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Home My WebLink About20201578.tiff COLORADO Department of Public Health&Environment Weld County - Clerk to the Board 1150 O St RECEIVED PO Box 758 Greeley, CO 80632 APR 2 7 2020 April 22, 2020 COMMISSIONERS Dear Sir or Madam: On April 23, 2020, the Air Pollution Control Division will begin a 30-day public notice period for DCP Operating Company, LP - Godfrey Bottom Compressor Station. 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 a Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator of corny I ivsi 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Direct Pu6I;C Rev:e4,1 cc:Flap),Ni-0-K),Pia(sM/ER/cK/cK) 2020-1578 6/3/PP oG(7M) 5/2102.0 i5 s i T1Tt.l D P H E Glycol Dehydration Unit APES y " Form APCD-202 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 glycol dehydration(dehy)units only. If your emission unit 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 at:www.cotorado.govicdphe/apcd. 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: 11 WE1479 AIRS ID Number: 123 / 9010 /005 (Leave blank Mess APCD has already assigned a permit C and AIRS ID1 Section 1 -Administrative Information Company Name: DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location; Site Location Sec. 10, T4N, R66W 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 E-Mail Address: RShankaralca n(gDCPMids m.mm 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 wilt require additional paperwork. ?Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 414585 Avir COLORADO Form APCD-2O2 Gtycol Dehydration Unit APFti - Revision 3/2019 Permit Number: 11 WE 1479 MRS ID Number: 123/°,°/005 IL-rave t+i a L-VSs AP TD ha;at, adi a;E$DEed a p,ErEon anEE AiR'a€DI Section 2-Requested Action ❑ NEW permit OR newly-reported emission source -OR- El MODIFICATION to existing permit/check each box below that applies) ❑ Change fuel or equipment O Change company name' O Add point to existing permit O Change permit limit O Transfer of ownership" O Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAi.PERMIT Acno.is- ID Limit Hazardous Air Pollutants($APs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 'i For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 -General Information General description of equipment and purpose: TEG dehydration unit for water removal Company equipment Identification No. (optional): D-1 For existing sources,operation began on: 7/11/2018 For new or reconstructed sources,the projected start-up date is: ❑Check this box if operating hours are 8,760 hours per year;if fewer,fill out the fields below: ( Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS o Yes ❑ No nonattainment area? Is this unit located at a stationary source that is considered 0 Yes 0 No a Major Source of(HAP)Emissions? is COLORADO j Form APCO.2O2 Glycol Dehydration Unit AP£t+- Revision 3/2019 2 I Permit Number: 11 WE 1479 AIRS ID Number: 123/900/005 h=xr t. - r.. ='"��'. �t v.r,,.; �..� '`Y'�`i., e e'I�`�c Al".:„ Section 4-Dehydration Unit Equipment Information Manufacturer: Dickson Process Systems Model Number: TEG Unit Dehydrator Serial Number: 2466 Reboiter Rating: 3.0 MMBTU/hr Glycol Used: O Ethylene Glycol(EG) O DiEthylene Glycol(DEG) ❑✓ TriEthylene Glycol(TEG) Glycol Pump Drive: Electric O Gas If Gas, injection pump ratio: / Acfm/gpm Pump Make and Model: FMC ! M1218 - 1 primary, 1 backup #of pumps: 2 Glycol Recirculation rate(gal/min): Max: 25.0 Requested: 25.0 Lean Glycol Water Content: 1.0 Wt.% ; '* Design Capacity: 155' ( MMSCF/day Dehydrator Gas Throughput: Requested5: -49275— MMSCF/year Actual: 827.1 MMSCF/year Inlet Gas: Pressure: 1,000 psig Temperature: 120 "F Water Content: Wet Gas: lb/MMSCF ❑ Saturated Dry gas: 5.0 tb/MMSCF Flash Tank: Pressure: 60 psig Temperature: 130 .F O NA Cold Separator: Pressure: psig Temperature: 'F i] NA Stripping Gas:(check one) 0 None O Flash Gas ❑Dry Gas O Nitrogen Flow Rate: scfm Additional Required Information: El Attach a Process Flow Diagram Q Attach GRI-GLYCatc 4.0 Input Report ii Aggregate Report(or equivalent simulation report/test results) Attach the extended gas analysis(including BTEX ft n-Hexane,temperature,and pressure) 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. AV COLOfADO Form APCD./i3 (it rc ai Dehydration(Jolt APEN Revision 3'20119 3 I Permit Number: 11 W1479 AIRS ID Number: 123/4010/OO5 {{i.ea�-.bil 'k($inns APCD t5.- /a>„>..,,,ad, _aa::, ., .. +i,,,s Sys ,k PA's VI i• M _ Section 5 - Stack Information Geographical Coordinates `.ft tudeit rte. Tt} 40.32997!-104.75378 a or S 19$e a@1 elnPt �9,W t W " etOY " st+t t +fix` ,`gyp ,,`- ." A i? eve „t " ,x 7 } '�'�`""� D-1 30.0 indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap O Horizontal O Other(describe): I Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): I Q Square/rectangle Interior stack width(inches): Interior stack depth(inches): I O Other(describe) 1 ECD combustion do used for still venh cars€rol has a 2.0 annual downtime for maintenance and repairs.Still vent emissions will vent teatmosphere during pinlods of ECD downtime. I # -. _ - Section 6 Control Device Information Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. I ` Used for control,of: O Condenser: Type: Make/Model: Maximum Tang: IF Average Temp: 'F Requested Control Efficiency: Used for Contra of: Flash Tank Emissions 0 VRU: Size: NA Make/Model: NA t Requested Control Efficiency: 100.0 . t(RU Downtime or Bypassed: 5,0 IUsed far control of: stmt Vent Emissions Rating: NA MMBtu/fir a Type: Enclosed Combustor Make/Model:Zeeco 4 Combustion ` Device: Requested Control Efficiency: 95.0 t 11=1Manufacturer Guaranteed Control Efficiency: 98,0 i ri i 4x i" `_t U. ""' 4 Minimum Temperature: NA 'F Waste Gas Heat Content: 1;000 Btu/scf i Constant Pilot Light: ® Yes O No Pilot Burner Rating: 0.065 MMBtu/hr Closed Used for control of: O Loop Desrription: System: System Downtime: Used for control of: Flash Tank Emissions during 5.0%VRU Downtime 0 Other: Description: ECD Combustion Device Requested Control Efficiency: 95.0 caaso c�+ a Fora A i, -2O2 Glycol Dehy=dration Unit O.FEN- Revision.i'201 4 I "°fig I 4 I I i Permit Number: 11WE1479 AIRS 1D Number: 123/9010/005 • i i •.: APc t - d AlPt 1 3 • Section 7- Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined)control efficiency(%reduction): tion of Control Methods Overall Requested Pollutant Description Method(s) Control Efficiency } (%reduction in emissions) PM SOx NOx CO VOC VRU/Enclosed Combustor i 100%/95% HAPs VRU/Enclosed Combustor 100%/95% €Other: From what year is the following reported actual annual emissions data? 2018 } Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions — -----1 Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units I. (AP-42, Emissions Emissions(' Emissions Emissions Mfg.,etc-) (tons/year) (tons/year) (tons/year) (tons/year) PM SOS NOx 0.068 lb/MMB1u AP-42 0.21 0.21 1--,0g- i-`.; 1;09 µ CO 0.31 lb/MMBtu AP-42 0.94 0,94 4.'84 4.84 a>= VOC 23.76 Ib/MMscf GLYCaIc 154.22 4.77 -585:33'_ 24.33'_, .> - , E-I t)t;c :u.'ion limit in:truicw'" t. t° .(win ttta c 3a i°tt to ytt.yasf ., ..6 r en I Lr,- c_.:--- rrt �:s f l�z= tt;lac for t tl Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name r Source Uncontrolled Controlled uncontrolled Service(CAS) Basis # Units (AP-42. Emissions Emissions6 # i mfg.,etc.) (pounds/year) (paundslyear) Benzene 71432 t 2.11 Ib/MMscf GLYCaIc 35,929 1,747 Toluene 108883 2.43 Ib!MMscf GLYCaIc 41,222 2,017 Ethylbenzene 100414 0.10 Ih/MMscf GLYCaIc 1,650 81 f Xylene 1330207 1.03 ,lbiMMscf GLYCaIc 17,498 862 I n-Hexane 110543 0.30 Ilb./IVIMscf GLYCaIc 5,156 168 2,2,4 540841 1 Trimethylpentane 1Other:Methanol I 5 Requested values will become permit€lmitations. Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave t blank. I . - Pff D 202 Glycol D h < 2 9 GOLORA06 r Fir;$Pitt 4✓"LI:iL 4 t�HS Unit l ,zsfLl J 5 I AMOY raY t I 1 Permit Number: 11 WE1479 AIRS ID Number: 123/900/005 !Leave ht3ru uni ss APCD ha-s a'se des#g led..r pe,n,}c .arid AIRS it Section 8- Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. 9/‘m.1-. 1..-'' q1101 ! 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: I 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 or(303)692-3148 APCD-SS-B1 1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.govicdpheiapcd A COLORADO Form APCD 202 Glycol Dehydration Unit ADEN keVtalOn 3%2019 6 I S3 • E General APEN - Form APCD-200 CO „�. 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 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 new filing fee. There may be a more specific APEN for your source(e.g.boiler, mining operations,engines,etc.). A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.colorado.govlcdphe/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: 11 WE 1479 AIRS ID Number: 123 /9010/009 jLease bL,ni,unless APCO has already assigned a menet k and AIRS ID] Section 1 - Administrative Information Company Name1: DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Sec. 10, T4N, R66W Site Location Weld Site Location: County: NAICS or SIC Code: 1311 Mailing Address; 370 17th Street, Suite 2500 (include Zip Code) Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base E-Mail Address2: RShankaran®DCPMidstream.com l 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. per COLORADO Form PCD•2`O Generat APEN Rev: 3/2019 1 L 3R" «»w a Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/009 t.9 3,14,,,r .�v ADC_ i i= f dt r ,i A;RS I Section 2 - Requested Action O NEW permit OR newly-reported emission source(check one below) O STATIONARY source O PORTABLE source -OR- Q MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit 0 Change permit limit O Transfer of ownership" O Other(describe below) -OR- O APEN submittal for update only(Note blank APENs will not be accepted) -ADarrwraL PERIur Acnorrs- ▪ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) O APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-lob)must be submitted. t For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-1Q4)must be submitted. Section 3 - General Information General description of equipment and purpose: Natural Gas Compression Turbine Manufacturer: Solar Model No.: Taurus 70 Serial No.: 1003B Company equipment Identification No. TU R B-1 (optional): For existing sources,operation began on: 7/11/2018 For new or reconstructed sources, the projected start-up date is: Q Check this box if operating hours are 8,760 hours per year;if fewer,fill out the fields below: I�pprrnat Hours of Source Operation: hours/day days/week weeks/year ilk Seasonal use percentage: Dec-Feb: Mar-May: Jun-Aug: Sep-Nov; Ay COLOR:DO Form APCD-201-General APEN RevisiF n 3/2019 2 i ;_ Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/009 Section 4 - Processing/Manufacturing Information & Material Use 0 Check box if this information is not applicable to source or process From what year is the actual annual amount? Design Process Actual Annual Requested Annual Description Rate Amount Permit Limits (Specify Units) (Specify Units) (Specify Units) Material Consumption: Finished Product(s): 5 Requested values wilt become permit limitattns, Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.32997 / -104.75878 O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. f)peiittrr Disc iaegeHeight ...ti . e i.3rc4ind Temp. Flaw Rate Stack ID!io , Abiay. .. Level(p'eet) f`� (At� sac) TURB-1 919 Indicate the direction of the stack outlet: (check one) Upward O Downward O Upward with obstructing raincap O Horizontal O Other(describe): Indicate the stack opening and size: check one ®Circular Interior stack diameter(inches): 4$,0 o Square/rectangle Interior stack width(inches): Interior stack depth(inches): o Other(describe): COLORADO Form APCD 200 Genera( AP_)! Re-.ssinn 3`ZUi9 3 I o gym« Permit Number: 11 WE 1479 AIRS ID Number: 123 t9010/009 [Le6+,e bt=m1k a:1e,i-,APCfl >alr c-ady,3 slyfled a rn-lit.7,i(rd AIRS O Section 6 -Combustion Equipment Et Fuel Consumption Information O Check box if this information is not applicable to the source(e.g. there is no fuel-burning equipment associated with this emission source) Design Input Rate Actual Annual Fuel Use Requested Annual Permit Limits {Mht8TUlh-6, . (Specify unfu) - .{Specify Units} 69.8 214.2 MMscf/yr 673.5 MMscf/yr From,what year is the actual annual fuel use data? 201 8 Indicated FibV represents Indicate the type of fuel useds: 2018 actual fuel use. An FHA' O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTUISCF) value of 908.2 Btu/scf(LHV) was used to calculate the O Field Natural Gas Heating value: BTU/SCF requested annual permit ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTUlgailon) limit of 6"3.5 MN-Bd./yr. O Propane (assumed fuel heating value of 2,300 BTU/SCF) o Coal Heating value: BTU/lb Ash content: Sulfur content: p Other(describer Pipeline Natural Gas Heating value(give units): 1,108.63 Btu/scf s Requested values will become permit limitations.Requested limit(s)should consider future process growth. s If fuel heating value is different than the listed assumed value,provide this information in the"other"field. Section 7 Criteria Pollutant Emissions Information t Attach all emission calculations and emission factor documentation to this APEN form. i Is any emission control equipment or practice used to reduce emissions? O Yes ®No . Iif yes,describe the control equipment AND state the overall control efficiency(%reduction): :- Control Equipment Overall Collection Efficiency ,. Overall Control Efficiency Pollutant Descnption 1 (%reduction in emissions) k TSP(PM) s PMt© PMzs SOD, NO. . .. CO VOC i Other: ii,*. CO IC N�A R9 1 Form APCD-200- General AP Ii . Revision 3 20!9 4 I •�• ,9, R. 3i Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/009 _.. Gl;-hEa' tiPCOh<. &. ,o v,?,!Et.8" 5r+9,<;2 From what year is the following reported actual annual emissions data? 2018 Use the following table to report the crit—ia pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission :A Ren led aAnnttat Pe tit Uncontrolled Actual Atrnual:rnlRlcr Pollutant. Emission l.rnissior�'tirlrl {5 Factor Factor Source (P iIY Units) (AP 42 M€g•, £ Uncontrolled (tons/year) Controtied7 Uncontrolled Controlled item/year) (tons/year) (tansfyear) TSP(PM) 5.60E-031b/MMBtu AP-42 0.78 O78 2.02 2.02 PM,0 6;60E-031b/MMBtu AP-42 0.78 0.78 2.02 2.02 PM2,5 5.50E-03Ib/MMatu AP-42 0.78 0.78 2.02 2.02 SO 3.40E-o3Ib/MMBtu AP-42 0.40 0.40 1.04 1.04 NO 0.056 Ib/MIVll3tu Mfg. 6.51 6.51 17-.96--- 4 95 . _ . CO 0.061 lb/MMBtu Mfg. 6.51 6.51 49752- 19:-52- �� 7- z�. VOC 2.70E-031b/MMgtu AP-42 0.25 0.25 -0':64""y' -0:64- ► ' `' Other: 5 Requested values will become permit limitations.Requested limits)should consider future process growth. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave ,, blank. �.. , Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Q 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: - Uncontrolled Uncontrolled Controlled Overall Emission Factor , CAS Chemical Emission Actual Actual Number Name Conti of Factor `Source Emissions Emissions2 Efficiency (specify units) (AP-4z,Mfg.,etc.) (Ibs/year) (lbs/year) 7 Annual emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating,leave blank. COLORADO Form AP(D-2.043 - Gene(at APEIi Rev 5uin 3'2019 5 I =r „'ItZ, Permit Number: I1 WE 1479 AIRS ID Number: 123 /9010/009 tco_,SAP(Dat.; .n:eda:E +cJ Est„tAtan AiD5i0 Section 9-Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. .7ffierez c't 1/ 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: EiDraft 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 or(303)692-3148 APCD-SS-81 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.sov/cdphelapcd AV COIO#A00 Form APCD 200-General APED! - Revision 3120i, 6 1133 CDPHE General APEN - Form APCD-200 CO Air Pollutant Emission Notice(APEN)and 10' 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 wilt 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. There may be a more specific APEN for your source(e.g.boiler,mining operations,engines,etc.).A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at:www.cotorado.govtcdphelapcd. 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, ILC.for revised APEN requirements. Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/010 (leave blank unless APCD has already assigned a permit a and AIRS ID] Section 1 -Administrative Information Company Name': DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location: Sec. 10, T4N, R66W Site County: Weld NAICS or SIC Code: 1311 Mailing Address: 370 17th Street, Suite 2500 ( (include zip Code) Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 Portable Source Home Base: E-Mail Address: RshankarareDCPMidstream.com I 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 a-mail to the address provided. 414587 COLORADO Form APCD 20O- General APEN-Revision 3/2019 1 I AV „; ;,�.„, ', Permit Number: 11 WE 1479 AIRS ID Number: 123 /90101010 (Lei ve trial'+k WIC si APCD ha ai,t-Jd,tissta,t,d a gu:.tr :f.. a;,t R ID Section 2 -Requested Action O NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source O PORTABLE source -OR- Q MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit 0 Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT Across- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) ❑ APEN submittal for permit exempt/grandfathered source Additional info&Notes: 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 General description of equipment and purpose: Natural Gas Compression Turbine Solar Taurus 70 10046 Manufacturer: Model No.: Serial No.: Company equipment Identification No. TU RB-2 (optional): For existing sources,operation began oa: 7/11/2018 For new or reconstructed sources, the projected start-up date is: ❑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 Seasorlal yse,pfrcetitage: Dec-Feb: Mar-May: Jun-Aug: Sep-Nov: t t Ay COtORA0O Form APCD.2i30 General APEti Revision 3'2019 2 I L�H.'G Permit Number: I1 W 1479 AIRS ID Number: 123 /9010/010 Section 4- Processing/Manufacturing Information &Material Use _ T 1:1 Check box if this information is not applicable to source or process From what year is the actual annual amount? _ Yy py �y tN5in Psi 3 $ -0�x �1} #x� ; Description Rat =' .14 foft s Requested values wilt become permit limitations,Requested limits)should consider future process growth, Section 5 - Stack Information Geographical Corardin lLnt(tuoe Lo<-g rude or ii ) 40.32997 1 -1 04,75878\ O Check box if the following information is not applicable to the source because emissions will not be emitted from a stack,If this is the case, the rest of this section may remain blank, -frPjfir.vidAzairj, -3 TURB-2 919 Indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap O Horizontal a Other(describe): Indicate the stack opening and size: (check one) Q Circular Interior stack diameter(inches): 48.0 Sguareirectangle Interior stack width(inches): Interior stack depth(inches): Q Other(describe): 1 Form D•2O0- General APEN - Revision 3/2019 3 1 co '"" � ,;. ,' 'Permit Number: 11'WE 1479' ,_._ .. AIRS 1O Number: 123 /3010/010. - (Leave Wank ante,.A PCD 11..a atr,aad,as a pa i anel AIRS i.> Section 6-Combustion Equipment Et Fuel Consumption Information O Check box if this information is not applicable to the source(e.g. there is no fuel-burning equipment associated with this emission source) Des tl lhput Rate Actual Annual Fuel Use Requested�Annual Permit Limits s18)"tithe fSp ►fy arts} (s cify units)' 69.8 214.8 MMscf/yr $73.5 MMscf/yr From what year is the actual cmn uei fuel use data? 2018 * Indicated FHV represents Indicate the type of fuel used: 2018 acts fuel use.An FHA' O Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) value of 908.2 Btuiscr i V) e Q Field Natural Gas Heating value: BTU/SCFv using t �alctllt tlt requested annual permit ❑Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) limit of 6715 f sc/yr„ 3 Q Propane (assumed fuel heating value of 2,300 BTU/KO i O Coal Heating value: BTU/lb Ash content: Sulfur content: i Q Other(describe): Pipeline Natural Gas Heating value(give units): 1,108.63 BtU/scf i 5 Requested values will become permit limitations.Requested timitisi should consider future process growth. b if fuel heating value is different than the listed assumed value,provide this information in the"Other"field. I 1 1 Section 7-Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. t IIs any emission control equipment or practice used to reduce emissions? O Yes 0 No If yes,describe the control equipment AND state the overall control efficiency(%reduction): I 11141,51111Control i Equip nment Overall Collection Efficie ncy' overall Control ffi I Pspll t ht crr eleri ., � 1O (%red i i r fir emissions) 1 TSP(PM). .. s PMr PM2.S t SOS I NO), CO VOC IOther: 1 i I .70,..„14,,,Form APCD-200- General APEN Revision 3/2019 4 1 �.o�ai� 1 Permit Number: 11 W E 479 AIRS ID Number: 123 /90101010 flevie btank witvss APCD has atzeAdy ._, i :. .,st ' t:=€ From what year Is the following reported actual annual emissions data? V Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these erissions. r ontrolled frtt5 ji • rat tlutant t°,4:4S„ onitaileT tit etc) (tons/year) ,� lleafi r s TSP(PM) 6.80E-31b1MMBtu 42 0/8 8 0.78 2.02 2.02 PM TO 6.60E-03 IbIMM Btu AP-42 0,78 0.78 2.02 2.02 • • . Paitt.s 6,60E-03 tbiMMBtu AP-42 0.78 0.78 2.02 2.02 SOx 3,40E-03it rMaww, AP-42 0.40 0.40 1.04 1,04 NO o.ose lb/MM1tu Mfg. 6.53 6.53 . 1 _ co 0:081 lb/IVIMBtu Mfg. 6.53 6.53 19.52 -19.52,.- u v c 2.10E-03IbiM Bit, AP-42 0,25 0.25 0.64 -._ 64 Other: 41# ` " s Requested values will become persist timitatsnns.Requested limits)should consider future process growth, i 7 Annual emissions fees will be based on actual controlled emissions reported,If source has not yet started operating,leave blank. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria Yes Eli No pollutants(e.g. HAP-hazardous air potletant)equal to or greater than 250 lbsiyear? Ej If yes, use the followmg table to report the non-criteria pollutant(HAP)emissions from source: overall Uncontrolled I Emission Factor Uncontrolled Controlled T7hemirat f Emission Actual Actual Control ' Source plumber Name Factor Errtissiorls Emissio 7" Efficiency.� � (.�F'•��,hff .,etc) F (Specify Units) ;j fhb dyear) abstyear f � { s 7 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. t �b COLORADO Farm APCD,-200-General APEN Revision 3/2019 5 ? LL t:': '.*° (`'Permit Number: 11 WE1479:. .;: _ AiRs ID Number: 123 /9010 r 04 _.: , [Lea 4-,b'..,k th Oss APCD ha atreaddy a sIgn?'d a pe#T'o'ur t.any AIRS by Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. RV), 1 } Signature of Legally Authorized Person(not a vendor or consultant) ate Marie Cameron Senior Environmental Engineer Name(print) Title Check the appropriate box to request a copy of the: Q✓ Draft permit prior to issuance lEll Draft permit prior to public notice ( g Checkin any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)ears.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 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https:I'www.colora do.eovdcdoheiapcd Il COtO0ADO Form APCD-200• General APEN • Revi on 3/2019 6 I .rrrrIIIIIIIIIIIIIIIIIIIII fr A CDPHE P H E Hydrocarbon Liquid Loading APEN Form APCD-208 CO --O` 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 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 hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit,glycol dehydration unit, 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 at:www.cotorado.gov/cdphe/apcd. 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, ILC. for revised APEN requirements. Permit Number: 11 WE1479 AIRS ID Number: 123 / 9010/ 012 {Leave blank 41ntess APO has already assigned a permit a and AIRS IDI Section 1 -Administrative Information Company Name': DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location Site Location: Sec. 10, T4N, R66W 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 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. 414538 p COLORADO Form AP 208 Nidrurrarbon Liquid Leidig APEN -Revision 3/2019 1 I Avt=== Permit Number; 11 WE1479 AIRS iD Number: 123 /9010/012 (Lt ',r ,.fir sa tt?5's APCC Pt, >dt a¢qt ..w 3 f tt r x AF-,S Section 2- Requested Action O NEW permit OR newly-reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit(check each box below thaw applies) ❑ Change fuel or equipment O Change company name3 Q Change permit limit O Transfer of ownership" O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- CI Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 1 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 'i For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APO-104)must be submitted. Section 3- General Information General description of equipment and purpose: Pressurized truck load out of condensate Company equipment identification No. (optional): L-1 For existing sources,operation began on: 7/11/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes Q No emissions? Does this source load gasoline into transport vehicles? ❑ Yes L1{, No Is this source located at an oil and gas exploration and production site? O Yes ❑Q No if yes: Does this source load less than 10,000 gallons of crude oil per day on an annual O Yes O No average? Does this source splash fill less than 6750 bbl of condensate per year? O Yes O No . v s this source submerge fill less than 16308 bbl of condensate per year? O Yes O No Av COI.oewoa Form APC0.208 Hyd ocarbon l id;t'r9 Loading APEN Revision 3/2019 2 Permit Number: 11WE1479 AIRS ID Number: 123 /9010/012 3.4:e F z +i a Cr 2, 3;i _..n,r, dk x z O Section 4 - Process Equipment information Product Loaded: ❑r Condensate 0 Crude Oil 0 Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions,complete the following: Average temperature of Saturation Factor: 'F bulk liquid loading: Molecular weight of True Vapor Pressure: Psia®60'F tb/tb-mol displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading tines, complete the following: Requested Volume Loadeds: 714,286 bbl/year ' Actual Volume Loaded: 56,333 bbl/year Product Density: 46.08 tb/ft3 Load Line Volume: 0.4218 ft3/truckload Vapor Recovery Line Volume: 0.0218 ft3/truckload 5 Requested values wilt become permit limitations.Requested limits)should consider future process growth. 714334 bbl/yr=4,286 loadout events/yr 56,333 bbl/yr=338 loadout events/yr (7,000 gallons/loadout event) 3 i AyForm APCD 208 Hyde arbon Li u'd Loading APED Revision '2019 f I Permit Number: 11WE1479 AIRS ID Number: 123 19010 1012 I Section 5 m Stack Information • I Geographical Coordinates I (Latitude/Longitude at UTM) E 40.32997 I-104.75878 C r c I a twi'1 -kl'ighe-— rt. ;,f, Ly, 'ms 1# ':.,t y ( _ '=I',-°A-c�"',.-. q b ti I Indicate the direction of the stack outlet:(check one) (0 Upward O Downward ❑Upward with obstructing raincap Q Horizontal Q Other(describe): Indicate the stack opening and size: (check one( 0 Circular Interior stack diameter(inches): i O Other(describe): Section 6 - Control Device Information ® Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. I0 Loading occurs using a vapor balance system: Requested Control Effit•Fiency: 100 I Used for t ctrtat of: Rating: MMBtu/hr Type: Make/Model: Combustion 0 Device: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: F Waste Gas Heat Content: Btu/se Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MiYettiihr Pollutants Controlled: Other: Description: Requested Control Efficiency: I b�»e COLOgADO Form APCti•2 Hydrocarbon Litiuid Lading APEN Pevisian 3/2019 II .,',1:7Z,7 ,',, i i Permit Number: 11 WE1479 AIRS ID Number: 123 /9010/012 APC i....rj-``.�.... ... s=i•�4i.(^t„a'.�ff.. an,1 AIRS Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Pollutant Description of Control Method(s) Control Efficiency - (X reduction in emissions) PM Sox NOx CO _ , _ VOC • HAPs Other: Using State Emission Factors(Required for GP07) VOL Benzene n-Hexane Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions inventory. Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s) Pollutant Uncontrolled Source Uncontrolled Controlled. Uncontrolled Controlled oasis Units (AP-42, Emissions Ernissionsb Emissions Emissions Mfg.,etc.) (tons/year) (tonslyear) (tons!yerr) (tons,Year) PM SOX NC1x CO 1111 VOC 1.055 Ibfload Eng.Est. 0.15 0.15 2,27 2.27 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Service Abstract( = Uncontrolled Units Source Uncontrolled Controlled Basis (AP 42, Emissions Emissions6 (pounds/year) Number Mfg•,etc. (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene _ 1330207 n-Hexane 110543 0.070 lb/load Eng.Est. 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. Form APCD-208 Hydrocarbon coc oa�oo Li�ei..., L��da,-� APEN Pevts�bn 3�?Oi9 5 I '�a „. w,an f Y w Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/012 tbaa&F b,.l k,r,trc APCD ha;a'₹..1, ?.tstgl$P i nr'9, . ??A,RS 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 GP07,I further certify that this source is and will be operated in full ompliance with each condition of General Permit GP07. SiAt/tCt 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: Q 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$312.50,if applicable,to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable t4: Or visit the APCD website at: Colorado Department of Public Health and Environment https:iiwww.colorado.Rov/cdphelapcd Form APCD-208 iiydrocarbor Ligrnd i.oad?ng APEN Pevislon 3/2019 6 I H Fugitive Component Leak Emission APEN ° Form APCD-203 t O1'°. CO ! 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 leak 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 at:www.colorado.eovicdphetapcd. 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,IL.C. for revised APEN requirements. Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/ 013 ]leave btank unless APCD has at ready assigned a permit A and AIRS ID] Section 1 -Administrative Information Company Names: DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location: Sec. 10, T4N, R66W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Ad Address: 370 17th Street, Suite 2500 Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E-Mail Address2: RShankaran@DCPMidstream.com i 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. • 414539 M. COLORADO Form APCD-203 Fugitive Comp rent Leat, Emissions AFEN Revision.3/2019 1 I Mar r==, Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/ ibeae b , . APC ; a,: Ai'SID Section 2 - Requested Action ,�]1 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 O Add point to existing permit O Change permit limit O Transfer of ownership4 O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDinoNAL 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: Previously APEN / Permit exempt 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): FUG For existing sources,operation began on: 7/11/2018 For new or reconstructed sources,the projected start-up date is: 3 Q Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Facility Type: ❑Well Production Facility's ❑Natural Gas Compressor Stations []Natural Gas Processing Plants O Other(describe): is ;r A 5 When selecting the facility type,refer to definitions in Colorado Regulation No.7,Section XVII. Avy caoa•oo Form AP D-203 Fugitive i o₹ „onent Leak E mcsions APEN - Revision 3/2019 2 I t. Permit Number: 11 WE1479 AIRS ID Number: 123 /9010/ .:,APco 1-/+t„ Section 4- Regulatory Information What is the date that the equipment commenced construction? 8/2017 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Witt 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 seat centrifugal compressors or reciprocating compressors ❑Yes 0 No located at this facility? Is this equipment subject to 40 CFR Part 60,Subpart KKK? O Yes 0 No Is this equipment subject to 40 CFR Part 60,Subpart 0000? O Yes 0 No Is this equipment subject to 40 CFR Part 60, Subpart 0000a? 0 Yes O No Is this equipment subject to 40 CFR Part 63,Subpart HH? O Yes 0 No Is this equipment subject to Colorado Regulation No. 7,Section XIL.G? O Yes 0 No Is this equipment subject to Colorado Regulation No.7,Section XVII.F? 0 Yes O 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 Ethylbenzene Xylene n-Hexane` Z� Stream Trimethylpentane twtz) (u/t"%) (wt xl lwt%) fwtl f, (wt i5) t - Gas 28.70 0.05 0.04 0.001 0.01 0.39 0.004 Heavy Oil (or Heavy Liquid) (or Light quid) 100 0.18 0.13 0.003 0.03 1 .37 0.01 Water/Oil Section 6- Geographical Information Geographical Coordinates (latitude/Longitude or UTM) 40.32997 /-104.75878 Attach a topographic site map showing location Ay CCLon�ao Form APU) 203 Fut3•tl'.e Component Leak Emissions A Eri- Revision 3 2 t 31 Permit Number: 11 WE1479 AIRS ID Number: 123 /9010/ ADCD fris =as,.45S' raed 6 PalMi[A a;°;;JAMS!D, Section 7- Leak Detection and Repair (LDAR)and Control Information Check the appropriate boxes to identify the WAR program conducted at this site: O LDAR per 40 CFR Part 60,Subpart KKK O Monthly Monitoring Control:88%gas valve, 76%light liquid valve,68%light liquid pump []Quarterly Monitoring-Control:70%gas valve,61%light liquid valve,45%tight liquid pump LDAR per 40 CFR Part 60,Subpart OOOO/OOOOa Monthly Monitoring Control:96%gas valve,95%light liquid valve,88%tight liquid pump,81% connectors LDAR per Colorado Regulation No. 7,Section XVILF ❑Other6: o No WAR Program 6 Attach other supplemental plan to APEN form if needed. COLORADO Form A?CD 203 Fu love Component Leak Emissions APEN Revasaon 3,2019 4 l A _RADmow. Permit Number: 11 WE 1479 AIRS iD Number: 123 /9010/ IL, r=,1F:.' i ,-A r 5 p,1 1,4 4 i- C fJ, 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. Q 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: 0 Estimated Component Count Actual Component Count conducted on the following date: Equipment Type Service Connectors Flanges Pump Seats f3pen�Ended 'Valves Other') • CountB 1,346 457 — 2 624 29 Emission Factor 2.20E-05 1.26E-05 - 7,72E-04 5.51 E-05 2.65E-04 Units lb/hr/source lb/hr/source — lb/hr/source ib/hr/source lb/hr/source Heavy` Oil(or HeavyLiquid)vyyY Counts — — _ _ Emission Factor — Units -- - Light Qll(or'tight Liquid) CountB 5,241 756 — 5 1,109 10 Emission Factor 2,14E-05 .5.29E-06 - 1.12E-03 4.19E-05 2.43E-04 Units lb/hr/source 113/hr/source — Ib/hrisource.lb/hr/source lb/hr/source Water/Oil Count8 Emission Factor Units _- 7 Table 2.4 and Table 2.8 are found in U-S.EPA's 1995 Protocol for Equipment Leak Emission Estimates(Document EPA-4531R- 95.0171. a 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 lines,pump seals,or valves. +' COLOR ADO Form APCD^2O3 Fugitive Component Leal.: Emissions APEN - Revision 3`2019 5 1 ,co. Permit Number: . IWE1479 AIRS ID Number: 123 /9010/ [Leave blank unless APCD has air asp-pied Section 9 ® Emissions inventory information Attach all emissions calculations and emission factor documentation to this APEN form. from what year is the following reported actual annul emissions data? 2018 Use the following table to report the criteria pollutant emissions and non-criteria pollutant(HAP)emissions from source; (Use the data reported in Section 8 to calculate these emissions.) } I m Requested Annual Permit Emisstta `O Sit''' I Actual Annual Emissions ( i CAS a_ : Limit(s) �' Cfiei Number f iical Nape ! Uncontrolled" Controlled Uncontrolled Controlled i , 3 _,..e..„.,......,,....._._.�........ _..d..._.-�.._ _......_ 'era= �, ati j "tons! ear (tons! elk *lt VOA.. 0,87 Q87 1,19 1.19 Does the emissions source have any actual emissions of non-criteria pollutants (e.g.HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? Yes n No If yes,use the following table to report the non-criteria pollutant(HAP)emissions from source: Requested Annual Pe Ictual Annual Emissions i Einnxti j Uncontrolled Controlled'" Uncontrolled za,..tall(l `y€ar 5J..e,a Benzene 71432 Toluene 108883 i � E Ethylbenzene 1£X3414 Xylem 1330207 n-Hexane 110543 2,2,4 Triniethylpentane 540841 Other: 10 Annuat emissions fees wilt be based on actual controlled emissions reported.If source has not yet started operating,leave blank. 11 Requested values will become permit Limitations. Requested timit(s)should consider future process growth,component count variability,and gas composition variability. I I I I casaaaoa t Form APCD-203 Fugitive Component Leak Emissions ADEN • Revision '2019 6 I to 1 Permit Number: 11 WE1479 AIRS ID Number: 123 /9010 r Section 10- Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. /4Atit 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: Q 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 or(303)692.3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment hops:t/www,colorado.govicdphe/apcd mar.COLORADO Form APCD 203 Fugdtt°ir Component Leak Fm sstons APEN Revision 3;2019 7 i AV „«„ 11) CE "F` Gas Venting APEN - Form APCD-211 CO Air Pollutant Emission Notice (APEN)and .'� Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs wilt 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 gas venting only.Gas venting includes emissions from gas/liquid separators,well head casing,pneumatic pumps, blowdown events,among other events. If your emission unit 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 at:www.colorado.Rovicdphe/apcd. 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, ti.C.for revised APEN requirements. Permit Number: 11 WE1479 AIRS ID Number: 123 /9010 / 19!5 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 -Administrative Information Company Name': DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location Site Location: Sec. 10, T4N, R66W County: Weld NAICS or SIC Code: 1311 Mailing Address: 370 17th Street, Suite 2500 (Include Zip Code) Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 E-Mail Address2: rshankaran@dcpmidstream.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt 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. 414591 pp COLORADO Form ARCD-211 Gas Venting APEN - Revision 3/2019 1 I k - Permit Number: 11 WE1479 AIRS ID Number: 123 /9010/ f Lea c bIafo, ir•3d,Nss PC0 has al€vadii a sggned a PeIrhIt ago AIRS ID1 Section 2- Requested Action NEW permit OR newly-reported emission source -OR- O MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted, 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted, Section 3 -General information General description of equipment and purpose: TURB-1, TURB-2 compressor blowdown emissions Company equipment Identification No. (optional): TURB-B D For existing sources,operation began on: 7/11/2018 For new,modified,or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year;if fewer,fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: Will this equipment be operated in any NAAQS nonattainment area? Q Yes O No Is this equipment bated at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No.7, ❑ Yes 0 No Section XVII.G? I A ♦ w t COLORADO Form APCO.211 Gas Venting APEN - Revision 3/2019 2 I R Permit Number: 11WE1479 AIRS ID Number: 123 /9O1O/ [Leaven l.t ink sz ii, >APCD is.1< s9a # f .vad wart €t are=t 4AS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make; Model: #of Pistons: Leak Rate: Scf/hr/gist Q Blowdown Events #of Events/year: 40 Volume per event: 0.028 MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? O Yes 0 No Vent Gas BTUt5CF Gas Venting Heating Value: 1332.5 Process Parameters: Requested: 1.10 MMSCF/year Actual: M MMSCF/year -OR- Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters: Molecular Weight: 22.9 VOC(Weight%) 28.70 Benzene(Weight%) 0.05 Vented Gas Toluene(Weight%) 0.04 Properties: Ethylbenzene(Weight%) 0.001 Xylene(Weight%) 0.01 n-Hexane(Weight%} 0.39 2,2,4-Trimethylpentane(Weight%) 0.004 Additional Required Information: O Attach a representative gas analysis(including BTEX Et n-Hexane, temperature,and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX ft n-Hexane, temperature,and pressure) 5 Requested values will become permit limitations.Requested limits)should consider future process growth. Ayr GO40R*OO Form APCD 211 Gas Venting APEN Revision 3.'2019 3 I Permit Numbers 11 WE1479 AIRS ID Number: 123 19010/ (Lei. .b#w k tplic,as APCD Pis „ _,. y rasa=d A c; .as.l MPS ID1 Section 5 - Stack Information Geographical Coordinates (Lotitude/tongitude or lfTM) 40.32997/A04/5878 TURB-BD Indicate the direction of the stack outlet: (chez*one) Q Upward ❑Downward 0 Upward with obstructing raincap 0 Horizontal 0Other(describe): Fugitive Source Indicate the stack opening and size:(Ova.one) I ❑Circular Interior stack diameter(inches): i i 2 Other(describe): Fugitive Source Section 6-Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section.: Pollutants Controlled: ISize: Make/Model: O VRU: Requested Control Efficiency: a VRU Downtime or Bypassed: Pollutants Controlled: Rating: MMBtuihr l Type: Make/Model: Combustion Requested Control Efficiency: Device: Manufacturer Guaranteed Control Efficiency: I Minimum Temperature: Waste Gas Heat Content: Btulscf t Constant Pilot tight: 0 Yes is No Pilot burner Rating: MMBtu/hr i Pollutants Controlled: 0 Other: Description: I Requested Control Efficiency: I GOkSYR A#C! Form C -211 Gas Venting APED - Revision .3120194 I AV 1 4 Permit Number: 11WE1479 AIRS ID Number: 123 /9010 N:ink r r>s., ^r°c {,.5, a?, :.: cile f far rM >and A f,It 3 Section 7- Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency a reduction): Overall ted Pollutant Description of Control Method(s) "Control Effie envy _ reduction in emissions) PM SOx N ©x CO VOC HAPs Other: From what year is the followingreported actual annual emissions data? NA Criteria Pollutant Emissions inventory Emission Factor Actual Annual Emissions t Requested Annual Perms „ Emissiontirnitts)s Pollutant , Source Uncontrolled Controlled Uncontrolled Controlled . Uncontrolled units (AP-42, 6 Basis Emissions Ernissioris Emissions„ E lssloutis_: Mfg„etc.) (tonslyear) (tons/year) (tens/yearr)- •(twns/year). '. PM Sox _ NO CO VOC 477.5 ib/btowoown Eng.Est. — 9.55 9.55 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS uncontrolled (AP-42, 6 Number ) , Basin Units Mfg.,etc. Emissions Emissior►s r ) (pounds/year) (pounds/year) --... -. Benzene I 71432 0.85 th/biowd wn Eng.Est. Toluene 108883 0,64 ibroiowiown Eng.Est. Ethylbenzene 100414 0,01 ibibirrwerwn Eng. Est. Xylene 1330207 0.12 Rolpiowdwm Eng. Est. n-Hexane 110543 6.53 Ibfiiowoown Eng. Est. thylp 540841 0.06 pia wao.n, Eng. Est. Trmethytpentane (Other: Methanol 67561 0.02 ibibiowd©wn Eng,Est. S Requested values will become permit limitations.Requested limit(s)should consider future process growth, 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank, G4iDRADG Form APC0 211 Gas Venting APEN - Revision 3/2019 5 I co: w , 6 Permit Number: 11 WE1479 AIRS ID Number: 123 19010/ I. 'a,,bi-3r t I APO h.a'teany ass $ yti-'. or„t=and ARS ID) Section 8 Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. .911m, 4212-7-i-- 5121/ Signature of Legally Authorized Person(not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(please 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 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 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.govicdphetapcd ® COLORADO Form APCD-211 Gas Venting APEN - Revrivin 3 20i19 6 I AD "�" N.a9s knipa.wwaf Aik `7 E Gas Venting APEN Form APCD-211 CO 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 gas venting only.Gas venting includes emissions from gas/tiquid separators,well head casing,pneumatic pumps, blowdown events,among other events. If your emission unit 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 at:www.cotorado.govicdphelapcd. 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, D.C. for revised APEN requirements. Permit Number: 11WE1479 AIRS ID Number: 123 /9010 / Ott, (Leave Mani'unless APCO has already assigned a permit e and MRS ID] Section 1 -Administrative Information Company Namei: DCP Operating Company, LP Site Name: Godfrey Bottom Compressor Station Site Location Site Location: Sec. 10, T4N, R66W County: Weld NAICS or SIC Code: 1311 Mailing Address: ?017th Street, Suite 2500 (Include Zip Code) Denver, CO 80202 Contact Person: Roshini Shankaran Phone Number: 303-605-2039 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. z Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 414592 GOIOR ADO Form APCD 211 Gas Ventmg APErs- Revision 3.'20'19 1 I A , Permit Number: 11WE1479 AIRS ID Number: 123 /9010/ (Lea.e btastk 4P CI t asst ,i,.s Y: t .F .rt =x 3,RS€ Section 2 - Requested Action Q NEW permit OR newly-reported emission source -OR- O MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership" O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADa nONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional info fi Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,rship,a completed Transfer of Ownership Certification Form(Form APCD-104}must be submitted. Section 3 General Information General description of equipment and purpose: TURB-1, TURB-2 compressor purging emissions Company equipment Identification No.(optional): TURB-Purge For existing sources,operation began on: 7/11/2018 For new, modified,or reconstructed sources,the projected start-up date is: f ❑Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation; f _ Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP)Emissions? ❑ Yes Q No Is this equipment subject to Colorado Regulation No.7, 'Sectioh XVA,G? ❑ Yes Q No ,,,, C4LOAAPO Form APCD-21I Gas Venting APEN Revision 3/`2019 2 I Mt Permit Number: 11 WE 1479 AIRS ID Number: 123 /9010/ i Lea kr< A'ti.D ha,a rislo,, ras gd 0:t of dt r t:,:-its n h,.In'n. Section 4- Process Equipment Information ❑ Gas/Liquid Separator ❑ Welt Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hripist Slowdown Events #of Events/year: 40 Volume per event: 0.006 MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes 0 No Vent Gas BTU/SCF Gas Venting Heating Value: 332.5 Process Parameters5: Requested: 0.22 MMSCF/year Actual: __ MMSCF/year -OR- Liquid Throughput Process Parameters- Requested: bbl/year Actual: bbl/year Molecular Weight: 22.9 VOC(Weight%) 28.70 Benzene(Weight%) 0.05 Vented Gas Toluene(Weight%) 0.04 Properties: Ethylbenzene(Weight%) 0.001 Xylene(Weight%) 0.01 n-Hexane(Weight%) 0.39 2,2,4-Trimethylpentane(Weight%) 0.004 Additional Required Information: • Attach a representative gas analysis(including BTEX f#n-Hexane, temperature,and pressure) Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature,and ❑ pressure) 5 Requested values will become permit limitations.Requested limits)should consider future process growth, (y, CC ORaDO Form A CD-21I Gas Venting AFEtt- Rev lion 3 2019 3 1 L#3►. .: Permit Number: 11 E1479 AIRS ID Number: 123 /9010/ fLeaNe bass =ks t,. ,t APCD 11,a_zere d'r'a. 3ned arKIAIR541 Section 5 -Stack Information Geographical Coordinates (Latitude/Longitude or_UTM) 40.32997/-104.75878 NSF zrwfp `5f a € _ s .gyp t, c a 3 4:40040%4400 , 0004A0006.7-M0-24.0141E016-0°041-4-1,0 TURB-Purge Indicate the direction of the stack outlet: (cheek one) Upward 0 Downward O Upward with obstructing raincap [Horizontal 0 Other(describe): Fugitive Source Indicate the stack opening and size:(rhwk one) ®Circular Interior stack diameter(inches: 0ther d ribe): Fugitive Sourc Section Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Size: Make/Model: 0 VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: Rating: MMBtuihr Type: Make/Model: Combustion Requested Control Efficiency: Device: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Waste Gas Heat Content: Btuiscf Constant Pilot Light: Yes 0 No Pilot burner Rating: MM8tuhr Pollutants Controlled: Other: Description: Requested Control Efficiency: ..... .^.sw,.., cQP.tl$Atto Form A"Cl -2.11 Gas Venting APED ' Revision 3/2019 4 i Permit Number: 11 1W E1479 7 AIRS ID Number. 123 /9010 1 - t ;.,;. r <. P, .a ,..1.aileady aril ed a pinTWit 4,old art.t't Section 7 s Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. It'multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency 1 reduction): _ _ ___ "Poltutart. Description of Control Methods) Control Efficiency -41,44,,,,-4,4,4,, ' (%reduction in nntssions)PM Sax Nox CO iw - HAPs Other NA From what year is the following reported actual annual emissions data? . _ Cnterra Pollutant Emissions Inventory Requested Annual Permit Emission Factor 1 Actual Annual Emissions t _ Emission Limit(s)5 Pollutant _�._..q Source ` Uncontrolled i Controlled Uncontrolled f Controlled � �.,� Uncontrolled a Units (41)42 � E€asis Emissions Eraii ssc�i Emissions Fissions i hi/5.,etc) fronsIyerr)i Ito ,Ira() Yrr tcPi i (toils/year) PM I SOx NO f VOC t 96.5 lb/purge Eng.Est, — I — j 1.93 1.93 Non-Criteria Reportable Pollutant Emissions Inventory _ 1 Chemical L Emission Factor Actual Annual Emissions Chemical Name e I Abstract ... $ { T Co atrolled � Source unc(mtrolled Service(CAS) uncontrolled F Unitsl Basis r Emissions= missions 1 [ Number 4 :r mfg.,.ett.) 1 (pouidsly#d (.oundslyearj i Benzene 71432 0.17 lb/purge Eng.Est Toluene 108883 0.13 lb/purge Eng.Est. Ethytbenzene 100414 0.003 lb/purge Eng.Est, Xylene 1330207 O.02 lb/purge Eng.Est. n-Heataaae 110543 1.32 lb/purge Eng.Est. t'y' Trimethylperltane 540841. 0.01 Ibsipurge Eng, Est, r. Other: Methanol 67561 0.015 Iblpurge Eng.Est. s Requested values will become permit limitations,Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported,if source has not yet started operating,leave blank. i cos.os4.ao Form APCD„21.1 Gas Venting APEN.Revision 312019 5 I Permit Number: 11 WE1479 AIRS ID Number: 123 19010 (Leave blank unless APCD has already assrgnei a pen It 4 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. intigtr? _ SALA Signature of Legally Authorized Person(not a vendor or consultant) Date Marie Cameron Senior Environmental Engineer Name(please print) Title Check the appropriate box to request a copy of the: Q 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, ILC. 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 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.Qovicdphe/aped COLORADO Form APCD 211 Gas Venting APEN Revision 3/2019 6 I ®� :. , COLORADO — Air Pollution Control Division CDP HE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 11 WE 1479 Issuance: 4 Date issued: Issued to: DCP Operating Company, LP Facility Name: Godfrey Bottom Compressor Station Plant AIRS ID: 123/9010 Physical Location: SEC 10 T4N R66W County: Weld County General Description: Natural Gas Compressor Station Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Emissions from the still vent are routed to an air-cooled One (1) Triethylene glycol (TEG), natural gas condenser and then dehydration unit (Make: Dickson Process to an enclosed Systems, Model: TEG Unit, Serial Number: combustor. Emissions 2466) with a design capacity of 135 MMscf from the flash tank per day. This emissions unit is equipped with are routed to a vapor D-1 005 two (2) electric driven glycol pumps (Make: recovery unit (VRU) to FMC, Model: M1218) with a design capacity recycle to plant inlet. of 25.0 gallons per minute. Only one pump is During VRU operated at a time; the other pump serves downtime, flash tank as a backup. This unit is equipped with a emissions are routed flash tank, reboiler and still vent. to an enclosed combustor. The VRU has a maximum 5% annual downtime. One (1) Solar Taurus 70, Serial Number: TURB-1 009 1003B, natural gas fired turbine rated at None 69.8 MMBtu/hr (LHV) heat input at 40°F Page 1 of 55 .7..1 COLORADO .4610-4111 Air Pollution Control Division E b Eli Department of Public Health&Envfrorwnent Dedicated to protecting and improving the health and environment of the people of Colorado ambient temperature and 9,439 horsepower. This turbine is used for natural gas compression. This source is equipped with SoLoNOx technology for minizing emissions of Nitrogen Oxides. One (1)Solar Taurus 70, Serial Number: 1004B, natural gas fired turbine rated at 69.8 MMBtu/hr (LHV) heat input at 40°F TURB-2 010 ambient temperature and 9,439 horsepower. None This turbine is used for natural gas compression. This source is equipped with SoLoNOx technology for minizing emissions of Nitrogen Oxides. Pressurized loading out of raw unstabilized condensate from pressurized condensate L-1 012 tanks to pressurized tanks trucks using vapor'', None balance. Emissions result from gas vented during hose disconnect. Fugitive emission component leaks FUG 013 None associated with the compressor station. Natural gas venting from turbine (TURB-1 TURB-BD 015 and TURB-2) compressor blowdowns during None turbine shutdowns. Natural gas venting from turbine (TURB-1 TURB-Purge 016 and TURB-2) compressor purging during None turbine startups. Point 005: The glycol pump may be replaced with another glycol pump in accordance with the provisions of the Alternate Operating Scenario (AOS) in this permit. Points 009 and 010: Each turbine may be replaced with another Solar Taurus 70 turbine rated at 9,439 HP in accordance with the temporary turbine replacement provision or with another Solar Taurus 70 turbine rated at 9,439 HP in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup Page 2 of 55 z'<M COLORADO Air Pollution Control Division CDPHE Department of Public Health&£nvirot neat Dedicated to protecting and improving the health and environment of the people of Colorado form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii =does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Monthly Limits: Facility AIRS Pounds per Month Emission Equipment ID Point Process Type PM2.5 NO. VOC CO D-1 005 01 --- 214 3,316 955 Point TURB-1 009 01 343 3,050 109 3,315 Point TURB-2 010 01 343 3,050 109 3,315 Point L-1 012 01 --- -- 384 - - Point FUG 013 01 --- --- 201 - Fugitive Note: Page 3 of 55 it ««- COLORADO Air Pollution Control Division CDAHE Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Monthly limits are based on a 31-day month. • For Point 009 the following process designation applies: o Process 01: Steady-state Turbine Emissions The owner or operator shall calculate monthly emissions based on the calendar month. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 1,359 pounds per month. Facility-wide emissions of total hazardous air pollutants shall not exceed 3,398 pounds per month. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point Process PM2.5 NO. VOC CO Type D-1 005 01 --- 1.3 19.5 5.6 Point 01 2.0 18.0 0.6 19.5 TURB-1 009 02 --- 0.1 0.9 4.4 Point 03 0.1 0.4 3.1 01 2.0 18.0 0.6 19.5 TURB-2 010 02 0.1 0.9 4.4 Point 03 --- 0.1 0.4 3.1 L-1 012 01 --- --- Point FUG 013 01 --- --- 1.2 --- Fugitive TURB-BD 015 01 --- --- 9.5 --- Point TURB-Purge 016 01 --- --- 1.9 --- Point Note: • See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. • Process 01, 02 and 03 for points 009 and 010 are as follows: o Process 01: Steady-state Turbine Emissions o Process 02: Start-up Turbine Emissions o Process 03: Shutdown Turbine Emissions Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. Page 4 of 55 r..- COLORADO Air Pollution Control Division , 4„,„,,I4o a EQPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a rolling twelve(12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator shall track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations shall be made available to the Division for inspection upon request. For the purposes_of this condition, insignificant activities are defined as any activity or equipment, which emits.'any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, shall be less than: • 50 tons per year of volatile organic compounds (VOC). 8. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. Point 005: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: dry gas throughput (measured at the outlet of the dehydrator), lean glycol recirculation rate, vapor recovery unit (VRU) downtime, condenser outlet temperature, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for dry gas throughput and VRU downtime, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 10. Point 005: On a daily basis, the owner or operator shall monitor and record operational values including: condenser outlet temperature, flash tank temperature and pressure, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years. 11. Point 013: The operator shall calculate actual emissions from this emissions point based on representative component counts for the facility with the most recent extended gas analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. Page 5 of 55 r.... COLORADO O Air Pollution Control Division DP Department Department of Pubitc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. The owner or operator shall operate and maintain the emission points in the table below with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Control Device Pollutants Equipment ID Point Controlled Still Vent: Enclosed Combustor VOC and HAP DEHY-1 005 Flash Tank: Recycled to plant inlet via VRU. VOC and Routed to enclosed combustor during VRU HAP downtime. 13. Point 005: Except during VRU downtime, 100%of emissions that result from the flash tank shall be recycled to the compressor station inlet and recompressed in a closed loop system. During VRU downtime, 100%of emissions that result from the flash tank shall be routed to an enclosed combustor(Regulation Number 3, Part B, Section III.E.) PROCESS LIMITATIONS AND RECORDS 14. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility AIRS Monthly Limit Equipment Point ' Process Process Parameter Annual Limit (31 days) ID Total Dry Gas 51,100.0 4,340 Throughput MMscf/yr MMscf/month Still vent waste gas 0.6 routed to and 7.4 MMscf/yr MMscf/month combusted by the ECD D-1 005 01 Flash tank waste gas routed to and 0.8 MMscf/yr --- combusted by the ECD Combustion of assist gas and pilot the enclosed fuel by 18.1 MMscf/yr 1.5 MMscf/month combustor 01 Consumption of 673.5 57.2 natural gas as a fuel MMscf/yr MMscf/month TURB-1 009 02 Ten minute turbine 100 events/yr --- start-up event 03 Ten minute turbine 100 events/yr shutdown event TURB-2 010 01 Consumption of 673.5 57.2 natural gas as a fuel MMscf/yr MMscf/month Page 6 of 55 COLORADO 4000_41 Air Pollution Control Division CD?at Department of Public Health fi Environment Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Monthly Limit Equipment Point Process Process Parameter Annual Limit (31 days) ID 02 Ten minute turbine 100 events/yr start-up event 03 Ten minute turbine 100 events/yr --- shutdown event L-1 012 01 Pressurized unloading 4,286 357 events events/yr events/month TURB-BD 015 01 Turbine compressor 40 events --- blowdown events TURB-Purge 016 01 Turbine compressor 40 events purge events Note: + Process 01, 02 and 03 for points 009 and 010 are as follows: o Process 01: Steady-state Turbine Emissions o Process 02: Start-up Turbine Emissions o Process 03: Shutdown Turbine Emissions The owner or operator shall monitor monthly process rates based on the calendar month. During the first twelve (12) months after permit issuance, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total, By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 15. Point 005: The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 16. Point 005: Within 90 days of issuance of this permit, the owner or operator shall continuously (i.e., at least once every 15 minutes) monitor and record the volumetric flow rate of assist gas routed to the flare using a flow meter. The operator shall assume a gas flow rate of 2,000 scfh for all times when the flare is operational but the flow meter is not functioning or collecting data. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 17. Point 005: This unit shall be limited to the maximum lean glycol circulation rate of 25 gallons per minute. The lean glycol recirculation rate shall be recorded daily in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. Page 7 of 55 •;- . COLORADO .D Air Pollution Control Division t OPHt` Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Lops) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 18. Point 005: The owner or operator shall monitor and record flash tank vapor recovery unit (VRU) downtime on a daily basis. Flash tank VRU downtime shall be defined as times when the waste gas vented from the dehydrator flash tank is routed to the enclosed combustor rather than the VRU. The total hours of flash tank VRU downtime, total flash tank waste gas volume, and total volume of flash tank waste gas routed to the ECD shall be recorded on a monthly basis. The owner or operator shall use monthly VRU downtime records, monthly gas volume records and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. 19. Point 009: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel using an operational continuous flow meter at the inlet of the turbine. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 20. Point 009:On a monthly basis, the owner or operator shall monitor and record the total number of turbine startup and shutdown events. By the end of each month, the total number of startup and shutdown events for the previous months' data shall be calculated, and a new twelve month total shall be calculated and recorded based on the previous twelve months' data. The owner or operator shall use monthly records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. 21. Point 010: The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas combusted as fuel using an operational continuous flow meter at the inlet of the turbine. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 22. Point 010: On a monthly basis, the owner or operator shall monitor and record the total number of turbine startup and shutdown events. By the end of each month, the total number of startup and shutdown events for the previous months' data shall be calculated, and a new twelve month total shall be calculated and recorded based on the previous twelve months' data. The owner or operator shall use monthly records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. 23. Point 015: On a monthly basis, the owner or operator shall monitor and record the total number of turbine compressor blowdown events. By the end of each month, the total number of turbine compressor blowdown events for the previous months' data shalt be calculated, and a new twelve month total shall be calculated and recorded based on the previous twelve months' data. The owner or operator shall use monthly records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. 24. Point 016: On a monthly basis, the owner or operator shall monitor and record the total number of turbine compressor purge events. The owner or operator shall use monthly records to demonstrate compliance with the process limits and to calculate emissions as described in this permit. Page 8 of 55 aM�~�x- COLORADO r�j Air Pollution Control Division Department of Publac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 25. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section Mi.) (State only enforceable) 26. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.1. £t 4.) 27. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 28. This source is located in an ozone non-attainment or attainment-maintenance area and subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2. The following requirements were determined to be RACT for this source. Facility AIRS Equipment Point Pollutant RACT ID Still Vent: Enclosed Combustor D-1 005 VOC Flash Tank: Recycled to plant inlet via VRU. Routed to enclosed combustor during 5% VRU downtime. NOx, VOC Natural gas as fuel, low NOx burners, good TURB-1 009 combustion practices NOx, VOC Natural gas as fuel, low NOx burners, good TURB-2 010combustion practices VOC Unloading using pressurized vessels and vapor L-1 012 balance FUG 013 VOC LDAR per Regulation 7, Part D, Section II.E TURB-BD 015 VOC Good Maintenance Practices TURB-Purge 016 VOC Good Maintenance Practices TEG Dehy (AIRS Point 005) 29. Point 005: This source is subject to Regulation 7, Part D, Section I.H. The operator shall comply with all applicable requirements of Section I and, specifically, shall: Page 9 of 55 4F COLORADO Air Pollution Control Division CDPHE Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Comply with the recordkeeping, monitoring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas-condensate-glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation 7, Part D, Section I.H.1.) H.1.) 30. Point 005: If actual average emissions of benzene from the glycol dehydration unit process vent to atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in 40 CFR §63.772(b)(2), the combustion device covered by this permit is subject to Regulation 7, Part D, Section II.B General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto-igniter upon installation of the combustion device; • All combustion devices `installed before May 1, 2014, must be equipped with an operational auto-igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 31. Point 005: If actual average emissions of benzene from the glycol dehydration unit process vent to atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in 40 CFR §63.772(b)(2),the glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation 7, Part D, Section II.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas-processing plant subject to control requirements pursuant to Section II.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. 32. Point 005: The glycol dehydration unit at this facility is subject to National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. If actual average emissions of benzene from the glycol dehydration unit process vent to atmosphere are greater than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart, the glycol dehydration unit shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E, Subpart A and HH) Page 10 of 55 .xa,� COLORADO Air Pollution Control Division CDPHE Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary §63.760 (f) - The owner or operator of an affected major source §63.760 - shall achieve compliance with the provisions of this subpart by Applicability and the dates specified in paragraphs (f)(1) and (f)(2) of this section. designation of The owner or operator of an affected area source shall achieve affected source compliance with the provisions of this subpart by the dates specified in paragraphs (f)(3) through (f)(6) of this section. §63.762 - Startups, §63.762(a) - The provisions set forth in this subpart shall apply at Shutdowns, and all times. Malfunctions §63.764(a) - Table 2 of this subpart specifies the provisions of subpart A (General Provisions) of this part that apply and those that do not apply to owners and operators of affected sources subject to this subpart. §63.764(b) All reports required under this subpart shall be sent to the Administrator at the appropriate address listed in §63.13. Reports may be submitted on electronic media. §63.764(d)(1) - Each owner or operator of an area source located within an UA plus offset and UC boundary shall comply with the requirements specified in paragraphs (d)(1)(i) through (iii) of this section. §63.764(d)(1)(i) - The owner or operator shall comply with the §63.764 - General control requirements for glycol dehydration unit process vents Standards specified in §63.765; §63.764(d)(1)(ii) - The owner or operator shall comply with the monitoring requirements specified in §63.773; and §63.764(d)(1)(iii) - The owner or operator shall comply with the recordkeeping and reporting requirements specified in §§63.774 and 63.775. §63.764(1) - In all cases where the provisions of this subpart require an owner or operator to repair leaks by a specified time after the leak is detected, it is a violation of this standard to fail to take action to repair the leak(s) within the specified time. If action is taken to repair the leak(s) within the specified time, failure of that action to successfully repair the leak(s) is not a violation of this standard. However, if the repairs are unsuccessful, a leak is detected and the owner or operator shall Page 11 of 55 r^;. _ COLORADO 4",--''`'' Air Pollution Control Division CDPHE Department of Pubitc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary take further action as required by the applicable provisions of this subpart. §63.765(b)(1) - For each glycol dehydration unit process vent, the owner or operator shall control air emissions by either paragraph (b)(1)(i) or (b)(1)(ii) of this section. §63.765(b)(1)(i) - The owner or operator shall connect the §63.765 - Glycol process vent to a control device or a combination of control Dehydration Unit devices through a closed-vent system. The closed-vent system Process Vent shall be designed and operated in accordance with the Standards requirements of §63.771(c). The control device(s) shall be designed and operated in accordance with the requirements of §63.771(d). §63.765(b)(2) - One or more safety devices that vent directly to the atmosphere may be used on the air emission control equipment installed to comply with §63.765(b)(1). §63.771(c)(1) - The closed-vent system shall route all gases, vapors, and fumes emitted from the material in an emissions unit to a control device that meets the requirements specified in paragraph (d) of this section. §63.771(c)(2) - The closed-vent system shall be designed and operated with no detectable emissions. §63.771(c)(3) - If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the §63.771 - Control gases, vapors, or fumes from entering the control device, the Equipment owner or operator shall meet the requirements specified in Requirements paragraphs (c)(3)(i) and (c)(3)(ii) of this section. §63.771(c)(3)(i) - For each bypass device, except as provided for in paragraph (c)(3)(ii) of this section, the owner or operator shall either: §63.771(c)(3)(i)(A) - At the inlet to the bypass device that could divert the stream away from the control device to the atmosphere, properly install, calibrate, maintain, and operate a flow indicator that is capable of taking periodic readings and sounding an alarm when the bypass device is open such that the Page 12 of 55 - „-.. COLORADO Air Pollution Control Division C DP HE Department o€Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado stream is being, or could be, diverted away from the control device to the atmosphere; or §63.771(c)(3)(i)(B) - Secure the bypass device valve installed at the inlet to the bypass device in the non-diverting position using a car-seal or a lock-and-key type configuration. §63.771(d) - Control device requirements for sources except small glycol dehydration units. §63.771(d)(1) - The control device used to reduce HAP emissions in accordance with the standards of this subpart shall be one of the control devices specified in paragraphs (d)(1)(i) through (iii) of this section. §63.771(d)(1)(i) - An enclosed combustion device (e.g., thermal vapor incinerator, catalytic vapor incinerator, boiler, or process heater) that is designed and operated in accordance with one of the following performance requirements: §63.771(d)(1)(i)(A) - Reduces the mass content of either T0C or total HAP in the gases vented to the device by 95.0 percent,by weight or greater as determined in accordance with the requirements of§63.772(e) §63.771(d)(3) - The owner or operator shall demonstrate that a control device achieves the performance,',requirements of paragraph (d)(1) of this section as specified in §63.772(e). §63.771(d)(4) - The owner or operator shall operate each control device in accordance with the requirements specified in paragraphs (d)(4)(i) and (ii) of this section. §63.771(d)(4)(i) - Each control device used to comply with this subpart shall be operating at all times when gases, vapors, and fumes are vented from the HAP emissions unit or units through the closed-vent system to the control device, as required under §63.765, §63.766, and §63.769. An owner or operator may vent more than one unit to a control device used to comply with this subpart. §63.771(d)(4)(ii) - For each control device monitored in accordance with the requirements of§63.773(d), the owner or operator shall demonstrate compliance according to the requirements of§63.772(f) or (g), as applicable. Page 13 of 55 • -.,;,..r... COLORADO Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary §63.772(c)(1) - The no detectable emissions test procedure shall be conducted in accordance with Method 21, 40 CFR part 60, appendix A. §63.772(c)(2) - The detection instrument shall meet the performance criteria of Method 21, 40 CFR part 60, appendix A, except that the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the fluid and not for each individual organic compound in the stream. §63.772(c)(3) - The detection instrument shall,be calibrated before use on each day of its use by the procedures specified in Method 21, 40 CFR part 60,appendix A. §63.772(c)(4) - Calibration gases shall be as follows: §63.772(c)(4)(i) - Zero air (less than 10 parts per million by volume hydrocarbon in air); and §63.772 - Test §63.772(c)(4)(ii) - A mixture of methane in air at a concentration Methods, less than 10,000 parts per million by volume. Compliance Procedures and §63.772(c)(5) - An owner or operator may choose to adjust or not Compliance adjust the detection instrument readings to account for the Demoristration background organic concentration level. If an owner or operator chooses to adjust the instrument readings for the background level, the background level value must be determined according to the procedures in Method 21 of 40 CFR part 60, appendix A. §63.772(c)(6)(i) - Except as provided in paragraph (c)(6)(ii) of this section, the detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60, appendix A, except the instrument response factor criteria in section 3.1.2(a) of Method 21 shall be for the average composition of the process fluid, not each individual volatile organic compound in the stream. For process streams that contain nitrogen, air, or other inert gases that are not organic hazardous air pollutants or volatile organic compounds, the average stream response factor shall be calculated on an inert-free basis. §63.772(c)(6)(ii) - If no instrument is available at the facility that will meet the performance criteria specified in paragraph (c)(6)(i) of this section, the instrument readings may be adjusted by Page 14 of 55 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado multiplying by the average response factor of the process fluid, calculated on an inert -free basis as described in paragraph (c)(6)(i) of this section. §63.772(c)(7) - An owner or operator must determine if a potential leak interface operates with no detectable emissions using the applicable procedure specified in paragraph (c)(7)(i) or (c)(7)(ii) of this section. §63.772(c)(7)(i) - If an owner or operator chooses not to adjust the detection instrument readings for the background organic concentration level, then the maximum organic concentration value measured by the detection instrument is compared directly to the applicable value for the potential leak interface as specified in paragraph (c)(8) of this section. §63.772(c)(7)(ii) - If an owner or operator chooses to adjust t detection instrument readings for the background organic concentration level, the value of the arithmetic difference between the maximum organic concentration value measured by the instrument and the background organic concentration value as determined in paragraph (c)(5) of this section is compared with the applicable value for the potential leak interface as specified in paragraph (c)(8) of this section. §63.772(c)(8) - A potential leak interface is determined to operate with no detectable organic emissions if the organic concentration value determined in paragraph (c)(7) of this section, is less than 500 parts per million by volume. §63.772(e) - Control device performance test procedures. This paragraph applies to the performance testing of control devices. The owners or operators shall demonstrate that a control device achieves the performance requirements of §63.771(d)(1), (e)(3)(ii) or (f)(1) using a performance test as specified in paragraph (e)(3) of this section. §63.772(e)(3) - For a performance test conducted to demonstrate that a control device meets the requirements of §63.771(d)(1), (e)(3)(ii) or (f)(1), the owner or operator shall use the test methods and procedures specified in paragraphs (e)(3)(i) through (v) of this section. The initial and periodic performance tests shall be conducted according to the schedule specified in paragraph (e)(3)(vi) of this section. §63.772(e)(3)(i) - Method 1 or 1A, 40 CFR part 60, appendix A, as appropriate, shall be used for selection of the sampling sites in Page 15 of 55 4 .. ..- COLORADO 4' ' 1 Air Pollution Control Division CD"H=. Department of Pubic Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado paragraphs (e)(3)(i)(A) and (B) of this section. Any references to particulate mentioned in Methods 1 and 1A do not apply to this section. §63.772(e)(3)(i)(A) - To determine compliance with the control device percent reduction requirement specified in §63.771(d)(1)(i)(A), (d)(1)(ii) or (e)(3)(ii), sampling sites shall be located at the inlet of the first control device, and at the outlet of the final control device. §63.772(e)(3)(ii) - The gas volumetric flowrate shall be determined using Method 2, 2A, 2C, or 2D, 40 CFR part 60, appendix A, as appropriate. §63.772(e)(3)(iii) - To determine compliance with the control device percent reduction performance requirement in §63.771(d)(1)(i)(A), (d)(1)(ii), and (e)(3)(ii), the owner or operator shall use one of the following methods: Method 18, 40 CFR part 60, appendix A; Method 25A, 40 CFR part 60, appendix A; ASTM D6420-99 (2004), as specified in §63.772(a)(1)(ii), or any other method or data that have been validated according to the applicable procedures in Method 301, 40 CFR part 63, appendix A. The following procedures shall be used to calculate percent reduction efficiency: §63.772(e)(3)(iii)(A) The minimum sampling time for each run shall be 1 hour in which either an integrated sample or a minimum of four grab samples shall be taken. If grab sampling is used, then the samples shall be taken at approximately equal intervals in time, such as 15-minute intervals during the run. §63.772(e)(3)(iii)(B) - The mass rate of either TOC (minus methane and ethane) or total HAP (E1, Eo) shall be computed using the equations and procedures specified in paragraphs (e)(3)(iii)(B)(1) through (3) of this section. As an alternative, the mass rate of either TOC (minus methane and ethane) or total HAP at the inlet of the control device (Ef) may be calculated using the procedures specified in paragraph (e)(3)(iii)(B)(4) of this section. §63.772(e)(3)(iii)(B)(1) - The following equations shall be used: fin+ Ei = K2 L CijMij Qi j=1 Page 16 of 55 a COLORADO Air Pollution Control Division Department of Public Wealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado E0 = K2 Where: n CojMoj Q0 j=1 Cii, Co; = Concentration of sample component j of the gas stream at the inlet and outlet of the control device, respectively, dry basis, parts per million by volume. E1, Eo = Mass rate of TOC (minus methane and ethane) or total HAP at the inlet and outlet of the control device, respectively, dry basis, kilogram per hour. Mii, Mo; = Molecular weight of sample component j of the gas stream at the inlet and outlet of the control device, respectively, gram/gram-mole. Q, Qp = Flowrate of gas stream at the inlet and outlet of the control device, respectively, dry standard cubic meter per minute. Kz = Constant, 2.494 x 10-6 (parts per million) (gram -mole per standard cubic meter) (kilogram/gram) (minute/hour), where standard temperature (gram -mole per standard cubic meter) is 20 °C. n = Number of components in sample. §63.772(e)(3)(iii)(B)(2) - When the TOC mass rate is calculated, all organic compounds (minus methane and ethane) measured by Method 18, 40 CFR part 60, appendix A, or Method 25A, 40 CFR part 60, appendix A, or ASTM D6420-99 (2004) as specified in §63.772(a)(1)(ii), shall be summed using the equations in paragraph (e)(3)(iii)(B)(1) of this section. §63.772(e)(3)(iii)(B)(3) - When the total HAP mass rate is calculated, only HAP chemicals listed in Table 1 of this subpart shall be summed using the equations in paragraph (e)(3)(iii)(B)(1) of this section. §63.772(e)(3)(iii)(B)(4) - As an alternative to the procedures for calculating E1 specified in paragraph (e)(3)(iii)(B)(1) of this section, the owner or operator may use the model GRI-GLYCaLcTM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCalcTM Technical Reference Manual. Inputs to the model shall be representative of actual operating conditions Page 17 of 55 „ . COLORADO Air Pollution Control Division CDPHI. Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado of the glycol dehydration unit and shall 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). When the TOC mass rate is calculated for glycol dehydration units using the model GRI- GLYCalcTM, all organic compounds (minus methane and ethane) measured by Method 18, 40 CFR part 60, appendix A, or Method 25A, 40 CFR part 60, appendix A, shall be summed. When the total HAP mass rate is calculated for glycol dehydration units using the model GRI-GLYCalcTM, only HAP chemicals listed in Table 1 of this subpart shall be summed. $63.772(e)(3)(iii)(C) - The percent reduction in TOC (minus methane and ethane) or total HAP shall be calculated as follows: Et —E0 o E Rcd = x 100/o L Where: Rai = Control efficiency of control device, percent. E; = Mass rate of TOC (minus methane and ethane) or total HAP at the inlet to the control device as calculated under paragraph (e)(3)(iii)(B) of this section, kilograms TOC per hour or kilograms HAP per hour. Ea = Mass rate of TOC (minus methane and ethane) or total HAP at the outlet of the control device, as calculated under paragraph (e)(3)(iii)(B) of this section, kilograms TOC per hour or kilograms HAP per hour. §63.772(e)(3)(vi) - The owner or operator shall conduct performance tests according to the schedule specified in paragraphs (e)(3)(vi)(A) and (B) of this section. §63.772(e)(3)(vi)(A) - An initial performance test shall be conducted within 180 days after the compliance date that is specified for each affected source in §63.760(f)(7) through (8), except that the initial performance test for existing combustion control devices (i.e., control devices installed on or before August 23, 2011) at major sources shall be conducted no later than October 15, 2015. If the owner or operator of an existing combustion control device at a major source chooses to replace such device with a control device whose model is tested under §63.772(h), then the newly installed device shall comply with all provisions of this subpart no later than October 15, 2015. The Page 18 of 55 , COLORADO Air Pollution Control Division CDPHE Department of Public Health&£nwonment Dedicated to protecting and improving the health and environment of the people of Colorado performance test results shall be submitted in the Notification of Compliance Status Report as required in §63.775(d)(1)(ii). §63.772(e)(3)(vi)(B) - Periodic performance tests shall be conducted for all control devices required to conduct initial performance tests except as specified in paragraphs (e)(3)(vi)(B)(1) and (2) of this section. The first periodic performance test shall be conducted no later than 60 months after the initial performance test required in paragraph (e)(3)(vi)(A) of this section. Subsequent periodic performance tests shall be conducted at intervals no longer than 60 months following the previous periodic performance test or whenever a source desires to establish a new operating limit. The periodic performance test results must be submitted in the next Periodic Report as specified in §63.775(e)(2)(xi). Combustion control devices meeting the criteria in either paragraph (e)(3)(vi)(B)(1) or (2) of this section are not required to conduct periodic performance tests. §63.772(f) - Compliance demonstration for control device performance requirements. This paragraph applies to the demonstration of compliance with the control device performance requirements specified in §63.771(d)(1)(i), (e)(3), and (f)(1).w Compliance shall be demonstrated using the requirements in paragraphs (f)(1) through (3) of this section. As an alternative, an owner or operator that installs a condenser as the control device to achieve the requirements specified in §63.771(d)(1)(ii), (e)(3), or (f)(1) may demonstrate compliance according to paragraph (g) of this section. An owner or operator may switch between compliance with paragraph (f) of this section and compliance with paragraph (g) of this section only after at least 1 year of operation in compliance with the selected approach. Notification of such a change in the compliance method shall be reported in the next Periodic Report, as required in §63.775(e), following the change. §63.772(f)(1) - The owner or operator shall establish a site specific maximum or minimum monitoring parameter value (as appropriate) according to the requirements of§63.773(d)(5)(i). §63.772(f)(2) - The owner or operator shall calculate the daily average of the applicable monitored parameter in accordance with §63.773(d)(4) except that the inlet gas flowrate to the control device shall not be averaged. §63.772(f)(3) - Compliance with the operating parameter limit is achieved when the daily average of the monitoring parameter Page 19 of 55 COLORADO a 4.4,1-40 Air Pollution Control Division co pH Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary value calculated under paragraph (f)(2) of this section is either equal to or greater than the minimum or equal to or less than the maximum monitoring value established under paragraph (f)(1) of this section. For inlet gas flowrate, compliance with the operating parameter limit is achieved when the value is equal to or less than the value established under §63.772(h) or under the performance test conducted under §63.772(e), as applicable. §63.772(f)(4) - Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits and required zero and span adjustments), the CMS required in §63.773(d) must be operated at all times the! affected source is operating. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. Monitoring system repairs are required to be completed in response to monitoring system malfunctions and to return the monitoring system to operation as expeditiously as practicable. §63.772(f)(5) - Data recorded during monitoring system malfunctions, repairs associated with monitoring system malfunctions, or required monitoring system quality assurance or control activities may not be used in calculations used to report emissions or operating levels. All the data collected during all other required data collection periods must be used in assessing the operation of the control device and associated control system. §63.772(f)(6) - Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required quality monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. Page 20 of 55 - "-.1 COLORADO vtif Air Pollution Control Division Department of Publac Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary §63.773(c)(1) - For each closed-vent system or cover required to comply with this section, the owner or operator shall comply with the requirements of paragraphs (c) (2) through (7) of this section. §63.773(c)(2) - Except as provided in paragraphs (c)(5) and (6) of this section, each closed-vent system shall be inspected according to the procedures and schedule specified in paragraphs (c)(2)(i) and (ii) of this section, each cover shall be inspected according to the procedures and schedule specified in paragraph (c)(2)(iii) of this section, and each bypass device shall be inspected according to the procedures of paragraph (c)(2)(iv) of this section. §63.773(c)(2)(i) - For each closed-vent system joints, seams, or other connections that are permanently or semi-permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted and gasketed ducting flange), the owner or operator shall: §63.773(c)(2)(i)(A) - Conduct an initial inspection according to §63.773 - Inspection the procedures specified in 563.772(c) to demonstrate that the and Monitoring closed-vent system operates with no detectable emissions. Requirements Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.775(d)(1) or (2). §63.773(c)(2)(i)(B) - Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in piping; loose connections; or broken or missing caps or other closure devices. The owner or operator shall monitor a component or connection using the procedures in §63.772(c) to demonstrate that it operates with no detectable emissions following any time the component is repaired or replaced or the connection is unsealed. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). §63.773(c)(2)(ii) - For closed-vent system components other than those specified in paragraph (c)(2)(i) of this section, the owner or operator shall: §63.773(c)(2)(ii)(A) - Conduct an initial inspection according to the procedures specified in 563.772(c) to demonstrate that the closed-vent system operates with no detectable emissions. Page 21 of 55 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Inspection results shall be submitted with the Notification of Compliance Status Report as specified in §63.775(d)(1) or (2). §63.773(c)(2)(ii)(B) - Conduct annual inspections according to the procedures specified in §63.772(c) to demonstrate that the components or connections operate with no detectable emissions. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). §63.773(c)(2)(ii)(C) - Conduct annual visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in ductwork; loose connections; or broken or missing caps or other closure devices. Inspection results shall be submitted in the Periodic Report as specified in §63.775(e)(2)(iii). §63.773(c)(2)(iv) - For each bypass device, except as provided for in §63.771(c)(3)(ii), the owner or operator shall either: §63.773(c)(2)(iv)(A) At the inlet to the bypass device that could divert the steam away from the control device to the atmosphere, set the flow indicator to take a reading at least once every 15 minutes; or §63.773(c)(2)(iv)(B) - If the bypass device valve installed at the inlet to the bypass device is secured in the non -diverting position using a car -seal or a lock -and -key type configuration, visually inspect the seal or closure mechanism at least once every month to verify that the valve is maintained in the non -diverting position and the vent stream is not diverted through the bypass device. §63.773(c)(3) - In the event that a leak or defect is detected, the owner or operator shall repair the leak or defect as soon as practicable, except as provided in paragraph (c)(4) of this section. §63.773(c)(3)(i) - A first attempt at repair shall be made no later than 5 calendar days after the leak is detected. §63.773(c)(3)(ii) - Repair shall be completed no later than 15 calendar days after the leak is detected. §63.773(c)(4) - Delay of repair of a closed -vent system or cover for which leaks or defects have been detected is allowed if the repair is technically infeasible without a shutdown, as defined in §63.761, or if the owner or operator determines that emissions resulting from immediate repair would be greater than the Page 22 of 55 ;:. COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado fugitive emissions likely to result from delay of repair. Repair of such equipment shall be complete by the end of the next shutdown. §63.773(c)(5) - Any parts of the closed-vent system or cover that are designated, as described in paragraphs (c)(5) (i) and (ii) of this section, as unsafe to inspect are exempt from the inspection requirements of paragraphs (c)(2)(i), (ii), and (iii) of this section if: §63.773(c)(5)(i) - The owner or operator determines that the equipment is unsafe to inspect because inspecting personnel would be exposed to an imminent or potential danger as a consequence of complying with paragraphs (c)(2)(i), (ii), or (iii) of this section; and §63.773(c)(5)(ii) - The owner or operator has a written plan that requires inspection of the equipment as frequently as practicable during safe-to-inspect times. §63.773(c)(6) - Any parts of the closed-vent system or cover that are,designated, as described in paragraphs (c)(6) (i) and (ii) of this section, as difficult to inspect are exempt from the inspection requirements of paragraphs (c)(2)(i), (ii), and (iii) of this section if: §63.773(c)(6)(i) -The owner or operator determines that the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters above a support surface; and §63.773(c)(6)(ii) - The owner or operator has a written plan that requires inspection of the equipment at least once every 5 years. §63.773(c)(7) - Records shall be maintained as specified in §63.774(b)(5) through (8). §63.773(d)(1) - For each control device, except as provided for in paragraph (d)(2) of this section, the owner or operator shall install and operate a continuous parameter monitoring system in accordance with the requirements of paragraphs (d)(3) through (7) of this section. Owners or operators that install and operate a flare in accordance with §63.771(d)(1)(iii) or (f)(1)(iii) are exempt from the requirements of paragraphs (d)(4) and (5) of this section. The continuous monitoring system shall be designed and operated so that a determination can be made on whether the control device is achieving the applicable performance requirements of§63.771(d), (e)(3), or (f)(1). Each continuous Page 23 of 55 COLORADO Air Pollution Control Division CDPHE Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado parameter monitoring system shall meet the following specifications and requirements: §63.773(d)(1)(i) - Each continuous parameter monitoring system shall measure data values at least once every hour and record either: §63.773(d)(1)(i)(A) - Each measured data value; or §63.773(d)(1)(i)(B) - Each block average value for each 1-hour period or shorter periods calculated from all measured data values during each period. If values are measured more frequently than once per minute, a single value for each minute may be used to calculate the hourly (or shorter period) block average instead of all measured values. §63.773(d)(1)(ii) - A site-specific monitoring plan must be prepared that addresses the monitoring system design, data collection, and the quality assurance and quality control elements outlined in paragraph (d) of this section and in §63.8(d). Each CPMS must be installed, calibrated, operated, and maintained in accordance with the procedures in your approved site-specific monitoring plan. Using the process described in §63.8(f)(4), you may request approval of monitoring system quality assurance and quality control procedures alternative to those specified in paragraphs (d)(1)(ii)(A) through (E) of this section in your site- specific monitoring plan. §63.773(d)(1)(ii)(A) - The performance criteria and design a=. specifications for the monitoring system equipment, including the sample interface, detector signal analyzer, and data acquisition and calculations; §63.773(d)(1)(ii)(B) - Sampling interface (e.g., thermocouple) location such that the monitoring system will provide representative measurements; §63.773(d)(1)(ii)(C) - Equipment performance checks, system accuracy audits, or other audit procedures; §63.773(d)(1)(ii)(D) - Ongoing operation and maintenance procedures in accordance with provisions in §63.8(c)(1) and (3); and §63.773(d)(1)(ii)(E) - Ongoing reporting and recordkeeping procedures in accordance with provisions in §63.10(c), (e)(1), and (e)(2)(i). Page 24 of 55 COLORADO Air Pollution Control Division coar�t Department of Public Health fs Environment Dedicated to protecting and improving the health and environment of the people of Colorado §63.773(d)(1)(iii) - The owner or operator must conduct the CPMS equipment performance checks, system accuracy audits, or other audit procedures specified in the site-specific monitoring plan at least once every 12 months. §63.773(d)(1)(iv) - The owner or operator must conduct a performance evaluation of each CPMS in accordance with the site- specific monitoring plan. §63.773(d)(3) - The owner or operator shall install, calibrate, operate, and maintain a device equipped with a continuous recorder to measure the values of operating parameters appropriate for the control device as specified in either paragraph (d)(3)(i), (d)(3)(ii), or (d)(3)(iii) of this section. §63.773(4){3)(i) - A continuous monitoring system that measures the following operating parameters as applicable: §63.773(d)(3)(i)(A) - For a thermal vapor incinerator that demonstrates during the performance test conducted under §63.772(e) that the combustion zone temperature is an accurate indicator of performance, a temperature monitoring device equipped with a continuous recorder. The monitoring device shall have a minimum accuracy of ±2 percent of the temperature being monitored in °C, or ±2.5 °C, whichever value is greater. The temperature sensor shall be installed at a location representative of the combustion zone temperature. §63.773(d)(4) - Using the data recorded by the monitoring system, except for inlet gas flowrate, the owner or operator must calculate the daily average value for each monitored operating parameter for each operating day. If the emissions unit operation is continuous, the operating day is a 24-hour period. If the emissions unit operation is not continuous, the operating day is the total number of hours of control device operation per 24-hour period. Valid data points must be available for 75 percent of the operating hours in an operating day to compute the daily average. §63.773(d)(5) - For each operating parameter monitor installed in accordance with the requirements of paragraph (d)(3) of this section, the owner or operator shall comply with paragraph (d)(5)(i) of this section for all control devices, and when condensers are installed, the owner or operator shall also comply with paragraph (d)(5)(ii) of this section. Page 25 of 55 a ...„. COLORADO Air Pollution Control Division CDPHE Department of Public Health t,E wirorment Dedicated to protecting and improving the health and environment of the people of Colorado §63.773(d)(5)(i) - The owner or operator shall establish a minimum operating parameter value or a maximum operating parameter value, as appropriate for the control device, to define the conditions at which the control device must be operated to continuously achieve the applicable performance requirements of §63.771(d)(1), (e)(3)(ii), or (f)(1). Each minimum or maximum operating parameter value shall be established as follows: §63.773(d)(5)(i)(A) - If the owner or operator conducts performance tests in accordance with the requirements of §63.772(e)(3) to demonstrate that the control device achieves the applicable performance requirements specified in §63.771(d)(1), (e)(3)(ii) or (f)(1), then the minimum operating parameter value or the maximum operating parameter value shall be established based on values measured during the performance test and supplemented, as necessary, by a condenser design analysis or control device manufacturer recommendations or a combination of both. §63.773(d)(6) - An excursion for a given control device is determined to have occurred when the monitoring data or lack of monitoring data result in any one of the criteria specified in paragraphs (d)(6)(i) through (vi) of this section being met. When multiple operating parameters are monitored for the same control device and during the same operating day and more than one of these operating parameters meets an excursion criterion specified in paragraphs (d)(6)(i) through (vi) of this section, then a single excursion is determined to have occurred for the control device for that operating day. §63.773(d)(6)(i) - An excursion occurs when the daily average value of a monitored operating parameter is less than the minimum operating parameter limit (or, if applicable, greater than the maximum operating parameter limit) established for the operating parameter in accordance with the requirements of paragraph (d)(5)(i) of this section. §63.773(d)(6)(iv) - An excursion occurs when the monitoring data are not available for at least 75 percent of the operating hours in a day. §63.773(d)(6)(v) - If the closed-vent system contains one or more bypass devices that could be used to divert all or a portion of the gases, vapors, or fumes from entering the control device, an excursion occurs when: Page 26 of 55 is -re~-1: COLORADO .1� Air Pollution Control Division _op Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary §63.773(d)(6)(v)(A) - For each bypass line subject to §63.771(c)(3)(i)(A) the flow indicator indicates that flow has been detected and that the stream has been diverted away from the control device to the atmosphere. §63.773(d)(6)(v)(B) - For each bypass line subject to §63.771(c)(3)(i)(B), if the seal or closure mechanism has been broken, the bypass line valve position has changed, the key for the lock-and-key type lock has been checked out, or the car-seal has broken §63.773(d)(7) - For each excursion, the owner or operator shall be deemed to have failed to have applied control in a manner that achieves the required operating parameter limits. Failure to achieve the required operating parameter limits is a violation of this standard. §63.774(b) - Except as specified in paragraphs (c), (d), and (f) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) through (11) of this section: §63.774(b)(1) - The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all §63:.774- information (including all reports and notifications) required by Recordkeeping this subpart. The files shall be retained for at least 5 years Requirements following the date of each occurrence, measurement, maintenance, corrective action, report or period. §63.774(b)(1)(i) - All applicable records shall be maintained in such a manner that they can be readily accessed. §63.774(b)(1)(ii) - The most recent 12 months of records shall be retained on site or shall be accessible from a central location by Page 27 of 55 a ,,,, COLORADO Air Pollution Control Division CDPHE Department of Public Health Et Envirorerrca_rt Dedicated to protecting and improving the health and environment of the people of Colorado computer or other means that provides access within 2 hours after a request. §63.774(b)(1)(iii) - The remaining 4 years of records may be retained offsite. §63.774(b)(1)(iv) - Records may be maintained in hard copy or computer-readable form including, but not limited to, on paper, microfilm, computer, floppy disk, magnetic tape, or microfiche. §63.774(b)(2) - Records specified in §63.10(b)(2); §63.774(b)(3) - Records specified in §63.10(c) for each monitoring system operated by the owner or operator in accordance with the requirements of §63.773(d). Notwithstanding the requirements of§63.10(c), monitoring data recorded during periods identified in paragraphs (b)(3)(i) through (iv) of this section shall not be included in any average or percent leak rate computed under this subpart. Records shall be kept of the times and durations of all such periods and any other periods during process or control device operation when monitors are not operating or failed to collect required data. §63.774(b)(3)(i) - Monitoring system breakdowns, repairs, calibration checks, and zero (low-level) and high-level adjustments; §63.774(b)(3)(iii)-Periods of non-operation resulting in cessation of the emissions to which the monitoring applies; and §63.774(b)(3)(iv) - Excursions due to invalid data as defined in §63.773(d)(6)(iv). §63.774(b)(4) - Each owner or operator using a control device to comply with §63.764 of this subpart shall keep the following records up-to-date and readily accessible: §63.774(b)(4)(i) - Continuous records of the equipment operating parameters specified to be monitored under §63.773(d) or specified by the Administrator in accordance with §63.773(d)(3)(iii). §63.774(b)(4)(ii) - Records of the daily average value of each continuously monitored parameter for each operating day determined according to the procedures specified in §63.773(d)(4) of this subpart, except as specified in paragraphs (b)(4)(ii)(A) through (C) of this section. Page 28 of 55 ,.... COLORADO . Y .Air Pollution Control Division CDPHE Department of Public Health S Environment Dedicated to protecting and improving the health and environment of the people of Colorado §63.774(b)(4)(iii) - Hourly records of the times and durations of all periods when the vent stream is diverted from the control device or the device is not operating. §63.774(b)(4)(iv) - Where a seal or closure mechanism is used to comply with §63.771(c)(3)(i)(B), hourly records of flow are not required. In such cases, the owner or operator shall record that the monthly visual inspection of the seals or closure mechanism has been done, and shall record the duration of all periods when the seal mechanism is broken, the bypass line valve position has changed, or the key for a lock-and-key type lock has been checked out, and records of any car-seal that has broken. §63.774(b)(5) - Records identifying all parts of the cover or closed-vent system that are designated as unsafe to inspect in accordance with §63.773(c)(5), an explanation of why the equipment is unsafe to inspect, and the plan for inspecting the equipment. §63.774(b)(6) - Records identifying all parts of the cover or', closed-vent system that are designated as difficult to inspect in accordance with §63.773(c)(6), an explanation of why the equipment is difficult to inspect, and the plan for inspecting the equipment. §63.774(b)(7) - For each inspection conducted in accordance with §63.773(c), during which a leak or defect is detected, a record of the information specified in paragraphs (b)(7)(i) through (b)(7)(viii) of this section. §63.774(b)(7)(i) - The instrument identification numbers, operator name or initials, and identification of the equipment. §63.774(b)(7)(ii) - The date the leak or defect was detected and the date of the first attempt to repair the leak or defect. §63.774(b)(7)(iii) - Maximum instrument reading measured by the method specified in §63.772(c) after the leak or defect is successfully repaired or determined to be nonrepairable. §63.774(b)(7)(iv) - "Repair delayed" and the reason for the delay if a leak or defect is not repaired within 15 calendar days after discovery of the leak or defect. §63.774(b)(7)(v) - The name, initials, or other form of identification of the owner or operator (or designee) whose Page 29 of 55 a . . COLORADO,;. 46," HEAir Pollution Control Division CDP Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary decision it was that repair could not be effected without a shutdown. §63.774(b)(7)(vi) - The expected date of successful repair of the leak or defect if a leak or defect is not repaired within 15 calendar days. §63.774(b)(7)(vii) - Dates of shutdowns that occur while the equipment is unrepaired. §63.774(b)(7)(viii) - The date of successful repair of the leak or defect. §63.774(b)(8) - For each inspection conducted in accordance with §63.773(c) during which no leaks or defects are detected, a record that the inspection was performed, the date of the inspection, and a statement that no leaks or defects were detected. §63.774(b)(9) - Records identifying ancillary equipment and compressors that are subject to and controlled under the provisions of 40 CFR part 60, subpart KKK; 40 CFR part 61, subpart V; or 40 CFR part 63, subpart H. §63.774(g) - The owner or operator of an affected source subject to this subpart shall maintain records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control equipment and monitoring equipment. The owner or operator shall maintain records of actions taken during periods of malfunction to minimize emissions in accordance with §63.764(j), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. §63.775(c) - Each owner or operator of an area source located within a UA plus offset and UC boundary shall submit the information listed in §63.775(c)(1) through (6). §63.775 - Reporting §63.775(d) - Each owner or operator of a source subject to this Requirements subpart shall submit a Notification of Compliance Status Report as required under§63.9(h) within 180 days after the compliance date specified in §63.760(f). In addition to the information required under§63.9(h), the Notification of Compliance Status Report shall include the information specified in §63.775(d). Page 30 of 55 rf COLORADO 411- Air Pollution Control Division COPHE DepartTnent of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Area Source MACT HH Applicable Requirements Within UA/UC boundary §63.775(e) - An owner or operator of an area source located inside a UA plus offset and UC boundary shall prepare Periodic Reports in accordance with paragraph §63.775(e)(3) and submit them to the Administrator. §63.775(f) - Whenever a process change is made, or a change in any of the information submitted in the Notification of Compliance Status Report, the owner or operator shall submit a report within 180 days after the process change is made or as a part of the next Periodic Report as required under §63.775(e), whichever is sooner. The report shall include the information specified in §63.775(f). 33. Point 005: The glycol dehydration unit at this facility is subject to the National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. If actual average emissions of.benzene from the glycol dehydration unit process vent to atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in§63.772(b)(2) of this subpart, the glycol dehydration unit shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH including, but not limited to the following: (Regulation Number 8, Part E, Subpart A and HH) MACT HH Applicable Area Source Requirements Benzene emissions exemption §63.764 (e)(1) - The owner or operator is exempt from the requirements of paragraph (d) of this section if the criteria listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be §63.764 - General maintained as required in §63.774(d)(1). Standards §63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. §63.772 - Test §63.772(b) - Determination of glycol dehydration unit flowrate or Methods, benzene emissions. The procedures of this paragraph shall be Compliance used by an owner or operator to determine glycol dehydration Procedures and unit natural gas flowrate or benzene emissions to meet the Compliance criteria for an exemption from control requirements under Demonstration §63.764(e)(1). Page 31 of 55 .. - COLORADO Air Pollution Control Division CDPHE Department of Pub1tc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. §63.772(b)(2)(i) - The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc TM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TM 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); or §63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to 563.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or_ §63.764(e)(1)(ii) shall maintain the records specified in paragraph §b3.774 - (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for Recordkeeping that glycol dehydration unit. Requirements §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). Turbines (Points 009 and 010): 34. Points 009 and 010: This source is subject to the Particulate Matter and Sulfur Dioxide Emission Regulations of Regulation Number 1 including, but not limited to, the following (Regulation Number 1, Section III.A.1. Ft VI.B.): a. No owner or operator shall cause or permit to be emitted into the atmosphere from any fuel-burning equipment, particulate matter in the flue gases which exceeds the following (Regulation 1, Section III.A.1.): (i) For fuel burning equipment with designed heat inputs greater than 1x106 BTU per hour, but less than or equal to 500x106 BTU per hour, the following equation will be used to determine the allowable particulate emission limitation. Page 32 of 55 COLORADO Air Pollution Control Division CD?F1E Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado PE=0.5(FI)-°•26 Where: PE = Particulate Emission in Pounds per million BTU heat input. Fl = Fuel Input in Million BTU per hour. b. Sources of sulfur dioxide shall not emit sulfur dioxide in excess of the following combustion turbine limitations. (Heat input rates shall be the manufacturer's guaranteed maximum heat input rates). (i) Combustion Turbines with a heat input of less than 250 Million BTU per hour: 0.8 pounds of sulfur dioxide per million BTU of heat input. (Regulation 1, Section VI.B.4.c.(i).) 35. Points 009 and 010: This source is subject to the New Source Performance Standards requirements of Regulation 6, Part B including, but not limited to, the following (Regulation Number 6, Part B, Section II): a. Standard for Particulate Matter - On and after the date on which the required performance test is completed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere of any particulate matter which is (Regulation Number 6, Part B, Section II.C.): (i) For fuel burning equipment generating greater than one million but less than 250 million Btu per hour heat input, the following equation will be used to determine the allowable particulate emission limitation: PE=0.5(FIy0.26 Where: PE is the allowable particulate emission in pounds per million Btu heat input. Fl is the fuel input in million Btu per hour. If two or more units connect to any opening, the maximum allowable emission rate shall be the sum of the individual emission rates. (ii) Greater than 20 percent opacity. b. Standard for Sulfur Dioxide - On and after the date on which the required performance test is competed, no owner or operator subject to the provisions of this regulation may discharge, or cause the discharge into the atmosphere sulfur dioxide in excess of (Regulation Number 6, Part B, Section II.D.): (i) Sources with a heat input of less than 250 million Btu per hour: 0.8 lbs. S02/million Btu. 36. Points 009 and 010: The combustion turbine is subject to the New Source Performance Standards requirements of Regulation Number 6, Part A, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines including, but not limited to, the following: • 40 CFR, Part 60, Subpart A- General Provisions • §60.4320 - Nitrogen Oxide Emissions Limits o §60.4320 (a) - NOx emissions shall not exceed 25 ppm at 15% 02 or 1.2 lb/MW-hr; • §60.4330 - Sulfur Dioxide Emissions Limits Page 33 of 55 �- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado o §60.4330 (a)(1) - 5O2 emissions shall not exceed 0.9 lb/MW-hr gross output; or o §60.4330 (a)(2)-Operator shall not burn any fuel that contains total potential sulfur emissions in excess of 0.060 lb SO2/MMBtu heat input. • §60.4333 - General Requirements o §60.4333 (a) Operator must operate and maintain your stationary combustion turbine, air pollution control equipment, and monitoring equipment in a manner consistent with good air pollution control practices for minimizing emissions at all times including during startup, shutdown and malfunction. • §60.4340 - NO,t Monitoring o §60.4340 (a) Operator shall perform annual performance tests in accordance with comp liance with NOx emissions limits. If the NOx emission result from the performance test is less than or equal to 75 percent of the NOx emission limit for the turbine, you may reduce the frequency of subsequent performance tests to once every 2 years (no more than 26 calendar months following the previous performance test). If the results of any subsequent performance test exceed 75 percent of the NOx emission limit for the turbine, you must resume annual performance tests. • §60.4365 {or§§60.4360 and 60.4370) SO2 Monitoring o The operator shall comply with §60.4365 or with both §§60.4360 and 60.4370 to demonstrate compliance with 502 emissions limits. }' • §60.4375 - Reporting o §60.4375 (b) - For each affected unit that performs annual performance tests in accordance with§60.4340(a),you must submit a written report of the results of each performance test before the close of business on the 60th day following the completion of the performance test. • §§60.4400 and 60.4415 - Performance Tests o Annual tests must be conducted in accordance with §60.4400(a) and (b). o Unless operator chooses to comply with §60.4365 for exemption of monitoring the total sulfur content of the fuel, then initial and subsequent performance tests for sulfur shall be conducted according to §60.4415. Pressurized Loadout (Point 012) 37. Point 012: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.E): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking,or other liquid or vapor loss during loading and unloading. b. All compartment hatches (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. The owner or operator shall inspect loading equipment and operations on site at the time of the inspection to ensure compliance with Condition 37 (a) and (b) above. The Page 34 of 55 COLORADO Air Pollution Control Division CDFHE Department of Pui tc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 38. Point 012: All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. Fugitive Equipment Leaks (Point 013) 39. Point 013: Fugitive component leaks at this natural gas compressor station are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-monitoring, recordkeeping and reporting contained in Regulation 7, Part D, Section I.L. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Part D, Section I.C.1. 40. Point 013: Fugitive component leaks at this natural gas compressor station are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-monitoring, recordkeeping and reporting contained in Regulation 7_.Part € , Section II.E. In addition, the operator shall comply with the General Provisionscon-tained in Regulation 7, Part D, Section II.B OPERATING & MAINTENANCE REQUIREMENTS 41. Points 005: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation;(Regulation Number 3, Part B, Section III.G.7.) 42. Points 009.and 010: At all times during normal operation, the owner or operator shall operate each turbine in SoLoNOx mode. On a daily basis, the owner or operator shall monitor and record the status of the SoLoNOx mode for each turbine, including records of when the unit is not operating in SoLoNOx mode. These records shall be made available to the Division upon request. Normal operation shall be defined as all periods of operation except for startup, shutdown, or malfunction events. COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 43. Point 005: Within one hundred and eighty days (180) after issuance of this permit, the owner/operator shall complete an initial site specific extended gas analysis ("Analysis") of the assist gas and pilot light fuel routed to this enclosed combustor. The initial sample shall be analyzed for stream composition including VOC, Benzene, Toluene, Ethylbenzene, Xylene, n- Hexane, 2,2,4-trimethylpentane, and methanol content using EPA approved methods. Results of the Analysis shall be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the Page 35 of 55 a «� COLORADO AutoAir Pollution Control Division CDPHE Department of Pubac Health&environment Dedicated to protecting and improving the health and environment of the people of Colorado permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 44. Points 009 and 010: Within one hundred and eighty days (180) after issuance of this permit, the owner or operator shall complete the initial sampling for net heating value of the fuel used in the turbine as required by this permit and submit the results to the Division as part of the self-certification process to demonstrate compliance with emissions limits. (Regulation Number 3, Part B, Section III.E.) 45. Point 013: Within one hundred and eighty days (180) after issuance of this permit, the permittee shall complete the initial extended gas analysis of gas samples that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self-certification process to ensure compliance with emissions limits. 46. Point 013: Within one hundred and eighty days (180) after issuance of this permit, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "light liquid service" and "gas service". The operator shall submit the results to the Division as part of the self-certification process to ensure compliance with emissions Limits. 47. Points 015 and 016: The owner or operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after issuance of this permit of the natural gas vented during turbine compressor blowdowns and purging in order to verify the VOC, benzene, toluene, ethylbenzene, xylene, "n-Hexane, 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site- specific emission factors for the pollutants referenced in this permit (in units of Ib/blowdown event) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Periodic Testing Requirements 48. Point 005: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the dehydration unit on an annual basis. The extended wet gas analysis shall be analyzed for total VOC, benzene, toluene, ethylbenzene, xylene, n-Hexane, 2,2,4-trimethylpentane and methanol content. Results of the extended wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. 49. Point 005: On an annual basis, the owner/operator shall complete a site specific extended gas analysis ("Analysis") of the assist gas and pilot light fuel routed to this enclosed combustor. Each sample shall be analyzed for stream composition including VOC content using EPA approved Page 36 of 55 . COLORADO Air Pollution Control Division CDPH€ Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado methods. Results of the Analysis shall be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF) using Division approved methods. Results of the Analysis must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 50. Points 009 and 010: Each turbine is subject to the periodic testing requirements of 40 C.F.R. Part 60, Subpart KKKK, as referenced in this permit. 51. Points 009 and 010: Replacements of each unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 52. Points 009 and 010: The owner or operator shall conduct, at a minimum, quarterly portable analyzer monitoring of each turbine exhaust outlet emissions of nitrogen oxides (NOr) and carbon monoxide (CO) to monitor compliance with the emissions limits for Process 01 - Steady- state Turbine emissions. Results of all tests conducted shall be kept on site and made available to the Division upon request. Any compliance test conducted to show compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the allowable number of operating hours for that averaging time. 53. Points 009 and 010: The net heating value of the fuel used in the turbine shall be sampled and analyzed, at a minimum, once per every three months with consecutive samples taken at least two months apart using EPA approved methods. If sampling is performed more"'often, the quarterly average results of all valid fuel analyses shall be used in the emission calculations. 54. Point 013: On an annual basis, the permittee shall complete an extended gas analysis of gas samples that are representative of volatile organic compounds (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. 55. Points 015 and 016: On an annual basis, the owner or operator shall complete a site specific extended gas analysis ("Analysis") of the natural gas vented during turbine compressor blowdowns and purging in order to verify the VOC, benzene, toluene, ethylbenzene, xylene, n- Hexane, 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/blowdown event) using Division approved methods. Results of the Analysis must be used to demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Page 37 of 55 -. COLORADO gir 4646 AllAir Pollution Control Division COPHE Department of Pubic Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado ALTERNATE OPERATING SCENARIOS 56. Point 005: The electric glycol pump may be replaced with another electric glycol pump in accordance with the requirements of Regulation Number 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. The maximum glycol recirculation rate of a replacement pump shall not exceed the glycol recirculation rate as authorized in this permit. 57. Point 005: The owner or operator shall maintain a log on-site or at a local field office to contemporaneously record the start and stop dates of any pump replacement, the manufacturer, model number, serial number and capacity of the replacement pump. 58. Point 005: All pump replacements installed and operated per the alternate operating scenarios authorized by this permit must comply with all terms and conditions of this construction permit. ADDITIONAL REQUIREMENTS 59. All previous versions of this permit are cancelled upon issuance of this permit. 60. This permit replaces the following permits and/or points, which are cancelled upon issuance of this permit. Existing Existing New Emission Point Permit Number Emission Point 15WE0147.XA 123/9010/006 123/9010/013 61. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or Page 38 of 55 g »a:. _ COLORADO ` Air Pollution Control Division CDPHE Department of Pubic Health&£nuirorment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. • Point 009 and 010: Within 14 calendar days of commencing operation of a permanent replacement turbine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement turbine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative-operating scenario and is installing a permanent replacement turbine. Submittal of an updated APEN is also required for replacement of components if such replacement results in a change of serial number. 62. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Emissions - tons per year Equipment AIRS Pollutant Threshold Current Permit Limit ID Point (tPY) (tPY) D-1 005 19.5 TURB-1 009 1.9 TURB-2 010 1.9 PW Tank 011 0.4 L-1 012 VOC 50 2.3 TURB-BD 015 9.5 TURB-Purge 016 1.9 APEN Exempt 4.2 Sources Notes: • The produced water storage vessel and other APEN exempt sources do not have permit limits. However, the PTE of these sources is still considered in the project increase when evaluating PSD and NANSR. • Fugitives are not included in this evaluation because the facility is not a listed source. Page 39 of 55 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 63. Point 005: MACT Subpart HH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities major stationary source requirements shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of Subpart HH. (Regulation Number 8, Part E) 64. Point 009 and 010: MACT Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines requirements shall apply to this source at any such time that this source becomes a major source of hazardous air pollutants (HAP) solely by virtue of a relaxation in any permit limitation and shall be subject to all appropriate applicable requirements of that Subpart on the date as stated in the rule as published in the Federal Register. (Regulation Number 8, Part E) GENERAL TERMS AND CONDITIONS 65. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 66. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditionsof the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate -are located in the Requirements to Self -Certify for Final Authorization section of this permit. 67. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 68. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 69. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. Page 40 of 55 7'z. COLORADO �7`1 Air Pollution Control Division a,. CDPME Department of PLLWtc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 70. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 71. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Carissa Money Permit Engineer Permit History Issuance Date Description Issuance 1 February 8, Issued to DCP Midstream, LP for Points 001-006 2012 Issuance 2 April 1, 2015 Modified point 005 (increase permit limits and change operating parameters). Point 006 (fugitives) is now APEN! exempt, and removed from permit. Added new points 007 and 008. Established limits on engine operation such that only four engines may operate at any time. Issuance 3 March 23, 2017 Cancellation of points 001, 002, 003, 004, 007, 008. Updated emissions from point 005 Added two turbines, points 009 and 010 Added loading emissions, point 012 Issuance 4 This Issuance Modify Point 005 by increasing throughput from 47,450 MMscf/yr but decreasing glycol recirculation rate from 40 gpm. Removed downtime for the enclosed combustor when controlling the still vent. Add supplemental fuel for the enclosed combustor and include in VOC, NOx and CO emission limits. Modify Points 009 and 010 to increase throughput and emission factors based on revised manufacturer spec sheet. Modify to add Page 41 of 55 C �•.,1- COLORADO Air Pollution Control Division CDPHE Department of Public Health&Envirorment Dedicated to protecting and improving the health and environment of the people of Colorado startup and shutdown emissions. Modify Point 012 to adjust emission factor basis which increased VOC emissions from 1.9 tpy. Add Point 013 to include fugitive emissions as APEN-required, permit-required (fugitive emissions were previously considered APEN exempt, AIRS ID 123/9010/006, 15WE0147.XA) Add turbine compressor blowdowns (point 015) to the permit. Add turbine compressor purging (point 016) to the permit. Page 42 of 55 -,. COLORADO / v.I .1 Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees wilt be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing alt of the criteria set forth in Part II.E.1 of the Common-Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants ::are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Uncontrolled Controlled Equipment AIRS Pollutant CAS # Emissions Emissions Point ID (lb/yr) (lb/yr) Benzene 71432 101,125 4,970 Toluene 108883 93,785 4,636 Ethylbenzene 100414 2,708 134 D-1 005 Xylenes 1330207 27,895 1,388 n-Hexane 110543 21,088 719 2,2,4- 540841 132 4 Trimethylpentane Methanol 67561 105,367 3,523 Formaldehyde 50000 434 434 Acetaldehyde 75070 24 24 TURB-1 009 Ethylbenzene 100414 20 20 Toluene 108883 80 80 Xylenes 1330207 39 39 Formaldehyde 50000 434 434 TURB-2 010 Acetaldehyde 75070 24 24 Page 43 of 55 ra � COLORADO Air Pollution Control Division CDPNE Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ethylbenzene 100414 20 20 Toluene 108883 80 80 Xylenes 1330207 39 39 Benzene 71432 39 39 Toluene 108883 105 105 Ethylbenzene 100414 13 13 L-1 012 Xylenes 1330207 79 79 n-Hexane 110543 298 298 2,2,4- 540841 26 26 Trimethylpentane FUG 013 n-Hexane 110543 32 32 Benzene 71432 34 34 Toluene 108883 26 26 TURB-BD 015 Ethylbenzene 100414 1 1 Xylenes 1330207 5 5 n-Hexane 110543 261 261 Benzene 71432 7 7 Toluene 108883 5 5 TURB-Purge 016 Xylenes 1330207 1 1 n-Hexane 110543 53 53 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 005: The VOC and HAP emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Actual controlled VOC and HAP flash tank emissions are based on 100% control efficiency when emissions are routed to the VRU and 95% control efficiency when emissions are routed to the ECD during VRU downtime. The VRU has a maximum of 5% annual downtime. To determine actual flash tank emissions during VRU downtime, the operator will multiply the lb/hr emission rates from the "Flash Tank Off Gas"stream in the GlyCalc model (based on total actual gas throughput during the month) by the total hours of VRU downtime. A 95%control efficiency is applied to this calculation based on the destruction efficiency of the ECD. Actual controlled VOC and HAP still vent emissions are based on a 95% ECD control efficiency. To determine actual still vent emissions while emissions are routed to the ECD, the operator will multiply the lb/hr emission rates from the "Uncontrolled Regenerator Emissions" stream in the Page 44 of 55 ...v COLORADO Air Pollution Control Division CDPHE. Department al Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado GlyCalc model by the total hours of ECD operation. The following table summarizes the control efficiency for each scenario: Control Scenario VOC Control Efficiency Still vent emissions routed to the ECD. 95% Flash tank emissions routed to the VRU and 100% recycled to the plant inlet. Flash tank emissions routed to the ECD 95% during VRU downtime. Methanol emissions from this source are based on a mass balance. The methanol/alcohol mole % from the periodic inlet wet gas analysis is specified with the n-Hexane mole % in the GlyCalc Wet Gas input stream. Uncontrolled actual methanol emission rates are calculated by multiplying the sum of the n-hexane lb/hour rate from the "Uncontrolled Regenerator Emissions" and "Flash Tank Off Gas" streams in the GlyCalc model by the ratio of the methanol/alcohol mole% in the inlet gas to then-Hexane mole% in the inlet gas. Actual controlled methanol emissions are calculated using the methodologies described above for VOC and HAP. 1b C4.= [(Flash Tank n—Hexane rateib +/Still Vent n Hexane rate,ib 11II methanol male 6) Uncontrolled Methanol \hr/ � hr \ hr 1J*\n—Hexane mole%) Combustion Emissions: Total actual NOx and CO emissions are based on the sum of the emissions for the still vent and flash tank controlled by the ECD and the combustion of ECD pilot and assist fuel. Actual volume of waste,gas combusted shall be based on the monthly GlyCalc report streams described in the notes beneath each table. Actual heat content of the waste gas stream shall be calculated monthly based on the GlyCalc report streams described in the notes beneath each table. Total combustion emissions are based on the following emission factors: Still Vent Controlled by the ECD: Uncontrolled CAS # Pollutant Emission Factors Source lb/MMBtu NOx 0.068 AP-42 Chapter 13.5 Industrial CO 0.31 Flares Note: The permitted combustion emissions are based on a still vent waste gas heating value of 1,901 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the"Condenser Vent Stream"in the most recent monthly GlyCalc report and the hours per month the still vent waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Condenser Vent Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Flash Tank Controlled by the ECD: Uncontrolled CAS # Pollutant Emission Factors Source lb/MMBtu NOx 0.068 AP-42 Chapter 13.5 Industrial CO 0.31 Flares Page 45 of 55 � - COLORADO Air Pollution Control Division CDPME Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: The permitted combustion emissions are based on a flash tank waste gas heating value of 1,566 Btu/scf. Actual emissions are calculated based on the heat content and waste gas flow rate from the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the hours per month the flash tank waste gas is routed to the ECD. The heat content is calculated on a monthly basis using the composition of the "Flash Tank Off Gas Stream" in the most recent monthly GlyCalc report and the higher heating value of each component. Combustion of ECD Pilot/Assist Fuel: Weight Emission CAS # Fraction Pollutant Factors Source of Gas (%) lb/MMscf NOx 67.932 AP-42 Chapter 13.5 CO 309.69 Industrial Flares 6.6 VOC 166.75 71432 0.004 Benzene 0.1082 Gas Analysis 110543 0.03 n-hexane 0.8114 Note: The VOC and HAP emissions were calculated using a representative fuel gas sample obtained on September 12, 2018 and an enclosed combustor control efficiency of 95%. The NOx and CO emission factors from AP-42 Chapter 13.5 (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/MMscf using a heating value of 999 Btu/scf. Actual emissions are calculated by multiplying the emissions factors in the table above by the total monthly recorded fuel flow of the pilot gas and assist sgas routed to the ECD. Permitted emissions are based on a constant pilot fuel flow rate of 65 scf/hr and a constant assist fuel flow rate of 2,000 scf/hr. Total VOC and HAP emissions for this source are based on the sum of emissions calculated using the monthly GlyCalc model and the combustion of ECD pilot and assist fuel. Points 009 and 010: Process 01: Turbine emissions during steady state operations: CAS Pollutant Emission Factors - Uncontrolled Source lb/MMBtu PPM at 15% 02 PM2.5 6.6x1O3 --- AP-42 Chapter 3 Table 3.1-2a PM10 6.6x1O3 AP-42 Chapter 3 Table 3.1-2a SOX 3.4x10-3 --- AP-42 Chapter 3 Table 3.1-2a NOx 5.59x10"2 14 Manufacturer CO 6.08x1O2 25 Manufacturer VOC 2.1x10-3 --- AP-42 Chapter 3 Table 3.1-2a 50000 Formaldehyde 7.1x10-4 - AP-42 Chapter 3 Table 3.1-3 Note: Emission factors are based on a heat input rate of 69.83 MMBtu/hr, a lower fuel heat value of 908.2 Btu/scf and 8,760 hours of operation a year. Actual emissions shall be calculated by multiplying the Page 46 of 55 a . . .., COLORADO Mr Pollution Control Division Department of Pubic Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado lb/MMBtu emission factors in the table above by the actual net (lower) heat value from the most recent quarterly heat content sample and the most recent monthly metered fuel gas volume. Process 02: Turbine start-up emissions CAS Pollutant Emission Factors Uncontrolled Source lb/event NOx 1.0 Manufacturer CO 88.0 Manufacturer VOC 18.0 Manufacturer Note: The manufacturer provided emission factors for turbine start-ups are based on 10 minute start-up events. Actual emissions shall be calculated by multiplying the emission factor in the table above by the recorded number of turbine start-up events. Process 03: Turbine shutdown emissions CAS Pollutant Emission Factors - Uncontrolled Source lb/event - NOx 1.0 Manufacturer - Co 62.0 Manufacturer VOC 8.0 Manufacturer Note: The manufacturer provided emission factors for turbine shutdowns are based on 10 minute shutdown events. Actual emissions shall be calculated by multiplying the emission factor in the table above by the recorded number of turbine shutdown events. 3F Point_012: Emissions associated with the pressurized loading of :condensate result from gasses that are released from hoses during disconnect. Emission factors in the table below are based on vapor and liquid line volumes and specific gravity of the liquid unloaded. Emission Factors - Uncontrolled CAS Pollutant (lb/loadout event) Source VOC 1.06 Engineering Calculation 110543 n-Hexane 0.0696 Emission factors are based on liquid and vapor line volumes of 0.0218 ft3/hose. Point 013: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1,346 0 5,241 0 Flanges 457 0 756 0 Open-ended Lines 0 0 0 0 Pump Seals 2 0 5 0 Valves 624 0 1,109 0 Other* 29 0 10 0 VOC Content (wt o) 28.7% --- 100% --- Benzene (wt%) 0.05% --- 0.18% --- Toluene (wt%) 0.04% --- 0.13% --- Page 47 of 55 a . ., COLORADO 41°41Y Air Pollution Control Division CDFHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ethylbenzene (wt%) 0.001% --- 0.003% --- Xylenes (wt%) 0.01% --- 0.03% --- n-hexane (wt%) 0.39% --- 1.37% --- *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 1.0E-05 7.5E-06 9.7E-06 1.0E-05 Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06 Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06 Pump Seals 3.5E-04 --- 5.1E-04 2.4E-05 Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06 Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05 Source: EPA-453/R95-017 Compliance with emissions limits in this permit will be demonstrated by using the TOC emission factors listed in the table above with representative component counts, multiplied by the VOC content from the most recent gas analysis. Point 015: Emission Factors CAS Weight % of Pollutant - Uncontrolled Source Gas lb/blowdown event 28.7 VOC 477.48 Mass Balance 110543 0.39 n-Hexane 6.53 Mass Balance Note: The emission factors for turbine compressor blowdown events are based on a compressor volume of 27,500 scf, a representative inlet gas analysis obtained from the Troudt Compressor Station inlet on 11/4/2016 and the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Actual emissions are calculated by multiplying the emission factor in the table above by the recorded number of turbine compressor blowdown events. Point 016: Emission Factors CAS Weight % of Pollutant - Uncontrolled Source Gas lb/blowdown event 28.7 VOC 96.54 Mass Balance Page 48 of 55 a ~≤ - COLORADO Air Pollution Control Division CDPHE Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: The emission factors for turbine purge events are based on a compressor volume of 5,560 scf, a representative inlet (pre-dehy) gas analysis obtained from the Troudt Compressor Station on 11/4/2016 and the EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3). Actual emissions are calculated by multiplying the emission factor in the table above by the recorded number of turbine compressor purging events. 7) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 8) This permit fulfills the requirement to hold a valid permit reflecting the glycol dehydration unit and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(B) when applicable. 9) Point 013: This source is subject to 40 CFR, Part 60, Subpart OOOOa-Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 (See June 3, 2016 Federal Register posting effective August 02, 2016). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: ttps://www.epo.gov/fdsys/pkg/FR-2016-06-03/pdf/2016-11971.pdf 10)This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, HAPs NANSR Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Applicable NSPS 0000a Applicable to Point 013 11) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Page 49 of 55 g . - COLORADO �' '11 Air Pollution Control Division CD?H€ Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 50 of 55 a1 . COLORADO to Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS TURBINES WITHOUT CONTINUOUS EMISSIONS MONITORING August 16, 2011 1. Routine Turbine Component Replacements The following physical or operational changes to the turbines in this permit are not considered a modification for purposes of NSPS GG, major stationary source NSR/PSD, or Regulation No. 3, Part B. Note that the component replacement provisions apply ONLY to those turbines subject to NSPS GG. Neither pre-GG turbines nor post GG turbines (i.e. KKKK turbines) can use those provisions. 1) Replacement of stator blades, turbine nozzles, turbine buckets, fuel nozzles, combustion chambers, seals, and shaft packings, provided that they are of the same design as the original. 2) Changes in the type or grade of fuel used, if the original gas turbine installation, fuel nozzles, etc. were designed for its use. 3) An increase in the hours of operation (unless limited by a permit condition) 4) Variations in operating loads within the engine design specification. 5) Any physical change constituting routine maintenance, repair, or replacement. Turbines undergoing any of the above changes are subject to all federally applicable and state only requirements set forth in this permit (including monitoring and record keeping). If replacement of any of the components listed in (1) or(5) above results in a change in serial number for the turbine, a letter explaining the action as well as a revised APEN and appropriate filing fee shall be submitted to the Division within 30 days of the replacement. Note that the repair or replacement of components must be of genuinely the same design. Except in accordance with the Alternate Operating Scenario set forth below, the Division does not consider that this allows for the entire replacement (or reconstruction) of an existing turbine with an identical new one or one similar in design or function. Rather, the Division considers the repair or replacements to encompass the repair or replacement of components at a turbine with the same (or functionally similar) components. 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of combustion turbines and turbine components 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 Page 51 of 55 �. - COLORADO 44.1/2';:a Air Pollution Control Division a cc, Department of Public Health tJ Environment Dedicated to protecting and improving the health and environment of the people of Colorado been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any turbine or turbine component replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such turbine or turbine component replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Turbine Replacement The following AOS is incorporated into this permit in order to deal with a turbine breakdown or periodic routine maintenance and repair of an existing onsite turbine that requires the use of a temporary replacement turbine. "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 turbine is in operation. If the turbine 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. Any permanent turbine replacement under this AOS shall result in the replacement turbine being considered a new affected facility for purposes of NSPS and shall be subject to all applicable requirements of that Subpart including, but not limited to, any required Performance Testing. All replacement turbines are subject to all federally applicable and state-only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with the NSPS requirements. Results of;all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any turbine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the turbine (s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement turbine. 2.1.1 The owner or operator may temporarily replace an existing turbine that is covered by this permit with a turbine that is the exact same make and model as the existing turbine without modifying this permit, so long as the temporary replacement turbine complies with the emission limitations for the existing permitted turbine and other requirements applicable to the original turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in section 2.2. 2.1.2 The owner or operator may permanently replace the existing turbine that is covered by this permit with a turbine that is the exact same make and model as the existing turbine without modifying this permit so long as the permanent replacement turbine complies Page 52 of 55 1� COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado with the emission limitations and other requirements applicable to the original turbine as well as any new applicable requirements for the replacement turbine. Measurement of emissions from the temporary replacement turbine shall be made as set forth in section 2.2. 2.1.3 An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement turbine shall be filed with the Division for the permanent replacement turbine within 14 calendar days of commencing operation of the replacement turbine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement turbine. This AOS cannot be used for permanent turbine replacement of a grandfathered or permit exempt turbine or a turbine that is not subject to emission limits. The owner or operator 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 turbine replacement. e AOS cannot be used for the permanent replacement of an entire turbine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non -Attainment Area New Source Review ("PSD/NANSR") ',unless the existing turbine has emission limits that are below the significance levels in Reg 3, Part D, II.A.44. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent turbine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally,in the event that any permanent turbine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the owner or operator from complying with PSD/NANSR and applicable ermitting requirements. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator 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 owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement turbine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement turbine. Page 53 of 55 7 COLORADO Air Pollution Control Division -DPW- Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado All portable analyzer testing required by this permit shall be conducted using the most current version of the Division's Portable Analyzer Monitoring Protocol as found on the Division's website. Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/MMBtu), output based (g/hp- hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement turbine 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 turbine 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 turbine 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 turbine is taken offline. 2.3 Applicable Regulations for Permanent Turbine Replacements 2.3.1 NSPS for Stationary Gas Turbines: 40 CFR 60, Subpart GG §60.330 Applicability and designation of affected facility. (a) The provisions of this subpart are applicable to the following affected facilities: All stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per hour, based on the lower heating value of the fuel fired. (b) Any facility under paragraph (a) of this section which commences construction, modification, or reconstruction after October 3, 1977, is subject to the requirements of this part except as provided in paragraphs (e) and (j) of§60.332. A Subpart GG applicability determination as well as an analysis of applicable Subpart GG monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall be included in any request for a permanent turbine replacement 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 Page 54 of 55 COLORADO 9 Air Pollution Control Division CbAHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado is first relocated to Colorado becomes equivalent to the commence construction date for purposes of determining the applicability of NSPS GG requirements). 2.3.2 NSPS for Stationary Combustion Turbines: 40 CFR 60, Subpart KKKK §60.4305 Does this subpart apply to my stationary combustion turbine? (a) If you are the owner or operator of a stationary combustion turbine with a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, which commenced construction, modification, or reconstruction after February 18, 2005, your turbine is subject to this subpart. Only heat input to the combustion turbine should be included when determining whether or not this subpart is applicable to your turbine. Any additional heat input to associated heat recovery steam generators (HRSG) or duct burners should not be included when determining your peak heat input. However, this subpart does apply to emissions from any associated HRSG and duct burners. (b) Stationary combustion turbines regulated under this subpart are exempt from the requirements of subpart GG of this part. Heat recovery steam generators and duct burners regulated under this subpart are exempted from the requirements of subparts Da, Db, and Dc of this part. A Subpart KKKK applicability determination as welt as an analysis of applicable Subpart KKKK monitoring, recordkeeping, and reporting requirements for the permanent turbine replacement shall be included in any request for a permanent turbine replacement 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 commence construction date for purposes of determining the applicability of NSPS KKKK requirements). 2.4 Additional Sources The replacement of an existing turbine with a new turbine 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; a turbine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite turbine has to go through the appropriate Construction/Operating permitting process prior to installation. Page 55 of 55 Hello