emission Factor 4.63E-04 2.43E-04 -- 2.87E-02 5.51 E-03 1.65E-02 Units lb/hr/component lb/hr/component — lb/hr/component lb/hr/component lb/hr/component Water/Oil Counts 0 0 0 0 0 0 Emission Factor -- -- — -- __ Units __ -- — -- -- -- 'Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-453/R- 95-017). 8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the actual calendar year emissions below. 9 The"Other"equipment type should be applied for any equipment other than connectors,flanges,open-ended tines,pump seals,or valves. - i I't,rrt A�'C.�i-2t13 lllaltl'::a .�� ₹`,�';. _, _ ! _c� _ >, 3 r'E=C� ._ �3�� 1�',`2'�15 5 I dwA" Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/034 Section 9 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Actual Annual Emissions Requested Annual Permit Emission Pollutant CAS Limit(s)10 Number Uncontrolled Controlled11 Uncontrolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) vOC 91.0 28.7 114.85 9.88 10 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 11 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. . Section 10- Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria12 Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Actual Annual Emissions Requested Annual Permit Chemical Name CAS Emission Limit(s)t0 Number Uncontrolled Controlledtl Uncontrolled Controlled (lbs/year) (lbs/year) (Ibs/year) (lbs/year) Benzene 71432 Toluene 108883 EJC per Ethylbenzene 100414 6/5/2020 email Xytene 1330207 n-Hexane 110543 1,490.8 467.0 1,954.1 736.2 168.0 2,2,4-Trimethylpentane 540841 Other: Methanol 67561 — -- 657.6 247.8 56.6 10 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 11 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. ®`COLORADO For APCD-203 Fw L'fE c n ,u L r e 1:c Er ;i,10 •cry!a ar�V151Jn 12;201H 6 (w.ni�uw Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/034 I _ a portal and.,'ter IJ} Section 11 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. V311).O Signature of Legally Authorized Person (not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692.3175 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692-3148 Denver,CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment a icoLORADO Form ;� APCD-2'3 Ft _r:_ _ 'W'= C. Lo Ei _�_ �A;DEll Pe,is,o 12;2019 7 ar.namdwrur JAM 3 1 2Q,. Spark Ignition Engine APEN C '44.41;10* Form APCD-201 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition (e.g. gas-fired) reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 / 0015 /051 [Leave bianK unless ARCD has d1s° ny assIgued a oarnlit r are NERD ID; Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location Site Location: SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail Address 2: 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 4211913 reliksICOLORADO Form APCD-7,01 �-'�. 1`?� _ . ._ _ ;1C Revisvm 7120 19 1 � .=a..d'�... Permit Number: 95OP'NE039 AIRS ID Number: 123 /0015/051 Section 2 - Requested Action O NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source O PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GPO23(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) O Change fuel or equipment O Change company name4 ❑ Add point to existing permit 0 Change permit limit ❑ Transfer of ownerships O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info&Notes: Lower criteria pollutant permit limits based on updated Reg 7 applicability for AOS replacement engine. 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g.ENG-1,Engine 3,etc.)? Yes If yes, provide the Company Equipment Identification No.: C-136 General description of equipment and purpose: Natural gas compression For existing sources, operation began on: 1973 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) 0 Yes O No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 se COLORADO Form AF,CD L I t'.=` crf APEN - 12,2019 2 1 e �E..°'A Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/051 H ,.-•`)C F)r a _�.. ��;� A Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression O Pump Jack O Water Pump O Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Waukesha Engine Model: L-7042 GSI Serial Number: 360657 What is the maximum designed horsepower rating? 1,232 hp What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7,580 BTU/hp-hr Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: Engine Features: Cycle Type: O 2-Stroke 0 4-Stroke Combustion: O Lean Burn 0 Rich Burn Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes,what type of AFRC is in use? 0 O2 Sensor(mV) ❑NOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? O Yes 0 No Engine Dates: What is the manufactured date of this engine? 3/06/1981 O If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? < 1981 What is the date this engine was first located to Colorado? April 2012 What is the date this engine was first placed in service/operation? < 1981 What is the date this engine commenced construction? < 1981 What is the date this engine was last reconstructed or modified? NA 7 The serial number must be submitted if coverage under GP02 is requested. F1Em.APC7-JQl iwyt,rn Eirciire1.Ptiti "?Yl;lOt't 12;`1019 3 I wrm00t. s.a Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/051 f.."f I A-S Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.69 Operator Discharge Height Temp. Flow Rate Velocity Above Ground Level Stack ID No. (Feet) F) (ACFM) (ft/sec) C-136 36 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) D Upward ❑ Downward ❑ Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) ✓❑Circular Interior stack diameter(inches): 12 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate 61 100%Load Actual Annual Fuel Use Requested Annual Permit Limits (SCF/hour) (MMSCF/year)SCF/flour , 4 (MMSCf/year) 8,980 65.2 78.7 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑Field Natural Gas Heating value: BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑✓ Other(describe): Residue gas Heating Value(give units): 1,075 Btu/scf 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. 4 i 7 rot ru:;ate ®Icoioe�oo [)- ;r i �< <1� _, t t: 1," ! P,2‘, 1�!Jil li `I to to �'°n.., Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/051 i t APCD ?i a„--_. ,., Section 7- Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant Description (%of total emissions captured by (%reduction of captured control equipment) emissions) - TSP(PM) PM10 PM2.5 SOx NOx NSCR 100% 91% VOC NSCR 100% 53% CO NSCR 100% 75% Other: NSCR-HAPs 100% Formaldehyde 76%,Other HAPs 50% From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Pollutant Emission Limit(s)8 Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissionst0 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 1,94E-02 lb/MMBtu AP-42 0.68 0.68 0.79 0.79 PM10 1.94E-02 Ib/MMBtu AP-42 0.68 0.68 0.79 0.79 PM2.5 1.94E-02 IbIMMBtu AP-42 0.68 0.68 0.79 0.79 SOx 5.88E-04 ib/MMBtu AP-42 0.021 0.021 0024 0.024 NOx 11.0 g/hp-hr Mfg 112.1 34.0 130.9 11.9 VOC 1.5 g/hpfir Mfg 15.3 8.4 17.8 8.3 j CO 8.0 g/hp-hr Mfg 81.5 34.0 95.2 23.8 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria 0 Yes ❑No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissionsl0 Number Mfg.,etc.) (lbs/year) (lbs/year) Formaldehyde 50000 2.05E-02 Ib/MMBtu AP-42 1436.35 344.72 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: 10 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO Form A°CI? '2i;'; r lc2r r < < _- ,.7' `,?EN - RPvislo5 12/2019 °""wa® COLOnt "c Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/051 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. lirriatot/ 1/3 I PE' Signature of Legally Authorized Person(not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver,CO 80246-1530 APCD Main Phone Number (303)692.3150 Make check payable to: Colorado Department of Public Health and Environment ® COLORADO Farm Srx, 4PEN Revision 7212019 6 I nit DCP Midstream fi� 370 17th St.,Suite 2500 � Denver,CO 80202 (303)605-2029 Midstream www.dcpmidstream.com February 12,2020 E-mail Delivery Colorado Department of Public Health and Environment Air Pollution Control Division LAVED ATTN: Elie Chavez RBI VW 2L) 4300 Cherry Creek Drive South Denver,CO 80246-1530 Sul loamy Sources Re: Spindle Natural Gas Processing Plant Title V Modification: 95OPWE039 AIRS ID 123/0015 Dear Mrs. Chavez: DCP Operating Company, LP(DCP)is submitting the attached minor modification application addendum for the Spindle Natural Gas Processing Plant(Spindle),located at SW Section 34,Range 67W,Township 2N in Weld County,Colorado.This facility currently operates under Title V permit 95OPWE039 originally issued on May 1, 1999 and last revised on October 15,2018. DCP is requesting that the changes proposed to the emission limits for compressor engines C-137 and C- 141 (AIRS 052,057)as part of the original minor modification application submitted January 31,2020 be rescinded.It has been determined that these proposed changes constitute a significant,rather than minor, modification to Title V permit 95OPWE039,-and a separate significant modification application for these two sources will be submitted. DCP requests that the proposed changes to facility fugitive emissions and compressor engine C-136 (AIRS 034,051)be processed as submitted. This addendum has been reviewed by DCP's Responsible Official Tauna Rignall, and the RO certification included as Attachment A to this addendum certifies that the proposed changes to facility fugitive emissions and compressor engine C-136 still meet the criteria for use of minor permit modification procedures under Colorado Regulation No.3,Part C, Section X.D.3. If you have any questions or require any additional information about this submittal,please contact Marie Cameron at(303)605-2029 or MECameron@dcpmidstream.com. Sincerely, DCP Operating Company,LP 711 Marie Cameron Senior Environmental Engineer Attachment A: Responsible Official Certification Spindle Natural Gas Processing Plant I have reviewed this Minor Modification application supplied under the Authority of Regulation No. 3, Part C,Section X(5 CCR 1001-5)in its entirety and,based on information and belief formed after reasonably inquiry,I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures be used to process this application.This certification is in conformance with Regulation No. 3,Part C,Section X.D.3 (5 CCR 1001-5). Tauna Rignall General Manager,North Area Operations Printed or Typed Name Title 1/41 Signal e of R- .ons ee icial D to DCP Midstream P 370 17Th St..Suite 2500 De CO �f 2 7 Denver.CO 80202 Midstream. (301)605-2039 www.dcpmidstream.com April 24, 2020 Via UPS: 1Z F46 915 02 9210 8013 Colorado Department of Public Health and Environment Air Pollution Control Division AKIN: Elie Chavez 4300 Cherry Creek Drive South Denver, CO 80246-1530 Re: Spindle Natural Gas Processing Plant Title V Modification: 95OPWE039 AIRS II) 123/0015 Dear Mrs. Chavez: DCP Operating Company. LP (DCP) is submitting the attached significant modification application for the Spindle Natural Gas Processing Plant (Spindle), located at SW Section 34, Range 67W, Township 2N in Weld County. Colorado. This facility currently operates under Title V permit 95OPWE039 originally issued on May 1, 1999. A minor modification package was submitted for the Facility in January 2020 that included some of the changes discussed below. However. the specific revisions requested in this package were determined to require a significant modification, rather than a minor modification. DCP has included the APEN forms provided with the January 2020 minor modification application, but is not resubmitting supporting emission calculations, per Division request. Summary of Changes Waukesha L-7042 GSI Compressor Engines 0137 and C141 (AIRS 052 and 057) DCP is requesting a decrease in the NO, emission limits and corresponding compliance emission factors for the above two compressor engines. DCP has previously submitted summaries of 2019 quarterly portable analyzer results in support of the requested emission limit decreases. DCI' is requesting these reduced emission limits to ensure that NO. emissions from each unit arc permitted below NA-NSR Major Modification significance levels, and that this facility can continue to perform permanent engine replacements under the Alternative Operating Scenarios(AOS) provisions detailed in Section 1.0, Condition 4.0 of Title V Operating Permit 95O1'WI.039 following the reclassification of the Colorado ozone non-attainment area from moderate to serious. Additionally, DCP is requesting that the serial number listed for engine C I37 (AIRS 052) be updated to reflect a permanent engine replacement that occurred on June 25. 2019. I Regulatory Analysis There are no changes in regulatory applicability for the compressor engines listed above based on the requested decreased emission limits. DCP will continue to comply with all applicable state and federal requirements for these engines. Attachments We are including the 100 series Title V forms pertaining to the facility, as well as forms specific to each engine and stack, where applicable. The list of the most recent APENs that have been submitted for the facility has been updated (form I02A)and copies of the relevant APEN forms from the January 2020 submission have been included. Emission calculations and supporting documentation were included in the previous submission for these engines and have not been resubmitted with this package. For each of the engines, we have included forms 200 (stack). 302 (internal combustion engine), 600 (emission unit EIAPs), 601 (emission unit criteria pollutants), 604 (applicable requirements), 606 (compliance certification), and a form 700 (to provide information regarding compliance methods). Only applicable requirements that are being revised are shown on form 604. Facility- wide I IAP and criteria pollutant forms have also been included (forms 602 and 603) and well as the necessary signed certification forms(800 series). The insignificant activities list for the facility has been updated. The following attachments needed to make the requested changes to operating permit 95OPWE 039 have been included: • Attachment A: Form APCD-102: Facility Emissions Inventory • Attachment B: Operating Permit Forms • Attachment C: Plot Plan • Attachment D: January 2020 minor modification APEN forms if you have any questions or require any additional information about this submittal. please contact me at(303)605-2039 or rshankarar Adcpmidstream.com. Sincerely, DCP Operating Company, LP Roshini Shankaran Senior Environmental Engineer Attachment A: Form APCD-102: Facility Emissions Inventory Spindle Natural Gas Processing Plant Colorado Department of Public Health and Environment u Form APCD-102 - Air Pollution Control Division H Facility Wide Emissions Inventory Form 9 Vet April,2015 CO gyp/ Company Name:Der Operating.Company,LP Source Noose:Spindle Gas Plain • 9; A. .:4.4rA Source AIRS ID:123/00 1 0 oneo:mood Pncenn,l In 0:0411P re) 10000lea Poentmi men.)Pic) cruenntvT)) '1 IleP.11n:ryr) Cn ur,n(IPV) I nAPa ObeyQ A112.5 115 equ'pete,u Desrei,00,, TSP 201219 P012.5 SOl NOs VOC CO 110110 Aremi 4ern 02 To En 90 n-Iles Stele 224-1'0IP '1'SP 1'5320 3• .5 Sul AOx 00C CO I Reno Aeetal Ono Pe "IL Etc \yl 0-Ilex 11e16 224"T11P 12300I 5/024 enginei'211 0.14 014 0.14 0.00 2865 400 30,40 1 305 42 24 8 0 0 46 014 0.14 0,1x1 000 500 2.22 500 I 71 01 20 13 4 0 I 0 03 0 1200010/014 ...ea 0.00 0.00 0.(b 000 000 114 85 D.DD I 0 0 0 216 1111 5 22 1010 658 000 050 000 000 000 988 000 I 0 0 0 89 4.1 2 8 716 248 2 1 2 3 201 510 5 1 Perin C-I36 029 0.19 079 002 13086 17.84 95.17 I 1677 220 215 109 16 250 0.19 0.73 019 002 11.90 833 23.79 I 114 108 65 23 1 0 125 96 2 0 0 4Ul a 0 12/U015N(2 Fogme C"113 9129 099 039 002 ,13940 1784:.. 0117 I 1421 228 615 129 46 2 In n 250 0 079:: 010 970. 002 0001. 916 001,1 I 403 1. 100 y5 21 I 8 0 3{5 9. 123/0015/051 p.na C-138 0.79 0.79 0.79 0.01 130.80 17.84 95.17 I 1.673 228 215 I. 40 2 I4 0 255 0 079 039 0.79 0.02 21.79 9.52 3962 I 403 114 108 60 23 1 a 0 III 1230010095 Euelue.e439 098 098 098 003 110.86 1784 95.17 12,066 281 265 159 511 2200 302 o 098 0.90 0.98 003 23.]9 1190 4759 I 496 141 Ill Se 20 I 10 0 154 123/00150050 Engine C"140 0.01 098 098 003 13086 1784 91.11 12,0611 281 265 'ISY 20 0 308 0 lien 093 098 003 II 90 2379 I 406 141 133 80 2HII 0 154 0 Sb ? 00.33 I I:n"f0d161D57 Geynnl.14: 074 070 079 002 .13084 17:84 95 17 149177 723 .616 129 '40 3 lb 0 250... 0' 0;'39 0:79 000 002 2401. 976 3462 I 401 114 105 05 21 1 4 11 ill 0',' `. 12.12015260 622lon 2,53 039 029 039 002 10620 14.48 77 2.1 16]3 028 215 ill 46 2 16 0 250 0 0.79 0.79 0.79 001 39.31 964 2897! 403 114 108 61 23 I 8 0 !00 123/0515;001 Engine C-215 039 0.39 019 0 02 11.73 21.46 46 91 4,093 618 398 34 32 14 0 194 0 039 019 0 39 0.02 1173 821 2).46 I 409 324 199 17 16 2 7 0 97 133:0015262 Engine C-T12n'.171 003 0.00 000 000 000 000 000 0 0 I3 0 0 0 0 000 0.00 000 0 00 0,00 000 000 I 0 0 0 0 0 0 0 0 0 0 123110015006] 11178 TEOOrhydralor 000 000 0.00 0.00 000 2137 0.00 0 0 0 2546 7,845 67 5,113 761 0 0 0.00 000 000 000 0.16 126 0.85 I 6 0 0 160 49.1 43 1 42 123)0411.064 P-17915Mm\ m3e Out 011n 0 0 0 .5 e41er 43 48 48 001 6.12 0,15 31 0 0 0 0 227 0 048 046 004 6.32 0.31 5.11 1 0 0 0 0 2 221 123!0005266 Stabilized Condelnale T.nkl.0 000 000 000 000 0.011 4]29 000 a 0 0 0 0 0 0 000 000 0001 0.00 000 2.10 000 1 0 0 0 0 0 0 0 0 0 0 , 123/00151070 Vug,iioi'.221 079 040 0.40 001 6866 6.87 4577 815 114 107 6121 8 0 116 0 040 0.40 0,40 001 22.89 4.58 22891 200 57 54 65 II I 4 0 62 0 123/00151081 (name C-147 0:90 098 098 003 13086 1784 95,17 2,066 281 265 159 56 20 0 108 0 098 a.02 0.98 000 23.79 5.95 2079 207 141 100 80 28 I 10 0 151 0 123/00151082 Plural FS. 000 000 0.00 0.01 2.15 112.79 9.74 0 0 0 490 268 46 0.074 0 0 005 0.00 0.00 O01 2.15 3664 9.74 1 00 0 25 13 0 2 154 0 0 12120/590 0 PROPANELOAD 00 0.00 0.00 0.00 0 0 l3 00 138 00 0 0 0 0 0 0 0 0 000 0011 0 0 00 000 00 118 ono I 0 0 0 0 0 0 0 0 0 0 1•e..1991 00,mees Stbimnl 9 8.71 8.31 1,31 030 1,139,76 1,087.54 881.63 19,8281 9,788 2,412 4,527 8,682 709 0,344 6,016 :3,199 5 830 8,31 8.31 0.30 210.79 139.66 334.021 3,904 1,394 1,208 929 780 56 415 1,160 1,522 2 Areti Only-Permit Eremil Sources 12300153 BD Pw"1'ANKS 00 0.0 00 0.0 00 14 00 0 0 0 73 0 0 0 229 0 ll 00 00 00 00 00 I4 00 i• 0 0 5 73 0 -0 0 229 0 0 I _- 1 I I APEN Only.9142,310 0.0 0.0 0.0 0.0 0.0 1.4 8.2 0 0 0 73 0 a o 229 o a o,5 5.5 0.0 0.8 5.5 14 0.0 , 0 0 0 73 0 0 0 339 0 0 APES Tempt/Im1pl1111.005 6.3 Spindle Ltsignilicam Activities D0 00 0.0 00 36 13 4.7 0 U U 0 D 0 0 201 324 0 OU 00 0,0 0,0 56 1.3 4.7 0 0 a 0 0 0 b 201 324 0 Iusiguircmll 5ublolal o 0.0 0.0 0,0 0.9 5.6 I,3 4.7 0 0 0 0 0 0 0 201 324 0 0.0 00 0.0 0.0 56 1.1' 4.7 ! 0 0 0 0 0 0 U 201 3I1 a 1'o3ol,A115oureer H I 8.7 I 8.3 I 8.3 I 0..1 1 1145.3 I 22002 I 886,3 19,8181 2.7881 2,416 I 4,600 I 8,688 I 159 I 5,046 I 6,446 I 3,523 I 5 I 8.4 I 8.1 I 8.3 I 0,3 1216.4 1 142,4 1338.7; 3,924 I 1,394 I 1208 11,002 I 720 I 56 1415 11,5901 1,843 I 1 Uncontrolled RAPS Summary 0209')4 9.9 I IA I 12 1 2.3 I 4.3 I 04 I 2.7 I 32 I 1.8 I 0.0 1 Controlledi8AP2Sammury(ITV)61 2.0 II 0.7 I 06 I 0,5 I 0.4 10.0 10.2 I 02 I 0.9 I 0.,1 llnconlrollea Talnl,an nags corv3-I 27;2 I Controlled Toot All 11e.(TPx•)=I ^.• Footnotes: I.This loan should he completed to include bosh existing sources and all proposed new or modifications to existing emissions sources 2 Iltile en3issions source is new then enter"proposed"under the Permit No.and AIRS ID data columns 3 HAP abbreviations include: HZ—Benzene 224-IMP_2,2,4-Trimethylpenlane Tot Toluene .4ceta1 Acetaldehyde ER=Blhylbenoune Aero=Acralein Xyl=X)Icne n-Hex=n-Iiex2ne HCHO Formaldehyde Meth=Methanol 4 ADEN Exempl/lnsigndiconl 1020001 should he included when warranted. One 001552ne Company.LP 3/1512020 Page 1 of 1 Attachment B: Operating Permit Forms Spindle Natural Gas Processing Plant t 1perating Pemtit Application FACILITY IDENTIFICATION FORM 2000-100 ('olorado thpartlnent of Public I lealth and Environment Rev U6-93 Air Pollution Control Division SEE INS1'RUC'TIONS ON REVERSE SIDE I. Facility name and Name Spindle Gas Processing Plant mailing address Street or Route 9101 Weld County Rd 14 City,State, Zip Code Ft Lupton,CO 80621 2. Facility location Street Address 3 ''A miles%pest of Fort Lupton,CO (No P.O. Box) City,County,Zip Code Fort Lupton,Weld,80621 3. Parent corporation Name DCP Operating Company,LP Street or Route 370 l7'h Street,Suite 2500 City, State.lip Code Denver,CO 80202 Country(if not U.S.) 4. Responsible Name Tauna Rignall official Title General 1lanager,North Arca Operations Telephone 970-352-3104 �. Permit contact person Name Roshini Shankaran Title Environmental Engineer (If Different than 4) Telephone 303-605-2039 6. Facility SIC code:I31 I 7. Facility identification code: CO 123-0015 8. Federal 'lax I. D. Number: 841041166 9. Primary activity of the operating establishment: Natural Gas Liquids Processing and Gathering 10. Type of operating permit 9 New ® Modified 9 Renewal I I. Is the facility located in a"nonattainment"area: Yes ❑No If"Yes",check the designated"non-attainment"pollutant(s): Attainment for all Pollutants 9 Carbon Monoxide 114 Ozone 9 PM l0 ❑ Other(specify) 12. List all (Federal and State)air pollution permits(including grandfathcred units),plan approvals and exemptions issued to this facility. List the number,date and what unit/process is covered by each permit. For a Modified Operating Permit,do not complete this item. utxrating Permit Application FACILITY PLOT PLAN FORM 2000-101 Colorado Department nt I'uhhc Itealth and I,Me innnnent Rev 06-95 Air Polluliun Control I)ivision Facility Name: Spindle Cas Processing Plant Facility Identification Code: CO 123-0015 The operating permit must be prepared and submitted on forms supplied by the Division. Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Ilse"NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. In order for a comprehensive air quality analysis to be accomplished, a facility plot plan MUST be included with the permit application. Drawings provided must fit on generic paper sizes of 8 1/2" X 11", 8 1/2" X 14" or 11" X 15", as appropriate to display the information being provided. Include the facility name and facility identification code on all sheets. For facilities with large areas, sketches of individual buildings, on separate drawings, may be needed to allow easy identification of stacks or vents. Insignificant activities do not need to be shown. ® 1. A plant layout (plan view) including all buildings occupied by or located on the site of the facility and any outdoor process layout. ❑ 2. The maximum height of each building (excluding stack height). ® 3. The location and coded designation of each stack. Please ensure these designations correspond to the appropriate stacks listed on the other permit forms in this application. The drawings need not be to scale if pertinent dimensions are annotated, including positional distances of structures, outdoor processes and free standing stacks to each other and the property boundaries. ❑ 4. The location of property boundary lines. ® 5. Identify direction "North" on all submittals. Are there any outdoor storage piles on the facility site with air pollution emissions that need to be reported? ❑ Yes ® No If "Yes", what is the material in the storage pile(s)? Are there any unpaved roads or unpaved parking lots on the facility site? ® Yes ❑ No List the name(s) of any neighboring statels)within a 50 mile radius of your facility: None (grating Permit Application SOURCE AND SITE DESCRIPTIONS FORM 2000-102 Colorado Department of Public IIcalttt and Inaironment Rev ti,-95 Air Pollution Control Division Facility Name: Spindle Gas Processine Plant Facility Identification Code:CO 123-0415 • The operating permit must be prepared and submitted on forms supplied by the Division, Use of this form is required for all operating permit applications. The Division will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this form is optional. Use"NA" where necessary to identify an information request that does not apply and is not in the optional shaded area. 1.Briefly describe the existing Unit(s)to be permitted. Attach copies of Form 2000-700 as needed to provide the information. Process flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing an understanding of the processes involved. The Spindle Gas Processing Plant consists of two operations: a gas processing skid and a fractionation assembly. The gas plant skid consists of two expander plants identified as Plant A and Plant B.The gas processing skid uses straight refrigeration coupled with cryogenic expander processes to recover natural gas liquid(NGL) mixtures from the inlet gas stream.The NGL stream is sent to the fractionation assembly to make various fuel products.A high Btu content methane/ethane residue gas stream is created by the removal of the NGL.The residue gas stream is recompressed and routed to the sales pipeline.A triethylene glycol(TEG)dehydration system operates to dehydrate a slip stream of the residue gas used to regenerate the mole sieves.The mole sieves function to dehydrate the inlet gas.There are twelve(12)engines powering natural gas compressors operating in the inlet,residue, refrigeration,or air compressor service.The site also operates with a 15 million Btu per hour hot oil heater,one propane and BG mix loadout rack, six(6) small natural gas fired heaters for various purposes,4 pressurized tanks for Condensate storage,and one emergency flare stack.All other insignificant activities were included in the 2016 Title V renewal application for this facility. 2.Site Location and Description (Include instructions needed to drive to remote sites not identified by street addresses) The Plant is located near 3 1/2 miles west of Ft. Lupton in Weld County,Colorado.The Plant address is 9101 Weld County Road 14,Fort Lupton, CO 80621. Driving Directions:From Fort Lupton,go 3.5 miles west on Highway 52 and then 1/4 miles north on County Road 19. 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: Protection ❑ Other, specify tII Hard Hat E Safety shoes Hearing Protection /4 Gloves Operating Pennit Application SOURCE DESCRIPTION -APENS FORM 2000-102A Colorado Department of Public Itkalth and hnviranment Rev 06-45 An Pollution(u'ntrol Division Facility Name: Spindle Gas Processing Plant Facility Identification Code:CO 123-0015 NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of $191.13 per APEN. 1.For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN)on file with the Division. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, date, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) P162 /C138 123-0015-053 Waukesha L7042 GSI 04/26/2018 P163 /C147 123-0015-081 Waukesha 17042 GSI 04/26/2018 P164/C139 123-0015-055 Waukesha 17042 GSI 06/28/2018 P165/C140 123-0015-056 Waukesha L7042 GSI 06/28/2018 P168/C217 123.0015-024 Caterpillar G342 NA 04/26/2018 P169 /C153 123-0015-060 Waukesha L7042 GSI 04/12/2019 P170/P215 123-0015-061 Superior 8SGTB 04/26/2018 P171 /C212 123-0015-062 Superior 6G825 04/30/2015 CIG-S-2 /C221 123-0015.075 Superior 6G825 04/12/2019 P178 123-0015-063 TEG Dehydrator 04/12/2019 P179 123-0015-064 15 MMBtu/hr Natural Gas Fired Hot Oil Heater 04/29/2016 P181 123-0015-034 Fugitive VOC emissions from Equipment Leaks 01/31/2020 P182 123-0015-066 Condensate Tank Truck Loadout 03/02/2017 F-1 123-0015-082 Plant Flare 12/20/2019 PW TANKS 123-0015-TBD Produced Water Storage Tanks 12/20/2019 PROPANE LOAD 123-0015-TBD Pressurized Propane Loadout to Trucks 12/20/2019 2.No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a construction permit application. New APEN and permit application submitted ❑with this application OR [� under separate cover to Construction Permits Section 3.A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of the unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application may need to be submitted. Revised APEN submitted as part of this application: O Yes No* Li Filing Fee Enclosed New permit application enclosed: ❑ Yes I! No Permit modification application enclosed: F I Yes Q No P160/C136 123-0015-051 Waukesha L7042 GSI 01/31/2020 P161 /C137 123-0015-052 Waukesha 17042 GSI 01/31/2020 P166/C141 123-0015-057 Waukesha 17042 GSI 01/31/2020 *Revised APENs for modified units C-137 and C-141 provided with 01/31/2020 minor modification application NOTE: Use additional copies of Form 2000-700 as needed to provide the above information. Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department ot`Public health and t:_ncironmcnt Rry 66-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3, Stack identification code:C137 3a.Construction Permit Number:95OPWE039 4. Exhausting Unit(s),use Unit identification code from appropriate Form(s)2000-300, 301,302,303, 304, 305,306,307 2000-300 2000-301 2000-302 C137 2000-303 2000-304 2000-305 2000-306 2000-307 5, Stack identified on the plot plan required on Form 2000-101 No Change in Engine Location 6. Indicate by checking: ►� This stack has an actual exhaust point.The parameters are entered in Items 7-13, 0 This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice(GEP)exceeds 65 meters(Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 36.0 (feet) 8. Inside dimensions at outlet(check one and complete): ►� Circular 1.0 (feet) 0 Rectangular —length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) ❑Calculated ❑ Stack Test 10. Exhaust gas temperature(normal): 1.055 (°F) 11. Does process modify ambient air moisture content? ❑ Yes k No If"Yes",exhaust gas moisture content: Nonnat�percent Maximum_percent 12. Exhaust gas discharge direction: 11 Up ❑ Down ❑ Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack?0 Yes / No *****Complete the appropriate Air Permit Application Forms(s)2000-300,301,302,303.304, ***** 305, 306,or 307 for each Unit exhausting through this stack. ulcratmiI'cnnnApplication STACK IDENTIFICATION FORM 2000-2011 Colorado Ucpaiunent or Public IleaIth and l iuvtrnnntcuu Rev 06.95 Air Ynthniun Control Division SEE INSIRUC[IONS ON REVERSE SIDE. I. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. Stack identification code: C141 3a. Construction Permit Number:95OPWE039 4. Exhausting Unit(s), use lJnit identification code from appropriate Form(s)2000-300, 301, 302,303, 304,305, 306, 307 2000-300 2000-301 2000-302 C14I 2000.3(13 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ® No Change in Engine Location 6. Indicate by checking: This stack has an actual exhaust point, the parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7.13, (o to next form. 0 When stack height Good Engineering Practice(sEP)exceeds 65meters(Colorado Air Quality Reg 3.A.V1ll.D)data entry is required for Item 7. 7. Discharge height above ground level: 36.0 (feet) R. Inside dimensions at outlet(check one and complete): ►i1 Circular 1.0 (feet) ❑ Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 114.1 (FPS) ❑Calculated ❑ Stack Test 10. Exhaust gas temperature(normal): 1,055 (°F) 11. Does process modify ambient air moisture content? D Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ®Up 0 Down 0 Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack?❑Yes®No *****Complete the appropriate Air Permit Application Forms(s)2000-300. 301,302.303, 304, ***** 305, 306.or 307 for each Unit exhausting through this stack, INTERNAL COMBUSTION ENGINE OPERATION (llxraling Penn Application FORM 2000-302 ('oluracIo I) partmenl of Public IIcallh and Insinuunent Rev(I6-45 Ali Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. Stack identification code:C137 4. Engine(Unit)code: CI37 4a. Date first placed in service: Before 2004 Date last modified: NA 5. Engine use: natural gas compression 6. Engine Features: 2-Cycle 4-Cycle® Spark-ignition ►.1 Diesel ❑ Standard rich burn ►,1 Standard lean burn ❑ Air/fuel ratio controller t:( 1 urbocharger Low-NOx design ❑ Other(Describe): 7. Emission controls: ❑ No Yes- Attach control device form No change in engine control device Nun-Selective catalytic reduction ® I hrce-v.ay catalyst ❑ Selective catalytic reduction ❑ Ammonia injected 0 Oxidation catalyst 0 Other: K. Manufacturer: Waukesha 9. Model No; 1.-7042 GS! S/N: 240602 10. Max Fuel Design Rate: 9.3 mmL3TU'hr I I. Horsepower Max Design: 1,232 Site: 1,232 12. Heat Rate: 7,580 BTtJ'HP-hr I3. Operating Temp: Min. Max. L:F 14. Fuels: Primary Fuel Backup Fuel tI Fuel Type: Natural Gas Heating Value BTU.-SCE 1,040 Sulfur Content (Wt.%) Neg. Ash Content (Wt.%) Neg. Moisture Content (%) Maximum Ilourly Consumption(Ft',gal) 8,980 scfihr � Maximum Yearly Consumption(Ft',gal) 78.7 MMsef/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15.Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp.(EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify,the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** INTERNAL COMBUSTION ENGINE OPERATION opmaing Permit Application FORM 2000-302 Co!otado Department of Public I lea ldt and rmucmtncnt Re D6.95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I, Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. Stack identification code: C141 4. Engine(Unit)code: C141 4a. Date first placed in service: Before 06/04/2006 Date last modified: ^� 5. Engine use: natural gas compression 6. Engine Features: 2-Cycle 4-Cycle® Spark-ignition ti Diesel ❑ Standard rich burn ® Standard lean burn ❑ Air/fuel ratio controller t7 Turbocharger ►:� Low-NOx design ❑ Other(Describe): 7. Emission controls: ❑ No ® Yes- Attach control device form No change in engine control device EJC per Non-Selective catalytic reduction Three-way catalyst ❑ 6/3/2020 Selective catalytic reduction ❑ Ammonia injected O email Oxidation catalyst ❑ Other: S. Manufacturer: Waukesha 9, Model No: L-7042 CSI SIN: 3500861144345 10. Max Fuel Design Rate: 9.3 mmI3TU;hr 11. Horsepower Max Design: 1,232 Site: 1,232 12 Heat Rate: 7,580 BTU/11P-hr 13. Operating Temp: Min, Max. I P 14, Fuels: Primary Fuel Backup Fuel t/I Fuel Type: Natural Gas Heating Value BTU/SCI: 1,040 Sulfur Content (Wt%) Neg, Ash Content (Wt.%) Neg. Moisture Content (%) Maximum Hourly Consumption(Ft',gal) 8,980 scf/hr Maximum Yearly Consumption(Ft',gal) 78.7 NINIscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used fair compliance demonstration 15, Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp.(EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify,the method of compliance demonstration by completing Form 2000-500, ***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** t>pvratn>>g Nona_Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado I>ep:uintcnt of Public I lealth and Environment Rev 06-95 An Pollution Coning I>ivision SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. Stack identification code:O137 4. Unit identification code:CI37 5. Unit material description:compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references, Attached❑emission calculations provided with 01/31/2020 minor modification application Pollutant CAS Common or Generic Actual emissions Allowable OR Potential to emit Pollutant Name Quantity Measurement Quantity Measurement Units Units 5000(1 Formaldehyde 347.6 lb/yr 402.5 lb/yr NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FOR%I 2000-600 Colorado I)partntent oY Public I lealth and Fm n'onment key On-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE_ I. Facility name:Spindle Gas Processing,Plant 2. Facility identification code: CO 123-0015 3. Stack identification code:( 141 4. Unit identification code:CI41 S. Unit material description: compressor engine 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission factor references. Attached❑emission calculations provided with 01/31/2020 minor modification application Pollutant CAS Common or Generic Actual emissions Allowable OR Potential to emit Pollutant Name Quantity Measurement Quantity Measurement Units Units 50000 Formaldehyde 347.5 lb/yr 402.5 lb/yr • NOTE: If there is a permit for this unit, the permit limits arc the same as the potential to emit. Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle(:as Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code: C137 4. Unit identification code:C137 • 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached ❑ emission calculations provided with 01/31/2020 minor modification application Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity i U TPY Quantity U TPY Particulates(TSP) 1.94E-02 2 0.69 1.43E-02 2 0.79 PM-10 1.94E-02 2 0.69 1.94E-02 2 0.79 Nitrogen oxides * 0.969 2 34.23 0.588 2 24.03 Volatile organic 0.238 2 8.42 0.238 2 9.76 compounds Carbon monoxide 0.969 2 34.23 0.969 2 39.62 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides *NOx 2019 actual emissions calculated using previous(non-modified)compliance emission factor. Updated potential emissions were calculated using the new(modified) compliance emission factor. Units (U) should be entered as follows: 1 =lb/hr 2=Ib/mmBTU 3=grains/dscf 4=lb/gallon 5=ppmdv 6=gram/HP-hour 7=lb/mrnscf 8=lb/HP-hour 9=other(specify) 10=other(specify) Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3. Stack identification code:C141 4. Unit identification code: C141 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached ❑ emission calculations provided with 01/31/2020 minor modification application Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) 1.94E-02 2 0.69 1.94E-02 - 2 0.69 PM-10 1.94E-02 2 0.69 1.94E-02 2 0.69 Nitrogen oxides * 0.588 2 34.23 0.588 2 24.03 Volatile organic 0.238 2 8.42 0.238 2 9.76 compounds Carbon monoxide 0.969 2 34.23 0.969 2 39.62 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds ....Hydrogen sulfide Sulfuric Acid Mist Fluorides *NOx 2019 actual emissions calculated using previous(non-modified)compliance emission factor. Updated potential emissions were calculated using the new(modified) compliance emission factor. Units(U) should be entered as follows: 1=lb/hr 2=Ib/mmBTU 3=grainsidscf 4=lb/gallon 5=ppmdv 6=gram/HP-hour 7=Ib/mmscf 8=lb/HP-hour 9=other(specify) 10=other(specify) operating Permit Application PLANT-WIDE HAZARDOUS AIR POLLUTANTS FORM 2000-602 (olorado Ihpa rtmcnt of Puhhc I lealth and Environment Rev 0( 95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name:Spindle Gas Processing Plant Facility identification code: CO 123-0015 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. Attached O emission calculations provided with 01/31/2020 minor modification application - Pollutant CAS � Common or Generic Actual Actual emissions Allowable OR Potential to emit Pollutant Name Quantity Units Quantity Units 50000 Formaldehyde 2.0 TPY 75070 Acetaldehyde 0.7 TPY 107028 Acrolein 0.6 TPY 71432 Benzene 03 TPY 108883 Toluene 0.4 TPY 100414 E thylbenienc 0.03 TPY 10330207 Xvlenc 0.2 TPY 110543 n-Hexane 0.8 TPY 67561 Methanol 0.9 TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application PI ANT-WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 ("olorado Department of PuNhc Health and Ins irunment j)`t-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name:Spindle Gas Processing 2. Facility identification code:CO 123-0015 Plant 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to emit Maximum allowable TPY TPY TPY Particulates(ESP) 8.3 PM-10 8.3 Nitrogen oxides 216.4 Volatile organic compounds 142.4 Carbon monoxide — 338.7 Lead Sulfur dioxide 0.3 Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist TM Fluorides operating Pcnnn Application APPLICABLE REQUIREMENTS TENTS AND FORM 2040-604 ('otor.do t)elnrnrnent olrPublic Health and t•-nvirnnment STATUS OF EMISSION UNIT Rev 06-95 An Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Spindle Gas Processing Plant 2.Facility identification code: CO 123-0015 3. Stack identification code: C137 4. Unit identification code: C137 5. Pollutant 6. Colorado Air Quality 7. R.I.imitation 9.Compliance Regulations State Status or Only IN OUT Construction Permit Number NOx 24.0 TPV X Note:This form only includes revised limits/requirements 10.Other requirements(e.g., malfunction reporting,special operating conditions from an existing State Only Compliance permit such as material usage,hours of operation,etc.) Status IN OW *Unit has not yet operated for twelve months following modification. **** USE FORM 2000-700 TO EXPLAIN FLOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** Unit 3 up rating PrmurApp hcauon APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado t)cpanmenl ,J I'uhti llca4h an4!I nvurmnrrnr STATUS OF EMISSION UNIT Rc‘Oh )5 Au Pollution('onnul SEE INSTRUCTIONS ON REVERSE SID I. Facility name: Spindle Gas Processing Plant 2. Facility identification code: CO 123-0015 3.Stack identification code: C141 4. Unit identification code: C141 5. Pollutant 6. Colorado Air Quality 7. fi. [.imitation 9. Compliance Regulations State Status or Only IN OUT Construction Permit Number NOx 24.0 TPY X Note: This form only includes revised limits/requirements • _ 10,Other requirements(e.g., malfunction reporting,special operating conditions from an existing State Only Compliance permit such as material usage.hours of operation,etc.) Status IN OUT *Unit has sot yet operated for helve months following modification. **** USE FORM 2000-700'1'O EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR E:ACIi APPLICABLE REQUIREMENT**** Unit 3 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-s4 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas 2. Facility identification code:CO 123-0015 Processing Plant 3. Stack identification code: C137 4. Unit identification code: C137 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. ►:r4 We will continue to operate and maintain this Unit in compliance with all applicable requirements. ►� Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Deadline Actions 1. 2. 3. Progress reports will be submitted: Start date: and every six (6) months thereafter Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas 2. Facility identification code:CO 123-0015 Processing Plant 3. Stack identification code: C141 4. Unit identification code: C141 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance,complete the following. ❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule (If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Deadline Actions 1. 2. 3. I ' Progress reports will be submitted: Start date:- and every six (6) months thereafter Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09.94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Spindle Gas Processing Plant 2. Facility identification code:CO 123-0015 3. This form supplements Form 2000- 604 for Emission Unit(e.g. 8001. POOL,etc.) C137 Additional Information,Diagram Item Number Requirement Compliance Methods DCP calculates rolling 12-month totals,updated NOx Emissions Limit: 24.0 tpy monthly. Records and calculations in Spindle 12- month rollin .totals calculations workbook. Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Spindle Gas Processing Plant Facility identification code:CO 123-0015 • 3. This form supplements Form 2000- 604 for Emission Unit(e.g. B001, P001,etc.) C141 Additional Information,Diagram Item Number ! I Requirement Compliance Methods DCP calculates rolling I 2-month totals,updated NOs Emissions Limit: 24.0 tpy monthly. Records and calculations in Spindle 12- month rolliintotals calculations workbook, O crating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 C•alorado Department of I lealth 09-94 Air Pollution Control Division Facilit Name: S indle Gas Processin= Plant Facility Identification Code:CO 123-0015 ADMINISIRA ION 1 his application contains the following forms ® I 20(X1-NHI,Facility Identification ▪ Donn 2(100.101.Facility Plot Plan ▪ onus 2000-102,-1021.and•10213.Source and Site Descriptions II EMISSIONS SOURCE DESCRIPTION Total Number n of 1 his onn phis application contains the following forms ® r Porn 20X3-200,Stack Identification 2 tone loon for each facility boiler.pnntim! _ ❑ Pori 2000-300.Boiler or Furnace Operation ❑ Donn 20(X1-301,Storage tanks loom 20(X1-302,Internal Combustion Engine 2 ❑ loon 2000-303,Incineration ❑ Port 2000-304,Printing Operations ❑ loon 2(5)0-305.Painting and Coating Operations O Font 2(X10-3116,Miscellaneous Processes ❑ loon 2000-3(17,Glycol Dehydration Unit 111 AIR POI I UTION C'C(N I ROL S5'STF�t total Number of phis I onn this application contains the Ioilotcmg forms: a— I 2000-400.Miscellaneous ❑ loon 2000.4(11.Condenser ❑ I onn 200(1-402,Adsorhers ❑ Dorm 2000-403,Catalytic or I hernial Oxidation ❑ (inn 20(X1-4(14,Cyclones'Setif Chambers O I onn 2000-405•Electrostatic Precipitators ❑ Form 2000-4(16,Viet Collection Systems ❑ loon 2000.407,Itaghouses Fabric Filters RPM IV (•OMPI LANCE 3utal Number DEMONSTRA ZION oil his Furl I his application contains the timlinwing fart 0 Faun 2000-500,Compliance Certification-Monitoring and lone for each facility boiler,printing olernoii. Reporting ❑ loon 2000-5(11.('mutinous Emission Monittnng O Form 20X't0-502,Periodic Emission Monitunng Ptrri3hle Mnnnors ❑ Fort 2011(1-503.Control System Parameters or Operation Parameters ofa Process ❑ loon 2000-504,Monitonng Maintenance Procedures ❑ Donn 2000-505,Stack Testing O Form 200O-506.Fuel Sampling and Analysis ❑ Form 2(X}0-507,Recordkeeping ❑ loon 2000-50S,Oilier Methods --� V. EMISSION SttAtAl:\ItV'AND Total Number COMP!I VVCE(`LRI It�l("A'I`If,)N of-t his Form This application contains the toltowing forms gtwntitving emissions,certifying compliance yi Form 2000-600.t'.missicm t nit Haiardous Air Pollutants 2 with applicable fequtrements,and developing a compliance plan ►�< Form 2000-601.F mission t ams Criteria Air Pollutants 2 • Form 2000-6O?,Facility Hazardous Air Pollutants I • Form 2(100-602.Facility Criteria Air Pollutants I ►�1 Form 2(RMl-b04.Applicable Requirements and Status of 2 Emission Unit O Form 2(M10-605.Permit Shield Protection Identification O Form 2(X10-60b.Emission Unit Compliance Plan- Commitinents and Schedule O I'mm 2000-b07.Plant-Wide Applicable Requirements O 1 onm 2(X10-608.PI.uw\Vide Compliance Plan- Conttmitiments and Schedule Vl. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry.I certify that the statements and information contained in this application are true,accurate and complete. B. CERI-IFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS(check one box only) • I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. O I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement, representation,or certification in,or Omits material information from this application is guilty-of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title Tauna Rignall General Manager, North Area Operations Signature -- Date Signed (meriting Permit Applieautm CERTIFICATION FOR STATE-ONLY CONDITIONS FORA 2000-80(1 (uloradu Department of I lealth 09-94 An Pollution Control I)i sun Facility Name: Spindle Gas Processini Plant Facility Identification Code:CO 123-0015 VI. SIGNATURE OF RESPONSIHI F OFFICIAL- S TAIL ONLY CONDITIONS A. STA]FMFNT OF COMPLETENESS I hat reviewed this application in its entirety and,based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STAR:-ONLY CONDITIONS(check one box only) ►.1 I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements.except for the follottine emissions unit(.): (list all non-complying units) WARNING: Any person %sho knowingly,as defined in§ 18-1-501(6).C.R.S.,makes any false material statement,representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance ssith the provisions of*25-7 122.1,C.R.S. Printed or Typed Name Title Tauna Rignall General Manager, North Area Operations Signature Date Signed SEND ALL MA I FRIA(S TO: COLORADO DEPART MEN1 OF HEALTH APCD-SS-RI 43(10 CEIERRY CREEK DRIVE SOUTH DENVER.CO&)246-1530 JAN 3 1 2020 Spark Ignition Engine APEN Y-.lu Form APCD-201 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition(e.g. gas-fired)reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 / 0015 /057 [Leave bta;k unless APCD ha atreaciy a ,eared a perr t "and AJRS Section 1 - Administrative Information Company Name: DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location: Site Location SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail Address 2: rshankaran@dcpmidstream.com 1 use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 12-3532— aICOIORADO 1ni A°�t: <Ot g =�u_ -, uan Engine APENRevision 12i 201` 1Depanoment Polak , ............ . . Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. 1/ 1/X.0 Signature of Legally Authorized Person (not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment ('. COLORADO rf �+ -,, 7 �'.. ? ['t_i ne ADEN - Revr -_7.;',n 12 201 6 1 Alk NsW i[plensent Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 i_c d. `'t<.nk u ;r,DED h ,alr. I I„ Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No if yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant (%of total emissions captured by (%reduction of captured Description control equipment) emissions) TSP(PM) PM10 PM2.5 SOx EJC per NOx NSCR 100% 70% I82%1 6/5/2020 VOC NSCR 100% 46% CO NSCR 100% 58% email Other: NSCR-HAPS 100% Formaldehyde 76%.Other HAPs 50% From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Pollutant Emission Limit(s)8 Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissions10 Emissions Emissions Mfg.,etc.) (tons/year) (tans/year) (tons/year) (tons/year) TSP(PM) 1.94E-02 Ib/MMBtu AP-42 0.69 0,69 0.79 0.79 PM10 1.94E-02 Ib/MMBtu AP-42 0.69 0.69 0.79 0.79 PM2.5 1.94E-02 Ib/MMBtu AP-42 0.69 0.69 0.79 0.79 SOx . 5.88E-04 Ib/MMBtu AP-42 0.021 0,021 0.024 0.024 NOx 11.0 gmp-hr Mfg 113.0 34.3 130.9 24.0 VOC 1.5 gfhhp-hr Mfg 15.4 8.4 17.8 9.8 CO 8.0 g/hhp-hr Mfg 82.2 34.2 95.2 39.6 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes ❑No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissionsl0 Number Mfg.,etc.) (lbs/year) (lbs/year) Formaldehyde 50000 2.05E-02 Ib/MMBtu AP-42 1,448.35 347.60 Acetaldehyde 75070 _ Acrolein 107028 Benzene 71432 Other: 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. el COLORADO t nl 'i`' " 0 1 Sp i.:, Vition Engine APE-NI Revision 12/2019 5 miaw Ai r Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 /4,437,630.69 Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. (SF) (ACFM) i'ft/sec) (Feet) C-137 36 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) O Upward ❑ Downward ❑ Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 12 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate®100%Load Actual Annual Fuel Use Requested Annual Permit Limit8 [.._ (SCF/hour) .'(MMSCFIyear) (MMSCF/year) 8,980 65.7 78.7 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑Field Natural Gas Heating value: BTU/scf O Propane (assumed fuel heating value of 2,300 BTU/scf) ❑Landfill Gas Heating Value: BTU/scf 0 Other(describe): Residue gas Heating Value (give units): 1,075 Btu/scf 8 Requested values wilt become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. � e COLORADO f. -2,•', 1 Lion Er,ine A Eri - R-,v1sion 12-291; 4 :..°`, Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power ❑ Emergency(max. 500 hrs/year) 0 Compression ❑ Pump Jack O Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Waukesha Engine Model: L-7042 GSI Serial Number7: 240602 What is the maximum designed horsepower rating? 1,232 hp What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 1OO% Load? 7,580 BTU/hp-hr Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: Engine Features: Cycle Type: ❑ 2-Stroke 0 4-Stroke Combustion: O Lean Burn El Rich Burn Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑ No If yes, what type of AFRC is in use? Q 02 Sensor(mV) ❑NOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? O Yes 0 No Engine Dates: What is the manufactured date of this engine? 1/22/1973 ❑ If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? Before 2004 What is the date this engine was first located to Colorado? Before 2004 What is the date this engine was first placed in service/operation? Before 2004 What is the date this engine commenced construction? Before 2004 What is the date this engine was last reconstructed or modified? NA 7 The serial number must be submitted if coverage under GP02 is requested. �c,rtn AP CD ≥•)1 Spa.k I;r?ie c;= Engine APEN Revision 121≥019 3 I gOICOLORADO filTattle Ilestetilt.ftemM Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 2 - Requested Action O NEW permit OR newly-reported emission source(check one below) O STATIONARY source O PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name4 O Add point to existing permit El Change permit limit O Transfer of ownerships O Other(describe below) -OR APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info Et Notes: Lower NOx permit limit based on portable analyzer test data 3 Only one engine may be reported per APEN for GP02 coverage.Coverage under GP02 is voluntary. 4 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. s For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g.ENG-1,Engine 3,etc.)? Yes If yes, provide the Company Equipment Identification No.: C-137 General description of equipment and purpose: Natural gas compression For existing sources, operation began on: 2000 For new or reconstructed sources, the projected start-up date is: Witt this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) El Yes O No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 ��i L{'i ' i �ICOIORADO �l _r.j Gc'i .,.C)i� l,iy 2 a..nIvI.a.w* JAN 3 1 2020 Spark Ignition Engine APEN :t114:1:" Form APCD-201 CDPHE Air Pollutant Emission Notice (APEN)and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition(e.g. gas-fired) reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 /0015 /052 [Leave hunk unless A'?CD has already assigned a pennrt =an.d AIRS ID Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location Site Location: SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include zip code) 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail Address:Home Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. (COLORADO Form Cr 20' , 1ofl Er9I;e APEI1 - Revision 12/2019 1 , w U w . . , : , . : , : , , , . . I . . . : . . . . . . : . . . I , : . , : , , .7 r . . . : . . , , , . , . r . . , r , . : , . . I . . r , I , . . . . , , , , r , , • : . . , . 1 . . , , . W r".,, -- E --- —�-- ---— -- ___- -_-_--- -- F-.--.---EQUIPMENT LIST PLANT B COLD/SEP. SKID V - _V `",", AMC--5 D%L COO.WWI[d.JDFN = 5 FGVTEL[Nwq -303-1 EXPMOER LURE O AMP -y _ __ _ PUMP (n xxx EA 4u1 x _ _ JII a eio ICE �— ^- .., I- AC-200 NCKER WRIER GOOIER IN O 800 COOWN S RAG -103-1 ANDS REAR.OI 0-46 STABILIZER PUNT A -5105 O OVERR N TAN I'D X EIO•l0i-f} DER PUMP N ..1 G. S •r 0 •® _ O,A K_SI0Z46 F- I E WA, -303 EXPANDER LOBE OIL PUMP U - ••AIb -___ - — - E. ' ®',Q" _ _. _ OUT CHASE INLET OM 'T,ill! oU sigix"X.a,enx Z-WC0 "L0TI xu CCHVET -° w,TRNO[R4 INLET COMPRESSOR 069 ILVE1 CHIP -- f - RE MOUE 0RON COMPRESSOR R_ R YCD St NM M-4020 FR SEPARATOR . }� O-"" _ L.P.R S COMPRESSOR _ M-3043 EXPANDER R FEED f11EMW. • 1 ....m ... I E i _0 - '0 k�OIL 5fCPAGF TANK -r TRACT "Brr °LP. WS COMPRESSOP s 3 WATER STORAGE TREK 1 OWE cossl:aeFs Dx PR sai °L PRODUCT GLYCOL REGEN. SKID p r -._ --- I -- C-'2 RESIDUE GAS CWPRE5TRUMPIT NR WS Fss 2N-6136 PROPANE PUFL R]OI,CL STORAGE iva D(-SIJBRCL OAP YER30A S 1, _� {= I C-13 RNDPRE G. COMPRESSOR IX-5151 2//:PMGMF rNal 4LVCWOII ttT[R .._.__ I - RESIWAwGRASC Y,.PESSORX" F.,,___51 0.Y nee, • U 5600 y.. PR -105PB ETME PURRPCC BED 5 TYCOI 1 ,... ".wor C 5611 -DMDE COMPRESSOR V-106PB ETHANE WRW EC BED VIE`ASEH I UP .O . I EAU STAGE SUCTION SCRUBBER RIM/RESOLE 2 TREATER 6 S V-111 CONDENEiSER PRESSURE rARA RACK SKIDS V-201 FUEL US SCRUBBER . •_'r. o_ - ■2 _ o R TRA MAO SURGE OAK LOADING _ •I� 0 117,RA UDDRACEG`K - 202 PROPANE RI RCOUR CONDENSATE AND MONO l0A➢NO • • E 303 DEtTWN ZfR PRLUx WIOFN011 0 CON`6�'ATE Si0AAGF 001£1 SRO 3 BIaWGOWN MU SG UMO NC E 104 [SV&OOIfR R r m nn rrr � , - _ r�w E4b0)]T"'"x"exOPN"2MFR R[�:iFPTG 2 V-14x VATTENOfFTM"Z�RF3LU INLET wCJ11ULCxxEwualA,OR SKID J CPvE5E AND PRODUCT ULHPM _" O �� 201 REPROPMEZE1117A''rr 2VREFL ACCUMULATOR • P-• s 1 RRISnTEuvENi ax wumEssax x iri s°IIR"Rc°mu"`iIuesEuRRLBeE" TRUCK TERMINAL EQUIPMENT 0 tun.moo w` �aa.7- • -_ — E4 901 4 INSTRUMENT MR COOMPRRESSOP .V-470 HEAT IDUE "'0L SURGE TANN J SUMP O EE4-901-4 9Di 5 INSTRUMENT AR GWRRLS5DA V 9WPAIE ORµy iMN A OP"RW t3 TAxx • J` r.,, - m F403DII R[G r4A5 PUUm Ju:iEl 540 UD(5 RANI 14iE SCRUB.3 SCRUBBER 6 gfYl Nft s1ORMt Ukx EK:j ,- Mil 2 EwI 1 u3(Nm Plwv 81 ww 5143 u E" P pu ' r /)we u, ra a WEST SONOLE ANGLE TRREEEiE SCRUBBER SCRUBWR EQUIPMENT IDENTIFICATION PREFIXES _P 3 R ,. �� I Ei0 Wt 3WF pfl:nxOEU XTH PUPu.V4^i� v 5,4i OW PRESSURE DRIP • ' .. �� _ w ...RI B - Go w] AO D,CON R [RAP WCB MGM.TARN ''''''',-;.w I .a ' T D MIXP P r ,�fi{r,, "I f o sm-: CONDENSER SL.. NEB Pu _- L..A ' W � ■ I f10 m1 1 '"W wpRoloJU lqu E vz 1 uGHuaLL SrNMAE TGE. KM COOLERS ORROF. AFRs, - . o � lip. I cio 12oi iN2 cEn. PAL RP1uP�LuR1ejl STTWx"wE iAx1°`Mt HCOMPRESSORS xTs REm PREIEMERs WO SUCTION VOTERS n"Y rte( 5g d 6 .,—,:,u., 0� E101101, OFWM�T PI V31002 Lq.DRAIN WP / DCP PARCEL 1 °k B 01rsD1 B PIATP ROW T 961z1'FN[W RSTORAGEIxN "U RR 1 BOOSTER R N ____ _.. `- E1D1'ioi sn"in( (w iFR 1101 eRaoucl SURGE TANK (uP PD _N ,,. 4�■_+ �+ �{ 0]rs0! URUrt WAIER PUMP V6 1101 1 PRODUCE SURGE TANK CFrvER5 _ • y I -0 0 gYIXNS TE 0 11oz 0 lmv MARE OP t.ROrW Ox rgvFR5.S,RPP[RS,ABSNRERS 51.wIUZEA5 9 ' _ u VIA -I SOLIDS AVER PROPANE ROAR LOK vE55[lS e r i4.:u C 104 6%1', MALT" 301 OW LEVEL JACKET WATER SUROF TANK 7.01 RF 0 U I w N r I 1 A A 1 I A A r 1 A ■■ ■■ ■ ■■■ .• �� F 15000 PIPELINE MISR 301 TARE SUCTION SCRUBBER U"'+U 5 "srTCACK V[R!11 a . .__._—_ - , y [l a F500 COALESCING FILTER VB 2lrMS - Y •� Y •.® ^ • m O e(I " NEAT NEOLUI"S ILLLT(NW V9 301 ODE SLUG CACHER L9FR 1pN AI - K [�] or F-60O 38!n & ,F-.5104 FLIER P.KR RA w1 CONDENSATE EDLIN y"E°D"° EIVER . `B m mw U Y ... S 3� ILNE Sf2rtFA"xR H.UM1fN 103-801 ].b1,a12 "INK 1r ,M , I GO-30I-2RESIDUEOAS51VL`R 4-1601-2 EMEHAM2N Ir�rtsfl B ®O ® y r' C-0-302 n RESIDUE F COOLER CR2,12112 n�1B 0dEE'5"NUWr4U eel/HT A I��W • S 304 z ESE LOXLEiE.vw COD. w SER SIA&UN rm_ / ca v'O 5143 VAPOR RFCWERr UNIT „._ •e �, -- _... - CB-1 ONCE ZERCNFB0A. B 400 I SLUG CATCHER 611-60, R PUNT A IW Slut WICx I o r 1 6038 PROMO CWtFA 400-2 6 ICNfA " B ". 0 IL87 '" CV pR_ I I GB-604 PRODUCT/HEAT MEOW 1wRLacEn PLANT A DEHYD SKID .R •i 1 "` .., i,�B o t'fl W �I" GB 610 INLET COOLERG wE5I(DIXEA _2001 T FILTER �.---- ��■RN■1 . $S Q_ l� 001 G6 COOLER 6 0A E let' ''''''R 1� uy�,, •A.. e ■ 901 i-SREEDw PRO ME fvDEN SOUR, 2002 Et fAi CMRIFR • J T>♦■ r-�.�� ... S g� '•e ,� • ,I ' 901 EEO rtm CENTS 1 REG. -J • „� .:. mn P CWelW1'AR(GCNGAB.E.17,,t,r'e"G - �._. ',�.3 _. D,._9Nn�• _, ___ -- ._ __- -.o___ ;l IDw1A EAT AWuuxPLANT A COL EP. SKID _ ..m _ ■ _ �wlOw� - �,,,.,�e,r„ • i_ GI0-320CID-ROT B HEST umuul UGC T.PLANT A G FF-34D3OO'A 2xw"IIFxiEWKLCA'nw w -1 5 - ^v' ?--±-- .. _ __ r "SlOwRPc`ALM�`JMUxER PURR cn i04A IN. "LEWL'CHILLERAS IDN4ER • -E" Try .._s._ •.__. _ _.. o .-. m....N - .._ _ _ pF GG EXCHANGER - '# I6i CMYv PBFirtxl[IXPUNI.WIr:c vuUP 41.222 40�C0LO F�C.65%r'x5 HANER I O 6 !E GPAYDFA EEFO WAIN P TREATED.10 IRON.RUMP SEPARATOR _ _ P-307uB oiWFpCi pWTNu5rER v8 2090211 CHILLER uREC TANK ND t s 201/ GHtiUM PLANT A EXPANDER SKID • I F-DOOR/ DGIYE0NN r'N"'pPUW 50 16.1 0jDOUF0E550R G e.eM. _11A U0 gWll PUMP E103021-I IXPuullOO TOIL CO PUMP -4 gg�PEi WATA kINF-UP WUv G6-302 GPINWH OM OIL COOLER l II P NLOW IPWP u '®'v°i` v-SI26�OPAJcNE PONDPA8Ie°c PLANT B DEHYD SKID ` 9 n v Sirs PROPANE ' R"'" ce-4wa,Ie Irv`H G45�/us nlc"�""w.vc`u"ER F g ,e.w F'w°'� 'eo R-3 0• FCGER �o A05B C0.D GES/GAS GCW3.SG -F is ❑®;a ❑w ,rte,b'°,r' 00'Pp P[MN 'p1BB GEA"UxA5 ZW RENTER PUNT 0 �',TRW �(y R-o160P''fIG"CE[C[MR 1B REI W{'�SfPNUNA �w3 W�WE-1�InD IXM9 WR pCWfXR f E g° 03 OF PO xvAN4EA'g3aAFR V10 IN.CAS 0.0 E DCP PARCEL 2 DCP PARCEL 3 INALLGEMENE V CHANCE dcp = RENTED TO PETRO SOURCE =. nl'.° B Midstream. _D 11/26/0MDq 361SOLw33 NY WELD COUNTY, COLORADO G - �, 'C 's____::::: ,w I3/D9p6 RNA uoc 02018.052161 SPINDLE PLANT AND LOADING RACK - —a WS 0 x T/I0055 RLrzxs PLOT PLAN n 1/000 60Um g OD W.. 50 GENERAL_ B " ---x n4ro REL GENERAL 6000.0N DADRAFiE00 00/BY:fief S�EE04BY:au B �_- --•. 4 M RS - - IT/01/05 A L NEVI MM.RMMCO 160 KNEW APPROVAL BY: DATE: 6Y D,II gLr..N 0.941,011e.xOaWwmW eM*W-x-,A Ao. MO BY rc5(vnW APP DWG NO.0 03402-01-SOI ISSUE { ISSUE - , O I Z ] 9 5 6 z R 9 10 II 12 I] t4 15 IB ti 1e IA 20 21 22 23 24 25 ze zJ xe 161 32 J] PLOT DATE: ACRD FILENAME: Attachment C: Piot Plan Spindle Natural Gas Processing Plant Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02.71171,e 477-tut,70-2 I I 3 Signature of Legally Authorized Person(not a vendor or consultant) D e Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑Draft permit prior to issuance ❑Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692.3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver,CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment �Aoss COLORADO F lJ 1€)i ;a.>in 17t�il�.nn En�;n: APP-A-1 (' .� ,z IL ''- `; 6 11R � Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No if yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant (%of total emissions captured by (X reduction of captured Description control equipment) emissions) TSP(PM) PM10 PM2 5 _..._._. SOx NOx NSCR 70`k VOC NSCR 45 CO NSCR 5a`?5 Other: NSCR-NAPS C#maldehyde 75%Omar H.APs 50"4 From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Pollutant Emission Limit(s)8 Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissionst° Emissions Emissions Mfg.,etc.) (tons/year) (tots/near) (tons/year) (tons/year) TSP(PM) 1.9404)2 18/MMBtu AP-42 069 0.69 0.79 0.79 PM10 1.94E-02 IbtMMBtu AP-42 069 - 0.69 0.79 079 PMz-5 1.94E-02 lb/MMEitu AP-42 0 69 0 59 0 79 0 79 SOx 5.88E-04 Ib/MMBS. AP-42 0 021 0 021 0.024 0.024 NOx 11.0 gfhrrhr Mfg 113 0 34.3 130.9 24 0 VOC 1.5 gTp-hr Mfg 15 4 8.4 17.8 9.8 CO 8.0 grt+p-hr M15 82 2 34.2 95.2 396 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes O No pollutants(e.g. HAP hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Units Units (AP-42, Emissions Emissions10 Number Basis Mfg.,etc.) (lbs/yegr) (lbs/year) Formaldehyde 50000 2 05E-02 16/14848t0 AP-42 1,448.09 347 54 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: _ t0 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Afii& co.oa,.00 5 :, © o.......rnr. Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.69 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec) (Feet) C-141 36 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) 0 Upward O Downward ❑ Upward with obstructing raincap ❑Horizontal ❑Other (describe): Indicate the stack opening and size: (check one) I]Circular - Interior stack diameter (inches): 12 ❑ Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑Other (describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limits (SCF/hour) (MMSCF/year) (MMSCF/year) 8,980 65.7 78.7 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value 01 1,020 BTU/scfl ❑Field Natural Gas Heating value: BTU/scf ❑ Propane (assumed fuel heating value of 2.300 BTUlscf) ❑ Landfill Gas Heating Value: BTU/scf ❑Other (describe): Residue gas Heating Value (give units): 1,075 Btu/scf 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. COLORADO Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression ❑ Pump Jack O Water Pump O Other: What is the maximum number of hours this engine wilt be used for emergency back-up power? 0 hours/year Engine Make: Waukesha Engine Model: L-7042 GSI Serial Number7: 350086 What is the maximum designed horsepower rating? 1,232 hp What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7,580 BTU/hp-hr Is this APEN reporting an AOS replacement engine? O Yes Q No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: Engine Features: Cycle Type: D 2-Stroke 0 4-Stroke Combustion: O Lean Burn 0 Rich Burn Aspiration: ❑ Natural Q Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes O No If yes, what type of AFRC is in use? 0 O2 Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? O Yes ❑ No Engine Dates: What is the manufactured date of this engine? 12/27/1967 O If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? Before 6/4/2006 What is the date this engine was first located to Colorado? Before 6/4/2006 What is the date this engine was first placed in service/operation? Before 6/4/2006 What is the date this engine commenced construction? Before 6/4/2006 What is the date this engine was last reconstructed or modified? NA 7 The serial number must be submitted if coverage under GP02 is requested. COLORADO Dnrw�.r wrap Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 2 - Requested Action O NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name4 O Add point to existing permit Q Change permit limit O Transfer of ownerships ❑ Other(describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info Et Notes: Lower NOx permit limit based on portable analyzer test data 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GPOZ.as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g.ENG 1,Engine 3,etc.)? Yes If yes, provide the Company Equipment Identification No.: C-141 General description of equipment and purpose: Natural gas compression For existing sources, operation began on: 1/28/2013 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) '❑ Yes ❑ No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: Mar-May: June-Aug: Sept-Nov: pe g 25 25 25 25 -COLORADO 2 ,1 noLoo Aci ..1W1i.�4.n.a�wwn r, Spark Ignition Engine APEN a , Form APCD-201 CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit AU sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and wilt require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition(e.g. gas-fired) reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 /0015 /057 • Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location: Site Location SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1321 Malting Address: !Include zip Cade, 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail AddressZ: rshankaran@dcpmidstream.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption Letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 429603 �!! COLOR•OO i ":::. Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. I€this is a registration for coverage under General Permit GP02, I further certify that this source is and wilt be operated in full compliance with each condition of General Permit GP02. p it A/1?-71a7/7-z.,-- 1/ 3-0 Signature of Legally Authorized Person(not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑Draft permit prior to issuance ❑Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. • Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$1,875,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division Oe APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver,CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment lf=re goo Permit Number: 95Op039 AIRS ID Number: 123 /0015/052 Section 7- Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations, Is any emission control equipment or practice used to reduce emissions? ❑� Yes ❑No If yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant Description (%of total emissions captured by (%reduction of captured control equipment) emissions) TSP(PM) PM10 PM2.s SOx NOx NSCR 100% 70% VOC NSCR 100% 48% CO NSCR 100% 58% Other: NSCR-HAPs 100% Formaldehyde 76%Other HAP5 50% From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)8 Pollutant Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissionsl0 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 1.94E-02 IDIMMBtu AP-42 0.69 0.69 079 0.79 PM10 1 94E-02 IWMMBtu AP-42 069 0.69 079 079 PM2,5 , 1.94E-02 ID!!.1MBtu AP-42 0 69 0 69 5 79 0 79 SOx 5 88E.04 ID/MMBtu AP-42 0 021 0 021 0.024 0.024 NOX 11.0 gR1p-hr Mfg 1130 34.3 130.9 24.0 VOC 1.5 gT1p-hr Mi9 154 8.4 178 9.8 CO 8 0 g/np-R% Mfg 82 2 34.2 95 2 39.6 E Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. t0 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes O No pollutants(e.g. HAP hazardous air pollutant)equal to or greater than 250 lbs/year? if yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions10 Number Mfg.,etc.) (ibs/year) (lbs/year) Formaldehyde 50000 2 056-02 Ib/MM81u AP.42 1.448.35 347.60 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. �..COtOR1D0 Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 • Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.69 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec) (FeetC-137 36 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) ❑ Upward O Downward O Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) El Circular Interior stack diameter(inches): 12 ❑ Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limit8 (SCF/hour) (MMSCF/year) (MMSCF/year) 8,980 65,7 78.7 From what year is the actual annual amount? 2O19 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑Field Natural Gas Heating value: BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTUfscf) D Landfill Gas Heating Value: BTU/scf ❑Other (describe): Residue gas Heating Value (give units): .1,075 Btu/scf 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs, including APEN updates. 9 If fuel heating value is different than the listed assumed value,provide this information in the"Other"field. ' -COLORADO 4 = IVO:» °.. Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power O Emergency(max. 500 hrs/year) El Compression ❑Pump Jack O Water Pump O Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year Engine Make: Waukesha Engine Model: L-7042 GSI Serial Number,: 240602 What is the maximum designed horsepower rating? 1,232 hp What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100%Load? 7,580 BTU/hp-hr Is this APEN reporting an AOS replacement engine? O Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: Engine Features: Cycle Type: ❑ 2-Stroke 0 4-Stroke Combustion: O Lean Burn 0 Rich Burn Aspiration: O Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes O No If yes, what type of AFRC is in use? 0 O,Sensor(mV) ❑NOx Sensor(ppm) O Other: Is this engine equipped with a Low-NOx design? O Yes 0 No Engine Dates: What is the manufactured date of this engine? 1/22/1973 O If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? Before 2004 What is the date this engine was first located to Colorado? Before 2004 What is the date this engine was first placed in service/operation? Before 2004 What is the date this engine commenced construction? Before 2004 What is the date this engine was last reconstructed or modified? NA 7 The serial number must be submitted if coverage under GPo2 is requested. ge, COLORADO 3 I ...°""". ..W.r Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/052 Section 2 - Requested Action 9 NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source 9 PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023(Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment O Change company name4 ❑ Add point to existing permit ❑Q Change permit limit O Transfer of ownerships O Other (describe below) •OR• ❑ APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info Et Notes: Lower NOx permit limit based on portable analyzer test data 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form Worm APCD-104)must be submitted. 6 This does not apply to General Permit GP02.as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG I.Engine 3.etc.)? Yes If yes, provide the Company Equipment Identification No.: C-137 General description of equipment and purpose: Natural gas compression For existing sources,operation began on: 2000 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) 0 Yes O No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 g"ail, COLORADO 2 r D'`.�� C"*„ Attachment D: January 2020 ADEN Forms Spindle Natural Gas Processing Plant ti Spark Ignition Engine APEN a ,Y , Form APCD-201 COPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and wilt require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information,or locks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition(e.g. gas-fired) reciprocating internal combustion engines(RICE). If your engine is a compression ignition engine(e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source(e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 / 0015 /052 Section 1 - Administrative information Company Name': DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location Site Loca€ion: SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail Address2: rshankaran@dcpmidstream.com ' Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD,Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 429602 Co LORADO Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 APCD alre a Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source O PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested,the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name' ❑ Add point to existing permit Change permit limit ❑ Transfer of ownerships O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS)permanent replacement6 Additional Info& Notes: Lower NOx permit limit based on portable analyzer test data 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. °For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 5 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g.ENG-t,Engine 3,etc.)? Yes If yes, provide the Company Equipment Identification No.: C-141 General description of equipment and purpose: Natural gas compression For existing sources, operation began on: 1/28/2013 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) Yes ID No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 COLORADO a )1 ;rk I r r cm Fr AREA Re Revision 12.2 '.' 2 I ® Room .. , Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Leave bi.9nk Ltr,., AFC[1 h a; ai n - .;;i; a 9 a-� u] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression O Pump Jack O Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 hours/year EJC per Engine Make: Waukesha Engine Model: L-7042 GSI Serial Number7: 350086 144345 6/5/2020 What is the maximum designed horsepower rating? 1,232 hp email What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,580 BTU/hp-hr Is this APEN reporting an AOS replacement engine? ❑Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: Engine Features: Cycle Type: ❑ 2-Stroke 0 4-Stroke Combustion: O Lean Burn 0 Rich Burn Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes,what type of AFRC is in use? 0 Oz Sensor(mV) ❑NOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑Yes 0 No Engine Dates: What is the manufactured date of this engine? 12/27/1967 ❑ If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? Before 6/4/2006 What is the date this engine was first located to Colorado? Before 6/4/2006 What is the date this engine was first placed in service/operation? Before 6/4/2006 What is the date this engine commenced construction? Before 6/4/2006 What is the date this engine was last reconstructed or modified? NA The serial number must be submitted if coverage under GP02 is requested. COLORDO Farm ,,`:r!, 20i Sp r, Ignitlen Engine APEN - Re`.ision 12 '2C,1,-) 3 Anwu` Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 ra a r , Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.69 Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. Cr)` (ACFM) (ft/sec) (Feet) C-141 36 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) (]Upward O Downward O Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 12 ❑ Square/Rectangle Interior stack diameter(inches): Interior stack depth(inches): ❑Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limit8 (SCF/hour) =, (MMSCF/year) (MMSCF! ear y ) 8,980 65.7 78.7 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating value: BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑Other(describe): Residue gas Heating Value (give units): 1,075 Btu/scf 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 9 tf fuel heating value is different than the listed assumed value,provide this information in the"Other"field. oICOLORADO F n ..,-�D-201 S ark IC,tilion Engine APEN - Revision 12 i2vi4 4 « Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 (Li-,e'. blank ii''._-s tiPC , .e;f 1` 3r.=)AI?). ID; Section 7- Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form.The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? El Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant (%of total emissions captured by (%reduction of captured Description control equipment) emissions) TSP(PM) PM10 x SO EJC per NOx NSCR 7U% 82% 6/5/2020 VOC NSCR 46% email CO NSCR 58% Other: NSCR-HAPs Formaldehyde 76%,Other HAPs 50% From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)8 Pollutant Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissionsl0 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) TSP(PM) 1.94E-02 lb/MMBtu AP-42 0.69 0.69 0.79 0.79 PM10 1.94E-02 lb/MMBtu AP-42 0.69 0.69 0.79 0.79 PM2.s 1 94E-02 lb/MMBtu AP-42 0.69 0.69 0.79 0.79 SOx 5.88E-04 lb/MMBtu AP-42 0.021 0.021 0.024 0.024 NOx 11.0 glhP-hr Mfg 113.0 34.3 130.9 24.0 VOC 1.5 glhp-hr Mfg 15 4 8.4 17.8 9.8 CO 8.0 glhp-hr Mfg 82.2 34.2 95.2 39.6 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria 0 Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions Number Basis Mfg.,etc.) (lbs/year) (lbs/year) Formaldehyde 50000 2.05E-02 lb/MMBtu AP-42 1,448.09 347.54 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: 10 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLORADO a *Motile � l D ?D1 Sp1r',-i ;litiori Engine APFF! . P.r�� _in I 2.'�l 5 I °s1,... Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/057 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. %771O2 ' i / 3 t A} Signature of Legally Authorized Person(not a vendor or consultant) D tap Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance L ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements. • Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment ®ICOLORADO H°(i0 201 Spark Ignition Engine APEN 12,,?C11 9 6 I Nip , '« DCP Midstream 370 17th Street,Suite 2500 Denver,CO 80202 Mi dstream Cream 303-603-2039 May 21,2020 UPS Tracking No.: 1Z F46 915 01 9498 5216 Colorado Department of Public Health and Environment APCD-SS-B 1-1400 4300 Cherry Creek Drive South Denver,CO 80246 ATTN: Elie Chavez Subject: Spindle Natural Gas Processing Plant Operating Permit No. 95OPWE039 Like Kind Replacement under the Alternative Operating Scenario(AOS) Engine C-140 AIRS ID: 123/0015/056 Dear Mrs. Chavez: This letter and the attached APEN provide the formal notification required under Operating Permit 95OPWE039 for the replacement of engine C-140(AIRS ID: 123/0015/056)with a like-kind engine. A check in the amount of$191.13 for the APEN filing fee is enclosed. The AOS included in the permit allows for the permanent replacement of a compressor engine with a like-kind engine provided that,among other things,emissions from the replacement engine are tested within seven calendar days and that an APEN is filed with the Division within 14 calendar days from when the replacement engine commenced operation. Compressor engine C-140 is currently identified as an 1,232 horsepower(hp) Waukesha L-7042 GSI engine, serial number 288108. The serial number for the replacement Waukesha L-7042 GSI engine is 263183. The replacement engine commenced operation on May 08,2020 and was tested May 12, 2020,using a portable analyzer to measure NOx and CO emissions in its exhaust stream. A field log is maintained at the facility to document all like-kind engine replacements. Both the test results and copy of the field log are included in this submittal.The Engine AOS Applicability Report is also attached. Please feel free to contact me at (303) 605-2039 or rshankaran@dcpmidstream.com with any questions regarding the use of the AOS to account for the above mentioned like-kind engine replacement at the Spindle Gas Plant. Sincerely, DCP Operating Company,LP • Roshini Shankaran Senior Environmental Engineer Attachments Spark Ignition Engine APEN Y-�+u Form APCD-201 ,, CDPHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for spark ignition (e.g. gas-fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel-fired)or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher/screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE039 AIRS ID Number: 123 / 0015 /056 [Leave blank unless APCD has already assigned a permit 7 and AIRS ID Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Spindle Natural Gas Processing Plant Site Location Site Location: SW Section 34, T2N, R67W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail AddressZ: rshankaran@dcpmidstream.com 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. jes,COLORADO Form APCD 201 Spark Ignition Engine APEN Revision 12/2019 1 I U e�x Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/056 [Leave blank unless APCD has already assigned a permit g and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source El PORTABLE source ❑ Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of$1,875 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name4 O Add point to existing permit El Change permit limit ❑ Transfer of ownerships ❑ Other(describe below) -OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ▪ APEN submittal for permit-exempt/grandfathered source ID Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info Et Notes: AOS Start Date: May 08, 2020 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted. s For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 6 This does not apply to General Permit GP02,as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1,Engine 3, etc.)? Yes If yes, provide the Company Equipment Identification No.: C-140 General description of equipment and purpose: Natural gas compression For existing sources, operation began on: 12/31/2000 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (See APCD website for NAAQS nonattainment area boundary map) 0 Yes ❑ No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25% Mar-May: 25% June-Aug: 25% Sept-Nov: 25% COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 12/2019 2 I H be:, me nt Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/056 [Leave blank unless APCD has already assigned a permit and AIRS D] Section 4 - Engine Information Engine Function: O Primary and/or Peaking Power O Emergency(max. 500 hrs/year) 0 Compression O Pump Jack ❑Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? hours/year Engine Make: Waukesha Engine Model: L7042 GSI Serial Number7: 263183 What is the maximum designed horsepower rating? 1,232 hp What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 9,340 BTU/hp-hr Is this APEN reporting an AOS replacement engine? 0 Yes ❑ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Waukesha Engine Model: L7042 GSI Serial Number: 288108 Engine Features: Cycle Type: O 2-Stroke 0 4-Stroke Combustion: ❑ Lean Burn 0 Rich Burn Aspiration: ❑ Natural 0 Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? 0 Yes ❑No If yes, what type of AFRC is in use? 0 Oz Sensor(mV) ONOx Sensor(ppm) ❑Other: Is this engine equipped with a Low-NOx design? ❑Yes 0 No Engine Dates: What is the manufactured date of this engine? 03/1974 O If the following date information is not available, check this box, and this engine will be considered newly constructed and/or newly relocated into the state of Colorado based on the engine start-up date. What date was this engine ordered? < 03/1974 What is the date this engine was first located to Colorado? < 06/2006 What is the date this engine was first placed in service/operation? 03/1974 What is the date this engine commenced construction? < 03/1974 What is the date this engine was last reconstructed or modified? NA 7 The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-201 Spark Ignition Engine APEN - Revision 12/2019 3 I HeRhbEn�lronmant Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/056 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 509,828.2 / 4,437,630.69 Dilarge Height r'ator � �� 'Camp. blow�e `elocity Above+Ground bevel C-140 36 1,055 5,377 114 Indicate the direction of the Stack outlet: (check one) ✓❑ Upward O Downward O Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 12 ❑Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): o Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Ilse Rate 1i Load Actual Ann[► 1 1 1 Use , Requested Annual Permit l imit8 ( /hou) (MMSCF/year)`, (MMSCF/ ) 11,064 65.6 96.9 From what year is the actual annual amount? 2019 - Indicate the type of fuel used9: O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) D Field Natural Gas Heating value: BTU/scf o Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑✓ Other(describe): Residue Gas Heating Value (give units): 1,078 Btu/scf B Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 9 If fuel heating value is different than the listed assumed value, provide this information in the"Other"field. !.COLORADO Form APCD-201 - Spark ignition Engine APEN - Revision 12/2019 4 I Xealll,6 LT�IwnmeM Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/056 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies: Control Equipment Collection Efficiency Control Efficiency Pollutant (%of total emissions captured by (%reduction of captured Description control equipment) emissions) TSP (PM) PM10 PM2.5 Sox NOx NSCR 100% 91 VOC NSCR 100% 53% CO NSCR 100% 75% Other: HAPs NSCR 100% HCHO-76%,Other HAPs-50% From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)8 Uncontrolled Units Source Uncontrolled Controlled Uncontrolled Controlled Basis (AP-42, Emissions Emissions70 Emissions Emissions Mfg.,etc.) (tons/year) (tons/vear) (tons/year) (tons/year) TSP(PM) 1.94E-02 Ib/MMBtu AP-42 0.69 0.69 0.98 0.98 PM10 1.94E-02 Ib/MMBtu AP-42 0.69 0.69 0.98 0.98 PM2.5 1 94E-02 Ib/MMBtu AP-42 0.69 0.69 0.98 0.98 SOx 5.88E-04 Ib/MMBtu AP-42 0.02 0.02 0.03 0.03 NOx 11.0 g/hp-hr Mfg. 91.81 8.34 130.86 11.90 VOC 1.5 g/hp-hr Mfg. 12.52 5.83 17.84 8.33 CO 8.0 g/hp-hr Mfg. 66.77 16.69 95.17 23.79 8 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 10 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria ❑✓ Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Uncontrolled Service(CAS) Units (AP-42, Emissions Emissions10 Basis Mfg.,etc.) (lbs/year)Number ( Y 1 (lbs/year) Formaldehyde 50000 2.05E-02 lb/MMBtu AP-42 1,449.74 347.94 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: Methanol 67561 10 Amual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 12/2019 5 I =7,1:72=„ Permit Number: 95OPWE039 AIRS ID Number: 123 /0015/056 dilCl/1,11,,3 ti Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. 5/21/2020 Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance ❑Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$1,875, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment �ICOLORADO 1'0.m APCD-2O1 Spark I;ills-1:)1 Ell;k-:'r PI=11 - Re'Vi;. 1' 12;2019 6 I fat Engine Emission Calculations Spindle Gas Processing Plant DCP Operating Company,LP Waukesha L 7042 GSI Engine C-140 123100101006 4 Stroke,Rich Burn Unit Rating: 1 2212 hp BSFC: 9.:a0 btu/hp-hr Maximum Heal Input: 11.5 mmbtu/hr Operating Schedule: 8.860 hr/y1 FHV: IMO btu/scf Maximum Fuel Use: 96.9 mmscf/yr 11064 scf/hr AONNFaft1nN10(i' ; Year Fuel Use Feat Value (MMsgflyrl (Btolsc0 January 5.57 1081.74 February 4.92 107426 March 582 107426 Alai' 5.57 1077.60 May 5.58 1082.67 June 537 1093.02 July 551 1069.67 August 551 107163 September 494 1070.79 October 573 1064.54 November 5.45 1087.56 December 561 1092.51 1078.35 Criteria Pollutant Emission Calculations Uncontrolled Controlled Potential Camgence Emission Factors Potential Emissions Compliance Factors : AotooE 13099301 f Emission Factors Emissions Factors AOWelE101a81et* Pollutant (ton/pr) (IblMMBtu) (tgntyr) (ton/yt) (IbIMMetu) (tonlyr) N00' 11.0 glbhp-Is 130.86 260 91.61 1.0 g/bhp-hr 11.90 0.236 8.34 VOC' 1.5 q/bhp-hr 17.84 035 12.52 0.7 g/bhp-hr 8.33 0.106 5.63 CO' 8.0 q/bhp-hr 95.17 1.89 88.77 2.0 g/bhp-hr 23.79 0.472 16.89 PM° 1.94E-02 lb/mmBlu 0.98 1.94E-02 0.69 1.94E-02 Ib/mmBtu 0.98 1.94E-02 0.89 SOS° 5.88E-04Ib/mmBlu 0.030 588E-04 0.021 5.88E-04 Ib/mmBtu 0.030 5.58E-04 0.021 °Manufacture.emissions factors °Uncontrolled emission factors from 4-stroke,Rich-burn(4SRS)engines from AP-42,Chapter 3,Table 3.2-3,(7/001. Non-Criteria Reportable Pollutant Calculations Controlled Controlled Actual Uncontrolled Potential Uncontrolled Actual Control Potential Emissions Emissions Efficiency Emissions Emissions • Pollutant HAP Emission factors° Data Source (18199 (18199 % (lblyt) (181yr) 1,1,2,2-Telrachlarcethane 253E-05Ib/mmetu EPA 255 1.79 50% 1.28 0.89 1,1,2-Trichloraethane <1.53E-05Ib/mmBtu EPA 154 108 50% 0.77 0.54 1,1 Dbchkmethane <1.13E-05 b/mm8tu EPA 0.36 0.80 50% 0.18 0.40 1,2 Dichboroethsne <1.13E-05 lb/mm Btu EPA 036 0.80 50% 0.18 0.40 1,2 Dbc1oropr0pane <1.30E-051b/mm Btu EPA 0.41 0.92 50% 0.20 0.46 1,3-Butadiene 6.63E-04 Ib/mmBtu EPA 6683 46.09 50% 33.42 2344 1,3-Dohloropropene <1.27E-051b/mm Btu EPA 1.28 0.90 50% 0.64 0.45 Acetaldehyde 2.79E-031b/mmBtu EPA 281.24 19731 50% 140.62 98.06 Acrolon 2.63E-031b/mmBtu EPA 265.11 185.99 50% 132.55 93.00 Benzene 1.58E-0316/mmBtu EPA 159.27 111,74 50% 79.63 55.87 Carbon Tetrachloride <1.77E-051b/mm0tu EPA 178 1.25 50% 0.89 0.63 Chbrobenzene <1.29E-05 Ib/mmBtu EPA 1.30 0.91 50% 0.65 0.46 Chloroform <1.37E-05 lb/mmBlu EPA 1.38 0.97 50% 0.69 0.48 Ethylbenzene <2.48E-05 lb/mm Btu EPA 2,50 1.75 50% 1.25 0.88 Ethylene Dibrombde <2.13E-051b/mmBtu EPA 2.15 1.51 50% 1.07 0.75 Formaldehyde 2.05E.421bimmflu EPA 2966.43 1449.74 76% 485.94 347,94 Methanol 3.06E-03 IblmmBtu EPA 306.45 216.40 50% 154.23 108.20 Methylene Chloride 4.12E-05 Ib/mmBtu EPA 4.15 291 50% 2.08 1.46 Naphthalene <9.71E-05lb/mmotu EPA 9.79 6.87 50% 4.89 3.43 PAH 1.41E-141b/mmBlu EPA 1421 9.97 50% 7.11 4.99 Styrene <1.19E-0516lmmBtu EPA 1.20 0.84 `00% 0.06 0.42 Toluene 5.58E-04 lb/mmBtu EPA 5625 3946 50% 28.12 19.73 Vinyl Chbride <7.18E-O6 Ib/mm8tu EPA 0.72 0.51 50% 036 025 6ykres(m,p.o) 1.95E-04Ib/mmotu EPA 1966 1379 50% 9.83 6.90 TOTAL — <3269 c2295 <1097 0771 °Uncontrolled emission factors from 4-stroke,Rich-burn(4SRB)engines from AP-42,Chapter 3,Table 3.2-3.17/00). DCP Operating Company,LP 5/20/2020 Engine AOS Applicability Report Certification I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this certification are true,accurate and complete. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s)shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, section I.B.9., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s)referenced in the Report(s)until such time as the Permit is revised to reflect the new requirements. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Charles A. Job Printed or Typed Name General Manager, North Area Operations Title 5126420 ignature Date Signed Colorado Regulation No. 7 Sections XVI and XVII.E Company: DCP Operating Company, LP Source ID: 123/0015/056 Permit#: 95OPWE039 Date: May 21, 2020 Determination of compliance and reporting requirements for a Manufacturer: Waukesha Model: L7042 GSI Nameplate HP: 1,232 Construction date: <03/1974 Date Relocated to Colorado: <06/2006 * *See attached APENfrom previous location for confirmation of in-state engine transfer. Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, §XVI ❑ Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, § XVII.E ® Does not apply to this engine. Engine does not have a maximum horsepower greater than 100 or the construction or relocation date precedes the applicability dates. ❑ Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): CO (g/hp-hr): VOC (g/hp-hr): Max Engine Construction or Emission Standards in g/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 NSPS JJJJ Report Note that as of September 1, 2008 that the Division has not yet adopted NSPS JJJJ. Until such time as it does,any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. NSPS Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Company: DCP Operating Company, LP Source ID: 123/0015/056 Permit#: 95OPWE039 Date: May 21, 2020 Manufacturer: Waukesha Model: L7042 GSI Nameplate HP: 1,232 Engine Type: 4 Stroke, Rich Burn Manufacture Date: 03/1974 Date Engine Ordered: <03/1974 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. NSPS JJJJ does not apply to this engine. ❑NSPS JJJJ does apply to this engine. Determination of NSPS JJJJ requirements: §60.4230 Applicability (a)(4)(i) Does not apply to this engine since it is a rich burn engine, greater than 500 HP, with a manufacture date prior to July 1, 2007. CONCLUSION OF FINDINGS This engine is an 1,232 HP, Waukesha L-7042 GSI which precedes the applicability date and is therefore not subject to the provisions of NSPS JJJJ. MACT ZZZZ Report MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: DCP Operating Company, LP Source ID: 123/0015/056 Permit#: 95OPWE039 Date: May 21, 2020 Manufacturer: Waukesha Model: L7042 GSI Nameplate HP: 1,232 Engine Type: 4 Stroke, Rich Burn Manufacture Date: 03/1974 Date Engine Ordered: <03/1974 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. n MACT ZZZZ does not apply to this engine. MACT ZZZZ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the major or area source MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at a major source of HAP emissions. Determination of MACT ZZZZ requirements: §63.6585 Applicability This subpart is applicable to DCP's engine since it is an existing stationary reciprocating internal combustion engine (RICE) at an area source of hazardous air pollutant(HAP) emissions. §63.6590 What Parts of My Plant Does This Subpart Cover? (a)(1)(iii) For stationary RICE located at an area source of HAP emissions, a stationary RICE is existing if you commenced construction or reconstruction of the stationary RICE before June 12, 2006. CONCLUSION OF FINDINGS This engine is subject to MACT ZZZZ since it is an existing non-emergency stationary RICE located at an area source of HAPs. DCP will comply with the provisions of this subpart by complying with the operating and emissions requirements outlined in 40 CFR 63, Subpart ZZZZ, Table 2d. APEN for previous engine location - SN: 263183 Reciprocating Internal Combustion 444, CDPHE Engine APEN - Form APCD-201 CO '10" Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for reciprocating internal combustion engines (RICE). If your engine is a diesel compression ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/aped. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 95OPWE100 AIRS ID Number: 123 /0107 /019 le ea've blank~mess APCD'laa al"'eadv assigned Uel"rrit s anc AIRS 1D] Section 1 - Administrative Information Company Name': DCP Operating Company, LP Site Name: Lucerne Natural Gas Processing Plant Site Location Site Location: 31495 Weld County Road 43 County: Weld Lucerne, CO NAICS or SIC Code: 1321 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 Portable Source E-Mail Address Z: rshankaran@dcpmidstream.com midstream.com Home Base: @ P 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. COLORADO Form APCD-201 Reciprocating internal Cor bustion Engine APEN Revision 11/2016 1 j . , =`;',r=,'; Permit Number: 95OPWE100 AIRS ID Number: 123 /0107 /019 [Leave blank unless APCD has .read„assigned a permit and AIRS iDi Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source (check one below) ❑ STATIONARY source ❑ PORTABLE source ❑ Request coverage under a Construction Permit ❑ Request coverage under General Permit GP023 (Natural Gas Only) If coverage under General Permit GP02 is requested, an additional fee of$1,500.00 is required in lieu of hourly fees. -OR • MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below) -OR- ✓❑ APEN submittal for update only(Blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario(AOS) permanent replacements Additional Info a Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. a For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. 5 GP02 fee is not required, but APEN filing fee is required. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? yes If yes, provide the Company Equipment Identification No. C-109 General description of equipment and purpose: natural gas compression For existing sources, operation began on: 7/10/2012 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No (http://www.colorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25 'y COLORADO Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 11/2016 2 I AMV Permit Number: 95OPWE100 AIRS ID Number: 123 /0107 /019 [Leave blank unless APCD has already assigned a permit x and AIRS ID] Section 4 - Engine Information Engine ❑ Primary and/or Peaking El Emergency Back-up Compression Function: ❑ Pump ❑Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency hours/year back-up power? Engine Make: Waukesha Engine Model: L7042 GSI Serial Number': 263183 What is the maximum designed horsepower rating? 1,232 hp What is the engine displacement? 9.58 l/cyl What is the maximum manufacturer's site-rating? 1,232 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,630 BTU/hp-hr Engine Features: Cycle Type: ❑ 2-Stroke ❑✓ 4-Stroke Combustion: ❑ Lean Burn ❑✓ Rich Burn Ignition Source: ❑✓ Spark ❑ Compression Aspiration: ❑ Natural E Turbocharged Is this engine equipped with an Air/Fuel ratio controller(AFRC)? ✓❑ Yes ❑ No If yes, what type of AFRC is in use? ❑✓ O2 Sensor(mV) ❑NOx Sensor(ppm) ❑ Other: Is this engine equipped with a Low-NOx design? ❑Yes No Engine Dates: What is the manufactured date of this engine? What date was this engine ordered? Prior to 6/06 What is the date this engine was first located to Colorado? Prior to 6/06 What is the date this engine was first placed in service/operation? What is the date this engine commenced construction? Prior to 6/06 What is the date this engine was last reconstructed or modified? Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 6 The serial number must be submitted if coverage under GP02 is requested. COLORADO Form APCD-201 Reciprocating Internal Combustion Engine APEN - Revision 11/2016 3 I A Permit Number: 95OPWE100 AIRS ID Number: 123 /0107 /019 [Leave blank unless A CD~ Area' assigned a perfr.it and A;°c ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.4567 / -104.6650 [?scharge Herght Operator 'Temp flow Rate velocity Above Groun $ Stack ll�Na. d (� (ai'�M/ {fttskr C-109 40 1,055 5,377 114.1 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap O Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 12 ❑ Square/Rectangle Interior stack diameter(inches): Interior stack depth (inches): ❑ Other(describe): Section 6 - Fuel Data and Throughput Information Fuel Use gate®,(00 Load Actual Annual Fuel Use ' Requested Annual permit Little (SCF/hour) (mA4SCF/yedr):-.:- (MMSCF/years 9,039 70.31 79.18 From what year is the actual annual amount? 2017 Indicate the type of fuel used: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑ Field Natural Gas Heating value: BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑✓ Other(describe): Residue Gas Heating Value (give units): 1082.21 Btu/scf 7 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 8 If fuel heating value is different than the listed assumed value, provide this information in the"Other"field. COLORADO Forrn API -2 1 Reciprocating Internal Combustion Engine APE 4 - Revision 11/2u16 4 I AMY "° Permit Number: 95OPWE100 AIRS ID Number: 123 /0107 /019 [Leave blank unless APCD has already assigned a;permit r and.AIRS ID Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency(%reduction): Overall Requested Control Pollutant Primary Control Equipment Description Efficiency (%reduction in emissions) TSP (PM) PM10 PM 2.5 SOX NOX NSCR 85% VOC CO NSCR 83% Other: Formaldehyde:NSCR 76% Use the following tables to report criteria and non-criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 201 7 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions`' Requested Annual Permit Pollutant Emission Limit(s) ' Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP (PM) 1.94E-02 Ib/mmBtu AP-42 0.74 0.74 0.80 0.80 PM10 1.94E-02 1b/mmBtu AP-42 074 0.74 0.80 0.80 PM 2.5 1.94E-02 Ib/mmBtu AP-42 0.74 0.74 0.80 0.80 SOX 5 88E-04 lb/mmBtu AP-42 0.022 0.022 0.024 0.024 NOx 13.1 g/hp-hr Mfg. 144.01 21.95 155.84 23.79 VOC 1.0 g/hp-hr Mfg. 11.00 11.00 11.90 11.90 CO 11.7 g/hp-hr Mfg. 128.62 21.95 139.19 23.79 Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, please use the following table to report the non-criteria pollutant(HAP) emissions from source: Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions9 Chemical Name Abstract Source Uncontrolled Service CAS Uncontrolled Controlled Emissions ( ) Units (AP-42, Emissions Basis (Pounds/year) Number Mfg.etc) (Pounds/year) Formaldehyde 50000 2.05E-02 Ib/MMBtu AP-42 1559.90 374.38 Acetaldehyde 75070 Acrolein 107028 Benzene 71432 Other: 'Requested values will become permit limitations. Requested limit(s)should consider future process growth. 9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. fotiw COLORA60 Form APCD-201 Reciprocating Internal Combustion Engine APED - Revision 11/2016 5 .4 ;,..7., Permit Number: 95OPWE 100 AIRS ID Number: 123 /0107 /019 (Leave blank unless APCD bas already assigned a permit and AIRS ID) Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under general permit GP02, I further certify that this source Is and will be operated in full compliance with each condition of general permit GP02. 4.1 Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type,etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$152.90(if applying for GPM For more information or assistance call: submit with an additional$1500), to: Colorado Department of Public Health and Small Business Assistance Program Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver,CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/aped Colorado Department of Public Health and Environment Telephone: (303)692-3150 COIORA00 Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 11/2016 6 i Q1 .,; , Portable Analyzer Test Results C-140 Old SN:288108 New SN:263183 Spindle'Gas Plant' Exhaust Flow Rate scf/hr=87111 scf/MMBtu*Fuel Consumption MMBtu/hr*2095%/(2095%-O2%) Fuel Consumption MMBtu/hr=Fuel Consumption(scf/hr)*Fuel Heating Value(Btu/scf)/1.1)00,000(Btu/MMBtu) Emissions(lb/hr)=measured ppmv/1(100.(100*Exhaust Flow(scf/hr)"mol.wt.(Ib/Ibmol)*I(Ibmol)/385.33(scf) where: molecular weight CO = 28.1111 molecular weight NOx = 46.07 Test Data Results(see attached) Source ID No. P-160 P-161 P-162 P-164 P-165 P-166 P-163 P-167 P-169 P-171 P-170 P-168 CIG-S-2 Site ID No. C-136 C-137 C-138 C-139 C-141( C-141 C-147 C-1511 C-153 C-212 C-215 C-217 C-221 Seoul Number 360657 240602 327101 286440 263183 144345 397541 361158 19941 314879 71B03385 18653 Engine Stack Test Date 05.12;20 Mom Conc.O2% = u Meas.Post-Converter CO ppmv= 156 i" Meas.Post-Convert.NOx ppmv=- Normal Fuel Heat Value Btu/scf= Max.Fuel Consumption(scf/hr)= 8976 8976 8976 8976 8976 8976 8976 952 8976 4471 8509 1632 4475 Max.Fuel Consump.(MMBtu/hr)= 0.00 0.110 O011 0.)0) 9.74 03(0 Il(111 II)))) 11.011 0.00 9.11 000 0.00 Max.Exhaust Flow Rate(scf/hr)= ll.11 0.0 011 11 0 84801.3 (1.0 1111 0(l (1(1 Il 0 196677.1 0.0 11.11 Max.Meas.CO Emiss.Rate(lb/hr)= 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.5 0.0 0.0 Permited CO Emiss.Limit(Ib/hr) = 9.1 9.1 9.0 8.82 5.43 9.1 5.4 0.8 6.6 4.0 10.7 1.5 5.2 Compliance with Hrly CO Limit YES YES YES YES YES YES YES YES YES YES YES YES YES Max.Meas.CO Emiss.Rate(tpy) = 0.0 0.0 0.0 0.0 4.2 0.0 0.0 0.00 0.00 0.00 2.25 0.00 0.0 Permited CO Emiss.Limit(tpy) = 39.6 39.6 39.6 33.0 23.8 39.0 2,3,5 3.02 28.96 17.30 403) 1.4 22.9 Compliance with Yrly CO Limit YES YES YES YES YES YES YES YES YES YES YES YES YES Max.Meas.NOx Emiss.Rate(Ib/hr)= 0.0 0.0 0.0 0.0 0.5 0.0 0.0 0.0 0.0 0.0 1.8 0.0 0.0 Permited NOx Emiss.Limit(lb/hr)= 9.1 9.1 5.4 4.41 2.72 9.1 5.4 0.6 4.4 2.6 5.4 1.0 5.2 Compliance with Hrly NOx Limit YES YES YES YES YES YES YES YES YES YES YES YES YES Max.Meas.NOx Emiss.Rate(tpy)= 0.0 0.0 0.0 0.0 2.0 0.0 0.0 0.00 0.00 0.00 7.88 0.00 0.0 Permited NOx Emiss.Limit(tpy) = 24.0 24.0 23.8 19.3 11.9 24.11 23.0 241 19.31 11.59 23,5 2.2 22.9 Compliance with Yrly NOx Limit YES YES YES YES YES YES YES YES YES YES YES YES YES e OM® Engine Emissions Test Report Emissions Test Date: 05/12/2020 Q2 10571 Ecom J2KN DCP Midstream CO: ppm NOx: ppm Daniel Huber + Phone: t.} 6.391 45.087 3026 4th Avenue Greeley,CO 80631 Pass Pass Mobile: (970)-433-8664 (976 ppm) (275 ppm) Email: Dhuber@dcpmidstream.com PHYSICAL LOCATION Operational Area: Weld County Facility Name: Spindle Plant EQUIPMENT INFORMATION Equipment: C-140 Unit#: C-140 AF Controller Make: Altronic Model: 7042 GSI Serial#: 263183 AF Controller Model: EPC 100E Service: Ref Residue Ignition Timing: 18.0 Catalytic Converter Make: DCL Stack Flow: Fuel Type: Gas:Natural Catalytic Converter Model: 75.5 Intake MP: Left: 40 Intake MT: Left: 105 Fuel Consumption: 9400 Right: 40 Right: 102 Horsepower: 500 Stack Height: FuelSG: RPM: 988 Equipment Fuel Pressure: 17 MV Target Set Point: .764 Hours: Stepper Left: 1072 Exhaust Temp: Left: 1222 MV Actual: Left: .762 Position: Right: 1102 Right: 1225 Right: .763 Catalyst dp: 2.0"w.c. Pre-Catalyst 961 Post-Catalyst Temp: 1016 Temp: PERMIT INFORMATION Permit#: 95OPWE039 Permit Date: 05/01/1999 Permit CO Limit: 976 Permit Equipment#: P-165 Permit Units: ppm @ 0%O2 Permit NOx Limit: 275 ANALYZER INFORMATION Model: ecom-J2KNpro Industrial Serial#: 10571 Last Stability Test: 5/12/2020 Last Linearity Test: 5/12/2020 EMISSIONS TEST RESULTS Parameter Test Test 2 Test 3 Overall Average O2% F` 0.00 0.00 0.00 0.00 CO Ppm 156.39 0.00 0.00 156.39 NOxppm 45.09 0.00 0.00 45.09 CO A1BNP-ht 0.423 0.000 0.000 0.423 NOxBHP-hr 0.197 0.000 0.000 0.197 COIbr 0.466 0.000 0.000 0.466 NOx lthr' 0.217 0.000 0.000 0.217 CO TRY 2.042 0.000 0.000 2.042 NOx TRY 0.951 0.000 0.000 0.951 CO IbImmBTI1 0.099 0.000 0.000 0.099 NOx lb/mmBTU 0.047 0.000 0.000 0.047 Test 1 - 05/12/20 Time 02 CO NO NO2 NOx 11:40:21 0.00 185.00 16.00 0.00 16.00 11:41:21 . 0.00 162.00 117.00 0.00 117.00 11:42:21 a`' 0.00 148.00 29.00 0.00 29.00 11:43:21 0.00 132.00 26.00 0.00 26.00 11:44:21 0.00 112.00 61.00 0.00 61.00 11:45:21 '' 0.00 156.00 44.00 0.00 44.00 11:46:21 0.00 262.00 64.00 0.00 64.00 11:47:21 _ 0.00 198.00 95.00 0.00 95.00 11:48:21 0.00 181.00 14.00 0.00 14.00 11:49:21 0.00 173.00 28.00 0.00 28.00 11:50:21 ` 0.00 90.00 38.00 0.00 38.00 11:51:21 -_ 0.00 128.00 27.00 0.00 27.00 11:52:21 0.00 115.00 164.00 0.00 164.00 11:53:21 0.00 170.00 36.00 0.00 36.00 11:54:21 . 0.00 325.00 21.00 0.00 21.00 11:55:21 0.00 107.00 35.00 0.00 35.00 11:56:21 ` ` 0.00 112.00 31.00 0.00 31.00 11:57:21 . 0.00 100.00 21.00 0.00 21.00 11:58:21 0.00 120.00 21.00 0.00 21.00 11:59:21 0.00 133.00 15.00 0.00 15.00 12:00:21 0.00 139.00 16.00 0.00 16.00 12:01:21` 0.00 217.00 17.00 0.00 17.00 12:02:21 0.00 132.00 101.00 0.00 101.00 Average O2= 0.00% Average NOx = 45.09 ppm Average CO= 156.39 ppm Average COmass= 156.391 ppm Average NO= 45.09 ppm Average NOxmass= 45.087 ppm Average NO2= 0.00 ppm ANALYZER AVERAGE INFORMATION Total Average O2= 0.00`)/0 Total Average NOx= 45.09 ppm Total Average CO= 156.39 ppm Total Average 156.391 ppm Total Average NO= 45.09 ppm Total Average 45.087 ppm COmass= NOxmass= Total Average NO2= 0.00_ppm a �4 tt a t - x [ r. : Y -ty+ •� d�}y �� ` x r .(:r I> [� x Yx ?., .af3 yi�r 1 �, i�,�• .- \..�.�.__.:.._},,., .v..,�.s.....,.T iv_ii i5s..t.•��:,k,�,.._..�r.,,,.s<,��....w.�r:'...�:4t...,.o.a_._...e�.�,.� Jam,�-. .. ., s � e...,.wv,.t.•.ti_. .. �uL� ..A L.F. i_4tf.Sk.i�'C{.'4_.✓a.tire�t 5-12-2020 test. New Engine initial Start date 5-8-2020. Commision Date 5-14-2020. 1�.`:f c. +� ?.r�T [7 Ti y: ✓Rtq, ,[ .r•<f°' gF r+.,:,. �i.,y�� o�rx F r�y, ry'J.'.13$`a a *� - T.;'}Y4 < '55.r.��`'aP�F�.�r�•a @Y;A, 14,-V S.S 1y, --s(•,V3V,C1, 1,<"MITAZ'',iy''tr..,,.,�' .3Y �.Y �('' n/(�7 L�-L+.{ p y S �;q i �{,V l 1. M1 �p fit. S5 VYS�l !`1j}f(f j1 AA,.Y+4,'�{'1,''.3 '.�'41.47-.T,n1,.,,v Fes` ^iN('i[ r§J' t7A1/4..60 ;i 4':�.;•+. LS'.L.� G.ttI�:;L7 .;�1....._ ...._.r...:-:.,`11.._..t x r a,:h.i�c.`.a`.�, .? fiFdT.t of t Sal`a.'.F 'v�34,._we-;1' �a4..c.s .,xylC A'Itre...;tt:.�x�>?a`C•8 llii te^•ri _ � .ife"sAag Daniel Huber DCP Midstream 3026 4th Avenue Greeley,CO 80631 Phone: Mobile:(970)-433-8664 Email:Dhuber@dcpmidstream.com Home Page:• ,h; .� �-:?,��+}'"s�'_:.� -"'s Ff� y ��n�Y'F�" `��^` ��' �e�� TrYg�k; a�!'9.�� `�,�'��"f�°�Ta-s '�' s�; • f r '".u.. L�.,.UL TIr'y.» T�..1i. F :4 4�t � ➢$.:c.*AFR1�\?'�Ea + W,sa�',u `F-S �F' ' r", .., `w 3k�ia2. s1'R r5 1116 2'y_s_.s. r 0 3 t ... x Equipment Type: Engine 500hp++w/o fuel meter Fuel Type: Gas: Natural Fuel Consumption :9400 Horsepower:500 Fuel(F) Factor: Based on: EPA RM-19 at 68 deg F and 14.696 psia i1 • 350 —02 —CO A _ -NO �I` —NO2 —NOx 300 —T{celU j 250 i 11 I. I , r ± + 1 200 1 `;I= l! 150 �� t 1 11 1 ) t 100 t 50 � � ... I 11 l 1i 11'10 tii ta41 ,1 sip Ian' ' ., u ;" --\--'-''',.„-_-:-------- 0 0 10 20 30 MirLtes Technician Date CCOM® Pre & Post Calibration Test Report Calibration Test Date: 05/12/2020 10571 Ecom J2KN DCP Midstream Sensor Span Gas Expiration Zero Error Cal Error Zero Drift Span Drift Value date %Limit %Limit %Limit : %Limit Daniel Huber O2% 20.9 4/8/2018 0.3 0.5 0.5 0.5 Phone: CO ppm 1008 7/16/2026 3 5 5 5 3026 4th Avenue NO ppm 618 10/9/2025 3 5 5 5 Greeley, CO 80631 NO2 ppm 52.07 5/18/2021 3 5 5 5 Mobile: (970)-433-8664 Email: Dhuber@dcpmidstream.com PHYSICAL LOCATION Operational Area: Weld County Facility Name: Spindle Plant EQUIPMENT INFORMATION Equipment: C-140 Unit#: C-140 AF Controller Make: Altronic Model: 7042 GSI Serial#: 263183 AF Controller Model: EPC 1.00E Service: Ref Residue Ignition Timing: 18.0 Catalytic Converter Maker DCL Stack Flow: Fuel Type: Gas: Natural Catalytic Converter Model: 75.5 Intake MP: Left: 40 Intake MT: Left: 105 Fuel Consumption: 9400 Right: 40 Right: 102 Horsepower: 500 Stack Height: FuelSG: RPM: 988 Equipment Fuel Pressure: 17 MV Target Set Point: .764 Hours: Stepper Left: 1072 Exhaust Temp: Left: 1222 MV Actual: Left: .762 Position: Right: 1102 Right: 1225 Right: .763 Catalyst dp: 2.0"w.c. Pre-Catalyst 961 Post-Catalyst Temp: 1016 • Temp: PERMIT INFORMATION Permit#: 95OPWE039 Permit Date: 05/01/1999 Permit CO Limit: 976 Permit Equipment#: P-165 Permit Units: ppm @ 0%O2 Permit NOx Limit: 275 ANALYZER INFORMATION Model: ecom-J2KNpro Industrial Serial#: 10571 Last Stability Test: 5/12/2020 Last Linearity Test: 5/12/2020 Calibration Secs O2% CO ppm NO ppm WWWO2 ppm Pre-Test Zero% 0.0 0.0 0.0 0.0 Post-Test Zero% 0.0 0.0 0.0 0.0 Mean Zero,Ccz 0.0 0.0 0.0 0.0 Zero Result Pass Pass Pass Pass Pre-Test Span 21.0 1010 618 52 Pre-Test Result Pass Pass Pass Pass Post Test Span 21.0 989 614 52 Post Test Drift% 0.5 1.9 0.6 0.1 Post Test Results Pass Pass Pass Pass Span Drift(%) 0.0 2.1 0.6 0.0 Mean Span,Corn 21.0 999.5 616.0 52.0 Pre Test Calibration Time 02 CO NO NO2 IFtow 11:22:01 21.0 0.0 0.0 0.0 2.59 11:22:03 , 21.0 0.0 *' 0.0 0.0 2.59 11;22:04 21.0 0.0 0.0 *10.0 2.59 1122:05 21.0 0.0 0.0 0.0 *' 2.59 11`23:01. 0.3 537 0.0 0.0 2.60 11:23:32 0.0 *' 1076 0.0 0.0 2.60 1124:01 0.0 1141 0.0 0.0 2.60 11:24:52 ' 0.0 1010 *2 0.0 0.0 2.59 11:25:01 0.0 1011 0.0 0.0 2.59 11:26:01 0.0 79 631 2 2.60 11:27:01 0.0 15 635 2 2.57 11:27:13 ` 0.0 12 618 *2 2 2.56 11:28:01 21.0 7 13 49 2.60 11:28:06 : 21.0 *2 6 11 51 2.60 11;29:01 "_ 21.0 3 4 56 2.60 11:29:21 21.0 3 3 52 *2 2.60 Post Test Drift Check Time O2 CO NO P1O2 IFiow 1220:14 20.8 0.0 0.0 0.0 2.58 12:20:16 = 20.8 0.0 *1 0.0 0.0 2.58 12:20:18 20.8 0.0 0.0 *1 0.0 2.58 12:20:19 20.8 0.0 0.0 0.0 *2 2.58 12:21:14 0.0 642 1 0.0 2.59 12:21:21 0.0 * 778 0.0 0.0 2.59 12:22:14 0.0 969 0.0 0.0 2.60 12:22:57 0.0 989 *z 0.0 0.0 2.59 12:23:14 0.0 995 0.0 0.0 2.60 12:24:14 0.0 65 607 2 2.55 1225:14 0.0 10 614 2 2.58 12:25:17 0.0 10 614 *2 2 2.57 12:26:14 20.9 3 13 46 2.58 1226:18 21.0 *1 3 12 48 2.58 Post Test Drift Check 12:27:14 ' :t;21.0 1 4 51 2.56 12:27:36 ` 21.0 0.0 3 52 *2 2.56 *' : Captured Zero : Captured Cal Response NOTES: TEST COMPLETED BY: Daniel Huber DCP Midstream 3026 4th Avenue Greeley, CO 80631 Phone: Mobile:(970)-433-8664 Email:Dhuber@dcpmidstreamcom Home Page: Technician Date CO 1008 Response Stability Linearity CO 503 Midspan ANALYZER INFORMATION Model#: ecom-J2KNpro Inds Serial#: 10571 Last Stability Test:5/12/2020 Last Linearity Test:5/12/2020 Test 1-05/12/20 Time CO Notes 10:11:01 0 10:12:01 868 10:13:01 1005 10:14:01 1008 10:15:01 1008 10:16:01 1007 10:17:01 1009 10:18:01 1009 10:19:01 1009 10:20:01 1010 10:21:01 1009 10:22:01 1009 10:23:02 1009 10:24:02 1009 10:25:02 1009 10:26:02 1009 10:27:02 1010 10:28:02 1009 10:29:02 743 10:30:02 516 10:31:02 509 10:32:02 507 Technician Date NO 618 Response Stability Linearity NO 303 Midspan ANALYZER INFORMATION Model#:ecom-J2KNpro Inch Serial#: 10571 Last Stability Test: 5/12/2020 Last Linearity Test :5/12/2020 Test 1-05/12/20 Time NO Notes 10:33:33 0 10:34:33 598 10:35:33 615 10:36:33 618 10:37:33 618 10:38:33 618 10:39:33 618 10:40:33 618 10:41:33 618 10:42:33 618 10:43:33 619 10:44:33 619 10:45:34 619 10:46:34 619 10:47:34 619 10:48:34 619 10:49:34 619 10:50:34 620 10:51:34 324 10:52:34 306 10:53:34 305 10:54:34 304 Technician Date NO2 52.07 Response Stability Linearity NO2 23,76 Midspan ANALYZER INFORMATION Model#: ecom-J2KNpro Inds Serial#: 10571 Last Stability Test: 5/12/2020 Last Linearity Test:5/12/2020 Test 1-05/12/20 Time NO2 Notes 10:57:39 0 10:58:39 39 10:59:39 51 • 11:00:39 51 11:01:39 51 11:02:39 52 11:03:39 52 11:04:39 52 11:05:39 52 11:06:39 52 11:07:39 52 11:08:39 52 11:09:39 52 11:10:39 52 11:11:39 52 11:12:39 52 11:13:39 52 11:14:39 52 11:15:39 52 11:16:39 32 11:17:39 26 11:18:39 25 Technician Date Engine Replacement Field Log Title V Operating Permit No.95OPWE039 DCP Operating Company,LP Spindle Natural Gas Processing Plant—PAGE 1 Source ID Like-Kind Original Engine Description Replacement Engine Description Engine Portable Engine Start Analyze Replacemen Date r Stack t Test Date Field Title V Yes No Make Model HP Serial Make Model HP Serial No. No. 140 P-165 X Waukesha L7042GSI 1000 288786 Waukesha L7042GSI 1000 362517 1/5/99 1/8/99 139 P-164 X Waukesha L7042GSI 1000 388531 Waukesha L7042GSI 1000 144043 9/27/00 9/27/00 139 P-164 X Waukesha L7042GSI 1000 144043 Waukesha L7042GSI 1000 388531 12/20/00 12/20/00 147 P-163 X Waukesha L7042GSI 1000 360925 Waukesha L7042GSI 1000 319041 1/18/02 1/23/02 153 P-169 X Waukesha L7042GU 1000 382939 Waukesha L7042GSI 1000 277151 1/24/02 1/28/02 138 P-162 X Waukesha L7042GSI 1000 262110 Waukesha L7042GSI 1000 396923 9/18/02 9/19/02 141 P-166 X Waukesha L7042GSI 1000 386916 Waukesha L7042GSI 1000 260958 1/8/03 1/14/03 150 P-167 X Waukesha F1197GU 125 306927 Waukesha F1197GU 125 262057 5/8/03 5/12/03 217 P-168 X Caterpillar G342NA 230 31B3201 Caterpillar G342NA 230 71B03385 6/27/03 7/1/03 136 P-160 X Waukesha L7042GSI 1000 389002 Waukesha L7042GSI 1000 351321 10/6/03 10/6/03 137 P-161 X Waukesha L7042GSI 1000 232481 Waukesha L7042GSI 1000 286434 3/5/04 3/12/04 140 P-165 X Waukesha L7042GSI 1000 362517 Waukesha L7042GSI 1000 240413 1/28/05 1/31/05 139 P-164 X Waukesha L7042GSI 1000 388531 Waukesha L7042GSI 1000 335792 4/24/08 4/25/08 138 P-162 X Waukesha L7042GSI 1000 396923 Waukesha L7042GSI 1000 266535 4/8/09 4/13/09 147 P-163 X Waukesha L7042GSI 1000 319041 Waukesha L7042GSI 1000 286440 5/20/09 5/26/09 137 P-161 X Waukesha L7042GSI 1000 286434 Waukesha L7042GSI 1000 350086 3/3/11 3/7/11 1 - Test engine using a portable analyzer within 7 calendar days from when the replacement engine began operation and complete APEN within fourteen(14) days from when the engine began operation. 2- Alternative Operating Scenario is limited to permanent like-kind engine replacements of the same make,model and hp. Engine Replacement Field Log Title V Operating Permit No.95OPWE039 DCP Operating Company,LP—Spindle Natural Gas Processing Plant—PAGE 2 Source ID Like-Kind Original Engine Description Replacement Engine Description Engine Portable Engine Start Analyzer Replacemen Date Stack t Test Date Field Title V Yes No Make Model HP Serial Make Model HP Serial No. No. 140 P-165 X Waukesha L7042GSI 1000 240413 Waukesha L7042GSI 1000 288108 4/5/12 4/9/12 136 P-160 X Waukesha L7042GSI 1,232 351321 Waukesha L7042GSI 1,232 240413 5/29/12 5/29/12 141 P-166 X Waukesha L7042GSI 1,232 260958 Waukesha L7042GSI 1,232 144345 1/28/13 2/4/13 153 P-169 X Waukesha L7042GU 1,000 382939 Waukesha L7042GU 1,000 361158 03/03/14 03/06/14 215 P-170 X Superior 8SGTB 1,215 315909 Superior 8SGTB 1,215 314879 4/28/15 5/4/15 138 P-162 X Waukesha L7042GSI 1,232 367248 Waukesha L7042GSI 1,232 327101 11/15/16 11/17/16 147 P-163 X Waukesha L7042GSI 1,232 286440 Waukesha L7042GSI 1,232 397541 11/11/17 11/15/17 139 P-164 X Waukesha L7042GSI 1,000 335792 Waukesha L7042GSI 1,000 286440 4/4/18 4/5/18 137 P-161 X Waukesha L7042GSI 1,232 350086 Waukesha L7042GSI 1,232 240602 6/25/19 6/26/19 136 P-160 X Waukesha L7042GSI 1,232 240413 Waukesha L7042GSI 1,232 360657 1/26/20 1/29/20 140 C-140 X Waukesha L7042GSI 1,232 288108 Waukesha L7042GSI 1,232 263183 5/08/20 5/12/20 1 - Test engine using a portable analyzer within 7 calendar days from when the replacement engine began operation and complete APEN within fourteen(14) days from when the engine began operation. 2- Alternative Operating Scenario is limited to permanent like-kind engine replacements of the same make,model and hp. 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review . E`;:: STATE OF' COLORADO Chavez-CDPHE, Elie<elie.chavez@state.co.us> + Spindle Significant Modification Draft Permit for Review Chavez-CDPHE, Elie <elie.chavez@state.co.us> Thu, Jun 4, 2020 at 9:15 AM To: "Shankaran, Roshini"<RShankaran@dcpmidstream.com> Hi Roshini, Thanks so much for getting this permit reviewed! Please see my responses below.Additionally, I've attached draft redlined APENs for the fugitive point(034)and the two engines(052 and 057). Please review and let me know if they look ok to you. Thanks so much, Elie Chavez Permit Engineer Title V Operating Permit Unit Stationary Sources Program Air Pollution Control Division :"•'- COLORADO Air Pollution Control Division CDPHE Department of Public Health tJ Environment P 303 692 6332 4300 Cherry Creek Drive South, Denver, CO 80246-1530 elie.chavez@state.co.us I www.coiorado.gov/cdphe/aped Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more. On Wed, Jun 3, 2020 at 2:59 PM Shankaran, Roshini <RShankaran@dcpmdstreamcom>wrote: Hi Elie, Thank you for providing us the opportunity to review the draft Title V permit at Spindle. Please see below for our comments. Also please see responses to your questions directly in your email below! • Section Unit Comment 1 � Responsible Facility-wide The RO for this facility.has changed as of 5/18 to Charles A.Job, General Official Manager, North Area Operations,303-605-1964 Done. 1.--- _-__j____-. _---1 l https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-a%3Ar-3466840437239187567&simpl=msg-a%3Ar-34668404... 1/5 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review Page 3 Submittal I We would like to request a change in the annual monitoring period from Deadlines I July 1-June 30 to January 1-December 31. Can this be altered in this permit? Unfortunately, it can't-we only change those at renewal. Section I, 6.1 C-140 Please update serial number due to AOS. Attached is the AOS documentation. Done. It looks like this engine is so old that it's no longer subject to the Reg 7 emission standards (Condition 1.11.1), so I removed the reference to C-140 from that condition. i_ _ _. �...-�_ _ .....�—_.�.�_�..e- Section II, 1.3 Natural gas If there is a possibility to update the fuel allocation equation,we would like consumption for the denominator to account for all fuel burning sources at the facility engines because there is not a dedicated fuel meter just for engines. Yep no problem. It looks exactly like the Greeley consumption calculation -does that work?Also, if it's ok with you, I'd like to update this for the Condition 2 and 3 engines as well so it's being calculated the same way throughout the permit. Section II, 1.4 Btu content of fuel I If there is a possibility to update the Btu requirement,we would like to update it to reflect higher heat value instead of lower heat value. Engines are all typically permitted on HHV. Done. As with the above, I'd like to update the Condition 2 and 3 engines to reflect this as well- let me know if that's ok. Section II, 6 P-181 j The monitoring interval on the first row is specified as semi-annual, however the LDAR or EGA requirements are both not semi-annual. It seems like updating the frequency to annual would be consistent with the annual EGA requirement and the annual emission limit. Please update the monitoring interval to annual. Done.--L-----Section II, 6.1 P-181 I Please update the heavy liquid control percentages per our discussion at Greeley to 75%/30%. It should not materially affect emissions. Done.___L I Please let me know if you have any further questions. Thanks, Roshini Roshini Shankaran Environmental Engineer—Weld County DCP Midstream https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-a%3Ar-3466840437239187567&simpl=msg-a%3Ar-34668404... 2/5 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review 370 17th Street, Suite 2500 Denver, CO 80202 Office: 303-605-2039 Cell: 720-391-7005 p Mid am From:Chavez-CDPHE, Elie [mailto:elie.chavez@state.co.us] Sent:Tuesday, March 3, 2020 10:58 AM To:Cameron, Marie E<MECameron@dcpmidstream.com>;Shankaran, Roshini <RShankaran@dcpmidstream.com> Subject:Spindle Significant Modification Draft Permit for Review Hi Marie and Roshini, Please find attached the Spindle draft permit and transmittal letter formally initiating source review. Please review this permit by 5/4/2020. I've left track changes on, so feel free to comment that way, or create a separate list of comments or do a hybrid of both-whatever is easiest for you. I'd sent an email in response to the minor modification addendum on 2/13 with a few questions, and I've come up with a few more when drafting the permit. To keep everything together, I've pasted the comments from the 2/13 email below and have added a couple minor things I found while drafting the permit: • It looks like the light liquid control percentages were applied to the heavy liquid components as well.Was there a reason for this? I'd always thought the reason we didn't grant control efficiencies specifically on the APEN for heavy liquids was because they are very not volatile (I think EPA 453 defines heavy liquid as something with a vapor pressure less than 0.3 kPa) and LDAR may not be as effective for these components. This makes almost no difference in the emission calculations since the heavy liquid emission factors are tiny and neither Greeley nor Spindle have a significant amount of heavy liquid components, so I don't need an answer on this to call them complete, but I did want to double check with you.As discussed at Greeley, it would be great if you could list the 75%/30% control efficiencies for heavy liquid components. No problem. • I am getting very different controlled HAP emissions. Our uncontrolled emissions match perfectly, but something went wrong with the controlled HAP and I'm not sure what. I'm getting closer to 0.13 tpy total HAP. I did notice that on the first page of the fugitive calculation the"total HAP" in the"liquid service HAP" column seems to be adding incorrectly (I'm getting 1.3%total HAP and the talc is getting 2.67%). I'm not sure if that's getting carried over into other calcs or not. If we need to redline the APEN for HAP, that's not a problem. There was an error in our calculations, 'after correcting this error, we are seeing total HAP emissions of 0.13 tpy as well. Please redline the APEN with the individual HAP totals you calculated. Please • see the attached draft. • On the fugitive APEN, I noticed that MACT HH is marked as applicable. I think the intention of the APEN is just to address fugitive emission MACT HH requirements, not dehy requirements. Since Spindle isn't a major source of HAP, I think the MACT HH box should be checked"no". I can redline if you agree-just let me know! Agreed, please redline the APEN! Please see the attached draft. • Per our phone conversation, I won't put in the monthly limits for the engines or fugitives. Great! https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-a%3Ar-3466840437239187567&simpl=msg-a%3Ar-34668404... 3/5 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review • The serial number listed on the C-141 (AIRS 057)APEN does not match the current operating permit. I can't find an AOS in our systems for this engine either. Can you please confirm the serial number for this engine? I can redline the APEN if necessary. This was an error on the submitted APEN. The correct SN for engine C-141 is 144345. Please redline the APEN!Additionally, it appears this error was carried over into the submitted TV forms as well. If possible, please redline any necessary forms from that submittal as well. Please see the attached draft. I've redlined the application as well with this information. • For engines C-137 (AIRS 052)and C-141 (AIRS 057) I'm getting a NOx control % closer to 82%. Can you please confirm this?The NOx control efficiency listed on the APENs are 70%for both engines, so I may need to redline-just let me know! 82% is the correct value for both units, please redline these APENs! Please see the attached drafts. • In the draft permit, can you please double check the SAR and annual certification submittal deadlines on the 2nd page of the permit?We are updating our permit title pages to have content controls that will eventually dump various information automatically into the letters we send (to save time hopefully).To fit the template, I had to use the standard table for submittal deadlines, and the previous version of the Spindle permit had some missing information-I think I got it all in there correctly, but I'd definitely appreciate a second pair of eyes on it. Please see comment included above, since this is not a renewal permit I'm not sure if these can be changed. Otherwise the dates appear correct. Thanks for the check, but as noted above, we can't change these dates until renewal. I'll make a note of this on the renewal application for Spindle. • I added the Reg 7 engine requirements (what was Section XVII.E) in the permit for all engines, not just C- 136. It seemed sort of strange to me to just say engine C-136 only was subject to Reg 7, since in reality, all the other engines are. Since this is being processed as a significant modification,this update isn't a problem, but I did want to make sure you were ok with me sort of making a modification of my own. I think it'll be less confusing for inspectors, but if you prefer I only address the C-136 requirements,just let me know and certainly can remove them. This is appreciated, thank you! Perfect- note that I altered the C-140 applicability based on the May 2020 AOS, as indicated in the table above. In addition to the above, I will also need a significant permit modification application for C-137 and C-141. Again, because you've already submitted APENs with the January 2020 mod, you don't need to pay for new APENs, but we will need copies of the APENs submitted with the January 2020 application, a cover letter requesting the sig mod, copies of the calculations provided with the January 2020 application and the applicable Title V application forms. Again, I'll just need the application before we start public notice, so no rush to get it in before you review the permit or anything. This was sent over in April. Thank you. Let me know if you have any questions or need anything else! Thanks so much, Elie Chavez Permit Engineer Title V Operating Permit Unit Stationary Sources Program Air Pollution Control Division Ct:+ COLORADO Air Pollution Control Division COME Department of Public Health&Environment P 303.692.6332 4300 Cherry Creek Drive South, Denver, CO 80246-1530 elie.chavez@state.co.us I www.colorado.govicdphe/aped Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more. https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-a%3Ar-3466840437239187567&simpl=msg-a%3Ar-34668404... 4/5 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review [Quoted text hidden] 3 attachments .� 123-0015-057 APEN MOD RL DRAFT.pdf 3532K cm 123-0015-052 APEN MOD RL DRAFT.pdf 3544K 123-0015-034 APEN MOD RL DRAFT.pdf 3732K https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-a%3Ar-3466840437239187567&simpl=msg-a%3Ar-34668404... 5/5 6/8/2020 State.co.us Executive Branch Mail-Spindle Significant Modification Draft Permit for Review STATE OF Chavez-CDPHE, Elie<elie.chavez@state.co.us> G")),' COLORADO Spindle Significant Modification Draft Permit for Review • Shankaran, Roshini <RShankaran@dcpmidstream.com> Fri, Jun 5, 2020 at 2:16 PM To: "Chavez-CDPHE, Elie"<elie.chavez@state.co.us> Hi Elie, Everything looks good on the APENs. The comments you pointed out below are also exactly what I was envisioning with regards to fuel allocation and the HHV(i.e. similar to Greeley). I also agree that updating them for all engines is a good idea. Thanks again for all your work on Spindle! Thanks, Roshini Roshini Shankaran Environmental Engineer—Weld County DCP Midstream 370 17th Street, Suite 2500 Denver, CO 80202 Office: 303-605-2039 Cell: 720-391-7005 cifJ Midstream • From:Chavez-CDPHE, Elie [mailto:elie.chavez@state.co.us] Sent:Thursday,June 4, 2020 9:16 AM To:Shankaran, Roshini<RShankaran@dcpmidstream.com> [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0?ik=85031 f40e8&view=pt&search=all&permmsgid=msg-M3A1668691467094976469&simpl=msg-f%3A16686914670... 1/1 Hello