The URL can be used to link to this page

Browse Search

Home My WebLink About20203789.tiff x.',r COLORADO RECEIVE[ Department of Public Health&Environment DEC 1 4 2020 WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 December 2, 2020 Dear Sir or Madam: On December 3, 2020, the Air Pollution Control Division will begin a 30-day public notice period for DCP Operating Company, LP - Enterprise 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 & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator Enclosure 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe I ,: - `f ,, Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director '.t Pv b I : C. Rev•:e c.-.) cc:Pl.(rP),H LOS lra)Pw((MIER/C.NIc-K), 2020-3789 12/23/20 060,A) 12/19/20 GYM Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit CDPHE Warranting Public Comment Website Title: DCP Operating Company, LP - Enterprise Compressor Station - Weld County Notice Period Begins: December 3, 2020 NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant: DCP Operating Company, LP 370 17th Street Suite 2500 Denver, CO 80202 Facility: Enterprise Compressor Station SWSW Section 30, T3N, R63W Keenesburg, CO 80643 DCP Operating Company, LP has applied to renew the Operating Permit for the Enterprise Compressor Station in Weld County, CO. This facility is a natural gas compressor station. The operating permit renewal for this facility includes the following changes for all points: modify permit limitations, emission factors and calculation methods to reflect the facility's current mode of operation, as requested in the renewal application, one administrative modification application, three minor modification applications and five significant modification applications, incorporate the applicable requirements of Colorado Construction Permits 19WE0094 and 19WE0492, update monitoring requirements to be consistent with recently issued permits and include the most recent version of applicable federal and state regulations. This operating permit renewal incorporates equipment previously permitted under Colorado Construction Permit 19WE0094, which includes compressor blowdowns. The emission limit for this point was decreased with the operating permit renewal. This operating permit renewal also incorporates equipment permitted under Colorado Construction Permit 19WE0492, which includes the condensate storage tanks, condensate truck loading and TEG dehydration unit D-3. Emission limitations for these three units were not modified with the operating permit renewal. In addition, two produced water tanks were permitted for the first time with this operating permit renewal. Total facility emissions were decreased from the previous operating permit issuance, as requested in the minor and significant modification applications submitted for this facility. A facility-wide HAP limit was introduced to ensure major source requirements are not triggered under federal rules. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 95OPWE103 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Elie Chavez of the Division at 303-692-6332 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any 3 COLORADO Department of Public 1 ' corMe Health Ft Environment interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission) to receive comments regarding the concerns listed above as well as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Elie Chavez Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 Hearing requests may be submitted to the email address or the mailing address noted above. COLORADO 2a . ..,. SDPNE Department of Public Health 6 Envlroament . oF 4;7 160 fir► SINE N� 18 '76 � Colorado Department of Public Health and Environment OPERATING PERMIT DCP Operating Company, LP Enterprise Compressor Station First Issued: May 1, 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: DCP Operating OPERATING PERMIT NUMBER Company, LP— Enterprise Compressor Station FACILITY ID: 123/0277 95OPWE 103 RENEWED DATE: DRAFT EXPIRATION DATE: DRAFT MODIFICATIONS: See Appendix F of Permit Issued in accordance with the provisions of the Colorado Air Pollution Prevention and Control Act, 25-7-101 et secs. and applicable rules and regulations. ISSUED TO: FACILITY LOCATION: DCP Operating Company, LP DCP Operating Company, LP Enterprise Compressor Station 370 17th Street, Suite 2500 SW 1/4 of SW 1/4, Section 30, T3N, R63W Denver, CO 80202 Between Keenesburg and Roggen, Weld County, CO INFORMATION RELIED UPON Operating Permit Renewal Application Received: July 26, 2016 And Additional Information Received: April 26, 2016;November 20, 2018; June 1,2020; August 24, 2020; October 30, 2020; November 19, 2020 Nature of Business: Natural Gas Liquids Processing and Gathering Primary SIC: 4922 RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON Name: Charles A. Job Name: Roshini Shankaran Title: General Manager, North Area Title: Senior Environmental Engineer Operations Phone: (303) 605-1964 Phone: (303) 605-2039 SUBMITTAL DEADLINES First Semi-Annual Monitoring Period: DRAFT Subsequent Semi-Annual Monitoring Periods: DRAFT Semi-Annual Monitoring Reports: DRAFT First Annual Compliance Period: DRAFT Subsequent Annual Compliance Periods: DRAFT Annual Compliance Certification: DRAFT Note that the Semi-Annual Monitoring Reports and Annual Compliance report must be received at the Division office by 5:00 p.m.on the due date.Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports. Table of Contents: SECTION I - General Activities and Summary 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 3 3. Non-Attainment New Source Review(NANSR) and Prevention of Significant Deterioration(PSD) 9 4. Accidental Release Program (112(r)) 9 5. Compliance Assurance Monitoring(CAM) 10 6. Summary of Emission Units 11 SECTION II- Specific Permit Terms 12 1. C-238 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 053 12 C-235 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst,AIRS ID: 055 12 C-236 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 056 12 C-234 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 070 12 2. C-237 - Caterpillar G3616 4,735 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 071 28 3. D2—Forum Triethylene Glycol Dehydration Unit, AIRS ID: 068 51 4. D-3 —Triethylene Glycol Dehydration Unit, AIRS ID: 077 73 5. P016—Stabilized Condensate Atmospheric Truck Loadout Rack, AIRS ID: 066 97 6. P013 -Eight(8) 300 bbl Stabilized Condensate Storage Tanks, AIRS ID: 063 106 7. SUMP-1/2 —Two (2) 90 bbl Produced Water Storage Tanks, AIRS ID: 075 121 8. COMP-BD—Reciprocating Compressor Blowdowns, AIRS ID: 076 124 9. HAP Emission Limitations for the Stabilized Condensate Storage Tanks, AIRS ID: 063, Produced Water Storage Tanks, AIRS ID: 075 and TEG Dehydration Unit, AIRS ID: 068 or 077 127 10. Facility-Wide Requirements 129 11. Portable Monitoring(ver. 6/26/2014) 145 12. Compliance Assurance Monitoring(ver. 4/16/2009) 146 SECTION III - Permit Shield 151 1. Specific Non-Applicable Requirements 151 2. General Conditions 152 3. Streamlined Conditions 152 SECTION IV - General Permit Conditions (ver. 1/21/2020) 154 1. Administrative Changes 154 2. Certification Requirements 154 3. Common Provisions 154 4. Compliance Requirements 158 5. Emergency Provisions 159 6. Emission Controls for Asbestos 159 7. Emissions Trading, Marketable Permits, Economic Incentives 159 8. Fee Payment 159 9. Fugitive Particulate Emissions 160 10. Inspection and Entry 160 11. Minor Permit Modifications 160 12. New Source Review 160 13. No Property Rights Conveyed 160 Table of Contents: 14. Odor 160 15. Off-Permit Changes to the Source 161 16. Opacity 161 17. Open Burning 161 18. Ozone Depleting Compounds 161 19. Permit Expiration and Renewal 161 20. Portable Sources 161 21. Prompt Deviation Reporting 161 22. Record Keeping and Reporting Requirements 162 23. Reopenings for Cause 163 24. Requirements for Major Stationary Sources 164 25. Section 502(b)(10) Changes 165 26. Severability Clause 165 27. Significant Permit Modifications 165 28. Special Provisions Concerning the Acid Rain Program 165 29. Transfer or Assignment of Ownership 165 30. Volatile Organic Compounds 165 31. Wood Stoves and Wood burning Appliances 166 APPENDIX A Inspection Information 1 APPENDIX B Reporting Requirements and Definitions 5 APPENDIX C Required Format for Annual Compliance Certification Report (ver 8/20/2014) 17 APPENDIX D Notification Addresses 20 APPENDIX E Permit Acronyms 21 APPENDIX F Permit Modifications 23 APPENDIX G Compliance Assurance Monitoring Plans 24 APPENDIX H Applicability Reports 32 Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 1 SECTION I- General Activities and Summary 1. Permitted Activities 1.1 The Enterprise Compressor Station is classified as a natural gas compressor station as set forth under Standard Industrial Classification Code 4922. This facility has a design natural gas throughput of 145 MMscfd and a stabilized condensate production rate of 202,848 bbl/year. The facility uses five(5)natural gas-fired internal combustion engines (AIRS 053, 055, 056, 070 and 071) to drive compressors to boost the inlet gas pressure from about 80 psig to about 1,050 psig, facilitating the movement of natural gas into pipeline transit.These compressors are periodically blown down for routine maintenance activities (AIRS 076). The station also includes one (1) triethylene glycol (TEG) dehydration unit (AIRS 077) which contacts "lean" TEG with the compressed natural gas stream to remove moisture. The "rich" TEG mixture is regenerated in a still for reuse in the process. The TEG dehydration system operates with a flash tank and a still vent.The flash tank emissions are routed back to the facility inlet using a vapor recovery unit(VRU), which is permitted 5% downtime, during which emissions are routed to an enclosed combustion device (COMB-1). The still vent stream is sent through a condenser to an enclosed combustion device (COMB- 1, included under AIRS 077) where it is combusted. This enclosed combustion device is permitted 1% downtime,during which still vent emissions are routed to atmosphere. It should be noted that no emission control from the condenser is claimed for this dehydration unit. A condensate product is generated when the inlet gas is routed through the inlet scrubber and liquids generated via pipeline transit are separated out. This condensate is then stabilized, and transferred to eight (8) 300 barrel stabilized condensate storage tanks (AIRS 063). A loading system (AIRS 066) is provided for moving stabilized condensate from the tanks into a truck for transport offsite. The condensate tanks and loadout are controlled with an enclosed combustion device. Two (2) 90 barrel produced water tanks (AIRS 075) store any water separated from the condensate stream. Emission control devices include:five(5)oxidation catalyst beds to control the compressor engine exhaust emissions, one (1) vapor recovery unit (VRU) permitted 5% downtime to control the dehydration unit flash tank emissions, one (1) enclosed combustion device (COMB-1) permitted 1% downtime to control the dehydration unit still vent emissions, and permitted to control flash tank emissions during VRU downtime (permitted 5%), and one (1) enclosed combustion device to control the stabilized condensate storage tank and loadout emissions. This permit contains provisions for the existing 110 MMscfd TEG dehydration unit D-2 (AIRS 068), which will be decommissioned and replaced with the 145 MMscfd TEG dehydration unit D-3 (AIRS 077). Upon startup of D-3, the conditions governing D-2 set forth in Section II, Condition 3 of this permit will no longer apply and the source shall operate D-3 pursuant to the requirements set forth in Section II, Condition 4. This facility is located one (1) mile north of US Highway 76 on the Gutterson Road between the towns of Keenesburg and Roggen, in Weld County, Colorado. This facility is located in an Area classified as Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 2 attainment for all pollutants except ozone. It is classified as non-attainment for the 8-hr ozone standard and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Part A, Section II.A.1. The 8- hr Ozone Control Area has been classified as a serious non-attainment area effective January 27, 2020. There are no affected states within 50 miles of the facility. Rocky Mountain National Park is a Federal Class I designated area within 100 kilometers of the facility. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements,limitations,and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3,Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permit(s): 97WE0553 00WE0470 19WE0094 19WE0492 1.4 All conditions in this permit are enforceable by the US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State-only enforceable conditions are: Permit Condition Number(s): Section II—Conditions 1.10.1.2 and 2.9.1.2 (Colorado Regulation No. 7, Part E, Section I.D.) Section II—Conditions 3.12.2 and 4.13.2 (Colorado Regulation No. 7, Part D, Section II.D.) Section II—Condition 4.10.1 (Colorado Construction Permit 19WE0492) Section II—Conditions 6.6.2 and 7.4.1 (Colorado Regulation No. 7, Part D, Section II.C.) Section II—Condition 10.5 (Colorado Regulation No. 7, Part D, Section II.B.) Section II—Condition 10.6 (Colorado Regulation No. 7, Part D, Section II.E.) Section II—Condition 10.7 (Colorado Regulation No. 7, Part D, Section V.) Section IV—Condition 3.g(Colorado Common Provisions Regulation, Affirmative Defense) Section IV—Condition 14 (Colorado Regulation No. 2, as noted) Section IV—Condition 18 (Colorado Regulation No. 15, as noted) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 3 Section IV—Condition 30 (Colorado Regulation No. 7, Part B, Sections I and III, as noted) 1.5 All information gathered pursuant to the requirements of this permit is subject to the Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. Either electronic or hard copy records are acceptable. 2. Alternative Operating Scenarios 2.1 Glycol Circulation Pump Alternative Operating Scenarios (Colorado Construction Permit 19WE0492,as modified under the provisions of Section I,Condition 1.3) The glycol circulation pumps for TEG dehydration units D-2 and D-3 may be replaced in accordance with the alternative operating scenario provisions set forth in Section II,Conditions 3.10 and 4.11,respectively. The facility must, contemporaneously with making a change from one operating scenario to another, maintain records at the facility of the scenario under which it is operating (Colorado Regulation No. 3, Part A, Section IV.A.1). Electronic or hard copy records are acceptable. 2.2 Natural Gas Fired Engine Alternative Operating Scenarios (Ver. 10/12/2012; updated to reflect changes to Colorado Regulation No.7,NSPS,and MACT rules) The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios,Regulation No.3,Part B,Construction Permits,and Regulation No.3, Part D,Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS,and the permittee shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 270 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 270 operating days in any 12 month period. The 270 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 270-day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit(including monitoring and record keeping), and shall be subject to any shield afforded by this permit. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 4 The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The permittee shall maintain a log on-site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log,the permittee shall maintain a copy of all Applicability Reports required under Section 2.2.1.2 and make them available to the Division upon request. 2.2.1.1 The permittee may temporarily replace an existing compressor engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in Section 2.2.2. The permittee may temporarily replace a grandfathered or permit exempt engine or an engine that is not subject to emission limits without modifying this permit. In this circumstance, potential annual emissions of NOx and CO from the temporary replacement engine must be less than or equal to the potential annual emissions of NOx and CO from the original grandfathered or permit exempt engine or for the engine that is not subject to emission limits, as determined by applying appropriate emission factors (e.g. AP-42 or manufacturer's emission factors). 2.2.1.2 Engines C-234, C-235, C-236 and C-238 only: The permittee may permanently replace the existing compressor engine for the emission points specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table l without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in Section 2.2.2. The AOS cannot be used for the permanent replacement of an entire engine at any source that is currently a major stationary source for purposes of Prevention of Significant Deterioration or Non-Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that are below the significance levels in Reg 3, Part D, II.A.44. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 5 days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the permittee is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found in Appendix H. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The permittee shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR requirements, nothing in this AOS shall excuse the permittee from complying with PSD/NANSR and applicable permitting requirements. 2.2.2 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 permittee may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The permittee shall measure nitrogen oxide (NOx) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven(7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: https://www.colorado.gov/pacific/cdphe/portable-analyzer-monitoring-protocol. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 6 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(8,760), whichever applies. For comparison with a short-term limit that is either input based(lb/mmBtu), output based(g/hp- hr)or concentration based(ppmvd @ 15%O2)that the existing unit is currently subject to or the replacement engine will be subject to,the results of the test shall be converted to the appropriate units as described in the above-mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations,the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the engine is taken offline. 2.2.3 Applicable Regulations for Permanent Engine Replacements 2.2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § III.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOx are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PMIo attainment/maintenance area, RACT applies to PMIo at any level of emissions and to NOx and SO2, as precursors to PM10, if the potential to emit of NOx or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural-gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 7 NOx: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM1o: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.2.3.2 Control Requirements and Emission Standards:Regulation No. 7,Part E, Sections I.B. and I.D. (State-Only conditions). Control Requirements: Section I.B. Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, Part E, section I.B., as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.2.1.2. Emission Standards: Section L D. —State-only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine Construction or Emission Standards in G/hp-hr HP Relocation Date NOx I CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500<Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 8 Condition 2.2.1.2. 2.2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp,7/1/2007 for engines greater than or equal to 500 hp except for lean bum engines greater than or equal to 500 hp and less than 1,350 hp,and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2.2. Note that under the provisions of Regulation No.6, Part B, Section I.C.,upon adoption of NSPS JJJJ into Regulation No. 6, Part A an internal combustion engine relocated from outside of the State of Colorado into the State of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section 1.C.2.a. Relocation is defined in Section I.C.1.a. However, as of September 14, 2019 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. 2.2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2.2, if approved in advance by the Division,provided that such test is conducted within the time frame specified in Condition 2.2.2. 2.2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not"routine replacement" of an existing unit. The AOS is Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 9 therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. Table 1 Internal Combustion Engine Information For AOS Emission Subject to Point Replacement Engine Periodic Monitoring CAM? C-238 Caterpillar Model G3612 Turbocharged Natural Gas Fired Portable Monitoring Reciprocating Internal Combustion Engine,4-Cycle,Standard Quarterly Yes Lean Burn,3,550 hp,Drive for Natural Gas Compressor C-235 Caterpillar Model G3612 Turbocharged Natural Gas Fired Portable Monitoring Reciprocating Internal Combustion Engine,4-Cycle,Standard Quarterly Yes Lean Burn,3,550 hp,Drive for Natural Gas Compressor C-236 Caterpillar Model G3612 Turbocharged Natural Gas Fired Portable Monitoring Reciprocating Internal Combustion Engine,4-Cycle,Standard Quarterly Yes Lean Burn,3,550 hp,Drive for Natural Gas Compressor C-234 Caterpillar Model G3612 Turbocharged Natural Gas Fired Portable Monitoring Reciprocating Internal Combustion Engine,4-Cycle,Standard Yes Quarterly Lean Burn,3,550 hp,Drive for Natural Gas Compressor 3. Non-Attainment New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx≥ 50 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself(i.e. a Potential to Emit of ≥50 TPY of either VOC or NOx)may result in the application of the NANSR review requirements. Based on the information provided by the applicant,this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself(Potential to Emit of> 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.2 There are no other Operating Permits associated with this facility for the purposes of determining the applicability of the PSD regulations. 4. Accidental Release Program (112(r)) 4.1 Based upon the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r)of the Federal Clean Air Act). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 10 5. Compliance Assurance Monitoring (CAM) 5.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV: AIRS ID 053 (C-238)—Compressor RICE (3,550 hp) for VOC AIRS ID 055 (C-235)—Compressor RICE (3,550 hp) for VOC AIRS ID 056 (C-236)—Compressor RICE(3,550 hp) for VOC AIRS ID 068 (D-2)—TEG Dehydration Unit(110 MMscfd) for VOC and HAP AIRS ID 070 (C-234)—Compressor RICE (3,550 hp) for VOC AIRS ID 071 (C-237)—Compressor RICE (4,735 hp) for CO and VOC AIRS ID 077 (D-3)—TEG Dehydration Unit (145 MMscfd) for VOC and HAP See Section II, Condition 12 for compliance assurance monitoring requirements. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED. DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 11 6. Summary of Emission Units 6.1 The emissions units regulated by this permit are the following: AIRS Plant Pollution Control Construction Stack Identifier Description Device Permit Number Caterpillar Model G3612 Turbocharged Natural Gas Fired Reciprocating Internal 053 C-238 Combustion Engine,4-Cycle,Standard Lean Burn,Site Rated at 3,550 hp,Serial Oxidation Catalyst 97WE0553 No.BKE00356,Drive for Natural Gas Compressor Caterpillar Model G3612 Turbocharged Natural Gas Fired Reciprocating Internal 055 C-235 Combustion Engine,4-Cycle,Standard Lean Burn,Site Rated at 3.550 hp,Serial Oxidation Catalyst 97WE0553 No. 1YG00047,Drive for Natural Gas Compressor Caterpillar Model G3612 Turbocharged Natural Gas Fired Reciprocating Internal 056 C-236 Combustion Engine,4-Cycle,Standard Lean Bum,Site Rated at 3,550 hp,Serial Oxidation Catalyst 97WE0553 No. l YG00028,Drive for Natural Gas Compressor 063 P013 Eight(8)300 bbl Stabilized Condensate Atmospheric Storage Tanks Enclosed Combustion 19WE0492 Device(ECD) 066 P016 Stabilized Condensate Atmospheric Truck Loadout Enclosed Combustion 19WE0492 Device(ECD) Forum Energy Technologies Custom TEG Dehydration Unit,Rated at 110 MMscfd,equipped with a flash tank,TEG regeneration still,still vent condenser D-2 (no control claimed)and one(I)Rotor Tech Model GS2212 electric glycol Flash Tank:VRU circulation pump rated at 20 gpm. (100%CE,5%DT) 068 00WE0470 Still Vent:COMB-1 Leed Fabrication Model L30-0018-00 Enclosed Combustion Device used to (95%CE, 1°/0 DT) COMB-1 control still vent emissions,and,during periods of VRU downtime,flash tank emissions. Caterpillar Model G3612 Turbocharged Natural Gas Fired Reciprocating Internal 070 C-234 Combustion Engine,4-Cycle,Standard Lean Burn,Site Rated at 3,550 hp,Serial Oxidation Catalyst None No. 1 YG00029,Drive for Natural Gas Compressor Caterpillar Model G3616 Turbocharged Natural Gas Fired Reciprocating Internal 071 C-237 Combustion Engine,4-Cycle,Standard Lean Burn,Site Rated at 4,735 hp,Serial Oxidation Catalyst None No.BLB00490,Drive for Natural Gas Compressor 075 SUMP-1/2 Two(2)90 bbl Produced Water Atmospheric Storage Tanks None None 076 COMP-BD Natural gas venting from reciprocating compressor blowdowns None 19WE0094 TEG Dehydration Unit,Rated at 145 MMscfd,equipped with a flash tank,TEG regeneration still,still vent condenser(no control claimed)and two(2)FMC D-3 Triplex electric glycol circulation pumps(one primary,one backup),rated at 25 Flash Tank:VRU 077 gpm each. (100%CE,5%DT) 19WE0492 Still Vent:COMB-1 Leed Fabrication Model L30-0018-00 Enclosed Combustion Device used to (95%CE,1%DT) COMB-1 control still vent emissions,and,during periods of VRU downtime,flash tank emissions. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 12 SECTION II- Specific Permit Terms 1. C-238 -Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst,AIRS ID: 053 C-235 -Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst,AIRS ID: 055 C-236 -Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 056 C-234 -Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst,AIRS ID: 070 Permit Monitoring Parameter Condition Compliance Limits Emission Factor Number Method Interval Emission&Consumption Limits' NOx 24.0 tons/year 0.228 lb/MMBtu Recordkeeping and 1.1 Twelve Month CO 27.4 tons/year 0.261 lb/MMBtu Rolling Total VOC 1.2 24.0 tons/year 0.228 lb/MMBtu Calculation Monthly Natural Gas Consumption 1.3 206.10 MMscf/year Fuel Meter, Twelve Month Rolling Total Other Requirements' ASTM or Other Natural Gas Heat Content 1.4 Division Approved Semi-Annually Method Hours of Operation 1.5 Recordkeeping Monthly Not to exceed 20%,except as provided for below: Opacity 1.6 For Certain Operational Activities-Not to Fuel Restriction—Natural Gas Only exceed 30%for a period or periods aggregating more than six(6)minutes in any sixty(60)consecutive minutes Control Device 1.7 See Condition 1.7 Requirements Portable Monitoring 1.8 Flue Gas Analyzer Quarterly Compliance Assurance 1.9 See Condition 1.9 Monitoring(CAM) Statewide Controls for Oil 1.10 See Condition 1.10 and Gas Operations 40 CFR 63 Subpart ZZZZ C-238 only: MACT 1.I 1 See Condition 1.11 40 CFR 63 Subpart A C-238 only: General Provisions MACT 1.12 See Condition 1.12 !Emission&Consumption Limits and Other Requirements apply to each engine individually unless otherwise specified. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 13 1.1 NOx & CO Emission Limitations & Compliance Monitoring Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from each engine shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permit 97WE0553). Except as provided for below, the emission factors listed above have been approved by the Division and shall be used to calculate emissions from these engines, as follows: 1.1.1 Monthly determination of NOx and CO emissions shall be conducted by the end of the subsequent month using the emission factors listed in Summary Table 1 above, the monthly natural gas consumption, as required by Condition 1.3 and the heat content of the natural gas obtained from the most recent analysis, as required by Condition 1.4, in the equation below: ( Ib (MMBtu) (MMscf) tons l Emission Factor (MMBtu)x Heat Content lMMscf x Fuel Use month J NOx or CO Emissions (month/ 2000 lb) Unit Conversion ( ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 1.1.2 Portable monitoring shall be conducted quarterly as required by Condition 1.8. If the results of the portable analyzer testing conducted under the provisions of Condition 1.8 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above, and in the absence of subsequent testing results to the contrary (as approved by the Division), the owner or operator shall apply for a modification to this permit to reflect,at a minimum,the higher emission rates/factors within 60 days of the completion of the test. 1.2 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds(VOC)from each engine shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permit 97WE0553). Compliance with the emission limitation shall be monitored as follows: 1.2.1 Monthly determination of VOC emissions shall be conducted by the end of the subsequent month using the emission factors listed in Summary Table 1 above, the monthly natural gas consumption, as required by Condition 1.3, and the heat content of the natural gas obtained from the most recent analysis, as required by Condition 1.4, in the equation below: ( lb MMBtu MMscf tons Emission Factor \MMBtu)x Heat Content MMscf)x Fuel Use (month) VOC or HAP Emissions (month) 2000 lb Unit Conversion ton Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 14 Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 1.2.2 Annual emissions of Hazardous Air Pollutants (HAP), for the purposes of APEN reporting and the payment of annual fees, shall be calculated using HAP emissions derived from the same method as required for VOC emissions,except that the compliance emission factor for each HAP species shall be obtained from EPA's AP-42: Compilation of Emission Factors, Section 3.2 for Natural Gas Fired Reciprocating Engines, Final Section, Table 3.2-2 (dated 8/2000). 1.3 Natural Gas Consumption Limitations & Compliance Monitoring Natural gas consumption for each engine shall not exceed the limitations listed in Summary Table 1 above (Colorado Construction Permit 97WE0553, as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No.3,Part B,Section II.A.6 and Part C,Section X based on requested limitations identified on the APEN received on 11/20/2018). Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas usage shall be recorded on the same day that run time hours have been recorded, as required by Condition 1.5. Allocation of natural gas to each engine shall be determined using the following equation: Btu MMscfl HREngine(month) MMscfl FCEngine(month/ ( Btu ( Btu )x FCFaciiity (month) E HREngine(month)+E HRother month Where: Btu hr HREngine (m nth/ = BSFC (hp•t h u )r x Hours of Operation (month)x Site Rated hp(hp) And: FCEngine =Individual Engine Fuel Consumption,MMscf/Month HREngine =Individual Engine Heat Requirement,Btu/Month HRother=Other Users Heat Requirement,Btu/Month FCFaciiity=Facility Wide Fuel Consumption(metered),MMsc f/Month BSFC=Brake Specific Fuel Consumption,Btu/hp•hr Monthly natural gas consumption for each engine shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 15 the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. Monthly natural gas consumption shall be used to monitor compliance with the NOx, CO and VOC emission limitations, as required by Conditions 1.1 and 1.2. 1.4 Natural Gas Heat Content The heat content of the natural gas used to fuel these engines shall be verified semi-annually using the appropriate ASTM Methods or equivalent,if approved in advance by the Division.At least four(4)months shall separate sequential sampling events. The heat content of the natural gas shall be based on the higher heating value (HHV) of the fuel. Results of the heat content verification shall be maintained and made available to the Division upon request. The heat content used by the Division in determining the emission limitations listed in Summary Table 1 was 1,020 Btu per standard cubic foot of natural gas. The heat content indicated by the most recent analysis shall be used to monitor compliance with the NOx, CO and VOC emission limitations, as required by Conditions 1.1 and 1.2. 1.5 Hours of Operation Hours of operation for each engine shall be monitored and recorded monthly. Hours of operation shall be recorded on the same day that the facility fuel gas consumption is recorded. Records of the monthly hours of operation shall be maintained and made available to the Division upon request. The hours of operation shall be used to monitor compliance with the natural gas consumption limitations, as required by Condition 1.3. 1.6 Opacity The following opacity requirements apply to each engine: 1.6.1 Except as provided for in Condition 1.62 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 1.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications,or adjustment or occasional cleaning of control equipment which is excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for these engines. The owner or operator shall maintain records that verify that only natural gas is used as fuel. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 16 1.7 Control Device Requirements These engines shall be equipped with an oxidation catalyst, as required by Conditions 1.10.1.1 and 1.10.1.2b. Parameters associated with the catalyst shall be monitored as follows for each engine except C-238: 1.7.1 The catalyst pressure drop shall not exceed 2 inches of water column from the baseline value established by the source when the engine is operating at maximum achievable load. This baseline pressure drop shall be established by the source during each initial compliance and portable analyzer test, and as noted below. The pressure drop across the catalyst shall be monitored and recorded monthly in a log to be made available to the Division upon request If the pressure is outside this range then the appropriate maintenance shall be performed to bring the pressure back into range. In lieu of maintenance the source may choose to perform a portable analyzer test of the engine to establish a new pressure drop value. If the test demonstrates that the engine is in compliance with its emission limits,the pressure drop value at which the engine is tested shall become the new baseline. The catalyst will be cleaned, reconditioned and replaced per the manufacturer's recommended schedule and a copy of maintenance reports shall be kept for Division review upon request. For new, cleaned or reconditioned catalyst: the new pressure drop baseline must be established by the operator within the first 7 days of engine/catalyst operation and re-established during'the next regularly scheduled emission test. 1.7.2 The catalyst inlet temperature shall be maintained between 450°F and 1,350°F. The catalyst inlet temperature shall be monitored and recorded daily in a log to be made available to the Division upon request. 1.7.3 When portable monitoring is scheduled,the above parameters in Conditions 1.7.1 and 1.7.2 shall be recorded during the portable monitoring event. 1.7.4 All control equipment required by Condition 1.7 shall be operated and maintained pursuant to manufacturer specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. Manufacturer specifications or equivalent shall be kept on file. 1.8 Portable Monitoring Portable monitoring shall be conducted quarterly in accordance with the requirements of Condition 11. 1.9 Compliance Assurance Monitoring(CAM) Each engine is subject to the Compliance Assurance Monitoring(CAM)requirements with respect to the annual VOC emission limitations set forth in Condition 1.2.Compliance with the CAM requirements shall be monitored in accordance with Condition 12 and the CAM Plan in Appendix G. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 17 1.10 Statewide Controls for Oil and Gas Operations 1.10.1 Colorado Regulation No. 7, Part E, Section I. Requirements Each engine is subject to the following requirements of Colorado Regulation No. 7, Part E, Section I., "Control of Emissions from Engines": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. 1.10.1.1 Air Pollution Technology Requirements (Colorado Regulation No. 7, Part E, Section I.B.). a. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater (Colorado Regulation No. 7, Part E, Section I.B.2.). b. The emission control equipment required by this Section I.B. (Condition a above) shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications (Colorado Regulation No. 7, Part E, Section I.B.3.). 1.10.1.2 Control of emissions from new, modified, existing and relocated natural gas fired reciprocating internal combustion engines(Colorado Regulation No. 7,Part E, Section I.D.). a. [State-Only Enforceable] New, Modified and Relocated Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.2.). (i) Engine C-238 only: Except as provided in Section I.D.2.b. (Condition (ii)below),the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in Table 1 shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in Section I.D.2.b. Table 1 Condition (ii) below) (Colorado Regulation No. 7, Part E, Section I.D.2.a.). (ii) Engine C-238 only: Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in Table 1 as expressed in units of Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 18 grams per horsepower-hour(g/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b.): Table 1 Maximum Construction or Relocation Date Emission Standard in g/hp-hr Engine HP NOx CO VOC On or after July 1,2007 2.0 4.0 1.0 > 500 HP On or after July 1,2010 1.0 2.0 0.7 Engine C-238 only: [Compliance Monitoring: Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly as specified in Condition 1.8. For comparison with the short—term limits in this Condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition (ii).] Engine C-238 only: [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition (ii).] b. Existing Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.3.). (i) [State-Only Enforceable] Except as provided in Section I.D.3.b.(ii) all lean burn reciprocating internal combustion engines with a manufacturer's nameplate design rate greater than 500 horsepower shall install and operate an oxidation catalyst by July 1, 2010. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.D.3.b.(i)). 1.10.2 Colorado Regulation No. 7, Part E, Section II Requirements Each engine is subject to the following requirements of Colorado Regulation No. 7, Part E, Section II., "Control of Emissions from Stationary and Portable Combustion Equipment in the 8-Hour Ozone Control Area": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. 1.10.2.1 Exemptions (Colorado Regulation No. 7, Part E, Section II.A.2.) The following stationary combustion equipment are exempt from the emission limitation requirements of Section II.A.4.,the compliance demonstration requirements Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 19 in Section II.A.5., and the related recordkeeping and reporting requirements of Sections I[.A.7.a-e. and II.A.8, but these sources must maintain any and all records necessary to demonstrate that an exemption applies (Condition 1.10.2.3b). These records must be maintained for a minimum of five years and made available to the Division upon request. Qualifying for an exemption in this section does not preclude the combustion process adjustment requirements of Section II.A.6. (Condition 1.10.2.2), when required by II.A.6.a (Condition 1.10.2.2a). Once stationary combustion equipment no longer qualifies for any exemption, the owner or operator must comply with the applicable requirements of this Section II.A. as expeditiously as practicable but no later than 36 months after any exemption no longer applies. Additionally, once stationary combustion equipment that is not equipped with CEMS or CERMS no longer qualifies for any exemption,the owner or operator must conduct a performance test using EPA test methods within 180 days and notify the Division of the results and whether emission controls will be required to comply with the emission limitations of Section II.A.4. a. Any natural gas-fired reciprocating internal combustion engines subject to a work practice or emission control requirement contained in this Regulation 7, Section I.A. or B. (Condition 1.10.1.1) (Colorado Regulation No. 7, Part E, Section II.A.2.e.). L10.2,2 Combustion Process Adjustment(Colorado Regulation No. 7, Part E, Section II.A.6.). a. As of January 1, 2017, this Section II.A.6. (Conditions 1.10.2.2) applies to stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016 (Colorado Regulation No. 7, Part E, Section II.A.6.a.(i)). b. The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments,as applicable(Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)): (i) Change oil and filters as necessary(Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)(A)). (ii) Inspect air cleaners, fuel filters,hoses,and belts and clean or replace as necessary (Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)(B)). (iii) Inspect spark plugs and replace as necessary(Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)(C)). c. The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, or good engineering and maintenance practices (Colorado Regulation No. 7, Part E, Section II.A.6.b.(vii)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 20 d. Frequency(Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)). (i) The owner or operator of boilers, duct burners, process heaters, stationary combustion turbines, and stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5)tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1,2017.An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017 (Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)(A)). (ii) The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i) (Condition e(i)) or II.A.6.c.(ii) (Condition e(ii)) (Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)(C)). e. As an alternative to the requirements described in Sections II.A.6.b.(iv) through II.A.6.b.(viii) (Conditions b through d above) (Colorado Regulation No. 7, Part E, Section II.A.6.c.): (i) The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (Colorado Regulation No. 7, Part E, Section II.A.6.c.(i)); or (ii) The owner or operator of combustion equipment that is subject to and required to conduct a periodic tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 or 40 CFR Part 63 (Colorado Regulation No. 7, Part E, Section II.A.6.c.(ii)). 1.10.2.3 Recordkeeping. The following records must be kept for a period of five years and made available to the Division upon request (Colorado Regulation No. 7, Part E, Section II.A.7.): a. For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6. (Condition 1.10.2.2),the following recordkeeping requirements apply(Colorado Regulation No. 7,Part E, Section II.A.7.f.): Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 21 (i) The owner or operator must create a record once every calendar year identifying the combustion equipment at the source subject to Section II.A. (Condition 1.10.2.2a) and including for each combustion equipment(Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)): (A)The date of the adjustment (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(A)); (B)Whether the combustion process adjustment under Section II.A.6.b.(iv) (Condition 1.10.2.2b) was followed, and what procedures were performed (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(B)); (C)Whether a combustion process adjustment under Sections II.A.6.c.(i). and II.A.6.c.(ii). (Conditions 1.10.2.2e(i) through 1.10.2.2e(ii)) was followed, what procedures were performed, and what New Source Performance or National Emission Standard for Hazardous Air Pollutants applied, if any(Colorado Regulation No. 7, Part E, Section II.A.f.(i)(C)); and (D)A description of any corrective action taken (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(D)). (E) If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation (Colorado Regulation No. 7, Part E, Section II.A.7.£(i)(E)). (ii) The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section II.A.6.c.(i). (Condition 1.10.2.2e(i)) for the life of the equipment (Colorado Regulation No. 7, Part E, Section II.A.7.f.(ii)). (iii) As an alternative to the requirements described in Section II.A.7.f.(i) (Condition (i) above), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (Colorado Regulation No. 7, Part E, Section II.A.7.f.(iii)). b. All sources qualifying for an exemption under Section II.A.2. (Condition 1.10.2.1)must maintain all records necessary to demonstrate that an exemption applies (Colorado Regulation No. 7, Part E, Section II.A.7.g.). 1.11 40 CFR Part 63 Subpart ZZZZ MACT Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 22 Engine C-238 only is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date,the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. Note that as of the date of revised permit issuance XX/XX/XXXX, the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 and later have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements, they will become both state and federally enforceable. General Requirements: 1.11.1 You must be in compliance with the emission limitations in Condition 1.11.3, operating limitations in Condition 1.11.4, and other requirements in this subpart that apply to you at all times. (§63.6605(a)). 1.11.2 At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§63.6605(b)). Emission Limitations: 1.11.3 Owners or operators of a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions shall: 1.11.3.1 Reduce CO emissions by 93 percent or more (§63.6600(b), Table 2a, Item 2.a.), or 1.11.3.2 Limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2(§63.6600(b), Table 2a, Item 2.b.). Operating Limitations: 1.11.4 Owners or operators of a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions shall: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 23 1.11.4.1 Maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test (§63.6600(b), Table 2b, Item].a.); and 1.11.4.2 Maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450°F and less than or equal to 1,350°F (§63.6600(b), Table 2b, Item l.b.). Subsequent Performance Test Requirements: 1.11.5 Subsequent performance tests shall be conducted semi-annually(§63.6615, Table 3, Item 1). 1.11.6 After compliance has been demonstrated for two consecutive tests,the frequency of semi-annual tests may be reduced to annually. If the results of any subsequent annual performance test indicates the stationary RICE is not in compliance with the CO emission limitations, or you deviate from any of your operating limitations, you must resume semi-annual performance tests (§63.6615, Table 3, Footnote 1). Performance Tests and Other Procedures 1.11.7 Each performance test must be conducted according to the requirements that this subpart specifies in Table 4 to this subpart. The test must be conducted at any load condition within plus or minus 10 percent of 100 percent load (§63.6620(b)). Monitoring, Installation, Collection, Operation and Maintenance Requirements: 1.11.13 You must install, maintain and operate a continuous parametric monitoring system (CPMS) to continuously monitor catalyst inlet temperature according to the requirements of§63.6625(b)(1) through (6) of this subpart(§63.6625(b), Table 5, Item 1). 1.11.9 If you operate a new,reconstructed,or existing stationary engine,you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Condition 1.11.3 to this subpart apply(§63.6625(h)). Monitoring and Collecting Data for Continuous Compliance: 1.11.10 Data must be monitored and collected in accordance with the following(§63.6635(a)): 1.11.10.1 Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities, you must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 24 maintenance or careless operation are not malfunctions. (§63.6635(b)). 1.11.10.2 You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must however, use all the valid data collected during all other periods (§63.6635(c)). Demonstrating Continuous Compliance with the Emission and Operating Limitations: 1.11.11 You must demonstrate continuous compliance with each emission and operating limitation in Conditions 1.11.3 and 1.11.4 as follows: 1.11.11.1 Conducting subsequent performance tests as specified in Condition 1.11.5 and demonstrating the required CO reduction in Condition 1.11.3.1 (§63.6640(a),Table 6, Item 1.i.). 1.11.11.2 Conducting semiannual performance tests for formaldehyde as specified in Condition 1.11.5 to demonstrate that your emissions remain at or below the formaldehyde concentration limit in Condition 1.11.3.2 (§63.6640(a), Table 6, Item 7.i.). 1.11.11.3 Collecting the catalyst inlet temperature data according to §63.6625(b) (Condition 1.11.8); (§63.6640(a), Table 6, Item 1.a.ii. or 7.a.ii.) and 1.11.11.4 Reducing these data to 4-hour rolling averages; ((§63.6640(a),Table 6, Item 1.a.iii. or 7.a.iii.) and 1.11.11.5 Maintaining the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Condition 1.11.4.2); (§63.6640(a), Table 6, Item l.a.iv. or 7.a.iv.) and 1.11.11.6 Measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop across the catalyst is within the operating limitation established during the performance test (§63.6640(a), Table 6, Item 1.v. and Item 7.v.). 1.11.11.7 After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests (§63.6640(a), Table 6, Footnote a). 1.11.12 You must report each instance in which you did not meet each emission limitation or operating limitation in Conditions 1.11.3 and 1.11.4. These instances are deviations from the emission and operating limitations in Conditions 1.11.3 and 1.11.4. These deviations must be reported according to the requirements in Conditions 1.11.18 through 1.11.22. If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE (§63.6640(b)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 25 1.11.13 For new, reconstructed, and rebuilt stationary RICE, deviations from the emission (Condition 1.11.3) or operating limitations (Condition 1.11.4) that occur during the first 200 hours of operation from engine startup(engine burn-in period)are not violations. Rebuilt stationary RICE means a stationary RICE that has been rebuilt as that term is defined in 40 CFR § 94.11(a) (§63.6640(d)). 1.11.14 You must also report each instance in which you did not meet the requirements in Condition 1.12 of this permit(§63.6640(e)). What Notifications to Submit and When: 1.11.15 You must submit all of the notifications in §63.7(b) and (c), 63.8(e), (0(4) and (0(6), 63.9(b) through (e), and (g) and (h)that apply to you by the dates specified. (§63.6645(a)). 1.11.16 If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in § 63.7(b)(1) (Condition 1.12.3) (§63.6645(g)). 1.11.17 If you are required to conduct a performance test as specified in Condition 1.11.5, you must submit the Notification of Compliance Status according to §63.6645(h)(1) and (h)(2) of this subpart(§63.6645(h)). What Reports to Submit and When: 1.1 1.18 You must submit each report in Table 7 of this subpart that applies to you (§63.6650(a)). 1.1 1.19 Unless the Division has approved a different schedule for submission of reports under §63.10(a) (Condition 1.12.6), you must submit Compliance Reports in accordance with the requirements of§63.6650(b)(1)through (b)(9) of this subpart (§63.6650(b)). 1.11.20 The Compliance Reports must include the information in §63.6650(c)(1) through (c)(6) of this subpart (§63.6650(c)). 1.11.21 For each deviation from any emission or operating limitation that occurs for a stationary RICE where you are using a CPMS to comply with the emission and operating limitations in this subpart you must include information in §63.6650(c)(1) through (4) and (e)(1) through (12) of this subpart(§63.6650(e)). 1.11.22 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A)or 40 CFR 71.6(a)(3)(iii)(A). If an affected source submits a Compliance report pursuant to Condition 1.11.18 along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the Compliance report includes all required information concerning deviations from any emission or operating limitation in this subpart, submission of the Compliance report shall be deemed to Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 26 satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a Compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permit authority §63.6650(f)). What Records to Keep: 1.1 L23 A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv) (Condition 1.12.6) (§63.6655(a)(1)). 1.11.24 Records of the occurrence and duration of each malfunction of operation(i.e.,process equipment) or the air pollution control and monitoring equipment. (§63.6655(a)(2)). 1.11.25 Records of performance tests and performance evaluations as required in §63.10(b)(2)(viii) (Condition 1.12.6) (§63.6655(a)(3)). 1.11.26 Records of all required maintenance performed on the air pollution control and monitoring equipment. (§63.6655(a)(4)). 1.11.27 Records of actions taken during periods of malfunction to minimize emissions in accordance with Condition 1.11.2, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation (§63.6655(a)(5)). 1.11.28 For each CPMS you must keep the following records (§63.6655(b)): 1.11.28.1 Records described in §63.10(b)(2)(vi) through (xi) (Condition 1.12.6) (§63.6655(b)(1)). 1.11.28.2 Previous (i.e., superseded) versions of the performance evaluation plan as required in §63.8(d)(3) (Condition 1.12.4) (§63.6655(b)(2)). 1.11.28.3 Requests for alternatives to the relative accuracy test for CPMS as required in §63.8(f)(6)(i) (Condition 1.12.4), if applicable (§63.6655(b)(3)). 1.11.29 You must keep the records required in Condition 1.11.11 to show continuous compliance with each emission or operating limitation that applies to you (§63.6655(d)). Form and Length of Recordkeeping: 1.11.30 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1) (Condition 1.12.6) (§63.6660(a)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 27 1.1 1.31 As specified in §63.10(b)(1)(Condition 1.12.6), you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.6660(b)). 1.11.32 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence,measurement,maintenance, corrective action,report,or record, according to §63.10(b)(1) (Condition 1.12.6) (§63.6660(c)). 1.12 40 CFR Part 63 Subpart A MACT Engine C-238 only is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to the following: 1.12.1 Prohibited activities and circumvention (§63.4) 1.12.2 Operation and maintenance requirements (§63.6(e)(1)) 1.12.3 Performance testing requirements (§63.7) 1.12.4 Monitoring requirements (§63.8) 1.12.5 Notification requirements (§63.9) 1.12.6 Recordkeeping and reporting requirements (§63.10) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 28 2. C-237 -Caterpillar G3616 4,735 hp Compressor Engine with Oxidation Catalyst,AIRS ID: 071 Permit Compliance Monitoring Parameter Condition Emission Factor Number Limits Method Interval Emission&Consumption Limits NOx 32.01 tons/year 0.206 lb/MMBtu Recordkeeping and 2.1 Twelve Month CO 36.58 tons/year 0.236 Ib/MMBtu Rolling Total VOC 2.2 32.01 tons/year 0.206 lb/MMBtu Calculation Monthly Natural Gas Consumption 2.3 304.22 Fuel Meter,Twelve MMscf/year Month Rolling Total Other Requirements ASTM or Other Natural Gas Heat Content 2.4 Division Approved Semi-Annually Method Hours of Operation 2.5 Recordkeeping Monthly Not to exceed 20%,except as provided for below: Opacity 2.6 For Certain Operational Activities-Not to Fuel Restriction—Natural Gas Only exceed 30%for a period or periods aggregating more than six(6)minutes in any sixty(60)consecutive minutes Portable Monitoring 2.7 Flue Gas Analyzer Quarterly Compliance Assurance Monitoring 2.8 See Condition 2.8 (CAM) Statewide Controls for Oil and Gas 2.9 Operations See Condition 2.9 40 CFR 60 Subpart JJJJ NSPS 2.10 See Condition 2.10 40 CFR 60 Subpart OOOO NSPS 2.11 See Condition 2.11 40 CFR 60 Subpart A General 2.12 See Condition 2.12 Provisions NSPS 40 CFR 63 Subpart ZZZZ MACT 2.13 See Condition 2.13 40 CFR 63 Subpart A General 2.14 See Condition 2.14 Provisions MACT 2.1 NOx & CO Emission Limitations & Compliance Monitoring Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from this engine shall not exceed the limitations listed in Summary Table 2 above. Except as provided for below, the emission factors listed Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 29 above have been approved by the Division and shall be used to calculate emissions from this engine, as follows: 2.1.1 Monthly determination of NOx and CO emissions shall be conducted by the end of the subsequent month using the emission factors listed in Summary Table 2 above, the monthly natural gas consumption, as required by Condition 2.3 and the heat content of the natural gas obtained from the most recent analysis, as required by Condition 2.4, in the equation below: lb (MMBtu) (MMscf) tons l Emission Factor (MMBtu�x Heat Content MMscf J)x Fuel Use l month J NOx or CO Emissions (month/ 2000 lb ) Unit Conversion ( ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 2.1.2 Portable monitoring shall be conducted quarterly as required by Condition 2.7. If the results of the portable analyzer testing conducted under the provisions of Condition 2.7 show that either the NOx or CO emission rates/factors are greater than the emission rates/factors listed above,and in the absence of subsequent testing results to the contrary (as approved by the Division), the owner or operator shall apply for a modification to this permit to reflect,at a minimum,the higher emission rates/factors within 60 days of the completion of the test. 2.2 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds (VOC) from this engine shall not exceed the limitation listed in Summary Table 2 above. Compliance with the emission limitation shall be monitored as follows: 2.2.1 Monthly determination of VOC emissions shall be conducted by the end of the subsequent month using the emission factors listed in Summary Table 2 above, the monthly natural gas consumption, as required by Condition 2.3, and the heat content of the natural gas obtained from the most recent analysis, as required by Condition 2.4, in the equation below: Ib (MMBtuI (MMscfl tons l Emission Factor (MMBtu)x Heat Content MMscf)x Fuel Use month J VOC or HAP Emissions (month/ 2000 lb Unit Conversion ( ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 30 2.2.2 Annual emissions of Hazardous Air Pollutants (HAP), for the purposes of APEN reporting and the payment of annual fees, shall be calculated using HAP emissions derived from the same method as required for VOC emissions,except that the compliance emission factor for each HAP species shall be obtained from EPA's AP-42: Compilation of Emission Factors, Section 3.2 for Natural Gas Fired Reciprocating Engines, Final Section, Table 3.2-2 (dated 8/2000). 2.3 Natural Gas Consumption Limitations & Compliance Monitoring Natural gas consumption from this engine shall not exceed the limitation listed in Summary Table 2 above (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part B, Section II.A.6 and Part C, Section X based on requested limitations identified on the APEN received on 11/20/2018). Facility-wide natural gas consumption shall be recorded using the existing fuel meter on a monthly basis. The natural gas usage shall be recorded on the same day that run time hours have been recorded, as required by Condition 2.5. Allocation of natural gas to this engine will be determined using the following equation: Btu l MMSCf HREngine(month) MMscf) FCEngine(month/ Btu l Btu x FCFaciiiry (month/ HREngine(month)+1 HROther(month) Where: Btu hr HREngine (month) = BSFC (hp t•hr)x Hours of Operation (month)x Site Rated hp(hp) And: FCEngine =Individual Engine Fuel Consumption,MMscf/Month HREngine =Individual Engine Heat Requirement,Btu/Month HRorher=Other Users Heat Requirement,Btu/Month FCFaciiity=Facility Wide Fuel Consumption(metered),MMscf/Month BSFC=Brake Specific Fuel Consumption,Btu/hp•hr Monthly natural gas consumption for this engine shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. Monthly natural gas consumption shall be used to monitor compliance with the NOx, CO and VOC emission limitations, as required by Conditions 2.1 and 2.2. 2.4 Natural Gas Heat Content Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 31 The heat content of the natural gas used to fuel this engine shall be verified semi-annually, or once every six months, using the appropriate ASTM Methods or equivalent, if approved in advance by the Division. At least four (4) months shall separate sequential sampling events. The heat content of the natural gas shall be based on the higher heating value (HHV) of the fuel. The heat content used by the Division in determining the emission limitations listed in Summary Table 2 was 1,020 Btu per standard cubic foot of natural gas. The heat content indicated by the most recent analysis shall be used to monitor compliance with the NOx, CO and VOC emission limitations, as required by Conditions 2.1 and 2.2. 2.5 Hours of Operation Hours of operation for this engine shall be monitored and recorded monthly. Hours of operation shall be recorded on the same day that the facility fuel gas consumption is recorded. Records of the monthly hours of operation shall be maintained and made available to the Division upon request. The hours of operation shall be used to monitor compliance with the natural gas consumption limitation, as required by Condition 2.3. 2.6 Opacity The following opacity requirements apply to this engine: 2.6.1 Except as provided for in Condition 2.6.2 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity (Colorado Regulation No. 1, Section II.A.1). 2.6.2 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, process modifications,or adjustment or occasional cleaning of control equipment which is excess of 30% opacity for a period or periods aggregating more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, Section II.A.4). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed since only natural gas is permitted to be used as fuel for this engine.The owner or operator shall maintain records that verify that only natural gas is used as fuel. 2.7 Portable Monitoring Portable monitoring shall be conducted quarterly in accordance with the requirements of Condition 11. 2.8 Compliance Assurance Monitoring (CAM) This engine is subject to the Compliance Assurance Monitoring(CAM) requirements with respect to the annual CO emission limitation set forth in Condition 2.1 and VOC emission limitation set forth in Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 32 Condition 2.2. Compliance with the CAM requirements shall be monitored in accordance with Condition 12 and the CAM Plan in Appendix G. 2.9 Statewide Controls for Oil and Gas Operations 2.9.1 Colorado Regulation No. 7, Part E, Section I. Requirements This engine is subject to the following requirements of Colorado Regulation No. 7, Part E, Section I., "Control of Emissions from Engines": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. 2.9.1.1 Air Pollution Technology Requirements (Colorado Regulation No. 7, Part E, Section I.B.). a. For lean burn reciprocating internal combustion engines, an oxidation catalyst shall be required. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater (Colorado Regulation No. 7, Part E, Section I.B.2.). b. The emission control equipment required by this Section I.B. (Condition a above) shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications (Colorado Regulation No. 7, Part E, Section I.B.3.). 2.9.1.2 Control of emissions from new, modified, existing and relocated natural gas fired reciprocating internal combustion engines(Colorado Regulation No. 7,Part E, Section I.D.). a. [State-Only Enforceable] New, Modified and Relocated Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.2.). (1) Except as provided in Section I.D.2.b.(Condition(ii)below),the owner or operator of any natural gas fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state, on or after the date listed in Table 1 shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in Section I.D.2.b. Table 1 Condition (ii) below) (Colorado Regulation No. 7, Part E, Section I.D.2.a.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 33 (ii) Actual emissions from natural gas fired reciprocating internal combustion engines shall not exceed the emission performance standards in Table 1 as expressed in units of grams per horsepower- hour(g/hp-hr) (Colorado Regulation No. 7, Part E, Section I.D.2.b.): Table 1 Maximum Emission Standard in g/hp-hr Engine HP Construction or Relocation Date NOx CO VOC On or after July 1, 2007 2.0 4.0 1.0 ≥ 500 HP On or after July 1, 2010 1.0 2.0 0.7 [Compliance Monitoring: Compliance with the NOx and CO emission limitations shall be monitored by conducting portable monitoring quarterly as specified in Condition 2.7. For comparison with the short—term limits in this Condition, the results of the portable monitoring test shall be converted to units of g/hp-hr to assess compliance with the NOx and CO emission limitations in this Condition (ii).] [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with the VOC limitation is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations in this Condition (ii).] b. Existing Natural Gas Fired Reciprocating Internal Combustion Engines (Colorado Regulation No. 7, Part E, Section I.D.3.). (i) [State-Only Enforceable] Except as provided in Section I.D.3.b.(ii) all lean burn reciprocating internal combustion engines with a manufacturer's nameplate design rate greater than 500 horsepower shall install and operate an oxidation catalyst by July 1, 2010. A lean burn reciprocating internal combustion engine is one with a normal exhaust oxygen concentration of 2% by volume, or greater. (Colorado Regulation No. 7, Part E, Section I.D.3.b.(i)). 2.9.2 Colorado Regulation No. 7, Part E, Section II. Requirements This engine is subject to the following requirements of Colorado Regulation No. 7, Part E, Section II., "Control of Emissions from Stationary and Portable Combustion Equipment in the 8-Hour Ozone Control Area": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. 2.9.2.1 Exemptions (Colorado Regulation No. 7, Part E, Section II.A.2.) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 34 The following stationary combustion equipment are exempt from the emission limitation requirements of Section II.A.4.,the compliance demonstration requirements in Section II.A.5., and the related recordkeeping and reporting requirements of Sections II.A.7.a-e. and 11.A.8, but these sources must maintain any and all records necessary to demonstrate that an exemption applies (Condition 2.9.2.3b). These records must be maintained for a minimum of five years and made available to the Division upon request. Qualifying for an exemption in this section does not preclude the combustion process adjustment requirements of Section II.A.6. (Condition 2.9.2.2),when required by II.A.6.a(Condition 2.9.2.2a). Once stationary combustion equipment no longer qualifies for any exemption, the owner or operator must comply with the applicable requirements of this Section II.A. as expeditiously as practicable but no later than 36 months after any exemption no longer applies. Additionally, once stationary combustion equipment that is not equipped with CEMS or CERMS no longer qualifies for any exemption,the owner or operator must conduct a performance test using EPA test methods within 180 days and notify the Division of the results and whether emission controls will be required to comply with the emission limitations of Section II.A.4. a. Any natural gas-fired reciprocating internal combustion engines subject to a work practice or emission control requirement contained in this Regulation 7, Section I.A. or B. (Condition 2.9.1.1) (Colorado Regulation No. 7, Part E, Section II.A.2.e.). 2.9.2.2 Combustion Process Adjustment(Colorado Regulation No. 7, Part E, Section II.A.6.). a. As of January 1, 2017, this Section II.A.6. (Conditions 2.9.2.2) applies to stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5)tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016 (Colorado Regulation No. 7, Part E, Section II.A.6.a.(i)). b. The owner or operator of a stationary internal combustion engine must conduct the following inspections and adjustments, as applicable(Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)): (i) Change oil and filters as necessary(Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)(A)). (ii) Inspect air cleaners, fuel filters, hoses,and belts and clean or replace as necessary (Colorado Regulation No. 7, Part E, Section II.A.6.b.(iv)(B)). (iii) Inspect spark plugs and replace as necessary(Colorado Regulation No. 7, Part E, Section 1I.A.6.b.(iv)(C)). c. The owner or operator must operate and maintain the stationary internal combustion engine consistent with manufacturer's specifications, if available, Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 35 or good engineering and maintenance practices (Colorado Regulation No. 7, Part E, Section II.A.6.b.(vii)). d. Frequency(Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)). (i) The owner or operator of boilers, duct burners, process heaters, stationary combustion turbines, and stationary reciprocating internal combustion engines with uncontrolled actual emissions of NOx equal to or greater than five (5) tons per year that existed at major sources of NOx (greater than or equal to 100 tpy NOx) as of June 3, 2016, must conduct the initial combustion process adjustment by April 1, 2017. An owner or operator may rely on a combustion process adjustment conducted in accordance with applicable requirements and schedule of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 to satisfy the requirement to conduct an initial combustion process adjustment by April 1, 2017 (Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)(A)). (ii) The owner or operator must conduct subsequent combustion process adjustments at least once every twelve (12) months after the initial combustion adjustment, or on the applicable schedule according to Sections II.A.6.c.(i) (Condition e(i)) or II.A.6.c.(ii) (Condition e(ii)) (Colorado Regulation No. 7, Part E, Section II.A.6.b.(viii)(C)). e. As an alternative to the requirements described in Sections II.A.6.b.(iv) through II.A.6.b.(viii) (Conditions b through d above) (Colorado Regulation No. 7, Part E, Section II.A.6.c.): (i) The owner or operator may conduct the combustion process adjustment according to the manufacturer recommended procedures and schedule (Colorado Regulation No. 7, Part E, Section II.A.6.c.(i)); or (ii) The owner or operator of combustion equipment that is subject to and required to conduct a periodic tune-up or combustion adjustment by the applicable requirements of a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 may conduct tune-ups or adjustments according to the schedule and procedures of the applicable requirements of 40 CFR Part 60 or 40 CFR Part 63 (Colorado Regulation No. 7, Part E, Section II.A.6.c.(ii)). 2.9.2.3 Recordkeeping. The following records must be kept for a period of five years and made available to the Division upon request (Colorado Regulation No. 7, Part E, Section II.A.7.): a. For stationary combustion equipment subject to the combustion process adjustment requirements in Section II.A.6. (Condition 2.9.2.2), the following Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 36 recordkeeping requirements apply(Colorado Regulation No. 7,Part E, Section II.A.7.f.): (i) The owner or operator must create a record once every calendar year identifying the combustion equipment at the source subject to Section II.A. (Condition 2.9.2.2a) and including for each combustion equipment(Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)): (A)The date of the adjustment (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(A)); (B)Whether the combustion process adjustment under Section II.A.6.b.(iv) (Condition 2.9.2.2b) was followed, and what procedures were performed (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(B)); (C)Whether a combustion process adjustment under Sections II.A.6.c.(i). and II.A.6.c.(ii). (Conditions 2.9.2.2e(i) through 2.9.2.2e(ii)) was followed, what procedures were performed, and what New Source Performance or National Emission Standard for Hazardous Air Pollutants applied, if any (Colorado Regulation No. 7, Part E, Section II.A.f.(i)(C)); and (D)A description of any corrective action taken (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(D)). (E) If the owner or operator conducts the combustion process adjustment according to the manufacturer recommended procedures and schedule and the manufacturer specifies a combustion process adjustment on an operation time schedule, the hours of operation (Colorado Regulation No. 7, Part E, Section II.A.7.f.(i)(E)). (ii) The owner or operator must retain manufacturer recommended procedures, specifications, and maintenance schedule if utilized under Section II.A.6.c.(i). (Condition 2.9.2.2e(i))for the life of the equipment (Colorado Regulation No. 7, Part E, Section II.A.7.f.(ii)). (iii) As an alternative to the requirements described in Section II.A.7.f.(i) (Condition (i) above), the owner or operator may comply with applicable recordkeeping requirements related to combustion process adjustments conducted according to a New Source Performance Standard in 40 CFR Part 60 or National Emission Standard for Hazardous Air Pollutants in 40 CFR Part 63 (Colorado Regulation No. 7, Part E, Section II.A.7.f.(iii)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED:DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 37 b. All sources qualifying for an exemption under Section II.A.2. (Condition 2.9.2.1)must maintain all records necessary to demonstrate that an exemption applies (Colorado Regulation No. 7, Part E, Section II.A.7.g.). 2.10 40 CFR Part 60 Subpart JJJJ NSPS This engine is subject to the New Source Performance Standards requirements of 40 CFR Part 60, Subpart JJJJ "Standards of Performance for Stationary Spark Ignition Internal Combustion Engines", including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart JJJJ published in the Federal Register on 8/30/2016. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60 Subpart JJJJ. These requirements have not been adopted into Colorado Regulation No. 6, Part A as of the date of this permit issuance XX/XX/XXXX, and are therefore not state-enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state-enforceable. Emission Standards for Owners and Operators: 2.10.1 Each engine must comply with the specific emission limitations shown in the table below (Table 1 of Subpart JJJJ). Manufacture Date:July 1,2010 Emission Standards( hp-hr) Emission Standards(ppmvd at 15%O2) NOx CO VOC NOx CO VOC 1.0 2.0 0.7 82 270 60 I 2.10.1.1 Owners and operators of new or reconstructed non-emergency lean burn SI stationary engines with a site rating of greater than or equal to 250 brake HP located at a major source that are meeting the requirements of 40 CFR part 63, subpart ZZZZ, Table 2a (Condition 2.13.3) do not have to comply with the CO emission standards of Table 1 of this subpart(Table 1 and Footnote b of Subpart JJJJ). 2.10.1.2 For purposes of this subpart, when calculating emissions of volatile organic compounds, emissions of formaldehyde should not be included (Table 1 and Footnote d of Subpart JJJJ). 2.10.1.3 For engines manufactured prior to January 1, 2011 that were certified to the certification emission standards in 40 CFR part 1048 applicable to engines that are not severe duty engines,if such stationary SI ICE was certified to a carbon monoxide(CO) standard above the standard in Condition 2.10.1 above, then the source may meet the CO certification (not field testing) standard for which the engine was certified (§60.4233(e)). Compliance Requirements for Owners and Operators: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 38 2.10.2 This facility shall keep a maintenance plan and records of conducted maintenance and, to the extent practicable,maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, this facility shall conduct an initial performance test and conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance (§60.4243(b)(2)(ii)). Testing Requirements for Owners and Operators: 2.10.3 Owners and operators of stationary SI ICE who conduct performance tests must follow the procedures in §60.4244(a)through (g) of this subpart(§60.4244). Notification, Reports and Records for Owners and Operators: 2.10.4 The facility must keep records of the following information: 2.10.4.1 All notifications submitted to comply with this subpart and all documentation supporting any notification (§60.4245(a)(1)). 2.10.4.2 Maintenance conducted on the engine (§60.4245(a)(2)). 2.10.4.3 If the engine is not a certified engine or is a certified engine operating in a non-certified manner and subject to §60.4243(a)(2), documentation that the engine meets the emission standards (§60.4245(a)(4)). 2.10.5 Engines that not been certified by an engine manufacturer to meet the emission standards in §60.4231 must submit an initial notification as required in §60.7(a)(1) (Condition 2.12.1). The notification must include the information in §60.4245(c)(1) through (c)(5) of this subpart (§60.4245(c)). 2.10.6 The source must submit a copy of each performance test as conducted in §60.4244 (Condition 2.10.3) within 60 days after the test has been completed (§60.4245(d)). 2.11 40 CFR Part 60 Subpart OOOO NSPS The compressor driven by this engine C-237 is subject to the New Source Performance Standard requirements of Colorado Regulation No. 6, Part A, Subpart OOOO (40 CFR Part 60, Subpart OOOO) "Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction,Modification or Reconstruction Commenced After August 23,2011,and on or before September 18, 2015" including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60 Subpart OOOO published in the Federal Register on 6/3/2016. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 60 Subpart OOOO. Standards for Reciprocating Compressor Affected Facilities Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 39 2.11.1 You must replace the reciprocating compressor rod packing according to either paragraph (a)(1) (Condition 2.11.1.1) or (2) (Condition 2.11.1.2) of this section or you must comply with paragraph (a)(3) (Condition 2.11.1.3) of this section (§60.5385(a)). 2.11.1.1 Before the compressor has operated for 26,000 hours. The number of hours of operation must be continuously monitored beginning upon initial startup of your reciprocating compressor affected facility,or October 15,2012,or the date of the most recent reciprocating compressor rod packing replacement, whichever is later (§60.5385(a)(1)). 2.11.1.2 Prior to 36 months from the date of the most recent rod packing replacement, or 36 months from the date of startup for a new reciprocating compressor for which the rod packing has not yet been replaced (§60.5385(a)(2)). 2.11.1.3 Collect the emissions from the rod packing using a rod packing emissions collection system which operates under negative pressure and route the rod packing emissions to a process through a closed vent system that meets the requirements of §60.5411(a) (Conditions 2.11.6 through 2.11.8) (§60.5385(a)(3)). 2.11.2 You must demonstrate initial compliance with standards that apply to reciprocating compressor affected facilities as required by §60.5410 (Condition 2.11.5) (§60.5385(b)). 2.113 You must demonstrate continuous compliance with standards that apply to reciprocating compressor affected facilities as required by §60.5415 (Condition 2.11.9) (§60.5385(c)). 2.11.4 You must perform the required notification, recordkeeping, and reporting as required by §60.5420 (Conditions 2.11.13 through 2.11.14) (§60.5385(d)). Initial Compliance Requirements for Reciprocating Compressor Affected Facilities 2.11.5 You must determine initial compliance with the standards for each affected facility using the requirements in paragraph (c) (Condition 2.11.5.1) of this section. The initial compliance period begins on October 15,2012, or upon initial startup, whichever is later,and ends no later than one year after the initial startup date for your affected facility or no later than one year after October 15, 2012. The initial compliance period may be less than one full year(§60.5410). 2.11.5.1 To achieve initial compliance with the standards for each reciprocating compressor affected facility you must comply with paragraphs (c)(1) (Condition a) through (4) (Condition d) of this section (§60.5410(c)). a. If complying with §60.5385(a)(1) (Condition 2.11.1.1) or (2) (Condition 2.11.1.2),during the initial compliance period, you must continuously monitor the number of hours of operation or track the number of months since the last rod packing replacement (§60.5410(c)(1)). b. If complying with §60.5385(a)(3) (Condition 2.11.1.3), you must operate the rod packing emissions collection system under negative pressure and route Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 40 emissions to a process through a closed vent system that meets the requirements of §60.5411(a) (Conditions 2.11.6 through 2.11.8) (§60.5410(c)(2)). c. You must submit the initial annual report for your reciprocating compressor as required in §60.5420(b) (Condition 2.11.13). (§60.5410(c)(3)). d. You must maintain the records as specified in §60.5420(c)(3) (Condition 2.11.14.1) for each reciprocating compressor affected facility (§60.5410(c)(4)). Additional Initial Compliance Requirements for Closed Vent Systems 2.11.6 You must design the closed vent system to route all gases, vapors, and fumes emitted from the material in the reciprocating compressor rod packing emissions collection system or the wet seal fluid degassing system to a control device or to a process that meets the requirements specified in §60.5412(a)through (c) of this Subpart(§60.5411(a)(1)). 2.11.7 You must design and operate the closed vent system with no detectable emissions as demonstrated by §60.5416(b) (Condition 2.11.11) (§60.5411(a)(2)). 2.11.8 You must meet the requirements specified in paragraphs (a)(3)(i) (Condition 2.11.8.1) and (ii) (Condition 2.11.8.2)of this section 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 (§60.5411(a)(3)). 2.11.8.1 Except as provided in paragraph (a)(3)(ii) (Condition 2.11.8.2) of this section, you must comply with either paragraph (a)(3)(i)(A) (Condition a) or (B) (Condition b) of this section for each bypass device (§60.5411(a)(3)(i)). a. You must properly install, calibrate, maintain, and operate a flow indicator at the inlet to the bypass device that could divert the stream away from the control device or process to the atmosphere that is capable of taking periodic readings as specified in §60.5416(a)(4) (Condition 2.11.10.4) and either sounds an alarm,or initiates notification via remote alarm to the nearest field office,when the bypass device is open such that the stream is being, or could be, diverted away from the control device or process to the atmosphere. You must maintain records of each time the alarm is activated according to §60.5420(c)(8) (Condition 2.11.14.4) (§60.5411(a)(3)(i)(A)). b. You must 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 (§60.5411(a)(3)(i)(B)). 2.11.8.2 Low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and safety devices are not subject to the requirements of paragraph (a)(3)(i) (Condition 2.11.8.1) of this section (§60.541 l(a)(3)(ii)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 41 Continuous Compliance Demonstration Requirements for Reciprocating Compressor Affected Facilities 2.11.9 For each reciprocating compressor affected facility complying with §60.5385(a)(1) (Condition 2.11.1.1) or(2) (Condition 2.1 1.1.2), you must demonstrate continuous compliance according to paragraphs (c)(1) (Condition 2.11.9.1)through (3) (Condition 2.11.9.3) of this section. For each reciprocating compressor affected facility complying with §60.5385(a)(3) (Condition 2.11.1.3), you must demonstrate continuous compliance according to paragraph(c)(4)(Condition 2.11.9.4) of this section (§60.5415(c)). 2.11.9,1 You must continuously monitor the number of hours of operation for each reciprocating compressor affected facility or track the number of months since initial startup, or October 15, 2012, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later(§60.5415(c)(1)). 2.11.9.2 You must submit the annual report as required in §60.5420(b)(Condition 2.11.13)and maintain records as required in §60.5420(c)(3) (Condition 2.11.14.1) (§60.5415(c)(2)). 2.11.9.3 You must replace the reciprocating compressor rod packing before the total number of hours of operation reaches 26,000 hours or the number of months since the most recent rod packing replacement reaches 36 months (§60.5415(c)(3)). 2.11.9A You must operate the rod packing emissions collection system under negative pressure and continuously comply with the closed vent requirements in §60.5416(a)(Condition 2.11.10) and (b) (Condition 2.11.11) (§60.5415(c)(4)). Initial and Continuous Cover and Closed Vent System Inspection and Monitoring Requirements 2.11.10 Except as provided in paragraphs §60.5416(b)(11) and (12) of this Subpart, you must inspect each closed vent system according to the procedures and schedule specified in paragraphs (a)(1) (Condition 2.11.10.1) and (2) (Condition 2.11.10.2) of this section, and inspect each bypass device according to the procedures of paragraph (a)(4) (Condition 2.11.10.4) of this section (§60.5416(a)).. 2,11.10.1 For each closed vent system joint, seam, or other connection that is permanently or semi-permanently sealed (e.g., a welded joint between two sections of hard piping or a bolted and gasketed ducting flange), you must meet the requirements specified in paragraphs (a)(1)(i) (Condition a) and (ii) (Condition b) of this section (§60.5416(a)(1)). a. Conduct an initial inspection according to the test methods and procedures specified in paragraph (b) (Condition 2.11.11) of this section to demonstrate that the closed vent system operates with no detectable emissions. You must maintain records of the inspection results as specified in §60.5420(c)(6) (Condition 2.11.14.2) (§60.5416(a)(1)(i)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP'I P g Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 42 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; liquid leaks; or broken or missing caps or other closure devices. You must monitor a component or connection using the test methods and procedures in paragraph (b) (Condition 2.11.11) of this section to demonstrate that it operates with no detectable emissions following any time) the component is repaired or replaced or the connection is unsealed. You must maintain records of the inspection results as specified in §60.5420(c)(6) (Condition 2.11.14.2) ((§60.5416(a)(1)(i i)). 2.11.10.2 For closed vent system components other than those specified in paragraph (a)(1) (Condition 2.11.10.1) of this section, you must meet the requirements of paragraphs (a)(2)(i) (Condition a)through (iii) (Condition c) of this section (§60.5416(a)(2)). a. Conduct an initial inspection according to the test methods and procedures specified in paragraph (b) (Condition 2.11.11) of this section to demonstrate that the closed vent system operates with no detectable emissions. You must maintain records of the inspection results as specified in §60.5420(c)(6) (Condition 2.11.14.2) (§60.5416(a)(2)(i)). b. Conduct annual inspections according to the test methods and procedures specified in paragraph (b) (Condition 2.11.11) of this section to demonstratC that the components or connections operate with no detectable emissions. You must maintain records of the inspection results as specified in §60.5420(c)(6) (Condition 2.11.14.2) (§60.5416(a)(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; liquid leaks; or broken or missing caps or other closure devices. You must maintain records of the inspection results as specified in §60.5420(c)(6) (Condition 2.11.14.2) (§60.5416(a)(2)(iii)). 2.11.10.3 For each cover, you must meet the requirements in paragraphs (a)(3)(i) (Condition a) and (ii) (Condition b) of this section (§60.5416(a)(3)). a. Conduct visual inspections for defects that could result in air emissions. Defects include, but are not limited to, visible cracks, holes, or gaps in the cover, or between the cover and the separator wall; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing hatches, access covers, caps, or other closure devices. In the case where the storage vessel is buried partially or entirely underground, you must inspect only those portions of the cover that extend to or above the ground surface,and those connections that are on such portions of the cover(e.g., fill ports, access hatches, gauge wells, etc.) and can be opened to the atmosphere (§60.5416(a)(3)(i)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAIN Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 43 b. You must initially conduct the inspections specified in paragraph (a)(3)(i) (Condition a above) of this section following the installation of the cover. Thereafter, you must perform the inspection at least once every calendar year, except as provided in paragraphs (b)(11) and (12) of this section. You must maintain records of the inspection results as specified in §60.5420(c)(7) (Condition 2.11.14.3) (§60.5416(a)(3)(ii)). 2.11.10.4 For each bypass device, except as provided for in §60.5411. (Condition 2.11.8.2), you must meet the requirements of paragraphs (a)(4)(i) (Condition a) or(ii) (Condition b) of this section (§60.5416(a)(4)). a. Set the flow indicator to take a reading at least once every 15 minutes at the inlet to the bypass device that could divert the steam away from the control device to the atmosphere (§60.5416(a)(4)(i)). 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. You must maintain records of the inspections according to §60.5420(c)(8) (Condition 2.11.14.4) (§60.5416(a)(4)(ii)). 2.11.11 No detectable emissions test methods and procedures. If you are required to conduct an inspection of a closed vent system or cover at your centrifugal compressor or reciprocating compressor affected facility as specified in paragraphs (a)(1) (Condition 2.11.10.1), (2) (Condition 2.11.10.2), or (3) (Condition 2.11.10.3) of this section, you must meet the requirements of paragraphs (b)(1) through (13) of this Subpart(§60.5416(b)). Notification, Recordkeeping and Reporting Requirements 2.11.12 If you own or operate a reciprocating compressor facility you are not required to submit the notifications required in §60.7(a)(1), (3), and (4) (§60.5420(a)(1)). 2.11.13 Reporting requirements. You must submit annual reports containing the information specified in paragraphs §60.5420(b)(1) and (b)(4) of this Subpart to the Administrator and performance test reports as specified in paragraph §60.5420(b)(7) or(8) of this Subpart. The initial annual report is due no later than 90 days after the end of the initial compliance period as determined according to §60.5410 (Condition 2.11.5). Subsequent annual reports are due no later than same date each year as the initial annual report. If you own or operate more than one affected facility, you may submit one report for multiple affected facilities provided the report contains all of the information required as specified in paragraphs §60.5420(b)(1)and(b)(4)of this section.Annual reports may coincide with title V reports as long as all the required elements of the annual report are included. You may arrange with the Administrator a common schedule on which reports required by this part may be submitted as long as the schedule does not extend the reporting period (§60.5420(b)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station; Permit# 95OPWE103 Page 44, 2.11.14 Recordkeeping requirements. You must maintain the records identified as specified in §60.7(f) (Condition 2.12.1) and in paragraphs (c)(3) (Condition 2.11.14.1), (c)(6) (Condition 2.11.14.2), (c)(8)(Condition 2.11.14.4)and(c)(9)Condition 2.11.14.5)and(c)(14)(Condition 2.11.14.6)of this section. All records required by this subpart must be maintained either onsite or at the nearest local field office for at least 5 years (§60.5420(c)). 2.11.14.1 For each reciprocating compressors affected facility, you must maintain the records in paragraphs (c)(3)(i)through (iii) of this section (§60.5420(c)(3)). a. Records of the cumulative number of hours of operation or number of months since initial startup or October 15, 2012, or the previous replacement of the reciprocating compressor rod packing, whichever is later(§60.5420(c)(3)(i)). b. Records of the date and time of each reciprocating compressor rod packing replacement, or date of installation of a rod packing emissions collection system and closed vent system as specified in §60.5385(a)(3) (Condition 2.11.1.3) (§60.5420(c)(3)(ii)). c. Records of deviations in cases where the reciprocating compressor was not operated in compliance with the requirements specified in §60.5385; (Conditions 2.11.1 through 2.11.3) (§60.5420(c)(3)(iii)). 2.11.14.2 Records of the cumulative number of hours of operation or number of months since initial startup or October 15, 2012, or the previous replacement of the reciprocating' compressor rod packing, whichever is later(§60.5420(c)(6)). 2.11.14.3 A record of each cover inspection required under§60.5416(a)(3)(Condition 2.11.10.3) for centrifugal or reciprocating compressors (§60.5420(c)(7)). 2.11.14.4 If you are subject to the bypass requirements of§60.5416(a)(4) (Condition 2.11.10.4) for reciprocating compressors or, a record of each inspection or a record each time they key is checked out or a record of each time the alarm is sounded (§60.5420(c)(8)). 2.11.14.5 If you are subject to the closed vent system no detectable emissions requirements of §60.5416(b) (Condition 2.11.1 1) for reciprocating compressors, a record of th monitoring conducted in accordance with §60.5416(b) (Condition 2.11.11 (§60.5420(c)(9)). 2.11.14.6 A log of records as specified in §60.5413(e)(4)of this Subpart for all inspection,repair and maintenance activities for each control device failing the visible emissions test (§60.5420(c)(14)). 2.12 40 CFR Part 60 Subpart A NSPS This engine is subject to the requirements in 40 CFR Part 60 Subpart A"General Provisions",as specified in 40 CFR Part 60 Subpart JJJJ §60.4246 and 40 CFR Part 60 Subpart OOOO §60.5425. These requirements include, but are not limited to the following: 2.12.1 Notification and recordkeeping(§60.7) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFt Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 45 2.12.2 Performance tests (§60.8) 2.12.3 Compliance with standards and maintenance requirements (§60.11) 2.12.4 Circumvention (§60.12) 2.12.5 General notification and reporting requirements (§60.19) 2.13 40 CFR Part 63 Subpart ZZZZ MACT This engine is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of Regulation No. 8,Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart ZZZZ. Note that as of the date of revised permit issuance XX/XX/XXXX, the requirements in 40 CFR Part 63 Subpart ZZZZ promulgated on March 3, 2010 and later have not been adopted into Colorado Regulation No. 8, Part E by the Division and are therefore not state-enforceable. In the event that the Division adopts these requirements, they will become both state and federally enforceable. General Requirements: 2.13.1 You must be in compliance with the emission limitations in Condition 2.13.3, operating limitations in Condition 2.13.4, and other requirements in this subpart that apply to you at all times. (§63.6605(a)). 2.13.2 At all times you must operate and maintain any affected source,including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (§63.6605(b)). Emission Limitations: 2.13.3 Owners or operators of a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions shall: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 46 2.13.3.1 Reduce CO emissions by 93 percent or more (§63.6600(b), Table 2a, Item 2.a.), or 2.13.3.2 Limit concentration of formaldehyde in the stationary RICE exhaust to 14 ppmvd or less at 15 percent O2(§63.6600(b), Table 2a, Item 2.b.). Operating Limitations: 2.13.4 Owners or operators of a new or reconstructed 4SLB stationary RICE with a site rating of more than 500 brake HP located at major source of HAP emissions shall: 2.13.4.1 Maintain your catalyst so that the pressure drop across the catalyst does not change by more than 2 inches of water at 100 percent load plus or minus 10 percent from the pressure drop across the catalyst that was measured during the initial performance test (§63.6600(b), Table 2b, Iteml.a.); and 2.13.4.2 Maintain the temperature of your stationary RICE exhaust so that the catalyst inlet temperature is greater than or equal to 450°F and less than or equal to 1350°F (§63.6600(b), Table 2b, Iteml.b.). Subsequent Performance Test Requirements: 2.13.5 Subsequent performance tests shall be conducted semi-annually(§63.6615, Table 3, Item 1). 2.13.6 After compliance has been demonstrated for two consecutive tests,the frequency of semi-annual tests may be reduced to annually. If the results of any subsequent annual performance test indicates the stationary RICE is not in compliance with the CO emission limitations, or you deviate from any of your operating limitations, you must resume semi-annual performance tests (§63.6615, Table 3, Footnote 1). Performance Tests and Other Procedures 2.13.7 Each performance test must be conducted according to the requirements that this subpart specifies in Table 4 to this subpart. The test must be conducted at any load condition within plus or minus 10 percent of 100 percent load (§63.6620(b)). Monitoring, Installation, Collection, Operation and Maintenance Requirements: 2.13.8 You must install, maintain and operate a continuous parametric monitoring system (CPMS) to continuously monitor catalyst inlet temperature according to the requirements of§63.6625(b)(1) through (6) of this subpart(§63.6625(b), Table 5, Item 1). 2.13.9 If you operate a new,reconstructed,or existing stationary engine,you must minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Condition 2.13.3 to this subpart apply(§63.6625(h)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 47 Monitoring and Collecting Data for Continuous Compliance: 2.13.10 Data must be monitored and collected in accordance with the following (§63.6635(a)): 2.13.10.1 Except for monitor malfunctions, associated repairs, required performance evaluations, and required quality assurance or control activities, you must monitor continuously at all times that the stationary RICE is operating. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. (§63.6635(b)). 2.13.10.2 You may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities in data averages and calculations used to report emission or operating levels. You must however, use all the valid data collected during all other periods (§63.6635(c)). Demonstrating Continuous Compliance with the Emission and Operating Limitations: 2.13.11 You must demonstrate continuous compliance with each emission and operating limitation in Conditions 2.13.3 and 2.13.4 as follows: 2.13.11.1 Conducting subsequent performance tests as specified in Condition 2.13.5 and demonstrating the required CO reduction in Condition 2.13.3.1 (§63.6640(a), Table 6, Item 1.i.). 2.13.11.2 Conducting semiannual performance tests for formaldehyde as specified in Condition 2.13.5 to demonstrate that your emissions remain at or below the formaldehyde concentration limit in Condition 2.13.3.2 (§63.6640(a), Table 6, Item 7.i.) 2.13.11.3 Collecting the catalyst inlet temperature data according to §63.6625(b) (Condition 2.13.8); (§63.6640(a), Table 6, Item 1.a.ii. or 7.a.ii.) and 2.13.11.4 Reducing these data to 4-hour rolling averages; ((§63.6640(a),Table 6, Item 1.a.iii.or 7.a.iii.) and 2.13.11.5 Maintaining the 4-hour rolling averages within the operating limitations for the catalyst inlet temperature (Condition 2.13.4.2); (§63.6640(a), Table 6, Item 1.a.iv. or 7.a.iv.) and 2.13.11.6 Measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop across the catalyst is within the operating limitation established during the performance test(§63.6640(a), Table 6, Item 1.v. and Item 7.v.). 2.13.1 1.7 After you have demonstrated compliance for two consecutive tests, you may reduce the frequency of subsequent performance tests to annually. If the results of any subsequent annual performance test indicate the stationary RICE is not in compliance with the CO or formaldehyde emission limitation, or you deviate from any of your operating limitations, you must resume semiannual performance tests (§63.6640(a), Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 48 Table 6, Footnote a). 2.13.12 You must report each instance in which you did not meet each emission limitation or operating limitation in Conditions 2.13.3 and 2.13.4. These instances are deviations from the emission and operating limitations in Conditions 2.13.3 and 2.13.4. These deviations must be reported according to the requirements in Conditions 2.13.18 through 2.13.22.If you change your catalyst, you must reestablish the values of the operating parameters measured during the initial performance test. When you reestablish the values of your operating parameters, you must also conduct a performance test to demonstrate that you are meeting the required emission limitation applicable to your stationary RICE (§63.6640(b)). 2.13.13 For new, reconstructed, and rebuilt stationary RICE, deviations from the emission (Condition 2.13.3) or operating limitations (Condition 2.13.4) that occur during the first 200 hours of operation from engine startup(engine burn-in period)are not violations. Rebuilt stationary RICE means a stationary RICE that has been rebuilt as that term is defined in 40 CFR § 94.11(a) (§63.6640(d)). 2.13.14 You must also report each instance in which you did not meet the requirements in Condition 2.14 of this permit(§63.6640(e)). What Notifications to Submit and When: 2.13.15 You must submit all of the notifications in §63.7(b) and (c), 63.8(e), (0(4) and (0(6), 63.9(b) through(e), and(g) and (h)that apply to you by the dates specified. (§63.6645(a)). 2.13.16 If you are required to conduct a performance test, you must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin as required in § 63.7(b)(1) (Condition 2.14.3) (§63.6645(g)). 2.13.17 If you are required to conduct a performance test as specified in Condition 2.13.5, you must submit the Notification of Compliance Status according to §63.6645(h)(1) and (h)(2) of this subpart(§63.6645(h)). What Reports to Submit and When: 2.13.18 You must submit each report in Table 7 of this subpart that applies to you (§63.6650(a)). 2.13.19 Unless the Division has approved a different schedule for submission of reports under §63.10(a) (Condition 2.14.6), you must submit Compliance Reports in accordance with the requirements of§63.6650(b)(1)through (b)(9) of this subpart(§63.6650(b)). 2.13.20 The Compliance Reports must include the information in §63.6650(c)(1) through (c)(6) of this subpart(§63.6650(c)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 49 2.13.21 For each deviation from any emission or operating limitation that occurs for a stationary RICE where you are using a CPMS to comply with the emission and operating limitations in this subpart you must include information in §63.6650(c)(1) through (4) and (e)(1) through (12) of this subpart (§63.6650(e)). 2.13.22 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or 71 must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A)or 40 CFR 71.6(a)(3)(iii)(A). If an affected source submits a Compliance report pursuant to Condition 2.13.18 along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the Compliance report includes all required information concerning deviations from any emission or operating limitation in this subpart, submission of the Compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a Compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permit authority §63.6650(f)). What Records to Keep: 2.13.23 A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv) (Condition 2.14.6) (§63.6655(a)(1)). 2.13.24 Records of the occurrence and duration of each malfunction of operation(i.e.,process equipment) or the air pollution control and monitoring equipment. (§63.6655(a)(2)). 2.13.25 Records of performance tests and performance evaluations as required in §63.10(b)(2)(viii) (Condition 2.14.6) (§63.6655(a)(3)). 2.13.26 Records of all required maintenance performed on the air pollution control and monitoring equipment. (§63.6655(a)(4)). 2.13.27 Records of actions taken during periods of malfunction to minimize emissions in accordance with Condition 2.13.2, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation (§63.6655(a)(5)). 2.13.28 For each CPMS you must keep the following records (§63.6655(b)): 2.13.28.1 Records described in §63.10(b)(2)(vi) through (xi) (Condition 2.14.6) (§63.6655(b)(1)). 2.13.28.2 Previous (i.e., superseded) versions of the performance evaluation plan as required in §63.8(d)(3) (Condition 2.14.4) (§63.6655(b)(2)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 50 2.13.28.3 Requests for alternatives to the relative accuracy test for CPMS as required in §63.8(f)(6)(i) (Condition 2.14.4), if applicable (§63.6655(b)(3)). 2.13.29 You must keep the records required in Condition 2.13.11 to show continuous compliance with! each emission or operating limitation that applies to you (§63.6655(d)). Form and Length of Recordkeeping: 2.13.30 Your records must be in a form suitable and readily available for expeditious review according to §63.10(b)(1)(Condition 2.14.6) (§63.6660(a)). 2.13.31 As specified in §63.10(b)(1)(Condition 2.14.6),you must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (§63.6660(b)). 2.13.32 You must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence,measurement,maintenance,corrective action,report,or record, according to §63.10(b)(1) (Condition 2.14.6 (§63.6660(c)). 2.14 40 CFR Part 63 Subpart A MACT This engine is subject to the requirements in 40 CFR part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart ZZZZ §63.6665. These requirements include, but are not limited to the following: 2.14.1 Prohibited activities and circumvention (§63.4) 2.14.2 Operation and maintenance requirements (§63.6(e)(1)) 2.14.3 Performance testing requirements (§63.7) 2.14.4 Monitoring requirements (§63.8) 2.14.5 Notification requirements (§63.9) 2.14.6 Recordkeeping and reporting requirements (§63.10) May Operating Permit Number: 95OPWE103 FIRST ISSUED: 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 51 3. D2—Forum Triethylene Glycol Dehydration Unit, AIRS ID: 068 This TEG Dehydration Unit D-2 will be removed upon commencement of operation of TEG Dehydration Unit D-3 (Condition 4) Permit Monitoring Parameter Condition Compliance Limits Compliance Emission Factor Number Method Interval Emission&Throughput Limits D-2:25.0 tons/year D-2:GLYCaIc 4.0 or higher VOC 3.1 Pilot:0.001 tons/year Pilot: 5.5 lb/MMscf Assist: 1.9 tons/year Assist:Calculation Process D-2:0.4 tons/year Simulation and D-2&Assist:0.068 lb/MMBtu NOx Pilot:0.02 tons/year Twelve Month Monthly Pilot: 100 lb/MMscf Rolling Total Assist: 1.0 tons/year 3.2 Calculation D-2:2.0 tons/year D-2&Assist:0.31 lb/MMBtu CO Pilot:0.02 tons/year Pilot: 84 lb/MMscf Assist:4.4 tons/year Total:40,150 MMscf/year VRU Downtime:Not to exceed 5%of total actual dry gas processed COMB-1 Downtime:Not to Meter and Twelve Dry Gas Throughput 3.3 exceed 1%of total actual dry Month Rolling Monthly gas processed Total Calculation Combustion Gas Limitations Pilot Gas: 0.44 MMscf/year Assist Gas:28.03 MMscf/year Lean Glycol Meter and Circulation Rate 3 4 20 gpm Recordkeeping Daily Other Requirements Extended Gas ASTM Methods Analysis 3'5 or Equivalent Annually Parametric Monitoring 3.6 Recordkeeping Weekly Hours of Operation 3.7 Recordkeeping Daily Not to exceed 30%for a period or periods Opacity 3.8 aggregating more than six See Condition 3.8 (6)minutes in any sixty(60) consecutive minutes Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 52 Control Device Requirements 3.9 See Condition 3.9 Alternative Operating Scenario(AOS) 3.10 See Condition 3.10 Compliance Assurance 3.11 See Condition 3.11 Monitoring(CAM) Statewide Controls for 3.12 Oil and Gas See Condition 3.12 Operations 40 CFR 63 Subpart 3.13 RE!MACT See Condition 3.13 40 CFR 63 Subpart A General Provisions 3.14 See Condition 3.14 MACT 3.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds(VOC)for this dehydration unit shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 00WE0470, as modified under the provisions of Section I, Condition 1.3, and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on 11/20/2018). Compliance with the emission limitations shall be monitored as follows: 3.1.1 Dehydration Unit VOC Emissions: Monthly determination of VOC emissions from the dehydration unit flash gas and still vent shall be conducted by the end of the subsequent month utilizing the Gas Research Institute's GLYCaIc (Version 4.0 or higher). 3,1.1.1 The following parameters shall be input to the process model: a. The inlet wet gas composition obtained from the most recent extended gas analysis, as required by Condition 3.5.1. b. The average daily dry gas processed, as required by Condition 3.3.1.1. c. The average monthly value of the lean glycol circulation rate, as required by Condition 3.4, the inlet wet gas temperature and pressure and the flash tank operating temperature and pressure, as required by Condition 3.6. 3.1.1.2 Control Efficiencies a. A control efficiency (CE) of 95% shall apply to the enclosed combustion device (COMB-1) when it is operational and emissions from the dehydration unit are routed to it, provided the requirements of Conditions 3.9.2, 3.12.1.1 and 3.12.2.1 are met. 3.1.1.3 Operating Hours Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 53 a. Hours of vapor recovery unit(VRU)downtime,as required by Condition 3.7.3, shall be input to the equation below, along with the corresponding control efficiency (CE) of 95% for COMB-1, to determine actual emissions of VOC during periods of VRU downtime, in which the flash tank emissions are routed to COMB-l. b. Total hours of operation for this dehydration unit, as required by Condition 3.7.1, and hours of COMB-1 downtime, as required by Condition 3.7.4 shall be input to the equation below, along with the corresponding control efficiency (CE) of 95% for COMB-1, to determine actual emissions of VOC during periods of COMB-1 operation, in which still vent emissions are routed to COMB-1. c. Hours of COMB-1 downtime,as required by Condition 3.7.4, shall be input to the equation below, to determine actual still vent emissions of VOC during periods of COMB-1 downtime, in which still vent emissions are routed to atmosphere. 3.1.1.4 Monthly emissions of VOC from the dehydration unit flash gas and still vent shall be calculated using the following equations: lb hrs ( _CE(%)1 tons ll FGvoc/HAP (hr)x DTVRu (month)x 1 100 ) Flash Gas Emissions (monthl (2000 lb) Unit Converstion ( ton ) lb hrs l tons l SVVOC/HAP (hr)x DTCOMB-1 (month) Still Vent Emissions (monthl 2000 lbm + Unit Converstion ( ton ) lb hrs hrs l _CE(%)1 SVVOC/HAP (hr)X [O (month)— DTcoMs-i(month)) x(1 100 f Unit Converstion (2000 lb) ton Where: FGvoc/HAP= Uncontrolled Flash Gas Emissions of VOC or HAP,lb/hr SVvoc/HAP= Uncontrolled Still Vent Emissions of VOC or HAP,lb/hr �HTEG =Total Dehydration Unit Operating Hours,hrs/month DTvRu =VRU Downtime,hrs/month DTCOMB-i =COMB—1 Downtime,hrs/month CE= Control Efficiency of COMB—1,95% Total monthly VOC emissions shall be the sum total of emissions contributed by the dehydration unit flash gas and still vent. The total monthly VOC emissions obtained from this calculation Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 54 shall be used in a twelve month rolling total to monitor compliance with the annual limitations.' Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon,, request. 3.1.2 Pilot Gas VOC Emissions: Monthly determination of VOC emissions from the combustion of pilot gas shall be conducted by the end of the subsequent month using the emission factor listed, in Summary Table 3 above (from EPA's AP-42: Compilation of Emission Factors, Section 1.4 for Natural Gas Combustion, Final Section, dated 7/98) and the monthly pilot gas flowrate, as required by Condition 3.3.2.1, in the equation below: ( lb / (MMscf) tons l = EF MMscf x FRpL1ot `month) Pilot Gas Emissions (month` 2000 lb ) Unit Conversion ( ton Where: EF=Emission Factor,lb/MMscf FRpito= =Pilot Gas Flowrate,scf/month The monthly VOC emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.1.3 Assist Gas VOC Emissions: Monthly determination of VOC emissions from the combustion of assist gas shall be conducted by the end of the subsequent month using the monthly assist ga4 flowrate, as required by Condition 3.3.2.2, the molecular weight and VOC content of the assist gas obtained from the most recent extended gas analysis, as required by Condition 3.5.2, and a control efficiency of 95%for COMB-1, provided the requirements of Conditions 3.9.2, 3.12.1.1, and 3.12.2.1 are met, in the equation below: ( scf 1 ( lb ( CE(%)1 tons l FRAssist month) x MWAssist llbmol�x xasstsr x 1— 100 ) Assist Gas Emissions (month` 2000 lb (379.5 scf) Unit Conversion ton )x Unit Conversion Ibmol Where: FRAssfst =Assist Gas Flowrate,scf/month MWAssist=Assist Gas Molecular Weight,lb/Ibmol xAssist =Assist Gas VOC or HAP content,mass fraction CE= Control Efficiency of COMB—1,95% Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 55 The monthly VOC emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.1.4 Emissions of Hazardous Air Pollutants(HAP)from the condensate storage tanks,produced water storage tanks and dehydration unit combined shall not exceed the facility-wide limitations listed in Summary Table 9 below. Monthly emissions of HAP shall be calculated by the end of the subsequent month using the same method as required for VOC emissions. Monthly HAP emissions shall be used in a twelve month total to monitor compliance with the facility-wide HAP emission limitation, as required by Condition 9.1. 3.2 NOx & CO Emission Limitations & Compliance Monitoring Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) generated by the destruction of emissions from this dehydration unit shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 00WE0470, as modified under the provisions of Section I, Condition 1.3, and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested emissions identified on the APEN submitted on 11/20/2018). Compliance with the emission limitations shall be monitored as follows: 3.2.1 Dehydration Unit NOx & CO Emissions: The NOx and CO emissions generated by dehydration unit flash gas and still vent combustion shall be calculated by the end of the subsequent month using the emission factors listed in Summary Table 3 above(from EPA's AP- 42: Compilation of Emission Factors, Section 13.5 for Industrial Flares, Final Section, dated 2/18), the hourly flash gas flowrate, the hourly still vent flowrate, the flash gas heat content and still vent heat content obtained from the most recent monthly process model run, as required by Condition 3.1.1,the total monthly hours of dehydration unit operation, as required by Condition 3.7.1, the total monthly hours of VRU downtime, as required by Condition 3.7.3, and the total monthly hours of COMB-1 downtime, as required by Condition 3.7.4, as inputs to the equation below. tons NOx or CO Emissions month FG MMscf) c x HC M( Btu x EF (( lb 1x DT hrs ( hr FMMscMf) IMMBtuI VRU month) Unit Conversion (2000 1b) ton MMscf MMBtu ( lb 1 hrs l hrs llll SV . hr )x HCsv (MMscf)x EF IMMBtu�X[DNrsc(month)— DT COMB-1 (monthlJ + 2000 lb Unit Conversion ton Where: FG = Uncontrolled Flash Gas Flowrate,MMscf/hr SV= Uncontrolled Still Vent Flowrate,MMscf/hr Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 56 HCFG =Heat Content of Flash Gas Emissions,MMBtu/MMscf HCsv =Heat Content of Still Vent Emissions,MMBtu/MMscf EF=Emission Factor,lb/MMBtu OHTEG =Total Dehydration Unit Operating Hours,hrs/month DTVRU = VRU Downtime,hrs/month DTcoMe-i =COMB—1 Downtime,hrs/month The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve;, month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.2.2 Pilot Gas NOx&CO Emissions: The NOx and CO emissions generated by pilot gas combustion; shall be calculated by the end of the subsequent month using the emission factor listed in Summary Table 3 above (from EPA's AP-42: Compilation of Emission Factors, Section 1.4 for Natural Gas Combustion, Final Section, dated 7/98) and the monthly pilot gas flowrate, as required by Condition 3.3.2.1, in the equation below: lb 1l MMscfl tons l_ EF �MMscf1 x FR lb �month1 (NOx or CO Emissions \month (2000 lb\ Unit Conversion l ton ) Where: EF=Emission Factor,lb/MMscf FRF[tot=Pilot Gas Flowrate,MMscf/month The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.2.3 Assist Gas NOx & CO Emissions: The NOx and CO emissions generated by assist gas combustion shall be calculated by the end of the subsequent month using the emission factor listed in Summary Table 3 above(from EPA's AP-42: Compilation of Emission Factors, Section 13.5 for Industrial Flares, Final Section, Table 13.5-2, dated 2/18), the monthly assist gas flowrate, as required by Condition 3.3.2.2, and the heat content of the assist gas obtained from the most recent extended gas analysis, as required by Condition 3.5.2 in the equation below: ( lb scf Btu tons = EF IMMBtu) x FRASSist (month)x HCASstst (scf) Assist Gas Emissions (month) (2000 lb 106 Btu Unit Conversion ton )x Unit Conversion (MMBtu) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAF'lI Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 57 Where: EF=Emission Factor,lb/MMBtu FRAssist =Assist Gas Flowrate,scf/month HCAssist =Assist Gas Heat Content,Btu/scf The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.3 Gas Throughput Limitations & Compliance Monitoring 3.3.1 Dehydration Unit Dry Gas Processing Limitations 3.3.1.1 Total Dry Gas Processed: The total amount of dry gas processed by this dehydration unit shall not exceed the limitations listed in Summary Table 3 above (Colorado Construction Permit 00WE0470, as modified under the provisions of Section I, Condition 1.3, and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7 based on requested limitations identified on the APEN submitted on 11/20/2018). The dry gas processed by this dehydration unit shall be monitored and recorded monthly using the flowmeter located at the unit outlet. The monthly dry gas throughput shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. An average daily dry gas processed rate shall be used as an input to the monthly process model run, as required by Condition 3.1.1. This average daily gas processed rate shall be calculated by dividing the total monthly dry gas processed by the total unit hours of operation, as required by Condition 3.7.1, as follows: Total Monthly Dry Gas Processed MMscf x Unit Conversion (24 hrs MMscf _ (month) day ) Average Daily Dry Gas Processed day hrs Total Hours of Operation (month) 3.3.1.2 Dry Gas Processed during VRU Downtime: The total amount of dry gas processed by this dehydration unit during periods of VRU downtime shall not exceed 5%of the total dry gas processed by this dehydration unit on a rolling twelve month basis (as provided for under the provisions of Section I,Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). VRU downtime is defined as periods when the dehydration unit is operating and flash tank emissions are routed to enclosed combustion device COMB-1.The dry gas processed by this dehydration unit during periods of VRU downtime shall be determined monthly as the total amount of Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP! Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 58', dry gas processed by this dehydration unit, as indicated by the outlet flowmeterl (Condition 3.3.1.1), during periods for which flash tank emissions were routed to COMB-1,as indicated by the hours of VRU downtime(Condition 3.7.3).The monthly, dry gas processed during VRU downtime shall be used in a twelve month rolling total, to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 3.3.1.3 Dry Gas Processed during COMB-1 Downtime: The total amount of dry gas, processed by this dehydration unit during periods of COMB-1 downtime shall not exceed 1% of the total dry gas processed by this dehydration unit on a rolling twelve, month basis (as provided for under the provisions of Section I, Condition 1.3 and', Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). COMB-, 1 downtime is defined as periods when the dehydration unit is operating and still vent emissions are routed to atmosphere. The dry gas processed by this dehydration unit during periods of COMB-1 downtime shall be determined monthly as the total amount of dry gas processed by this dehydration unit, as indicated by the outlet flowmeter,� (Condition 3.3.1.1), during periods for which still vent emissions were routed td atmosphere, as indicated by the hours of COMB-1 downtime (Condition 3.7.4). The, monthly dry gas processed during COMB-1 downtime shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data.Records, of calculations shall be maintained and made available to the Division upon request. 3.3.2 Combustion Device Gas Throughput Limitations 3.3.2.1 Pilot Gas Throughput: The amount of pilot gas throughput to enclosed combustion device COMB-1 shall not exceed the limitations listed in Summary Table 3 above(as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). The pilot gas throughput td enclosed combustion device COMB-1 shall be assumed to have a constant value of 50 sefh. Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by enclosed combustion device COMB-1 monthly hours of operation; as required by Condition 3.7.2. Records of the monthly pilot gas throughput calculation and the manufacturer specification for the hourly pilot gas throughput shall be maintained and made available to the Division upon request. The monthly pilot gas throughput shall be used to monitor compliance the VOC, NOx and CO emission limitations, as required by Conditions 3.1.2 and 3.2.2. 3.3.2.2 Assist Gas Throughput: The amount of assist gas throughput to enclosed combustion device COMB-1 shall not exceed the limitations listed in Summary Table 3 above (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). A flowmeter shall be located on the assist gas line routed to enclosed combustion device COMB-1 upon installation of such an assist gas line. The assist gas throughput to enclosed combustion device Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 59 COMB-1 shall be monitored and recorded monthly using the flowmeter located on the assist gas line routed to COMB-1. Records of the monthly assist gas throughput shall be maintained and made available to the Division upon request. The monthly assist gas throughput shall be used to monitor compliance the VOC, NOx and CO emission limitations, as required by Conditions 3.1.3 and 3.2.3. 3.4 Lean Glycol Circulation Rate Limitations & Compliance Monitoring The circulation rate of lean glycol for this dehydration unit shall not exceed the limitation listed in Summary Table 3 above (Colorado Construction Permit 00WE0470, as modified under the provisions of Section I,Condition 1.3,and Colorado Regulation No.3,Part C,Section I.A.7 and Part C,Section III.B.7). The lean glycol flowrate shall be recorded daily using the existing glycol flowmeter.The recorded flowrate shall be the sum of the flowrate from each pump and all other glycol injection points (if applicable). For any period during which the lean glycol circulation rate cannot be obtained from the glycol flowmeter, the maximum permitted lean glycol circulation rate listed in Summary Table 3 above shall be used. Records of the daily lean glycol circulation rate shall be maintained and made available to the Division upon request. A monthly average of the lean glycol circulation rate shall be calculated from the daily recorded values from that month for this dehydration unit. This monthly average shall be used as an input to the monthly process model run, as required by Condition 3.1.1. 3.5 Extended Gas Analysis 3.5.1 An extended gas analysis of the inlet wet gas to this dehydration unit shall be performed annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division. At least eight (8) months shall separate sequential sampling events. The extended analysis shall identify the VOC and HAP constituents of the wet gas, including any BTEX components. Results of the wet gas analysis shall be maintained and made available to the Division upon request. The composition indicated by the most recent extended wet gas analysis shall be used as an input to the monthly process model run, as required by Condition 3.1.1. 3.5.2 An extended gas analysis of the assist gas shall be performed annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division(as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). At least eight(8) months shall separate sequential sampling events. The extended analysis shall identify the heat content and VOC and HAP constituents of the assist gas, including any BTEX components. Results of the extended gas analysis shall be maintained and made available to the Division upon request. The composition and heat content indicated by the most recent extended gas analysis shall be used to monitor compliance with the assist gas VOC, NOx and CO emission limitations, as required by Conditions 3.1.3 and 3.2.3. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 60'i 3.6 Parametric Monitoring The following operating parameters for this dehydration unit shall be monitored and recorded at the intervals specified in the table below. Values of the parameters recorded shall be representative of the, unit's operation for the duration of the monitoring period. Records of the values recorded shall be', maintained and made available to the Division upon request. Parameter Monitoring Frequency Inlet Wet Gas Temperature Weekly Inlet Wet Gas Pressure Weekly Flash Tank Operating Temperature Weekly Flash Tank Operating Pressure Weekly Monthly averages of each parameter shall be obtained by averaging the operating values recorded for that] month. These monthly averages shall be used as inputs to the monthly process model run, as required byl Condition 3.1.1. 3.7 Hours of Operation 3.7.1 Total Hours of Operation: Hours of operation for this dehydration unit shall be monitored and recorded daily in a log to be made available to the Division upon request. Monthly hours of operation shall be used to monitor compliance with the VOC,NOx and CO emission limitations, as required by Conditions 3.1.1 and 3.2.1, and to determine the average daily dry gas processed, as required by Condition 3.3.1.1. 3.7.2 COMB-1 Hours of Operation: Hours of operation of enclosed combustion device COMB-1 shall be monitored and recorded daily in a log to be made available to the Division upon request, (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. Part C, Section I.A.7 and Part C, Section III.B.7). Hours of operation shall be determined using the COMB-1 run status indication. Hours of COMB-1 operation shall be used to monitor compliance with the pilot gas throughput limitations, as required by Condition 3.3.2.1. 3.7.3 VRU Downtime: Hours of downtime during which the VRU was not operating and emissions from the dehydration unit flash tank were routed to COMB-1 shall be monitored and recorded daily in a log to be made available to the Division upon request (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7). Hours of downtime shall be determined using the VRU run status indication. Hours of VRU downtime shall be used to monitor compliance with the VOC, NOx and CO emission limitations, as required by Conditions 3.1.1 and 3.2.1, and to monitor compliance with the dry gas processed during VRU downtime limitation, as required by Condition 3.3.1.2. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAF Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 61 3.7.4 COMB-1 Downtime: Hours of downtime during which COMB-1 was not operating and emissions from the dehydration unit still vent were routed to atmosphere shall be monitored and recorded daily in a log to be made available to the Division upon request(as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7).Hours of downtime shall be determined using the difference between the D-2 run status, as required by Condtion 3.7.1, and COMB-1 run status, as required by Condition 3.7.2. Hours of COMB-1 downtime shall be used to monitor compliance with the VOC, NOx and CO emission limitations, as required by Conditions 3.1.1 and 3.2.1, and to monitor compliance with the dry gas processed during COMB-1 downtime limitation,as required by Condition 3.3.1.3. 3.8 Opacity The following opacity requirements apply to enclosed combustion device COMB-1: 3.8.1 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed, provided the requirements of Conditions 3.9.2 and 10.5.4 are met. 3.9 Control Device Requirements 3.9.1 The following requirements apply to the Vapor Recovery Unit(VRU): 3.9.1.1 The owner or operator shall complete a daily visual inspection of the air pollution control equipment to ensure that the valves for the piping from the dehydration unit flash tank vent to the VRU are open, except during periods of permitted downtime. The results of this daily visual inspection shall be maintained and made available to the Division upon request. 3.9.2 The following requirements apply to enclosed combustion device COMB-1: 3.9.2.1 The owner or operator shall complete a daily visual inspection of the air pollution control equipment to ensure that the valves for the piping from the dehydration unit still vent (and, if the VRU is experiencing downtime, the flash tank vent) to the enclosed combustion device COMB-1 are open, except during periods of permitted downtime. The results of this daily visual inspection shall be maintained and made available to the Division upon request. 3.9.2.2 The enclosed combustion device COMB-1 shall be operated with a pilot light present at all times, except during periods of permitted downtime. A thermocouple or equivalent heat sensing device shall continuously monitor the presence of the pilot light. If a flame is not detected, an alarm will indicate the absence of the pilot light. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP! Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 62, Records of pilot light outage events, the duration of such events and an estimation of emissions shall be maintained and made available to the Division upon request. a. In the event the pilot light presence cannot be verified by the thermocouple or equivalent heat sensing device, visual inspection of the pilot light shall be' completed daily to verify pilot light presence. A daily log with the results from the visual inspection shall be maintained and made available to the Division upon request. 3.9.2.3 Visible Emissions Observations a. A six (6) minute visual observation of enclosed combustion device COMB-1, shall be performed daily to monitor for the presence of smoke. The results of the daily visual observation shall be maintained in a log and made available to the Division upon request. b. In the event smoke is observed during the six (6) minute observation periods required by Condition a above,an EPA Reference Method 22 observation shall! be conducted to monitor compliance with the no visible emission requirements set forth in Condition 10.5.4 by determining if visible emissions are present for a period of at least one (1) minute in any fifteen (15) minute period of normal operation. The results of any Method 22 observations performed shall bel maintained in a log and made available to the Division upon request. c. In the event visible emissions are observed pursuant to an EPA Reference Method 22 test required by Condition b above, an EPA Reference Method 9 opacity observation shall be performed to monitor compliance with the opacity limitations set forth in Condition 3.8.The results of any Method 9 observations performed shall be maintained in a log and made available to the Division upon request. (i) The EPA Reference Method 9 opacity observations shall be performed by an observer with a current and valid Method 9 certification. A clear; and readable copy of the observer's certificate and any opacit}), observations shall be kept on file and made available to the Division for review upon request. (ii) Subject to the provisions of§25-7-123.1, C.R.S., and in the absence of credible evidence to the contrary, exceedance of the opacity limit (Condition 3.8) shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 3.10 Alternative Operating Scenario (AOS) The electric glycol circulation pumps may be replaced with another electric glycol circulation pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 63 revision to this permit or obtaining a new construction permit, provided the following requirements are met: 3.10.1 A replacement pump shall operate at the same or lower glycol recirculation rate as required by Condition 3.4. 3.10.2 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. This log shall be made available to the Division upon request. 3.11 Compliance Assurance Monitoring (CAM) This dehydration unit is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual emission limitations in Condition 3.1 for VOC and Condition 9.1 for HAP. Compliance with the CAM requirements shall be monitored in accordance with the requirements in Condition 12 and the CAM Plan in Appendix G. 3.12 Statewide Controls for Oil and Gas Operations 3.12.1 Colorado Regulation No. 7, Part D, Section I.H. Requirements: This dehydration unit and associated air pollution control equipment are subject to the following "Emission Reductions from Glycol Natural Gas Dehydrators" of Colorado Regulation No. 7, Part D, Section I., "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Part D, Section I. General Requirements 3.12.1.1 This dehydration unit is subject to the General Provisions of Colorado Regulation No. 7, Part D, Section I.C., as required by Conditions 10.2.1 and 10.2.2. Part D, Section I.H. Control Requirements 3.12.1.2 Beginning May 1, 2005, 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,drip station or gas-processing plant in the 8- Hour Ozone Control Area and subject to control requirements pursuant to Section I.H.3. (Condition 3.12.1.3), shall reduce uncontrolled actual emissions of volatile organic compounds by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment(Colorado Regulation No. 7,Part D, Section I.H.1.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 64 [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the requirements VOC reduction requirements of Condition 3.12.1.2' shall be presumed as long as the control device requirements in Conditions 3.9 and 3.12.1.1 are met.] 3.12.1.3 The control requirements of Section I.H.I. (Condition 3.12.1.2)apply where: a. Actual uncontrolled emissions of volatile organic compounds from the glycol natural gas dehydrator are equal to or greater than one ton per year (Colorado1 Regulation No. 7, Part D, Section I.H.3.a.); and b. The sum of actual uncontrolled emissions of volatile organic compounds from any single glycol natural gas dehydrator or grouping of glycol natural gas dehydrators at a single stationary source is equal to or greater than 15 tons per year. To determine if a grouping of dehydrators meets or exceeds the 15 tons per year threshold, sum the total actual uncontrolled emissions of volatile'i organic compounds from all individual dehydrators at the stationary source,) including those with emissions less than one ton per year(Colorado Regulation No. 7, Part D, Section I.H.3.b.). 3.12.1.4 For purposes of Section I.H. (Condition 3.12.1), emissions from still vents and ventsi from any flash separator or flash tank on a glycol natural gas dehydrator shall bed calculated using a method approved in advance by the Division(Colorado Regulation No. 7, Part D, Section I.H.4.). Part D, Section I.H. Monitoring and Recordkeeping Requirements 3.12.1.5 [Additional Monitoring: The owner or operator shall maintain current records of uncontrolled actual emissions on a rolling twelve month basis for this glycol dehydration unit. Such records shall be used to determine whether the contr 4 requirements in Condition 3.12.1.2 apply. Such records shall be maintained and made available for the Division upon request. Dehydration units that are not subject to the control requirements in Conditio4 3.12.1.2 that increase uncontrolled actual emissions from the dehydrator and/or group of dehydrators at the facility above the thresholds listed in Conditions 3.12.1.3a and/or 3.12.1.3b shall comply with the control requirements of Condition 3.12.1.. within 60 days of discovery of the emission increase.] 3.12.1.6 Monitoring and Recordkeeping(Colorado Regulation No. 7, Part D, Section I.H.5.) a. Beginning January 1, 2017, owners or operators of glycol natural gas dehydrators subject to the control requirements of Sections I.H.1. (Condition 3.12.1.2) must check on a weekly basis that any condenser or air pollution control equipment used to control emissions of volatile organic compounds is operating properly (Colorado Regulation No. 7, Part D, Section I.H.5.a.), and document: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1991 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 65 (i) The date of each inspection (Colorado Regulation No. 7, Part D, Section I.H.5.a.(i)); (ii) A description of any problems observed during the inspection of the condenser or air pollution control equipment(Colorado Regulation No. 7, Part D, Section I.H.5.a.(ii)); and (iii) A description and date of any corrective actions taken to address problems observed during the inspection of the condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section I.H.5.a.(iii)). b. The owner or operator must check and document on a weekly basis that the pilot light on a combustion device is lit,that the valves for piping of gas to the pilot light are open, and visually check for the presence or absence of smoke (Colorado Regulation No. 7, Part D, Section I.H.5.b.). c. The owner or operator must document the maintenance of the condenser or air pollution control equipment, consistent with manufacturer specifications or good engineering and maintenance practices (Colorado Regulation No. 7, Part D, Section I.H.5.c.). d. The owner or operator must retain records for a period of five years and make these records available to the Division upon request(Colorado Regulation No. 7, Part D, Section I.H.5.d.). Part D, Section I.H. Reporting Requirements 3.12.1.7 On or before November 30, 2017, and semi-annually by April 30 and November 30 of each year thereafter, the owner or operator must submit the following information for the preceding calendar year (April 30 report) and for May 1 through September 30 (November 30 report) using Division-approved format (Colorado Regulation No. 7, Part D, Section I.H.6.a.). a. A list of the glycol natural gas dehydrator(s) subject to Section I.H. (Colorado Regulation No. 7, Part D, Section I.H.6.a.(i)); b. A list of the condenser or air pollution control equipment used to control emissions of volatile organic compounds from the glycol natural gas dehydrator(s) (Colorado Regulation No. 7, Part D, Section I.H.6.a.(ii)); and c. The date(s) of inspection(s) where the condenser or air pollution control equipment was found not operating properly or where smoke was observed (Colorado Regulation No. 7, Part D, Section I.H.6.a.(iii)). 3.12.2 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.D. Requirements: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station! Permit# 95OPWE103 Page 66' This dehydration unit and associated air pollution control equipment are subject to the following State-Only Enforceable "Emission Reductions from Glycol Natural Gas Dehydrators" of Colorado Regulation No. 7, Part D, Section II, "Statewide Controls for Oil and Gas Operations Conditions shown in italic text below represent monitoring, recordkeeping and recording' provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Part D, Section II. General Requirements 3.12.2.1 This dehydration unit is subject to the General Provisions of Colorado Regulation No. 7, Part D, Section II.B., as required by Conditions 10.5.1 through 10.5.5. Part D, Section II.D. Control Requirements 3.12.2,2 Beginning May 1, 2008, 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.2. (Condition 3.12.2.3), shall reduce uncontrolled actual emissions of volatile organic compounds by at least 90 percent through the use of a condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.D.1.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the requirements VOC reduction requirements of Condition 3.12.2.2 shall be presumed as long as the control device requirements in Conditions 3.9 and 3.12.2.1 are met.] 3.12.2.3 The control requirements in Section II.D.1. (Condition 3.12.2.2)apply where: a. Actual uncontrolled emissions of volatile organic compounds from the glycol natural gas dehydrator are equal to or greater than two tons per year; and (Colorado Regulation No. 7, Part D, Section II.D.2.a.) b. The sum of actual uncontrolled emissions of volatile organic compounds from any single glycol natural gas dehydrator or grouping of glycol natural gas dehydrators at a single stationary source is equal to or greater than 15 tons pe year. To determine if a grouping of dehydrators meets or exceeds the 15 tons per year threshold, sum the total actual uncontrolled'emissions of volatile organic compounds from all individual dehydrators at the stationary source; including those with emissions less than two tons per year (Colorado Regulation No. 7, Part D, Section II.D.2.b.). 3.12.2.4 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. (Condition 3.12.2.5), shall reduce Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 67 uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.D.3.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the hydrocarbon reduction requirements of Condition 3.12.2.4 shall be presumed as long as the control device requirements in Conditions 3.9 and 3.12.2.1 are met.] If a combustion device is used (to meet the requirements of Condition 3.12.2.4), it shall have a design destruction efficiency of at least 98% for hydrocarbons except where: a. The combustion device has been authorized by permit prior to May 1, 2.014 (Colorado Regulation No. 7, Part D, Section II.D.3.a.); and b. A building unit or designated outside activity area (as defined in Section II.D.4.c.) is not located within 1,320 feet of the facility at which the natural gas glycol dehydrator is located (Colorado Regulation No. 7, Part D, Section II.D.3.b.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the design destruction efficiency requirements of Condition 3.12.2.4 shall be presumed as long as the requirements in Conditions 3.12.2.7 and 3.12.2.8 are met.] 3.12.2.5 The control requirements in Section II.D.3. (Condition 3.12.2.4) apply where: a. Uncontrolled actual emissions of VOC from a single glycol natural gas dehydrator constructed before May 1, 2015, are equal to or greater than (Colorado Regulation No. 7, Part D, Section II.D.4.b.): (i) six (6)tons per year, or (ii) two (2) tons per year if the glycol natural gas dehydrator is located within 1,320 feet of a building unit or designated outside activity area (as defined in Section II.D.4.c.). Part D, Section II.D. Recordkeeping Requirements 3.12.2.6 [Additional Monitoring: The owner or operator shall maintain current records of uncontrolled actual emissions on a rolling twelve month basis for each glycol dehydrator. Such records shall be used to determine whether the control requirements in either Conditions 3.12.2.2 or 3.12.2.4 apply. Such records shall be maintained and made available for the Division upon request. Dehydrators that are not subject to the control requirements in Conditions 3.12.2.2 or 3.12.2.4 that increase uncontrolled actual emissions from the dehydrator and/or Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 68! group of dehydrators at the facility above the thresholds listed in Conditions 3.12.2.3; and/or 3.12.2.5 shall comply with the control requirements of Conditions 3.12.2.2 and/or 3.12.2.4 within 60 days of discovery of the emission increase.] 3.12.2.7 [Additional Monitoring: If the owner or operator is claiming an exemption from the control requirements of Condition 3.12.2.4 based on the location of the facility, the owner or operator shall maintain records that document whether the facility is located within 1,320 feet of a residential building unit or designated outside activity area. Such records shall be reviewed annually and updated if necessary, and made available to the Division upon request. Dehydrators that are not subject to the control requirements in Condition 3.12.2.411 that become subject based on additions of or changes to residential building units or designated outside activity areas shall comply with the control requirements of Condition 3.12.2.4 within 60 days of discovery of the changes.] 3.12.2.8 [Compliance Monitoring: The owner or operator shall maintain records that document the design efficiency of the combustion device used to meet the requirements of Condition 3.12.2.4. Such records shall be maintained and made available for Division review.] 3.13 40 CFR Part 63 Subpart HH MACT This dehydration unit is subject to the National Emission Standards for Hazardous Air Pollutants requirements of Colorado Regulation No. 8,Part E, Subpart HI-I(40 CFR Part 63, Subpart HH)"Nationa' Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", including, but not limited to, the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart HH published in the Federal Register on 8/16/2012. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart HH. Affirmative Defense for Violations of Emission Standards during Malfunction 3.13.1 The provisions set forth in this subpart shall apply at all times (§63.762(a)). General Standards 3.13.2 Except as specified in paragraph(e)(1)(Condition 3.13.3)of this section,the owner or operator of an affected source located at an existing or new area source of HAP emissions shall comply with the applicable standards specified in paragraph (d) (Condition 3.13.2.1) of this section (§63.764(d)). 3.13.2.1 Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63.761) shall comply with paragraphs (d)(2)(i) through (iii) (Conditions a through c, below)of this section (§63.764(d)(2)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 69 a. Determine the optimum glycol circulation rate using the following equation (§63.764(d)(2)(i)): ( gal TEG) F x (1— 0) LOPT = 1.15 x 3.0 lb H2O J x 24 hr/day Where: LoPT = Optimal circulation rate,gal/hr F = Gas flowrate (MMSCF/D) I = Inlet water content(lb/MMSCF) 0 = Outlet water content(lb/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG to water ratio (gal TEG/lb H20) 1.15 = Adjustment factor included for a margin of safety b. Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) (Condition a, above) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with paragraph (d)(2)(i) (Condition a, above), the owner or operator must calculate an alternate circulation rate using GRI-GLYCalcTM, Version 3.0 or higher. The owner or operator must document why the TEG dehydration unit must be operated using the alternate circulation rate and submit this documentation with the initial notification in accordance with §63.775(c)(7) of this subpart (§63.764(d)(2)(ii)). c. Maintain a record of the determination specified in paragraph (d)(2)(ii) (Condition b, above) in accordance with the requirements in §63.774(f) (Condition 3.13.8) and submit the Initial Notification in accordance with the requirements in §63.775(c)(7). If operating conditions change and a modification to the optimum glycol circulation rate is required, the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) (Condition a, above) or (ii) (Condition b, above) of this section and submit the information specified under §63.775(c)(7)(ii) through (v) of this subpart(§63.764(d)(2)(iii)). 3.13.3 The owner or operator of an area source is exempt from the requirements of paragraph (d) (Condition 3.13.2) of this section if the criteria listed in paragraph(e)(1)(i) (Condition 3.13.3.1, below) or (ii) (Condition 3.13.3.2, below) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1) (Condition 3.13.7) (§63.764(e)(1)). 3.13.3.1 The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day, as determined by the procedures Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT I I Air Pollution Control Division DCP Operating Company, LP! Colorado Operating Permit Enterprise Compressor Station) Permit#95OPWE103 Page 70 I specified in §63.772(b)(1) (Condition 3.13.5.1) of this subpart(§63.764(e)(1)(i)); or 3.13.3.2 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) (Condition 3.13.5.2) of this subpart; (§63.764(e)(1)(ii)). 3.13.4 At all times the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination o whether such operation and maintenance procedures are being used will be based on informatio h available to the Administrator which may include,but is not limited to,monitoring results,review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.764(j)). Test methods, compliance procedures, and compliance demonstrations 3.13.5 Determination of glycol dehydration unit flowrate, benzene emissions, or BTEX emissions. Th procedures of this paragraph shall be used by an owner or operator to determine glyco dehydration unit natural gas flowrate, benzene emissions, or BTEX emissions (§63.772(b)). 3.13.5.1 The determination of actual flowrate of natural gas to a glycol dehydration unit shal be made using the procedures of paragraph (b)(1)(i) (Condition a, below) of this section (§63.772(b)(1)). a. The owner or operator shall install and operate a monitoring instrument thalt directly measures natural gas flowrate to the glycol dehydration unit with aii accuracy of plus or minus 2 percent or better. The owner or operator shalil convert annual natural gas flowrate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processed natural gas (§63.772(b)(1)(i)). 3.13.5.2 The determination of actual average benzene or BTEX emissions from a gly0 dehydration unit shall be made using the procedures of paragraph(b)(2)(i) (Condition a, below) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place (§63.772(b)(2)). a. The owner or operator shall determine actual average benzene or BTEX( emissions using 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 of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1) (§63.772(b)(2)(i)). Recordkeeping Requirements Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 71 3.13.6 Except as specified in paragraphs (d) (Condition 3.13.7) and (f) (Condition 3.13.8) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) (Condition 3.13.6.1) through (2) (Condition 3.13.6.2) of this section (§63.774(b)): 3.13,6.1 The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information(including all reports and notifications)required by this subpart. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or period. (§63.774(b)(1)). a. All applicable records shall be maintained in such a manner that they can be readily accessed(§63.774(b)(1)(i)). b. The most recent 12 months of records shall be retained on site or shall be accessible from a central location by computer or other means that provides access within 2 hours after a request(§63.774(b)(1)(ii)). c. The remaining 4 years of records may be retained offsite (§63.774(b)(1)(iii)). d. 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)(1)(iv)). 3.13,6.2 Records specified in §63.10(b)(2) (Condition 3.14.4) (§63.774(b)(2)). 3.13.7 An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) (Condition 3.13.3.1) or §63.764(e)(I)(ii) (Condition 3.13.3.2) shall maintain the records specified in paragraph (d)(1)(i) (Condition 3.13.7.1) or paragraph (d)(1)(ii) (Condition 3.13.7.2) of this section, as appropriate, for that glycol dehydration unit (§63.774(d)(1)). 3,13.7.1 The actual annual average natural gas throughput (in terms of natural gas flowrate to the glycol dehydration unit per day) as determined in accordance with §63.772(b)(1) (Condition 3.13.5.1) (§63.774(d)(1)(i)), or 3.13.7.2 The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with§63.772(b)(2)(Condition 3.13.5.2)(§63.774(d)(1)(ii)). 3.13.8 The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in accordance with §63.764(d)(2)(i) (Condition 3.13.2.1a) or §63.764(d)(2)(ii) (Condition 3.13.2.1b), as applicable (§63.774(f)). 3.14 40 CFR Part 63 Subpart A MACT Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station! Permit# 95OPWE103 Page 721 This dehydration unit is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions"„ as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 631 Subpart HH §63.764(a). These requirements include, but are not limited to the following: 3.14.1 Prohibited activities and circumvention (§63.4) 3.14.2 Compliance with standards and maintenance requirements (§63.6(e)(1)) 3.14.3 Notification requirements (§63.9(j)) 3.14.4 Recordkeeping and reporting requirements (§63.10) II Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAPIT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 73 4. D-3—Triethylene Glycol Dehydration Unit,AIRS ID: 077 Permit Compliance Limits Monitoring Parameter Condition Compliance Emission Factor Number Monthly Annual Method Interval Emission&Throughput Limits D-3:3,751 lb/month D-3:22.1 tons/year D-3:GLYCalc 4.0 or higher VOC 4.1 Pilot:0.2 lb/month Pilot:0.001 tons/year Pilot:5.5 lb/MMscf Assist:316 lb/month Assist: 1.9 tons/year Assist:Calculation Process D-3:85 lb/month D-3:0.5 tons/year Simulation, D-3&Assist:0.068 lb/MMBtu Recordkeeping NOx Pilot:4 lb/month Pilot:0.02 tons/year and Twelve Monthly Pilot: 100 lb/MMscf Month Rolling Assist: 165 lb/month Assist: 1.0 ton/year Total 4.2 Calculation D-3:386 lb/month D-3:2.3 tons/year D-3&Assist:0.31 lb/MMBtu CO Pilot:4 lb/month Pilot:0.02 tons/year Pilot:84 lb/MMscf Assist: 753 lb/month Assist:4.4 tons/year Dry Gas Limitations Total:52,925 MMscf/year VRU Downtime:Not to exceed 5%of total Total:4,495 actual dry gas MMscf/month processed COMB-1 Meter and Gas Throughput 4.3 Downtime:Not to Twelve Month Monthly exceed 1%of total Rolling Total actual dry gas Calculation processed Combustion Gas Limitations Pilot Gas:0.04 Pilot Gas:0.44 MMscf/month MMscf/year Assist Gas:2.38 Assist Gas:28.03 MMscf/month MMscf/year Lean Glycol Meter and Circulation Rate 4 4 25 gpm Recordkeeping Daily Other Requirements Extended Gas ASTM Analysis 4.5 Methods or Annually Equivalent Parametric 4.6 Monitoring Recordkeeping Weekly Flours of Operation 4.7 Recordkeeping Daily Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP' Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 741 Not to exceed 30%for a period or periods Opacity 4.8 aggregating more than six(6)minutes in See Condition 4.8 any sixty(60)consecutive minutes Control Device 4.9 See Condition 4.9 Requirements Final Approval 4.10 See Condition 4.10 Requirements Alternative Operating Scenario(AOS) 4.11 See Condition 4.11 Compliance Assurance 4.12 See Condition 4.12 Monitoring(CAM) Statewide Controls for Oil and Gas 4.13 See Condition 4.13 Operations 40 CFR 63 Subpart 4.14 See Condition 4.14 111-1 MACT 40 CFR 63 Subpart A General Provisions 4.15 See Condition 4.15 MACT 4.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds (VOC) for this dehydration unit shall not exceed tF e limitations listed in Summary Table 4 above (Colorado Construction Permit 19WE0492). During the first twelve months of operation, compliance with both the monthly and annual limitations are required. After the first twelve months of operation, compliance with only the annual limitation is required. Compliance with the emission limitation shall be monitored as follows: 4.1.1 Dehydration Unit VOC Emissions: Monthly determination of VOC emissions from the dehydration unit flash gas and still vent shall be conducted by the end of the subsequent month utilizing the Gas Research Institute's GLYCaic (Version 4.0 or higher). 4.1.1.1 The following parameters shall be input to the process model: a. The inlet wet gas composition obtained from the most recent extended gas analysis, as required by Condition 4.5.1. b. The average daily dry gas processed, as required by Condition 4.3.1.1. c. The average monthly value of the lean glycol circulation rate, as required by Condition 4.4, and the inlet wet gas temperature and pressure, the flash tank operating temperature and pressure, as required by Condition 4.6. 4.1.1.2 Control Efficiencies Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 75 a. A control efficiency (CE) of 95% shall apply to the enclosed combustion device (COMB-1) when it is operational and emissions from the dehydration unit are routed to it, provided the requirements of Conditions 4.9.2, 4.13.1.1 and 4.13.2.1 are met. 4.1.1.3 Operating Hours a. Hours of vapor recovery unit(VRU)downtime,as required by Condition 4.7.3, shall be input to the equation below, along with the corresponding control efficiency (CE) of 95% for COMB-1, to determine actual emissions of VOC during periods of VRU downtime, in which the flash tank emissions are routed to COMB-1. b. Total hours of operation for this dehydration unit, as required by Condition 4.7.1, and hours of COMB-1 downtime, as required by Condition 4.7.4, shall be input to the equation below,along with the corresponding control efficiency (CE) of 95% for COMB-1, to determine actual emissions of VOC during periods of COMB-1 operation, in which still vent emissions are routed to COMB-1. c. Hours of COMB-1 downtime, as required by Condition 4.7.4, shall be input to the equation below, to determine actual still vent emissions of VOC during periods of COMB-1 downtime, in which still vent emissions are routed to atmosphere. 4.1.1.4 Monthly emissions of VOC from the dehydration unit flash gas and still vent shall be calculated using the following equations: lb hrs ( _CE(%)) tons l FGVOC/HAP (hr)x DTVRu (month)x 1 100 J Flash Gas Emissions (month/ Unit Conversion (2000 lb) ton lb hrs tons l _ SVVOC/HAP (hr)x DT cam B_1 (month + ) Still Vent Emissions (month/ Unit Converstion (2000 lb) ton lb hrs \ hrs l ( _CE(%)) SVvoc/HAP (h3)x [OHTEG(month)— DTCOMB-1(month)] x 1 100 ) Unit Converstion (2000 lb) ton Where: FGVOC/HAP = Uncontrolled Flash Gas Emissions of VOC or HAP,lb/hr SVvoc/HAP= Uncontrolled Still Vent Emissions of VOC or HAP,lb/hr OHTEG =Total.Dehydration Unit Operating Hours,hrs/month Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP, Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 76 DTvRu=VRU Downtime,hrs/month DTcome-i =COMB—1 Downtime,hrs/month CE=Control Efficiency of COMB—1,95% Total monthly VOC emissions shall be the sum total of emissions contributed by the dehydration unit flash gas and still vent. The total monthly VOC emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations) Each month, a new twelve month total shall be calculated using the previous twelve months( data. Records of calculations shall be maintained and made available to the Division upon request. 4.1.2 Pilot Gas VOC Emissions: Monthly determination of VOC emissions from the combustion of pilot gas shall be conducted by the end of the subsequent month using the emission factor listed in Summary Table 4 above (from EPA's AP-42: Compilation of Emission Factors, Section 1.4 for Natural Gas Combustion, Final Section, dated 7/98) and the monthly pilot gas flowrate, a' required by Condition 4.3.2.1, in the equation below: ( lb 1 (MMscfl tons EF MMscf x FRpilor (month) = Pilot Gas Emissions l month/ Unit Conversion (2000 lb) ton 1 Where: EF=Emission Factor,lb/MMscf FRpuot=Pilot Gas Flowrate,scf/month The monthly VOC emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.1.3 Assist Gas VOC Emissions: Monthly determination of VOC emissions from the combustion of assist gas shall be conducted by the end of the subsequent month using the monthly assist gas flowrate, as required by Condition 4.3.2.2, the molecular weight and VOC content of the assist gas obtained from the most recent extended gas analysis, as required by Condition 4.5.2, and a control efficiency of 95% for COMB-1, provided the requirements of Conditions 4.9.2, 4.13.1'.1 and 4.13.2.1 are met, in the equation below: scf ( lb l CE(%) tons FRAssist (month) x MWASsist.k.lbmol)x XAssist X(1— 100 ) Assist Gas Emissions (month) 2000 Ib (379.5 scf) Unit Conversion ton )x Unit Conversion Ibmol Where: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 77 FRAssist =Assist Gas Flowrate,scf/month MWAssist =Assist Gas Molecular Weight,lb/lbmol XAssist =Assist Gas VOC or HAP content,mass fraction CE=Control Efficiency of COMB-1,95% The monthly VOC emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.1.4 Emissions of Hazardous Air Pollutants(HAP)from the condensate storage tanks,produced water storage tanks and dehydration unit combined shall not exceed the facility-wide limitations listed in Summary Table 9 below. Monthly emissions of HAP shall be calculated by the end of the subsequent month using the same method as required for VOC emissions. Monthly HAP emissions shall be used in a twelve month total to monitor compliance with the facility-wide HAP emission limitation, as required by Condition 9.2. 4.2 NOx & CO Emission Limitations & Compliance Monitoring Emissions of Nitrogen Oxides (NOx) and Carbon Monoxide (CO) generated by the destruction of emissions from this dehydration unit shall be determined monthly and used to monitor compliance with the limitations listed in Summary Table 4 above (Colorado Construction Permit 19WE0492). During the first twelve months of operation, compliance with both the monthly and annual limitations are required. After the first twelve months of operation, compliance with only the annual limitation is required. 4.2.1 Dehydration Unit NOx & CO Emissions: The NOx and CO emissions generated by dehydration unit flash gas and still vent combustion shall be calculated by the end of the subsequent month using the emission factors listed in Summary Table 4 above(from EPA's AP- 42: Compilation of Emission Factors, Section 13.5 for Industrial Flares, Final Section, Table 13.5-2,dated 2/18),the hourly flash gas flowrate,the hourly still vent flowrate,the flash gas heat content and still vent heat content obtained from the most recent monthly process model run, as required by Condition 4.1.1, the total monthly hours of dehydration unit operation, as required by Condition 4.7.1, the total monthly hours of VRU downtime, as required by Condition 4.7.3, and the total monthly hours of COMB-1 downtime, as required by Condition 4.7.4, as inputs to the equation below: tons NOx or CO Emissions month FG (MMscf)x HCFc (MMBtuI x EF ( lb )x DTvRu( hrs 1 hr MMscf JJ MM month)Unit Conversion (2000 lb) ton I r SV (MMscfl x HC (MMBtuI x EF lb )X[OH ( hrs 1_ DT ( hrs 11 hr ) S MMscf J MMBtu TEG month) COMB-1 month)) 2000 lb Unit Conversion . ton Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station' Permit# 95OPWE103 Page 78' Where: FG= Uncontrolled Flash Gas Flowrate,MMscf/hr SV=Uncontrolled Still Vent Flowrate,MMscf/hr HCFG =Heat Content of Flash Gas Emissions,MMBtu/MMscf HCsv=Heat Content o f Still Vent Emissions,MMBtu/MMscf EF=Emission Factor,lb/MMBtu OHTEG =Total Dehydration Unit Operating Hours,hrs/month DTvRu=VRU Downtime,hrs/month DTCOMB_1 =COMB—1 Downtime,hrs/month The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. .4.2.2 Pilot Gas NOx&CO Emissions: The NOx and CO emissions generated by pilot gas combustion shall be calculated by the end of the subsequent month using the emission factor listed in Summary Table 4 above (from EPA's AP-42: Compilation of Emission Factors, Section 1.4 for Natural Gas Combustion, Final Section, dated 7/98) and the monthly pilot gas flowrate, as required by Condition 4.3.2.1, in the equation below: ( lb 1 (MMscf) tons = EF MMscf)x FRpi1ot `month NOx and CO Emissions month 2000 lb) Unit Conversion ton Where: EF=Emission Factor,lb/MMscf FRFaot =Pilot Gas Flowrate,MMscf/month The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.2.3 Assist Gas NOx & CO Emissions: The NOx and CO emissions generated by assist gas combustion shall be calculated by the end of the subsequent month using the emission factor listed in Summary Table 4 above(from EPA's AP-42: Compilation of Emission Factors, Section 13.5 for Industrial Flares, Final Section, Table 13.5-2, dated 2/18), the monthly assist gas flowrate, as required by Condition 4.3.2.2, and the heat content of the assist gas obtained from the most recent extended gas analysis, as required by Condition 4.5.2 in the equation below: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENE WED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 79 ( Ib l scf Btu tons _ EF\MMBtu� x FRAssise ,month)x HCAsstst (scf) Assist Gas Emissions (month) (106 Btu) 2000 lb Unit Conversion (2000 )x Unit Conversion MMBtu Where: EF=Emission Factor,lb/MMBtu FRAssisr=Assist Gas Flowrate,scf/month HCAssist=Assist Gas Heat Content,Btu/scf The monthly NOx and CO emissions obtained from this calculation shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.3 Gas Throughput Limitations & Compliance Monitoring 4.3.1 Dehydration Unit Dry Gas Processing Limitations 4.3.1.1 Total Dry Gas Processed: The total amount of dry gas processed by this dehydration 'unit shall not exceed the limitations listed in Summary Table 4 above (Colorado Construction Permit 19WE0492). During the first twelve months of operation, compliance with both the monthly and annual limitations are required. After the first twelve months of operation, compliance with only the annual limitation is required. The dry gas processed by this dehydration unit shall be monitored and recorded each month using the flowmeter located at the unit outlet. The monthly dry gas processed shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. An average daily dry gas processed rate shall be used as an input to the monthly process model run, as required by Condition 4.1.1. This average daily gas processed rate shall be calculated by dividing the total monthly dry gas processed by the total unit hours of operation, as required by Condition 4.7.1, as follows: Total Monthly Dry Gas Processed MMscf x Unit Conversion 24 hrs MMscf = (month) ( day Average Daily Dry Gas Processed day hrs Total Hours of Operation (month) 4.3.1.2 Dry Gas Processed during VRU Downtime: The total amount of dry gas processed by this dehydration unit during periods of VRU downtime shall not exceed 5%of the total dry gas processed by this dehydration unit on a rolling twelve month basis (Colorado Construction Permit 19WE0492). VRU downtime is defined as periods Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 80 when the dehydration unit is operating and flash tank emissions are routed to enclosed combustion device COMB-1. The dry gas processed by this dehydration unit during periods of VRU downtime shall be determined monthly as the total amount of dry gas processed by this dehydration unit, as indicated by the outlet flowmeter (Condition 4.3.1.1), during periods for which flash tank emissions were routed to COMB-1, as indicated by the hours of VRU downtime (Condition 4.7.3). The monthly dry gas processed during VRU downtime shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.3.1.3 Dry Gas Processed during COMB-1 Downtime: The total amount of dry gas processed by this dehydration unit during periods of COMB-1 downtime shall not exceed 1% of the total dry gas processed by this dehydration unit on a rolling twelve month basis (Colorado Construction Permit 19WE0492). COMB-1 downtime is defined as periods when the dehydration unit is operating and still vent emissions are routed to atmosphere. The dry gas processed by this dehydration unit during periods of COMB-1 downtime shall be determined monthly as the total amount of dry gas processed by this dehydration unit, as indicated by the outlet flowmeter (Condition 4.3.1.1), during periods for which still vent emissions were routed to atmosphere, as indicated by the hours of COMB-1 downtime (Condition 4.7.4). The monthly dry gas processed during COMB-1 downtime shall be used in a twelve month rolling total to monitor compliance with the annual limitations.Each month,a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 4.3.2 Combustion Device Gas Throughput Limitations 4.3.2.1 Pilot Gas Throughput: The amount of pilot gas throughput to enclosed combustion device COMB-1 shall not exceed the limitations listed in Summary Table 4 above. During the first twelve months of operation, compliance with both the monthly and annual limitations are required.After the first twelve months of operation,compliance with only the annual limitation is required. The pilot gas throughput to enclosed combustion device COMB-1 shall be assumed to have a constant value of 50 scfh. Monthly pilot gas throughput shall be determined by multiplying this hourly pilot gas throughput by enclosed combustion device COMB-1 monthly hours of operation, as required by Condition 4.7.2. Records of the monthly pilot gas throughput calculation and the manufacturer specification for the hourly pilot gas throughput shall be maintained and made available to the Division upon request. The monthly pilot gas throughput shall be used to monitor compliance the VOC, NOx and CO emission limitations, as required by Conditions 4.1.2 and 4.2.2. 4.3.2.2 Assist Gas Throughput: The amount of assist gas throughput to enclosed combustion device COMB-1 shall not exceed the limitations listed in Summary Table 4 above. During the first twelve months of operation, compliance with both the monthly and Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 81 annual limitations are required.After the first twelve months of operation,compliance with only the annual limitation is required. A flowmeter shall be located on the assist gas line routed to enclosed combustion device COMB-1 upon installation of such an assist gas line.The assist gas throughput to enclosed combustion device COMB-1 shall be monitored and recorded monthly using the flowmeter located on the assist gas line routed to COMB-1. Records of the monthly assist gas throughput shall be maintained and made available to the Division upon request. The monthly assist gas throughput shall be used to monitor compliance the VOC, NOx and CO emission limitations, as required by Conditions 4.1.3 and 4.2.3. 4.4 Lean Glycol Circulation Rate Limitations & Compliance Monitoring The circulation rate of lean glycol for this dehydration unit shall not exceed the limitation listed in Summary Table 4 above (Colorado Construction Permit 19WE0492). The lean glycol flowrate shall be recorded daily using a glycol flowmeter. The recorded flowrate shall be the sum of the flowrate from each pump and all other glycol injection points (if applicable). For any period during which the lean glycol circulation rate cannot be obtained from the glycol flowmeter, the maximum permitted lean glycol circulation rate listed in Summary Table 4 above shall be used. Records of the daily lean glycol circulation rate shall be maintained and made available to the Division upon request. A monthly average of the lean glycol circulation rate shall be calculated from the daily recorded values from that month for this dehydration unit. This monthly average shall be used as an input to the monthly process model run, as required by Condition 4.1.1. 4.5 Extended Gas Analysis 4.5.1 An extended gas analysis of the inlet wet gas to this dehydration unit shall be performed annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division (Colorado Construction Permit 19WE0492). At least eight (8) months shall separate sequential sampling events. The extended analysis shall identify the VOC and HAP constituents of the wet gas, including any BTEX components. Results of the wet gas analysis shall be maintained and made available to the Division upon request. The composition indicated by the most recent extended wet gas analysis shall be used as an input to the monthly process model run, as required by Condition 4.1.1. 4.5.2 An extended gas analysis of the assist gas shall be performed annually according to appropriate ASTM methods, or equivalent, if approved in advance by the Division (Colorado Construction Permit I9WE0492). At least eight (8) months shall separate sequential sampling events. The extended analysis shall identify the heat content and VOC and HAP constituents of the assist gas, including any BTEX components. Results of the extended gas analysis shall be maintained and made available to the Division upon request. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 82 The composition and heat content indicated by the most recent extended gas analysis shall be used to monitor compliance with the assist gas VOC, NOx and CO emission limitations, as required by Conditions 4.1.3 and 4.2.3. 4.6 Parametric Monitoring The following operating parameters for this dehydration unit shall be monitored and recorded at the intervals specified in the table below. Values of the parameters recorded shall be representative of the unit's operation for the duration of the monitoring period. Records of the values recorded shall be maintained and made available to the Division upon request. Parameter Monitoring Frequency Inlet Wet Gas Temperature Weekly Inlet Wet Gas Pressure Weekly Flash Tank Operating Temperature Weekly Flash Tank Operating Pressure Weekly Monthly averages of each parameter shall be obtained by averaging the operating values recorded for that month. These monthly averages shall be used as inputs to the monthly process model run, as required by Condition 4.1.1. 4.7 Hours of Operation 4.7.1 Total Hours of Operation: Hours of operation for this dehydration unit shall be monitored and recorded daily in a log to be made available to the Division upon request. Monthly hours of operation shall be used to monitor compliance with the dehydration unit VOC, NOx and CO emission limitations, as required by Conditions 4.1.1 and 4.2.1, and to determine the average daily dry gas processed, as required by Condition 4.3.1.1. 4.7.2 COMB-1 Hours of Operation: Hours of operation of enclosed combustion device COMB-1 shall be monitored and recorded daily in a log to be made available to the Division upon request. Hours of operation shall be determined using the COMB-1 run status indication. Hours of COMB-1 operation shall be used to monitor compliance with the pilot gas throughput limitations, as required by Conditions 4.3.2.1. 4.7.3 VRU Downtime: Hours of downtime during which the VRU was not operating and emissions from the dehydration unit flash tank were routed to COMB-1 shall be monitored and recorded daily in a log to be made available to the Division upon request (Colorado Construction Permit 19WE0492). Hours of downtime shall be determined using the VRU run status indication. Hours of VRU downtime shall be used to monitor compliance with the VOC, NOx and CO emission limitations, as required by Conditions 4.1.1 and 4.2.1, and to monitor compliance with the dry gas processed during VRU downtime limitation, as required by Condition 4.3.1.2. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 83 4.7.4 COMB-1 Downtime: Hours of downtime during which COMB-1 was not operating and emissions from the dehydration unit still vent were routed to atmosphere shall be monitored and recorded daily in a log to be made available to the Division upon request(Colorado Construction Permit 19WE0492). Hours of downtime shall be determined using the difference between the D- 3 run status, as required by Condition 4.7.1, and COMB-I run status, as required by Condition 4.7.2. Hours of COMB-1 downtime shall be used to monitor compliance with the VOC, NOx and CO emission limitations, as required by Conditions 4.1.1 and 4.2.1, and to monitor compliance with the dry gas processed during COMB-1 downtime limitation, as required by Condition 4.3.1.3. 4.8 Opacity The following opacity requirements apply to enclosed combustion device COMB-1: 4.8.1 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed, provided the requirements of Conditions 4.9.2 and 10.5.4 are met. 4.9 Control Device Requirements 4.9.1 The following requirements apply to the Vapor Recovery Unit(VRU): 4.9.1.1 The owner or operator shall complete a daily visual inspection of the air pollution control equipment to ensure that the valves for the piping from the dehydration unit flash tank vent to the VRU are open, except during periods of permitted downtime. The results of this daily visual inspection shall be maintained and made available to the Division upon request. 4.9.2 The following requirements apply to enclosed combustion device COMB-1: 4.9.2.1 The owner or operator shall complete a daily visual inspection of the air pollution control equipment to ensure that the valves for the piping from the dehydration unit still vent (and, if the VRU is experiencing downtime, the flash tank vent) to the enclosed combustion device COMB-I are open, except during periods of permitted downtime. The results of this daily visual inspection shall be maintained and made available to the Division upon request. 4.9.2.2 The enclosed combustion device COMB-I shall be operated with a pilot light present at all times, except during periods of permitted downtime. A thermocouple or equivalent heat sensing device shall continuously monitor the presence of the pilot light. If a flame is not detected, an alarm will indicate the absence of the pilot light. Records of pilot light outage events, the duration of such events and an estimation of Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 84 emissions shall be maintained and made available to the Division upon request. a. In the event the pilot light presence cannot be verified by the thermocouple or equivalent heat sensing device, visual inspection of the pilot light shall be completed daily to verify pilot light presence. A daily log with the results from the visual inspection shall be maintained and made available to the Division upon request. 4.9.2.3 Visible Emissions Observations a. A six (6) minute visual observation of enclosed combustion device COMB-1 shall be performed daily to monitor for the presence of smoke. The results of the daily visual observation shall be maintained in a log and made available to the Division upon request. b. In the event smoke is observed during the six (6) minute observation period required by Condition a above,an EPA Reference Method 22 observation shall be conducted to monitor compliance with the no visible emission requirement set forth in Condition 10.5.4 by determining if visible emissions are present for a period of at least one (1) minute in any fifteen (15) minute period of normal operation. The results of any Method 22 observations performed shall be maintained in a log and made available to the Division upon request. c. In the event visible emissions are observed pursuant to an EPA Reference Method 22 test required by Condition b above, an EPA Reference Method 9 opacity observation shall be performed to monitor compliance with the opacity limitations set forth in Condition 4.8.The results of any Method 9 observations performed shall be maintained in a log and made available to the Division upon request. (i) The EPA Reference Method 9 opacity observations shall be performed by an observer with a current and valid Method 9 certification. A clear and readable copy of the observer's certificate and any opacity observations shall be kept on file and made available to the Division for review upon request. (ii) Subject to the provisions of§25-7-123.1, C.R.S., and in the absence of credible evidence to the contrary, exceedance of the opacity limit (Condition 4.8) shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 4.10 Final Approval Requirements 4.10.1 [State-Only Enforceable] The permit number and ten digit AIRS ID assigned by the Division shall be marked on this dehydration unit for ease of identification(Colorado Construction Permit 19WE0492). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 85 4.10.2 The Division shall be notified no later than fifteen days of the commencement of operation, by submitting a Notice of Startup form for the dehydration unit covered by this Condition 4. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage- permit. (Colorado Construction Permit 19WE0492). 4.10.3 The following information shall be provided to the Division within fifteen (15) days of commencement of operation (Colorado Construction Permit 19WE0492): 4.10.3.1 The manufacturer name, model number and serial number of the dehydration unit 4.10.3.2 The manufacturer name and model number of the glycol circulation pumps This information shall be included with the Notice of Startup (Condition 4.10.1) submitted for this dehydration unit. 4.10.4 The operator shall complete the following initial compliance testing and sampling (Colorado Construction Permit 19WE0492): 4.10.4.1 The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22,40 C.F.R. Part 60,Appendix A,to determine the presence or absence of visible emissions within one hundred and eighty days (180) of commencement of operation of this dehydration unit. 4.10.4.2 The owner or operator shall complete the initial extended gas analysis of the inlet wet gas within one hundred and eighty days (180) of commencement of operation of this dehydration unit. 4.10.4.3 The owner or operator shall complete the initial extended gas analysis of the fuel gas used for assist gas within one hundred and eighty days (180) of commencement of operation of this dehydration unit. Results of all initial testing required by this condition shall be submitted with the first semi- annual report due after the initial testing was conducted. 4.10.5 This Condition 4 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 Colorado Construction Permit 19WE0492 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 (Colorado Regulation Number 3, Part B, Section III.F.4.). 4.11 Alternative Operating Scenario (AOS) The electric glycol circulation pumps may be replaced with another electric glycol circulation pump in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 86 revision to this permit or obtaining a new construction permit, provided the following requirements are met: 4.11.1 A replacement pump shall operate at the same or lower glycol recirculation rate as required by Condition 4.4. 4.11.2 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. This log shall be made available to the Division upon request. 4.12 Compliance Assurance Monitoring (CAM) This dehydration unit is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the annual emission limitations in Condition 4.1 for VOC and Condition 9.2 for HAP. Compliance with the CAM requirements shall be monitored in accordance with the requirements in Condition 12 and the CAM Plan in Appendix G. 4.13 Statewide Controls for Oil and Gas Operations 4.13.1 Colorado Regulation No. 7, Part D, Section I.H. Requirements: This dehydration unit and associated air pollution control equipment is subject to the following "Emission Reductions from Glycol Natural Gas Dehydrators" of Colorado Regulation No. 7, Part D, Section I., "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Part D, Section 1. General Requirements 4.13.1.1 This dehydration unit is subject to the General Provisions of Colorado Regulation No. 7, Part D, Section I.C., as required by Conditions 10.2.1 and 10.2.2. Part D, Section I.H. Control Requirements 4.13.1.2 Beginning May 1, 2005, 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, drip station or gas-processing plant in the 8 Hour Ozone Control Area and subject to control requirements pursuant to Section I.H.3. (Condition 4.13.1.3), shall reduce uncontrolled actual emissions of volatile; organic compounds by at least 90 percent on a rolling twelve-month basis through tha use of a condenser or air pollution control equipment(Colorado Regulation No. 7,Part D, Section I.H.1.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 87 [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the requirements VOC reduction requirements of Condition 4.13.1.2 shall be presumed as long as the control device requirements in Conditions 4.9 and 4.13.1.1 are met.] 4.13.1.3 The control requirements of Sections I.H.1. (Condition 4.13.1.2)apply where: a. Actual uncontrolled emissions of volatile organic compounds from the glycol natural gas dehydrator are equal to or greater than one ton per year (Colorado Regulation No. 7, Part D, Section I.H.3.a.); and b. The sum of actual uncontrolled emissions of volatile organic compounds from any single glycol natural gas dehydrator or grouping of glycol natural gas dehydrators at a single stationary source is equal to or greater than 15 tons per year. To determine if a grouping of dehydrators meets or exceeds the 15 tons per year threshold, sum the total actual uncontrolled emissions of volatile organic compounds from all individual dehydrators at the stationary source, including those with emissions less than one ton per year(Colorado Regulation No. 7, Part D, Section I.H.3.b.). 4.13.1.4 For purposes of Section I.H. (Condition 4.13.1), emissions from still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator shall be calculated using a method approved in advance by the Division (Colorado Regulation No. 7, Part D, Section I.H.4.). Part D, Section I.H. Monitoring and Recordkeeping Requirements 4.13.1.5 [Additional Monitoring: The owner or operator shall maintain current records of uncontrolled actual emissions on a rolling twelve month basis for this glycol dehydration unit. Such records shall be used to determine whether the control requirements in Condition 4.13.1.2 apply. Such records shall be maintained and made available for the Division upon request. Dehydration units that are not subject to the control requirements in Condition 4.13.1.2 that increase uncontrolled actual emissions from the dehydrator and/or group of dehydrators at the facility above the thresholds listed in Conditions 4.13.1.3a and/or 4.13.1.3b shall comply with the control requirements of Condition 4.13.1.2 within 60 days of discovery of the emission increase.] 4.13.1.6 Monitoring and Recordkeeping(Colorado Regulation No. 7, Part D, Section I.H.5.) a. Beginning January 1, 2017, owners or operators of glycol natural gas dehydrators subject to the control requirements of Sections I.H.1. (Condition 4.13.1.2) must check on a weekly basis that any condenser or air pollution control equipment used to control emissions of volatile organic compounds is operating properly (Colorado Regulation No. 7, Part D, Section I.H.5.a.), and document: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 88 (i) The date of each inspection (Colorado Regulation No. 7, Part D, Section I.H.5.a.(i)); (ii) A description of any problems observed during the inspection of the condenser or air pollution control equipment(Colorado Regulation No. 7, Part D, Section I.H.5.a.(ii)); and (iii) A description and date of any corrective actions taken to address problems observed during the inspection of the condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section I.H.5.a.(iii)). b. The owner or operator must check and document on a weekly basis that the pilot light on a combustion device is lit,that the valves for piping of gas to the pilot light are open, and visually check for the presence or absence of smoke (Colorado Regulation No. 7, Part D, Section I.H.5.b.). c. The owner or operator must document the maintenance of the condenser or air pollution control equipment, consistent with manufacturer specifications or good engineering and maintenance practices (Colorado Regulation No. 7, Part D, Section I.H.5.c.). d. The owner or operator must retain records for a period of five years and make these records available to the Division upon request(Colorado Regulation No. 7, Part D, Section I.H.5.d.). Part D, Section I.H. Reporting Requirements 4.13.1.7 On or before November 30,2017,and semi-annually by April 30 and November 30 of each year thereafter,the owner or operator must submit the following information for the preceding calendar year (April 30 report) and for May 1 through September 30 (November 30 report) using Division-approved format (Colorado Regulation No. 7, Part D, Section I.H.6.a.). a. A list of the glycol natural gas dehydrator(s) subject to Section I.H. (Colorado Regulation No. 7, Part D, Section I.H.6.a.(i)); b. A list of the condenser or air pollution control equipment used to control emissions of volatile organic compounds from the glycol natural gas dehydrator(s) (Colorado Regulation No. 7, Part D, Section I.H.6.a.(ii)); and c. The date(s) of inspection(s) where the condenser or air pollution control equipment was found not operating properly, or where smoke was observed (Colorado Regulation No. 7, Part D, Section I.H.6.a.(iii)). 4.13.2 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.D. Requirements: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 89 This dehydration unit and associated air pollution control equipment are subject to the following State-Only Enforceable "Emission Reductions from Glycol Natural Gas Dehydrators" of Colorado Regulation No. 7,Part D, Section II, "Statewide Controls for Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Part D, Section II. General Requirements 4.13.2.1 This dehydration unit is subject to the General Provisions of Colorado Regulation No. 7, Part D, Section II.B., as required by Conditions 10.5.1 through 10.5.5. Part D, Section II.D. Control Requirements 4.13.2.2 Beginning May 1, 2008, 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.2. (Condition 4.13.2.3), shall reduce uncontrolled actual emissions of volatile organic compounds by at least 90 percent through the use of a condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.D.1.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the requirements VOC reduction requirements of Condition 4.13.2.2 shall be presumed as long as the control device requirements in Conditions 4.9 and 4.13.2.1 are met.] 4.13.2.3 The control requirements in Section II.D.1. (Condition 4.13.2.2) apply where: a. Actual uncontrolled emissions of volatile organic compounds from the glycol natural gas dehydrator are equal to or greater than two tons per year; and (Colorado Regulation No. 7, Part D, Section II.D.2.a.) b. The sum of actual uncontrolled emissions of volatile organic compounds from any single glycol natural gas dehydrator or grouping of glycol natural gas dehydrators at a single stationary source is equal to or greater than 15 tons per year. To determine if a grouping of dehydrators meets or exceeds the 15 tons per year threshold, sum the total actual uncontrolled emissions of volatile organic compounds from all individual dehydrators at the stationary source, including those with emissions less than two tons per year (Colorado Regulation No. 7, Part D, Section II.D.2.b.). 4.13.2.4 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. (Condition 4.13.2.5), shall reduce Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 90 uncontrolled actual emissions of hydrocarbons by at least 95 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.D.3.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the hydrocarbon reduction requirements of Condition 4.13.2.4 shall be presumed as long as the control device requirements in Conditions 4.9 and 4.13.2.1 are met.] If a combustion device is used (to meet the requirements of Condition 4.13.2.4), it shall have a design destruction efficiency of at least 98% for hydrocarbons except where: a. The combustion device has been authorized by permit prior to May 1, 2014 (Colorado Regulation No. 7, Part D, Section II.D.3.a.); and b. A building unit or designated outside activity area (as defined in Section II.D.4.c.) is not located within 1,320 feet of the facility at which the natural gas glycol dehydrator is located (Colorado Regulation No. 7, Part D, Section II.D.3.b.). [Compliance Monitoring: In absence of credible evidence to the contrary, compliance with the design destruction efficiency requirements of Condition 4.13.2.4 shall be presumed as long as the requirements in Conditions 4.13.2.7 and 4.13.2.8 are met.] 4.13.2.5 The control requirements in Section II.D.3. (Condition 4.13.2.4) apply where: a. Uncontrolled actual emissions of VOCs from a glycol natural gas dehydrator constructed on or after May 1, 2015, are equal to or greater than two (2) tons per year. Such glycol natural gas dehydrators must be in compliance with Section II.D.3. (Condition 4.13.2.4) by the date that the glycol natural gas dehydrator commences operation (Colorado Regulation No. 7, Part D, Section II.D.4.a.). Part D, Section II.D. Recordkeeping Requirements 4.13.2.6 [Additional Monitoring: The owner or operator shall maintain current records of uncontrolled actual emissions on a rolling twelve month basis for each glycol dehydrator. Such records shall be used to determine whether the control requirements in either Conditions 4.13.2.2 or 4.13.2.4 apply. Such records shall be maintained and made available for the Division upon request. Dehydrators that are not subject to the control requirements in Conditions 4.13.2.2 or 4.13.2.4 that increase uncontrolled actual emissions from the dehydrator and/or group of dehydrators at the facility above the thresholds listed in Conditions 4.13.2.3 and/or 4.13.2.5 shall comply with the control requirements of Conditions 4.13.2.2 Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 91 and/or 4.13.2.4 within 60 days of discovery of the emission increase.] 4.13.2.7 [Additional Monitoring: If the owner or operator is claiming an exemption from the control requirements of Condition 4.13.2.4 based on the location of the facility, the owner or operator shall maintain records that document whether the facility is located within 1,320 feet of a residential building unit or designated outside activity area. Such records shall be reviewed annually and updated if necessary, and made available to the Division upon request. Dehydrators that are not subject to the control requirements in Condition 4.13.2.4 that become subject based on additions of or changes to residential building units or designated outside activity areas shall comply with the control requirements of Condition 4.13.2.4 within 60 days of discovery of the changes.] 4.13.2.8 [Compliance Monitoring: The owner or operator shall maintain records that document the design efficiency of the combustion device used to meet the requirements of Condition 4.13.2.4. Such records shall be maintained and made available for Division review.] 4.14 40 CFR Part 63 Subpart HH MACT This dehydration unit is subject to the National Emission Standards for Hazardous Air Pollutants requirements of Colorado Regulation No. 8, Part E, Subpart HH (40 CFR Part 63, Subpart HH)"National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities", including, but not limited to,the following: The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart HH published in the Federal Register on 8/16/2012. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63 Subpart HH. Applicability and Designation of Affected Source 4.14.1 The owner or operator of an affected area source that is not located in an Urban-1 county, as defined in §63.761, the construction or reconstruction of which commences on or after July 8, 2005, shall achieve compliance with the provisions of this subpart immediately upon initial startup or January 3, 2007, whichever date is later(§63.760(f)(6)). Affirmative Defense for Violations of Emission Standards during Malfunction 4.14.2 The provisions set forth in this subpart shall apply at all times (§63.762(a)). General Standards 4.14.3 Except as specified in paragraph(e)(1)(Condition 4.14.4)of this section,the owner or operator of an affected source located at an existing or new area source of HAP emissions shall comply Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 92 with the applicable standards specified in paragraph (d) (Condition 4.14.3.1) of this section (§63.764(d)). 4.14.3.1 Each owner or operator of an area source not located in a UA plus offset and UC boundary (as defined in §63.761) shall comply with paragraphs (d)(2)(i) through (iii) (Conditions a through c, below) of this section (§63.764(d)(2)). a. Determine the optimum glycol circulation rate using the following equation (§63.764(d)(2)(i)): ( gal TEG) F x (I— 0) LoPr = 1.15 x 3.0 lb H2O x 24 hr/day Where: LOPT = Optimal circulation rate,gal/hr F = Gas flowrate (MMSCF/D) I =Inlet water content(lb/MMSCF) 0 = Outlet water content (lb/MMSCF) 3.0 = The industry accepted rule of thumb for a TEG to water ratio (gal TEG/lb H20) 1.15 = Adjustment factor included for a margin of safety b. Operate the TEG dehydration unit such that the actual glycol circulation rate does not exceed the optimum glycol circulation rate determined in accordance with paragraph (d)(2)(i) (Condition a, above) of this section. If the TEG dehydration unit is unable to meet the sales gas specification for moisture content using the glycol circulation rate determined in accordance with! paragraph (d)(2)(i) (Condition a, above),the owner or operator must calculate; an alternate circulation rate using GRI-GLYCa1cTM, Version 3.0 or higher.', The owner or operator must document why the TEG dehydration unit must be, operated using the alternate circulation rate and submit this documentations, with the initial notification in accordance with §63.775(c)(7) (Condition) 4.14.10.2) of this subpart (§63.764(d)(2)(ii)). c. Maintain a record of the determination specified in paragraph (d)(2)(ii)', (Condition b, above) in accordance with the requirements in §63.774(f) (Condition 4.14.9) and submit the Initial Notification in accordance with the; requirements in §63.775(c)(7) (Condition 4.14.10.2). If operating conditions change and a modification to the optimum glycol circulation rate is required,) the owner or operator shall prepare a new determination in accordance with paragraph (d)(2)(i) (Condition a, above) or (ii) (Condition b, above) of this; section and submit the information specified under §63.775(c)(7)(ii) through) (v) (Conditions 4.14.10.2b through 4.14.10.2e) of this subpart] (§63.764(d)(2)(iii)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999] RENEWED: DRAFT; Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 93 4.14.4 The owner or operator of an area source is exempt from the requirements of paragraph (d) (Condition 4.14.3) of this section if the criteria listed in paragraph (e)(1)(i) (Condition 4.14.4.1, below) or (ii) (Condition 4.14.4.2, below) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1) (Condition 4.14.8) (§63.764(e)(1)). 4.14.4.1 The actual annual average flowrate of natural gas to the glycol dehydration unit is less than 85 thousand standard cubic meters per day, as determined by the procedures specified in §63.772(b)(1) (Condition 4.14.6.1) of this subpart (§63.764(e)(1)(i)); or 4,14.4.2 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) (Condition 4.14.6.2) of this subpart (§63.764(e)(1)(ii)). 4.14.5 At all times the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include,but is not limited to,monitoring results,review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (§63.764(j)). Test methods, compliance procedures, and compliance demonstrations 4.14.6 Determination of glycol dehydration unit flowrate, benzene emissions, or BTEX emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate, benzene emissions, or BTEX emissions (§63.772(b)). 4.14.6.1 The determination of actual flowrate of natural gas to a glycol dehydration unit shall be made using the procedures of paragraph (b)(1)(i) (Condition a, below) of this section (§63.772(b)(1)). a. The owner or operator shall install and operate a monitoring instrument that directly measures natural gas flowrate to the glycol dehydration unit with an accuracy of plus or minus 2 percent or better. The owner or operator shall convert annual natural gas flowrate to a daily average by dividing the annual flowrate by the number of days per year the glycol dehydration unit processed natural gas (§63.772(b)(1)(i)). 4.14`6.2 The determination of actual average benzene or BTEX emissions from a glycol dehydration unit shall be made using the procedures of paragraph (b)(2)(i) (Condition a, below) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place (§63.772(b)(2)). a. The owner or operator shall determine actual average benzene or BTEX emissions using the model GRI-GLYCalcTM, Version 3.0 or higher, and the Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 94 procedures presented in the associated GRI-GLYCalcTM Technical Reference] Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1) (§63.772(b)(2)(i)). Recordkeeping Requirements 4.14.7 §63.774(b)Except as specified in paragraphs(d)(Condition 4.14.8)and(1)(Condition 4.14.9) of this section, each owner or operator of a facility subject to this subpart shall maintain the records specified in paragraphs (b)(1) (Condition 4.14.7.1) through (2) (Condition 4.14.7.2) of this section: 4.14.7,1 The owner or operator of an affected source subject to the provisions of this subpart shall maintain files of all information(including all reports and notifications)required by this subpart. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report or period. (§63.774(b)(1)). a. All applicable records shall be maintained in such a manner that they can be readily accessed (§63.774(b)(1)(i)). b. The most recent 12 months of records shall be retained on site or shall be accessible from a central location by computer or other means that provides access within 2 hours after a request(§63.774(b)(1)(ii)). c. The remaining 4 years of records may be retained offsite (§63.774(b)(1)(iii)). d. 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)(1)(iv)). 4.14.7.2 Records specified in §63.10(b)(2) (Condition 4.15.4) (§63.774(b)(2)). 4.14.8 An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i)(Condition 4.14.4.1)or§63.764(e)(1)(ii)(Condition 4.14.4.2)shall maintain the records specified in paragraph (d)(I)(i) (Condition 4.14.8.1) or paragraph (d)(1)(ii) (Condition 4.14.8.2)of this section, as appropriate, for that glycol dehydration unit(§63.774(d)(1)). 4.14.8.1 The actual annual average natural gas throughput (in terms of natural gas flowrate td the glycol dehydration unit per day) as determined in accordance with §63.772(b)(1) (Condition 4.14.6.1) (§63.774(d)(1)(i)), or 4.14.8.2 The actual average benzene emissions (in terms of benzene emissions per year) as, determined in accordance with§63.772(b)(2)(Condition 4.14.6.2)(§63.774(d)(1)(ii)) 4.14.9 The owner or operator of an area source not located within a UA plus offset and UC boundary must keep a record of the calculation used to determine the optimum glycol circulation rate in Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 95 accordance with §63.764(d)(2)(i) (Condition 4.14.3.1a) or §63.764(d)(2)(ii) (Condition 4.14.3.1b), as applicable (§63.774(f)). 4,14.10 Except as provided in paragraph (c)(8) (Condition 4.14.10.3), each owner or operator of an area source subject to this subpart shall submit the information listed in paragraph (c)(1) (Condition 4.14.10.1) of this section. If the source is located within a UA plus offset and UC boundary, the owner or operator shall also submit the information listed in paragraphs(c)(2)through (6)of this section. If the source is not located within any UA plus offset and UC boundaries, the owner or operator shall also submit the information listed within paragraph (c)(7) (Condition 4.14.10.2) (§63.775(c)). 4.14.10.1 The initial notifications required under §63.9(b)(2) (Condition 4.15.3) not later than January 3, 2008. In addition to submitting your initial notification to the addressees specified under §63.9(a) (Condition 4.15.3), you must also submit a copy of the initial notification to the EPA's Office of Air Quality Planning and Standards. Send your notification via email to Oil and Gas Sector@epa.gov or via U.S. mail or other mail delivery service to U.S. EPA, Sector Policies and Programs Division/Fuels and Incineration Group (E143-01), Attn: Oil and Gas Project Leader, Research Triangle Park,NC 27711 (§63.775(c)(1)). 4.14.10.2 The information listed in paragraphs (c)(7)(i) through (v) (Conditions a through e) of this section. This information shall be submitted with the initial notification (§63.775(c)(7)). a. Documentation of the source's location relative to the nearest UA plus offset and UC boundaries. This information shall include the latitude and longitude of the affected source; whether the source is located in an urban cluster with 10,000 people or more; the distance in miles to the nearest urbanized area boundary if the source is not located in an urban cluster with 10,000 people or more; and the name of the nearest urban cluster with 10,000 people or more and nearest urbanized area(§63.775(c)(7)(i)). b. Calculation of the optimum glycol circulation rate determined in accordance with §63.764(d)(2)(i) (Condition 4.14.3.1a) (§63.775(c)(7)(ii)). c. If applicable, documentation of the alternate glycol circulation rate calculated using GRI-GLYCalcTM, Version 3.0 or higher and documentation stating why the TEG dehydration unit must operate using the alternate glycol circulation rate (§63.775(c)(7)(iii)). d. The name of the manufacturer and the model number of the glycol circulation pump(s) in operation (§63.775(c)(7)(iv)). e. Statement by a responsible official, with that official's name, title, and signature,certifying that the facility will always operate the glycol dehydration unit using the optimum circulation rate determined in accordance with Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 96 §63.764(d)(2)(i) (Condition 4.14.3.1a) or §63.764(d)(2)(ii) (Condition 4.14.3.1b), as applicable (§63.775(c)(7)(v)). 4.14.10.3 An owner or operator of a TEG dehydration unit located at an area source that meets the criteria in §63.764(e)(1)(i) (Condition 4.14.4.1) or §63.764(e)(1)(ii) (Condition 4.14.4.2) is exempt from the reporting requirements for area sources in paragraphs (c)(1) through (7) (Conditions 4.14.10.1 and 4.14.10.2) of this section, for that unit (§63.775(c)(8)). 4.15 40 CFR Part 63 Subpart A MACT This dehydration unit is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as adopted by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 Subpart HH §63.764(a). These requirements include, but are not limited to the following: 4.15.1 Prohibited activities and circumvention (§63.4) 4.15.2 Compliance with standards and maintenance requirements (§63.6(e)(1)) 4.15.3 Notification requirements (§63.9(a), (b)(2) & (j)) 4.15.4 Recordkeeping and reporting requirements (§63.10) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 97 5. P016—Stabilized Condensate Atmospheric Truck Loadout Rack,AIRS ID: 066 Permit Compliance Emission Monitoring Parameter Condition Compliance Limits Factor Number Method Interval ' Emission&Throughput Limits VOC 5.1 0.94 tons/year 0.186 lb/bbl Recordkeeping and Twelve Month Condensate Rolling Total Monthly Throughput 5.2 202,848 bbl/year Calculation Other Requirements Extended Liquids ASTM Methods or Once Analysis 5'3 Equivalent Every 5 years Not to exceed 30%for a period or periods Opacity 5.4 aggregating more than six(6)minutes in See Condition 5.4 any sixty(60)consecutive minutes Operational Requirements 5.5 See Condition 5.5 Control Device Requirements 5.6 See Condition 5.6 Reasonably Available Control 5.7 Submerged Fill Recordkeeping "Technology (RACT) Statewide Controls for Oil and Gas 5.8 See Condition 5.8 Operations 5.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds (VOC) from stabilized condensate truck loading operations shall not exceed the limitation listed in Summary Table 5 above (Colorado Construction Permit 19WE0492). Compliance with the emission limitations shall be monitored as follows: 5.1.1 Monthly determination of VOC emissions shall be calculated by the end of the subsequent month using the following methodology: 5.1.1.1 The following parameters shall be input to the equation below: a. The emission factor listed in Summary Table 5 above. b. The monthly condensate throughput to the loadout rack, as required by Condition 5.2. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 98 c. A control efficiency (CE) of 95% shall apply to the enclosed combustion device when it is operational and emissions from the condensate truck loading rack are routed to it, provided the requirements of Condition 5.6 are met. lb gal tons =EF(103 gal)x F(month)x (1—CE(%)) VOC or HAP Emissions(month) (2000 lb Unit Conversion ton Where: EF=Loading Loss Emission Factor,lb/103ga1 F= Condensate Throughput,103 gal/month CE=Enclosed Combustion Device Control Efficiency,95% Monthly VOC emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 5,1.2 Annual emissions of Hazardous Air Pollutants (HAP), for the purposes of APEN reporting and the payment of annual fees, shall be calculated using HAP emissions derived from the same method as required for VOC emissions,except that the following emission factors shall be input to the equation above: HAP Species Emission Factor(lb/bbl) n-Hexane 3.62 x 10.3 Benzene 5.16 x 10-4 Toluene 6.34 x 10-4 Ethylbenzene 1.78 x 10-5 Xj'lene 9.62 x 10-5 5.1.3 A verification analysis of the emission factor listed in Summary Table 5 above shall be performed once every five (5) years to ensure any variation in process conditions does not result in an underestimation of emissions. The initial verification analysis shall be conducted within one (1)j year of permit issuance. At least four (4) years shall separate sequential verification analyses. This emission factor was derived using Equation 1 of AP-42, Chapter 5.2, Transportation and Marketing of Petroleum Liquids (07/2008): S x P sia x M lb i(bbl) L lb 12.46 x (°°R) x 1000 gal gal (x Unit Conversion 42 gal T( ) \ bbl ) Where: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 99 LL =Loading Loss Emission Factor,0.186 lb/bbl S=Saturation Factor for Submerged Loading,0.6 P=True Vapor Pressure of Loaded Liquid,4.65 psia M=Molecular Weight of Vapors,66 lb/lbmol T=Temperature of Bulk Liquid,519.67°R To verify this emission factor, the physical properties indicated by the most recent extended liquids analysis, as required by Condition 5.3, shall be input to the equation above to obtain an emission factor in terms of lb VOC/bbl condensate. If the emission factor obtained from this verification analysis is greater than the emission factor listed in Summary Table 5 above, the owner or operator shall apply for a permit modification within sixty (60) days of the verification analysis. Results of this verification analysis shall be maintained and made available to the Division upon request. 5.2 Condensate Throughput Limitations & Compliance Monitoring The quantity of condensate loaded into trucks shall not exceed the limitation listed in Summary Table 5 above(Colorado Construction Permit 19WE0492). Sales or haul tickets from each loading operation shall be used to monitor the volume of condensate transferred. The monthly condensate throughput shall be the sum of the volume transferred,as indicated on each sales or haul ticket for all loading operations that took place during that month. The monthly condensate throughput shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. The monthly condensate throughput shall be used to monitor compliance with the VOC emission limitation, as required by Condition 5.1. 5.3 Extended Liquids Analysis An extended liquids analysis of the condensate loaded shall be performed once every five (5) years, according to appropriate ASTM methods or equivalent, if approved in advance by the Division.The initial analysis shall be performed within one (1) year of permit issuance. At least four (4) years shall separate sequential sampling events. Results of each analysis shall be maintained and made available to the Division upon request. The physical parameters as indicated by the most recent analysis shall be monitored to ensure the static emission factor set forth in this permit does not require modification, pursuant to Condition 5.1.3. 5.4 Opacity The following opacity requirements apply to the enclosed combustion device: Operating Permit Number: 95OPWEl 03 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 100 5.4.1 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presumed, provided the requirements of Condition 5.6.2 are met. 5.5 Operational Requirements 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 (Colorado Construction Permit 19WE0492). The following loading procedures shall be utilized to minimize the leakage of VOCs to the atmosphere including, but not limited to: 5.5.1 All compartment hatches at the facility(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. 5.5.2 Thief hatch seals shall be inspected annually for integrity and replaced as necessary. Thief hatch covers shall be weighted and properly seated. 5.5.3 Pressure relief devices (PRD) shall be inspected annually for proper operation and replaced as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. 5.5.4 The equipment design requirements, loading procedures and monthly onsite loading equipment inspections set forth in Condition 5.8.1.2c for controlled loading operations shall be utilized to minimize the leakage of VOC to atmosphere.This requirement shall apply at all times,regardless of actual loadout throughput. Records of standard loadout operating procedures and equipment design documentation validating the loadout is designed to minimize leakage of VOC, as well as records of each inspection of onsite loading equipment, compartment hatch operation, thief hatches, and pressure relief devices shall be maintained and made available to the Division upon request. These records must include an indication of equipment status, a description of any problems found, any replacements made and their resolution. 5.6 Control Device Requirements 5.6.1 The enclosed combustion device shall be operated with a pilot light present at all times. A thermocouple or equivalent heat sensing device shall continuously monitor the presence of the pilot light. If a flame is not detected, an alarm will indicate the absence of the pilot light. Records of pilot light outage events, the duration of such events and an estimation of emissions shall be maintained and made available to the Division upon request. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 101 5.6.1.1 In the event the pilot light presence cannot be verified by the thermocouple or equivalent heat sensing device, visual inspection of the pilot light shall be completed daily to verify pilot light presence. A daily log with the results from the visual inspection shall be maintained and made available to the Division upon request. 5.6.2 Visible Emissions Observations 5.6.2.1 A six (6) minute visual observation of the enclosed combustion device shall be performed daily to monitor for the presence of smoke. The results of the daily visual observation shall be maintained in a log and made available to the Division upon request. 5.6.2.2 In the event smoke is observed during the six (6) minute observation period required by Condition 5.6.2.1 above, an EPA Reference Method 22 observation shall be conducted to monitor compliance with the no visible emission requirement set forth in Condition 10.5.4 by determining if visible emissions are present for a period of at least one (1) minute in any fifteen (15) minute period of normal operation. The results of any Method 22 observations performed shall be maintained in a log and made available to the Division upon request. 5.6.2.3 In the event visible emissions are observed pursuant to an EPA Reference Method 22 test required by Condition 5.6.2.2 above, an EPA Reference Method 9 opacity observation shall be performed to monitor compliance with the opacity limitations set forth in Condition 5.4. The results of any Method 9 observations performed shall be maintained in a log and made available to the Division upon request. a. The EPA Reference Method 9 opacity observations shall be performed by an observer with a current and valid Method 9 certification. A clear and readable copy of the observer's certificate and any opacity observations shall be kept on file and made available to the Division for review upon request. b. Subject to the provisions of§25-7-123.1, C.R.S.,and in the absence of credible evidence to the contrary, exceedance of the opacity limit(Condition 5.4) shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 5.7 Reasonably Available Control Technology (RACT) The condensate truck loadout point is subject to Reasonably Available Control Technology (RACT) (Colorado Regulation No. 3, Part B, Section III.D.2.a.). RACT for this point has been determined to be loading the tank trucks using submerged fill, as required by Condition 5.8.1.2. This requirement shall apply at all times, regardless of actual loadout throughput. Records of standard loadout operating procedures and equipment design documentation validating the loadout is designed for submerged fill and operated as such shall be maintained and made available to the Division upon request. 5.8 Statewide Controls for Oil and Gas Operations Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Jnterprise Compressor Station Permit# 95OPWE103 Page 1021 5.8.1 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.C.5. Requirements: This hydrocarbon liquid loadout and associated air pollution control equipment are subject to the following State-Only Enforceable "Storage Tank Hydrocarbon Liquids Loadout Requirement at Well Production Facilities, Natural Gas Compressor Stations and Natural Gas Processin Plants" of Colorado Regulation No. 7, Part D, Section II., "Statewide Controls for Oil and Ga Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recordin provisions that are not included in Colorado Regulation No. 7 as of the issuance date of thi permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. Part D, Section II. General Requirements 5.8.1.1 This hydrocarbon liquid loadout is subject to the General Provisions of Colorad Regulation No. 7, Part D, Section II.B., as required by Conditions 10.5.1 through 10.5.5. Part D, Section II.C.5. Operation and Control Requirements 5.8.1.2 Owners or operators of well production facilities,natural gas compressor stations,anci natural gas processing plants with a hydrocarbon liquids loadout to transport vehicle throughput of greater than or equal to 5,000 barrels per year on a rolling 12-mont basis must control emissions from the loadout of hydrocarbon liquids from controlle storage tanks to transport vehicles by using (a) submerged fill and (b) a vapo collection and return system and/or air pollution control equipment (Colorad Regulation No. 7, Part D, Section II.C.5.a.). a. Compliance with Section II.C.5. (Condition 5.8.1) must be achieved i accordance with the following schedule (Colorado Regulation No. 7, Part D Section II.C.5.a.(i)): (i) Facilities constructed before May 1, 2020, must be in compliance May 1, 2021 (Colorado Regulation No. 7, Part D, Section II.C.5.a.(i)(B)). (ii) Facilities not subject to Section II.C.5.a.(i)(B) (Condition (i) above that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. [Compliance Monitoring:In the absence of credible evidence to the contrary,', compliance with the requirements of this Condition shall be presumed as long as the recordkeeping requirements of Condition e(vi)and e(vii) below indicate that the liquid loading equipment is capable of submerged fill and the vapor Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199? RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 103 collection and return system and/or air pollution control equipment is installed and operating.] b. Storage tanks must operate without venting at all times during loadout (Colorado Regulation No. 7, Part D, Section II.C.5.a.(ii)). [Clarification: Venting,for the purposes of this Condition b, is as defined in Colorado Regulation No. 7, Part D, Section II.C.2.a.(i) (Condition 6.6.2.9a).] [Compliance Monitoring:In the absence of credible evidence to the contrary, compliance with the requirements of this Condition shall be presumed as long as observations are being conducted pursuant to Conditions d(i) and d(ii) and the associated recordkeeping requirements of Conditions e(ii)and e(iii) below indicate that venting did not occur during loadout.] c. The owner or operator must,as applicable(Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)): (i) Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(A)). (ii) Include devices to prevent the release of vapor from vapor recovery hoses not in use (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(B)). (iii) Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(C)). (iv) Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(D)). (v) The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(E)). d. Loadout observations and operator training (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iv)): (i) The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station; Permit#95OPWE103 Page 104 less frequently, then as often as loadout is occurring (Colorado) Regulation No. 7, Part D, Section II.C.5.a.(iv)(A)), (ii) If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation) is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iv)(B)). (iii) The owner or operator must install signage at or near the loadou control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iv)(C)). [Clarification: Signage may include, but is not limited to, 1) a indication that the thief hatches, pressure relief devices and/or othe access points should not be opened to load out hydrocarbon liquids, 2) identification of the location for the appropriate equipment to be used during loadout and 3) location of additional detailed information o , the use of equipment to control emissions during loadout.] (iv) The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadou activities subject to Section II.C.5. (Condition 5.8.1)that includes, at l minimum,operating procedures for each type of loadout control system (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iv)(D)). [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with this condition may be presumed, provided records are kept of the training program as required by Condition e(v).] e. Owners or operators must retain records and make such records available to the Division upon request (Colorado Regulation No. 7, Part D, Section' II.C.5.a.(v)). (i) Records of the annual facility hydrocarbon liquids loadout to transporti vehicles throughput (Colorado Regulation No. 7, Part D, Section II.C.5.a.(v)(A)). (ii) Inspections, including a description of any problems found and theirs resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) (Conditions c and d above) must be documented in a log (Colorado Regulation No. 7, Part D, Section II.C.5.a.(v)(B)). (iii) Records of the infeasibility of observation of loadout (Coloradq Regulation No. 7, Part D, Section II.C.5.a.(v)(C)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 105 (iv) Records of the frequency of loadout (Colorado Regulation No. 7, Part D, Section II.C.5.a.(v)(D)). (v) Records of the annual training program, including the date and names of persons trained (Colorado Regulation No. 7, Part D, Section II.C.5.a.(v)(E)). (vi) [Additional Recordkeeping: A description of the loading equipment used to conduct submerged fill.] (vii) [Additional Recordkeeping:A description of the vapor collection and return equipment and any devices used to prevent release of vapor from vapor recovery hoses not in use.] [Clarification: Note that in accordance with the requirements in Section IV, Conditions 22.b and 22.c records shall be kept for a period of five years.] f. Air pollution control equipment used to comply with this Section II.C.5. (Condition 5.8.1) must comply with Section II.B. (Condition 5.8.1.1), be inspected in accordance with Sections II.C.1.d.(ii) through (v) (Conditions 6.6.2.7b through 6.6.2.7e), and achieve a hydrocarbon control efficiency of 95% (Colorado Regulation No. 7, Part D, Section II.C.5.a.(iv)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP's, Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 1061, 6. P013-Eight(8)300 bbl Stabilized Condensate Storage Tanks,AIRS ID: 063 g Permit Emission Monitoring Parameter Condition Compliance Limits Factor Number Method Interval Emission&Throughput Limits VOC 6.1 1.7 tons/year 0.33 lb/bbl Recordkeeping and Twelve Month Rolling Monthly Condensate Throughput 6.2 202,848 bbl/year Total Calculation Other Requirements Extended Liquids 6 3 ASTM Methods or En Once 6.3 Every5 Analysis Equivalent y years Not to exceed 30%for a period or periods Opacity 6.4 aggregating more than six(6)minutes in See Condition 6.4 any sixty(60)consecutive minutes Control Device 6.5 See Condition 6.5 Requirements Statewide Controls for 6.6 See Condition 6.6 Oil and Gas Operations 6.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds (VOC) from the stabilized condensate storage tanks shall no exceed the limitation listed in Summary Table 6 above (Colorado Construction Permit 19WE0492). Compliance with the emission limitation shall be monitored as follows: 6.1.1 Monthly determination of VOC emissions shall be calculated by the end of the subsequent month; using the following methodology: 6.1.1.1 The following parameters shall be input to the equation below: a. The emission factor listed in Summary Table 6 above. b. The monthly condensate throughput to the condensate tanks, as required by Condition 6.2. c. A control efficiency (CE) of 95% shall apply to the enclosed combustion device when it is operational and emissions from the condensate tanks are routed to it, provided the requirements of Condition 6.5 are met. lb bbl x(1—CE(%)) tons l_EF�bbl�x F lmonth� VOC or HAP Emissions(month/ (2000 lb Unit Conversionton Where: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 107 EF=Emission Factor,lb/bbl F=Condensate Throughput,bbl/month CE=Enclosed Combustion Device Control Efficiency,95% Monthly VOC emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 6.1.2 Emissions of Hazardous Air Pollutants(HAP)from the condensate storage tanks,produced water storage tanks and dehydration unit combined shall not exceed the facility-wide limitations listed in Summary Table 9 below. Monthly emissions of HAP shall be calculated by the end of the subsequent month using the same method as required for VOC emissions, except that the following emission factors shall be input to the equation above: HAP Species I Emission Factor(1b/bbl) n-Hexane 3.2 x 10-2 Benzene 4.0 x 10-3 Toluene 1.5 x 10-2 Ethylbenzene 1.0 x 10-4 Xylene 1.1 x 10-2 Monthly HAP emissions shall be used in a twelve month total to monitor compliance with the facility-wide HAP emission limitation, as required by Condition 9.1. 6.1.3 A verification analysis of the emission factor listed in Summary Table 6 above shall be performed once every five (5) years to ensure any variation in process conditions does not result in an underestimation of emissions. The initial verification analysis shall be conducted within one (1) year of permit issuance. At least four (4) years shall separate sequential verification analyses. The most recent rolling twelve month condensate throughput total, as required by Condition 6.2 and the physical properties indicated by the most recent extended liquids analysis, as required by Condition 6.3, shall be used in conjunction with the methods set forth in EPA's AP-42: Compilation of Emission Factors, Chapter 7 for Liquid Storage Tanks to obtain an emission factor in terms of lb VOC/bbl condensate. If the emission factor obtained from this verification analysis is greater than the emission factor listed in Summary Table 6 above, the owner or operator shall apply for a permit modification within sixty(60) days of the verification analysis. Results of this verification analysis shall be maintained and made available to the Division upon request. 6.2 Condensate Throughput Limitations & Compliance Monitoring The quantity of condensate throughput to the tank battery shall not exceed the limitation listed in Summary Table 6 above. Sales or haul tickets from each loading operation shall be used to monitor the volume of Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 108 condensate transferred. The monthly condensate throughput shall be the sum of the volume transferred, as indicated on each sales or haul ticket for all loading operations that took place during that month. The monthly condensate throughput shall be used in a twelve month rolling total to monitor compliance with the annual limitations.Each month,a new twelve month total shall be calculated using the previous twely months' data.Records of calculations shall be maintained and made available to the Division upon request The monthly condensate throughput shall be used to monitor compliance with the VOC emission limitation, as required by Condition 6.1, and to ensure the static emission factor set forth in this permit does not require modification, pursuant to Condition 6.1.3. 6.3 Extended Liquids Analysis An extended liquids analysis of the condensate stored in this tank battery shall be performed once ever five (5) years, according to appropriate ASTM methods or equivalent, if approved in advance by th Division. The initial analysis shall be performed within one (1) year of permit issuance. At least four (4 years shall separate sequential sampling events. Results of each analysis shall be maintained and made available to the Division upon request. The condensate composition and physical properties indicated by the most recent analysis shall be use to ensure the static emission factor set forth in this permit does not require modification, pursuant t Condition 6.1.3. 6.4 Opacity The following opacity requirements apply to the enclosed combustion device: 6.4.1 No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30°4 opacity for a period or periods aggregating more than six minutes in any sixty consecutiv minutes. (Colorado Regulation No. 1, Section II.A.5). In the absence of credible evidence to the contrary, compliance with the opacity limit shall be presume , provided the requirements of Conditions 6.5.2 and 10.5.4 are met. 6.5 Control Device Requirements 6.5.1 The enclosed combustion device shall be operated with a pilot light present at all times. A thermocouple or equivalent heat sensing device shall continuously monitor the presence of the pilot light. If a flame is not detected,an alarm will indicate the absence of the pilot light. Records of pilot light outage events, the duration of such events and an estimation of emissions shall be maintained and made available to the Division upon request. 6.5.1.1 In the event the pilot light presence cannot be verified by the thermocouple or equivalent heat sensing device, visual inspection of the pilot light shall be completed daily to verify pilot light presence. A daily log with the results from the visual Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 109 inspection shall be maintained and made available to the Division upon request. 6.5.2 Visible Emissions Observations 6.5.2.1 A six (6) minute visual observation of the enclosed combustion device shall be performed daily to monitor for the presence of smoke. The results of the daily visual observation shall be maintained in a log and made available to the Division upon request. 6.5.2.2 In the event smoke is observed during the six (6) minute observation period required by Condition 6.5.2.1 above, an EPA Reference Method 22 observation shall be conducted to monitor compliance with the no visible emission requirement set forth in Condition 10.5.4 by determining if visible emissions are present for a period of at least one (1) minute in any fifteen (15) minute period of normal operation. The results of any Method 22 observations performed shall be maintained in a log and made available to the Division upon request. 6.5.2.3 EPA Reference Method 9 opacity observations are required as follows: a. In the event visible emissions are observed pursuant to an EPA Reference Method 22 test required by Condition 6.5.2.2 above, an EPA Reference Method 9 opacity observation shall be performed to monitor compliance with the opacity limitations set forth in Condition 6.4. The results of any Method 9 observations performed shall be maintained in a log and made available to the Division upon request. b. An EPA Reference Method 9 opacity observation shall be performed annually to monitor compliance with the opacity limitation set forth in Colorado Regulation No. 7, Part D, Section I.I.4.b. (Condition 6.6.1.1d(ii)). This observation must be performed during normal operations only. The results of this annual Method 9 observation performed shall be maintained in a log and made available to the Division upon request. c. The EPA Reference Method 9 opacity observations shall be performed by an observer with a current and valid Method 9 certification. A clear and readable copy of the observer's certificate and any opacity observations shall be kept on file and made available to the Division for review upon request. d. Subject to the provisions of§25-7-123.1, C.R.S.,and in the absence of credible evidence to the contrary, exceedance of the opacity limit (Condition 6.4 or 6.6.1.1d(ii)) shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 6.6 Statewide Controls for Oil and Gas Operations 6.6.1 Colorado Regulation No. 7, Part D, Section 1.1. Requirements: Operating Permit Number: 95OPWEl 03 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 110 This tank battery is subject to the following requirements of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b. 6.6.1.1 The requirements of Sections I.D. through I.F. do not apply to the owner or operator of any natural gas compressor station or natural gas drip station located in an Ozone Nonattainment or Attainment/Maintenance Area if(Colorado Regulation No. 7, Part D, Section I.I.): a. Air pollution control equipment is installed and properly operated to reduce emissions of volatile organic compounds from all atmospheric condensate storage tanks (or tank batteries) that have uncontrolled actual emissions of greater than or equal to two tons per year(Colorado Regulation No. 7, Part D, Section LL1.); b. The air pollution control equipment is designed to achieve a VOC control efficiency of at least 95% on a rolling 12-month basis and meets the requirements of Sections I.C.1.a. (Condition 10.2.1) and I.C.1.b (Condition 10.2.2) (Colorado Regulation No. 7, Part D, Section I.I.2.); c. The owner or operator of such natural gas compressor station or natural gas drip station does not own or operate any exploration and production facilities in the Ozone Nonattainment or Attainment-maintenance Area (Colorado Regulation No. 7, Part D, Section I.1.3.); and d. The owner or operator of such natural gas compressor station or natural gas drip station does the following and maintains associated records and reports for a period of five years (Colorado Regulation No. 7, Part D, Section 1.1.4.): (i) Documents the maintenance of the air pollution control equipment according to manufacturer specifications (Colorado Regulation No. 7, Part D, Section I.I.4.a.); (ii) Conducts an annual opacity observation once each year on the air pollution control equipment to verify opacity does not exceed 20% during normal operations (Colorado Regulation No. 7, Part D, Section I.I.4.b.); [Compliance Monitoring: Compliance with this opacity limitation shall be demonstrated using EPA Reference Method 9, as required by Condition 6.5.2.3b.] (iii) Maintains records of the monthly stabilized condensate throughput and monthly actual VOC emissions (Colorado Regulation No. 7, Part D, Section I.I.4.c.); Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 111 (iv) [Additional Recordkeeping: Maintains documentation verifying the owner or operator does not own or operate any exploration and production facilities in the Ozone Nonattainment or Attainment- maintenance Area, if claiming this exemption pursuant to Part D, Section 11.3. (Condition 6.6.1.1 c);] (v) [Additional Recordkeeping: Maintains manufacturer documentation of the design destruction efficiency if a combustion device is used; and] (vi) Reports compliance with these requirements (Conditions (i) through (v) above) to the Division annually (Colorado Regulation No. 7, Part D, Section I.I.4.d.). 6.6.2 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.C. Requirements: This tank battery is subject to the following State-Only Enforceable "Emission Reduction from Storage Tanks at Oil and Gas Exploration and Production Operations,Well Production Facilities, Natural Gas Compressor Stations and Natural Gas Processing Plants" requirements of Colorado Regulation No. 7, Part D, Section II, "Statewide Controls for Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. Part D, Section II. General Requirements 6.6.2.1 This tank battery is subject to the General Provisions of Colorado Regulation No. 7, Part D, Section II.B., as required by Conditions 10.5.1 through 10.5.5. Part D, Section II.C. Control Requirements: 6.6.2.2 Beginning May 1, 2008, owners or operators of all storage tanks storing condensate with uncontrolled actual emissions of VOCs equal to or greater than twenty (20) tons per year based on a rolling twelve-month total must collect and control emissions from each storage tank by routing emissions to and operating air pollution control equipment that has a control efficiency of at least 95%for VOCs(Colorado Regulation No. 7, Part D, Section II.C.1.a.). [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with the 95% VOC control efficiency requirement shall be presumed as long as the requirements in Conditions 6.5 and 6.6.2.1 are met.] 6.6.2.3 Owners or operators of storage tanks with uncontrolled actual emissions of VOCs equal to or greater than six(6)tons per year based on a rolling twelve-month total must collect and control emissions from each storage tank by routing emissions to and operating air pollution control equipment that achieves a hydrocarbon control efficiency of 95% (Colorado Regulation No. 7, Part D, Section 11.C.I.b.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, L1 Colorado Operating Permit Enterprise Compressor Statio Permit# 95OPWE103 Page 112 [Compliance Monitoring: In the absence of credible evidence to the contrary compliance with the 95% hydrocarbon control efficiency requirement shall bo presumed as long as the requirements in Conditions 6.5 and 6.6.2.1 are met.] 6.6.2.4 Control requirements of Section II.C.I.b. (Condition 6.6.2.3) must be achieved in accordance with the following schedule (Colorado Regulation No. 7, Part D, Section II.C.I.b.(i)): a. A storage tank constructed before May 1,2014,must be in compliance by Ma' 1, 2015 (Colorado Regulation No. 7, Part D, Section II.C.1.b.(i)(B)). b. A storage tank not otherwise subject to Section II.C.1.b.(i)(B) (Condition above) that increases uncontrolled actual emissions to six (6) tons per year VOC or more on a rolling twelve month basis after May 1, 2014, must be iii compliance within sixty (60) days of discovery of the emissions increase (Colorado Regulation No. 7, Part D, Section II.C.I.b.(i)(C)). 6.6.2.5 Owners or operators of storage tanks with uncontrolled actual emissions of VOCi equal to or greater than two (2) tons per year based on a rolling twelve-month total must collect and control emissions from each storage tank by routing emissions to and operating air pollution control equipment that achieves a hydrocarbon control efficiency of 95% (Colorado Regulation No. 7, Part D, Section II.C.1.c.). [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with the 95% hydrocarbon control efficiency requirement shall l�e presumed as long as the requirements in Conditions 6.5 and 6.6.2.1 are met.] 6.6.2.6 Control requirements of Section II.C.1.c. (Condition 6.6.2.5) must be achieved in accordance with the following schedule (Colorado Regulation No. 7, Part D, Section II.C.1.c.(i)): a. A storage tank constructed before March 1,2020,that is not already controlled under Sections I.D. or II.C.1.b. (Condition 6.6.2.3) must be in compliance by May 1, 2021 (Colorado Regulation No. 7, Part D, Section II.C.1.c.(i)(B)). b. A storage tank not otherwise subject to Section II.C.1.c.(i)(B) (Condition;a above) that increases uncontrolled actual emissions above the applicable threshold in Section II.C.1.c.(i)(B) (Condition a above) after the applicable date in Section II.C.1.c.(i)(B) (Condition a above) must be in compliance within sixty(60)days of the first day of the month after which the storage taiik emissions exceeded the applicable threshold based on a rolling twelve-month basis (Colorado Regulation No. 7, Part D, Section II.C.1.c.(i)(C)). Part D, Section II.C. Visual Inspection Requirements: 6.6.2.7 Beginning May 1, 2014, or the applicable compliance date in Section II.C.1.b.(i) (Condition 6.6.2.4) or II.C.1.c.(i) (Condition 6.6.2.6), whichever comes later, owners or operators of storage tanks subject to Section II.C.1. (Conditions 6.6.2.2, 6.6.2.3 and 6.6.2.5) must conduct audio, visual, olfactory ("AVO") and additional visual Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 19!99 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 113 inspections of the storage tank and any associated equipment (e.g. separator, air pollution control equipment, or other pressure reducing equipment) at the same frequency as liquids are loaded out from the storage tank. These inspections are not required more frequently than every seven (7) days but must be conducted at least every thirty one (31) days, unless otherwise specified below. Monitoring is not required for storage tanks or associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section II.C.I.e. (Condition 6.6.2.8). The additional visual inspections must include,at a minimum(Colorado Regulation No. 7, Part D, Section II.C.I.d.): a. Visual inspection of any thief hatch,pressure relief valve,or other access point to ensure that they are closed and properly sealed (Colorado Regulation No. 7, Part D, Section II.C.1.d.(i)); b. Visual inspection or monitoring of the air pollution control equipment to ensure that it is operating, including that the pilot light is lit on combustion devices used as air pollution control equipment (Colorado Regulation No. 7, Part D, Section II.C.I.d.(ii)); c. Visual inspection of the autoigniter and valves for piping of gas to the pilot light to ensure they are functioning properly(Colorado Regulation No. 7, Part D, Section II.C.1.d.(iii)); d. Visual inspection of the air pollution control equipment to ensure that the valves for the piping from the storage tank to the air pollution control equipment are open (Colorado Regulation No. 7, Part D, Section II.C.1.d.(iv)) e. Daily inspection of the device for the presence or absence of smoke,as required by Condition 6.5.2 (Colorado Regulation No. 7, Part D, Section II.C.1.d.(v)); f. Beginning May 1, 2020, or the applicable compliance date in Section II.C.1.c.(i) (Condition 6.6.2.6), whichever comes later, visual observation of the dump valve(s) of the last separator(s) before the storage tank(s) to ensure the dump valve is free of debris and not stuck open. The owner or operator is not required to observe the actuation of the dump valve during this inspection; however, if a dump event occurs during the inspection, the owner or operator must confirm proper operation of the valve (Colorado Regulation No. 7, Part D, Section II.C.I.d.(vi)). g. Beginning May 1, 2020, or the applicable compliance date in Section II.C.1.c.(i)(Condition 6.6.2.6),whichever comes later,a check for the presence of liquids in liquid knockout vessels that do not drain automatically, underground lines, and aboveground piping (Colorado Regulation No. 7, Part D, Section II.C.1.d.(vii)). (i) For liquid knockout vessels for which a procedure exists to check liquid level, check for the presence of liquids. If liquids are present above the Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP1 Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 114 low level indication point, drain liquids (Colorado Regulation No. 7� Part D, Section II.C.1.d.(vii)(A)). (ii) For liquid knockout vessels for which no procedure exists to check liquid level, drain liquids (Colorado Regulation No. 7, Part D, Section II.C.I.d.(vii)(B)). (iii) For underground lines and aboveground piping that is not sloped to liquid knockout or tank and for which a procedure exists to check fo the presence of liquids accumulation, check for the presence of liquid and drain liquids as needed(Colorado Regulation No.7,Part D,Section II.C.I.d.(vii)(C)). (iv) For underground lines and aboveground piping that is not sloped to liquid knockout vessel or tank and for which no written procedur exists to check for the presence of liquids accumulation, drain liquid quarterly (Colorado Regulation No. 7, Part D, Section II.C.I.d.(vii)(D)). 6.6.2.8 If storage tanks or associated equipment is unsafe,difficult,or inaccessible to monitor, the owner or operator is not required to monitor such equipment until it become feasible to do so (Colorado Regulation No. 7, Part D, Section II.C.1.e.). Part D, Section II.C. Capture Requirements: 6.6.2.9 Capture requirements for storage tanks that are fitted with air pollution control equipment as required by Section II.C.1. (Conditions 6.6.2.2, 6.6.2.3 and 6.6.2.5): Owners or operators of storage tanks must route all hydrocarbon emissions to air pollution control equipment,and must operate without venting hydrocarbon emissio s from the thief hatch (or other access point to the tank)or pressure relief device durin normal operation, unless venting is reasonably required for maintenance, gaugin (unless the use of a storage tank measurement system is required pursuant to and the operator compiles with Section II.C.4.; Condition 6.6.2.11),or safety of personnel and equipment. Compliance must be achieved in accordance with the schedule in Section II.C.2.b.(ii) (Condition d). (Colorado Regulation No. 7, Part D, Section II.C.2.a.). a. Venting is emissions from a controlled storage tank thief hatch, pressure relief device, or other access point to the storage tank, which (Colorado RegulatiglIn No. 7, Part D, Section II.C.2.a.(i)): (1) Are primarily the result of over-pressurization, whether related io design, operation, or maintenance (Colorado Regulation No. 7, Part D, Section II.C.2.a.(i)(A)); or (ii) Are the result of an open, unlatched, or visibly unseated pressure relief device (e.g., thief hatch or pressure relief valve), an open vent line, or an unintended opening in the storage tank (e.g., crack or hole) (Colorado Regulation No. 7, Part D, Section II.C.2.a.(i)(B)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 19 9 RENEWED: D) T I Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 115 b. When emissions from a controlled storage tank are observed,the Division may require the owner or operator to submit sufficient information demonstrating whether or not the emissions were primarily the result of over-pressurization. Absent a demonstration that such emissions were not primarily the result of over-pressurization, such emissions will be considered venting for purposes of Section II.C.2.a. (Condition 6.6.2.9) (Colorado Regulation No. 7, Part D, Section II.C.2.a.(ii)). c. When venting is observed, the owner or operator must confirm within twenty- four(24) hours of taking action to return the storage tank to operation without venting that the action(s)taken was effective.If the venting was observed using an approved instrument monitoring method, the confirmation must be made using an approved instrument monitoring method(Colorado Regulation No. 7, Part D, Section II.C.2.a.(iii)). [Clarification: For the purposes of this condition, approved instrument monitoring method means an infra-red camera or EPA Method 21.1 [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with the requirements of this Condition shall be presumed as long as the recordkeeping requirements of Conditions 6.6.2.10b and 6.6.2.10f indicate that hydrocarbon emissions venting did not occur during normal operation unless venting is reasonably required for maintenance, gauging, or safety of personnel and equipment.] d. Owners or operators must achieve the requirements of Section II.C.2.a. (Condition 6.6.2.9) and begin implementing the required approved instrument monitoring method in accordance with the following schedule (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)): [Clarification: For the purposes of this condition, approved instrument monitoring method means an infra-red camera or EPA Method 21.] Part D, Section II.C. Initial Compliance Dates for Capture Requirements and AIMM Inspections (i) A storage tank subject to Sections II.C.1.a. (Condition 6.6.2.2) or II.C.1.b. (Condition 6.6.2.3)and constructed before May 1,2014, must comply with the requirements of Section II.C.2.a. (Condition 6.6.2.9) by May 1, 2015 (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(B)). (ii) A storage tank subject to Section II.C.1.c. (Condition 6.6.2.5) and constructed before March 1, 2020, that is not subject to the control requirements of the system-wide control strategy in Section I.D.1.must comply with the requirements of Section II.C.2.a. (Condition 6.6.2.9) by May 1, 2021. Approved instrument monitoring method inspections Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 116 of the storage tank must begin in 2021 (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(E)). (iii) A storage tank with uncontrolled actual emissions of VOCs equal to or greater than six (6) and less than or equal to twelve (12) tons per year must begin semi-annual approved instrument monitoring method inspections in 2020 (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(F)). (iv) A storage tank not otherwise subject to Section II.C.2.b.(ii)(B) ((i) above) that increases uncontrolled actual emissions to six (6) tons per year VOC or more on a rolling twelve month basis after May 1, 2014, must comply with the requirements of Sections II.C.2.a. (Condition 6.6.2.9) and implement the required approved instrument monitoring method inspections within sixty(60)days of discovery of the emissions increase (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(G)). (v) A storage tank not otherwise subject to Sections II.C.2.b.(ii)(A) through II.C.2.b.(ii)(F) (Conditions (i) through (iii) above) that increases uncontrolled actual emissions above the applicable threshold in Section II.C.1.c.(i)(B) (Condition 6.6.2.6a) after the applicable date in Section II.C.1.c.(i)(B) (Condition 6.6.2.6a), must comply with the requirements of Section II.C.2.a. (Condition 6.6.2.9)and implement the required approved instrument monitoring method inspections within sixty(60)days of the first day of the month after which the storage tank VOC emissions exceeded the applicable threshold based on a rolling twelve-month basis (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(H)). Part D, Section II.C. AIMM Inspection Frequency (vi) Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the inspection frequency in Table 1 (Colorado Regulation No. 7, Part D, Section II.C.2.b.(ii)(I)) Table 1 —Storage Tank Inspections Threshold: Storage Tank Approved Instrument Uncontrolled Actual VOC Monitoring Method Inspection Emissions(tpy) Frequency >2 and < 12 Semi-Annually > 12 and<50 Quarterly >50 Monthly Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 117 [Additional Monitoring: For the purposes of this Condition (vi), uncontrolled actual emissions shall be evaluated on a rolling twelve month basis. When rolling twelve month actual uncontrolled emissions increase such that a storage tank becomes subject to a higher inspection frequency, the owner or operator shall conduct the next inspection within 30 days of the discovery of the emission increase, or at the time that next inspection was scheduled as per the previous inspection frequency, whichever occurs first. e. Owners or operators are not required to monitor storage tanks and associated equipment that are unsafe, difficult, or inaccessible to monitor, as defined in Section II.C.I.e. (Condition 6.6.2.8) (Colorado Regulation No. 7, Part D, Section II.C.2.b.(iii)). Part D, Section II.C. Recordkeeping 6.6.2.10 The owner or operator must maintain records of any required monitoring and make them available to the Division upon request, including (Colorado Regulation No. 7, Part D, Section II.C.3.): a. The AIRS ID for the storage tank(Colorado Regulation No. 7, Part D, Section II.C.3.a.). b. The date and duration of any period where the thief hatch, pressure relief device, or other access point are found to be venting hydrocarbon emissions, except for venting that is reasonably required for maintenance,gauging(unless use of a storage tank measurement system is required pursuant to and the operator complies with Section II.C.4.; Condition 6.6.2.11), or safety of personnel and equipment (Colorado Regulation No. 7, Part D, Section II.C.3.b.). c. The date and duration of any period where the air pollution control equipment is not operating (Colorado Regulation No. 7, Part D, Section II.C.3.c.). d. Records of the inspections required in Sections II.C.1.d. (Condition 6.6.2.7) and II.C.2.b.(ii) (Condition 6.6.2.9d), including the time and date of each inspection and a description of any problems observed, description and date of any corrective action(s)taken,and name of employee or third party performing corrective action(s) (Colorado Regulation No. 7, Part D, Section II.C.3.d.). e. Where a combustion device is being used, the date and result of any EPA Method 22 test or investigation pursuant to Section II.C.I.d.(v) (Condition 6.6.2.7e) (Colorado Regulation No. 7, Part D, Section II.C.3.e.). f. The timing of and efforts made to eliminate venting, restore operation of air pollution control equipment, and mitigate visible emissions, including the dates and results of action(s) taken and the monitoring used to confirm the Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Ili Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 118 action(s) were successful (Colorado Regulation No. 7, Part D, Section II.C.3.f.). g. A list of equipment associated with the storage tank that is designated asll unsafe, difficult, or inaccessible to monitor, as described in Section II.C.I.e.l (Condition 6.6.2.8),an explanation stating why the equipment is so designated,) and the plan for monitoring such equipment (Colorado Regulation No. 7, Partl D, Section II.C.3.g.). [Clarification: Note that in accordance with the requirements in Section IV, Conditions 22.b and 22.c records shall be kept for a period of five years.] Part D, Section II.C. Storage Tank Measurement System Requirements 6.6.2.11 Storage tank measurement system requirements at well production facilities, natural gas compressor stations, and natural gas processing plants (Colorado Regulation No. 7, Part D, Section II.C.4.). a. The owners or operators of controlled storage tanks at well production facilities, natural gas compressor stations, or natural gas processing plants constructed on or after May 1, 2020, and at any facilities that are modified on or after May 1, 2020, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water, must use a storage tank measurement system to determine the quantity of liquids in the storage tank(s) (Colorado Regulation No. 7, Part D, Section Il.C.4.a.(i)). [Compliance Monitoring:In the absence of credible evidence to the contrary, compliance with this condition is presumed, provided records are kept of the date of construction of the storage vessels, as required by Conditions g(i), and a description of the storage tank measurement system, as required by Condition g(ii).] b. The owners or operators of controlled storage tanks at well production facilities, natural gas compressor stations, or natural gas processing plants constructed on or after January 1, 2021, and at any facilities that are modified on or after January 1, 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water, must use a storage tank measurement system to determine the quality and quantity of liquids in the storage tank(s) (Colorado Regulation No. 7, Part D, Section II.C.4.a.(ii)). [Compliance Monitoring:In the absence of credible evidence to the contrary, compliance with this condition is presumed, provided records are kept of the date of construction of the storage vessels, as required by Conditions g(i), and a description of the storage tank measurement system, as required by Condition g(ii).] Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 119 c. Owner or operators subject to the storage tank measurement system requirements in Section II.C.4.a. (Conditions a and b above), must keep thief hatches (or other access points to the tank) and pressure relief devices on storage tanks closed and latched during activities to determine the quality and/or quantity of liquids in the storage tank(s) (Colorado Regulation No. 7, Part D, Section II.C.4.b.). [Compliance Monitoring: The owner or operator shall record the date and time of all qualitative and/or quantitative measurement events in a log to be made available to the Division upon request. The log shall include an indication of whether the thief hatch, other access points and any pressure relief devices were open or closed during these events.] d. Operators may inspect, test, and/or calibrate the storage tank measurement system semi-annually, or as directed by the Bureau of Land Management (see 43 CFR Section 3174.6(b)(5)(ii)(B) (November 17, 2016)) or system manufacturer. Opening the thief hatch if required to inspect, test, or calibrate the system is not a violation of Section II.C.4.b. (Condition c above)(Colorado Regulation No. 7, Part D, Section II.C.4.c.). e. The owner or operator must install signage at or near the storage tank that indicates which equipment and method(s) is used and the appropriate and necessary operating procedures for that system (Colorado Regulation No. 7, Part D, Section II.C.4.d.). [Clarification:Signage may include, but is not limited to, 1)an indication that the thief hatches,pressure relief devices and/or other access points should not be opened to obtain data on the quality or quantity of hydrocarbon liquids, 2) identification of the location for obtaining the quality and quantity data and 3) location of additional detailed information on the storage tank measurement system and expectations for truck loading.] f. The owner or operator must develop and implement an annual training program for employees and/or third parties conducting activities subject to Section II.C.4. (Conditions a and b above) that includes, at a minimum, operating procedures for each type of system(Colorado Regulation No. 7, Part D, Section II.C.4.e.). [Compliance Monitoring: In the absence of credible evidence to the contrary, compliance with this condition may be presumed,provided records are kept of the training program as required by Condition g(v).] g. Owner or operators must retain records and make such records available to the Division upon request, including (Colorado Regulation No. 7, Part D, Section II.C.4.f.): (i) Date of construction of the storage vessel or facility (Colorado Regulation No. 7, Part D, Section II.C.4.f.(i)). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 120 (ii) Description of the storage tank measurement system used to comply with Section II.C.4.a.(Conditions a and b above)(Colorado Regulation No. 7, Part D, Section II.C.4.f.(ii)). (iii) Date(s) of storage tank measurement system inspections, testing, and/or calibrations pursuant to Section II.C.4.c. (Condition d above) (Colorado Regulation No. 7, Part D, Section II.C.4.f.(iii)). (iv) Manufacturer specifications regarding storage tank measurement system inspections,and/or calibrations, if followed pursuant to Section II.C.4.c. (Condition d above) (Colorado Regulation No. 7, Part D, Section II.C.4.f.(iv)). (v) Records of the annual training program, including the date and names of persons trained (Colorado Regulation No. 7, Part D, Section II.C.4.f.(v)). [Clarification: Note that in accordance with the requirements in Section IV, Conditions 22.b and 22.c records shall be kept for a period of five years.] Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 121 7. SUMP-1/2 —Two (2) 90 bbl Produced Water Storage Tanks,AIRS ID: 075 Permit Monitoring Parameter Condition Compliance Limits Compliance Emission Factor Number Method Interval Emission&Throughput Limits Recordkeeping and VOC 7.1 1.9 tons/year 0.28 lb/bbl Twelve Month Rolling Monthly Total Calculation Produced Water Recordkeeping and Throughput 7.2 13,299 bbl/year Twelve Month Rolling Monthly Total Calculation Other Requirements Flash Liberation 7 3 ASTM Methods or Annually Analysis Equivalent Statewide Controls for Oil and Gas 7.4 See Condition 7.4 Operations 7.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds(VOC)from the produced water storage tanks shall not exceed the limitations listed in Summary Table 7 above (as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7., based on requested emissions identified on the APEN submitted on 6/1/2020). Compliance with the emission limitation shall be monitored as follows: 7.1.1 Monthly determination of VOC and HAP emissions shall be calculated by the end of the subsequent month using the following methodology: 7.1.1.1 The following parameters shall be input to the equation below: a. The emission factor listed in Summary Table 7 above. b. The monthly produced water throughput to the produced water tanks, as required by Condition 7.2. lb ( bbl VOC or HAP Emissions r tons l 6F(bb11 x \month \month/ Unit Conversion (2000 lb) ton 1 Where: EF=Emission Factor,lb/bbl F=Produced Water Throughput,bbl/month Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 122 Monthly VOC emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 7.1.2 Emissions of Hazardous Air Pollutants(HAP)from the condensate storage tanks,produced water storage tanks and dehydration unit combined shall not exceed the facility-wide limitations listed in Summary Table 9 below. Monthly emissions of HAP shall be calculated by the end of the subsequent month using the same method as required for VOC emissions, except that the following emission factors shall be input to the equation above: HAP Species I Emission Factor Ilb/bbl n-Hexane I 0.026 Monthly HAP emissions shall be used in a twelve month total to monitor compliance with the facility-wide HAP emission limitation, as required by Condition 9.1. 7.1.3 A verification analysis of the emission factor listed in Summary Table 7 above shall be performed annually to ensure any variation in process conditions does not result in an underestimation of emissions. At least eight (8) months shall separate sequential verification analyses. The most recent rolling twelve month produced water throughput total, as required by Condition 7.2 and the physical properties indicated by the most recent flash liberation analysis, as required by Condition 7.3, shall be used in conjunction with the methods set forth in EPA's AP-42: Compilation of Emission Factors, Chapter 7 for Liquid Storage Tanks to obtain an emission factor in terms of lb VOC/bbl produced water. If the emission factor obtained from this verification analysis is greater than the emission factor listed in Summary Table 7 above, the owner or operator shall apply for a permit modification within sixty(60) days of the verification analysis. Results of this annual verification analysis shall be maintained and made available to the Division upon request. 7.2 Produced Water Throughput Limitations & Compliance Monitoring The quantity of produced water throughput to the produced water storage tanks shall not exceed the limitation listed in Summary Table 7 above. Sales or haul tickets from each loading operation shall be used to monitor the volume of produced water transferred. The monthly produced water throughput shall be the sum of the volume transferred, as indicated on each sales or haul ticket for all loading operations that took place during that month.The monthly produced water throughput shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. The monthly produced water throughput shall be used to monitor compliance with the VOC emission limitation, as required by Condition 7.1. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 123 7.3 Flash Liberation Analysis A flash liberation analysis of the pressurized produced water routed to these produced water storage tanks shall be performed annually, according to appropriate ASTM methods or equivalent, if approved in advance by the Division. At least eight (8) months shall separate sequential sampling events. Results of each analysis shall be maintained and made available to the Division upon request. The flash gas composition and physical properties indicated by the most recent analysis shall be used to ensure the static emission factor set forth in this permit does not require modification, pursuant to Condition 7.1.3. 7.4 Statewide Controls for Oil and Gas Operations 7,4.1 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.C. Requirements: These produced water storage tanks are subject to the following State-Only Enforceable "Emission Reduction from Storage Tanks at Oil and Gas Exploration and Production Operations, Well Production Facilities,Natural Gas Compressor Stations and Natural Gas Processing Plants" requirements of Colorado Regulation No. 7, Part D, Section II, "Statewide Controls for Oil and Gas Operations": Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. Part D, Section II. General Requirements 7.4.1.1 These produced water storage tanks are subject to the General Provisions of Colorado Regulation No. 7, Part D, Section II.B., as required by Conditions 10.5.1 and 10.5.2. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 124 8. COMP-BD—Reciprocating Compressor Blowdowns,AIRS ID: 076 Permit Monitoring Parameter Condition Compliance Limits Compliance Emission Factor Number Method Interval Emission&Throughput Limits C-234,C-235,C-236,C-238: 2,883 scf/event Recordkeeping and VOC' 8.1 9.8 tons/year Twelve Month Rolling Monthly C-237: Total Calculation 5,674 scf/event Each Compressor: Recordkeeping and Blowdown Events 8.2 Twelve Month Rolling Monthly 63 events/year Total Calculation Other Requirements Extended Gas ASTM or Other Division Analysis 8'3 Approved Method Annually Reasonably Available Control 8.4 Operating Practices Recordkeeping Technology (RACT) Final Approval 8.5 See Condition 8.5 Requirements 'This emission limitation applies to all blowdown events combined. 8.1 VOC Emission Limitations & Compliance Monitoring Emissions of Volatile Organic Compounds (VOC) from reciprocating compressor blowdowns shall not exceed the limitations listed in Summary Table 8 above (Colorado Construction Permit 19WE0094, as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7.,based on requested emissions identified on the APEN submitted on 10/30/2020). Compliance with the emission limitation shall be monitored as follows: 8.1.1 Monthly determination of VOC and HAP emissions shall be calculated by the end of the subsequent month using the following methodology: 8.1.1.1 The following parameters shall be input to the equation below: a. The emission factor listed in Summary Table 8 above. b. The number of blowdown events, totaled monthly, as required by Condition 8.2. c. The molecular weight and VOC content obtained from the most recent extended gas analysis, as required by Condition 8.3. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 125 8.1.1.2 Monthly emissions of VOC and HAP from the reciprocating compressor blowdowns shall be calculated using the following equation: scf events (( lb tons _ EF(event)x E kmonth�x MW lb tons X x° VOC or HAP Emissions(month) 2000 lb (379.5 scf Each Compressor Unit Conversion ( ton x lbmol ) Where: EF=Compressor Blowdown Event Emission Factor,scf/event E= Compressor Blowdown Events,events/month MW=Blowdown Gas Molecular Weight,lb/lbmol xG =Blowdown Gas VOC or HAP Content,mass fraction Monthly VOC emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 8,1.2 Annual emissions of Hazardous Air Pollutants (HAP), for the purposes of APEN reporting and the payment of annual fees, shall be calculated using HAP emissions derived from the same method as required for VOC emissions, except that the HAP content obtained from the most recent extended gas analysis, as required by Condition 8.3, shall be input to the equation above. 8.2 Blowdown Event Limitations & Compliance Monitoring The number of blowdowns from each compressor shall not exceed the limitation listed in Summary Table 8 above(Colorado Construction Permit 19WE0094,as provided for under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C, Section I.A.7 and Part C, Section III.B.7., based on requested limitations identified on the APEN submitted on 10/30/2020). The compressor facility identifier and the date of each blowdown event for that compressor shall be recorded in a log to be made available to the Division upon request. The monthly blowdown events for each compressor shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. The monthly blowdown events for each compressor shall be used to monitor compliance with the VOC emission limitation, as required by Condition 8.1. 8.3 Extended Gas Analysis An extended gas analysis of a gas representative of the blowdown emissions shall be performed annually, according to appropriate ASTM methods or equivalent, if approved in advance by the Division(Colorado Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 126 Construction Permit 19WE0094). At least eight (8) months shall separate sequential sampling events. Results of each analysis shall be maintained and made available to the Division upon request. The VOC content and molecular weight indicated by the most recent analysis shall be used to monitor compliance with the VOC emission limitation, as required by Condition 8.1. 8.4 Reasonably Available Control Technology (RACT) The reciprocating compressor blowdown point is subject to Reasonably Available Control Technology (RACT)(Colorado Regulation No.3,Part B, Section III.D.2.a.).RACT for these reciprocating compressor blowdowns has been determined to be good work practices. Good work practices shall be performed during each blowdown event to minimize emissions, unless it is determined to be unsafe to perform such a work practice (Colorado Construction Permit 19WE0094, as modified under the provisions of Section I,Condition 1.3 and Colorado Regulation No.3,Part C, Section I.A.7 and Part C,Section III.B.7). Records of the good work practices used during each blowdown event, as well as an explanation of infeasibility if good work practices were not used, shall be maintained and made available to the Division upon request. 8.5 Final Approval Requirements The operator shall complete the following initial compliance testing and sampling(Colorado Construction Permit 19WE0094): 8.5.1 The owner or operator shall complete the initial extended gas analysis of the natural gas vented from this emissions unit within one hundred and eighty days (180) of permit issuance. Results of all initial testing required by this condition shall be submitted with the first semi-annual report due after the initial testing was conducted. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 127 9. HAP Emission Limitations for the Stabilized Condensate Storage Tanks, AIRS ID: 063, Produced Water Storage Tanks,AIRS ID: 075 and TEG Dehydration Unit,AIRS ID: 068 or 077 Permit Limitations Compliance Monitoring Parameter Condition Emission Number Monthly Annual Factor Method Interval For AIRS 063, 075&068 only: 9.1 Individual: 8 tons/year Recordkeeping HAP Total: 20 tons/year and Twelve Month Rolling Monthly For AIRS 063, Individual: 1 359 lb/month Individual: 8 tons/year Total 075&077 only: 9.2 Calculation HAP Total: 3,398 lb/month Total: 20 tons/year 9.1 HAP Emission Limitations & Compliance Monitoring for AIRS 063,AIRS 075 & AIRS 068 Emissions of Hazardous Air Pollutants(HAP)from the Stabilized Condensate Storage Tanks(AIRS 063), Produced Water Storage Tanks (AIRS 075)and TEG Dehydration Unit D-2 (AIRS 068) shall not exceed the annual limitations listed in Summary Table 9 above. Compliance with the emission limitations shall be monitored as follows: 9.1.1 Monthly emission calculations shall be completed for each HAP with uncontrolled actual emissions above the de minimis reporting level (per individual emission unit), as defined in Colorado Regulation No. 3 Appendix A. Calculations for the dehydration unit, condensate storage tanks and produced water storage tanks shall be conducted using the methodology required by Conditions 3.1, 6.1 and 7.1. 9.1.2 Facility-wide emissions for an individual HAP shall be the sum total emissions of that HAP from the dehydration unit, condensate storage tanks and produced water storage tanks combined for which uncontrolled actual emissions of that HAP are above the de minimis reporting threshold. Monthly emissions of each HAP shall be used in a twelve month rolling total to monitor compliance with the individual HAP annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 9.1.3 Facility-wide emissions for total HAP shall be the sum total of all HAP emitted from the dehydration unit,condensate storage tanks and produced water storage tanks combined for which uncontrolled actual emissions are above the de minimis reporting threshold. Monthly emissions of total HAP shall be used in a twelve month rolling total to monitor compliance with the total HAP annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 128 This Condition 9.1 only shall apply to the Stabilized Condensate Storage Tanks (AIRS 063), Produced Water Storage Tanks (AIRS 075) and TEG Dehydration Unit D-2 (AIRS 068) until TEG Dehydration Unit D-3 (AIRS 077) commences operation, after which compliance with this Condition 9.1 is no longer required and Condition 9.2 only shall apply. 9.2 HAP Emission Limitations & Compliance Monitoring for AIRS 063,AIRS 075 & AIRS 077 Emissions of Hazardous Air Pollutants(HAP)from the Stabilized Condensate Storage Tanks(AIRS 063), Produced Water Storage Tanks (AIRS 075) and TEG Dehydration Unit D-3 (AIRS 077) shall not exceed the annual limitations listed in Summary Table 9 above. During the first twelve months of TEG dehydration unit D-3 operation, compliance with both the monthly and annual limitations are required. After the first twelve months of operation, compliance with only the annual limitation is required. Compliance with the emission limitations shall be monitored as follows: 9.2.1 Monthly emission calculations shall be completed for each HAP with uncontrolled actual emissions above the de minimis reporting level (per each individual emission unit), as defined in Colorado Regulation No. 3 Appendix A. Calculations for the dehydration unit, condensate storage tanks and produced water storage tanks shall be conducted using the methodology required by Conditions 4.1, 6.1, and 7.1. 9.2.2 Facility-wide emissions for an individual HAP shall be the sum total emissions of that HAP from the dehydration unit, condensate storage tanks and produced water storage tanks combined for which uncontrolled actual emissions of that HAP are above the de minimis reporting threshold. Monthly emissions of each HAP shall be used in a twelve month rolling total to monitor compliance with the individual HAP limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. 9.2.3 Facility-wide emissions for total HAP shall be the sum total of all HAP emitted from the dehydration unit,condensate storage tanks and produced water storage tanks combined for which uncontrolled actual emissions are above the de minimis reporting threshold. Monthly emissions of total HAP shall be used in a twelve month rolling total to monitor compliance with the total HAP limitations. Each month, a new twelve month total shall be calculated using the previous twelve months' data. Records of calculations shall be maintained and made available to the Division upon request. This Condition 9.2 only shall apply to the Stabilized Condensate Storage Tanks (AIRS 063), Produced Water Storage Tanks (AIRS 075) and TEG Dehydration Unit D-3 (AIRS 077) upon commencement of operation of TEG Dehydration Unit D-3 (AIRS 077). Compliance with this Condition 9.2 is not required until TEG Dehydration Unit D-3 (AIRS 077) commences operation, after which Condition 9.1 shall no longer apply. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 129 10. Facility-Wide Requirements 10.1 The project permitted under Colorado Construction Permit 19WE0492, Issuance 1 avoided major New Source Review (NSR) permitting requirements and is potentially subject to the relaxation provisions of Colorado Regulation No. 3, Part D, Section V.A.7.b. The emission units associated with this project include the stabilized condensate storage tanks (AIRS 063), stabilized condensate loadout (AIRS 066), produced water storage tanks (AIRS 075), TEG dehydration unit D-3 (AIRS 077),and the reboiler associated with TEG dehydration unit D-3 (insignificant activity). Major NSR applicability details for this project are included in the Technical Review Document (TRD) associated with the XX/XX/XXXX issuance of this permit (Colorado Construction Permit 19WE0492). 10.2 Colorado Regulation No. 7, Part D, Section I.C. Requirements: This facility is subject to the following"General Provisions"of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring,recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. 10.2.1 All air pollution control equipment used to demonstrate compliance with this Section I. must be operated and maintained consistent with manufacturer specifications and good engineering and maintenance practices. The owner or operator must keep manufacturer specifications on file. In addition, all such air pollution control equipment must be adequately designed and sized to achieve the control efficiency rates required by this Section I.and to handle reasonably foreseeable fluctuations in emissions of volatile organic compounds. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable (Colorado Regulation No. 7, Part D, Section I.C.1.a.). 10.2.2 All hydrocarbon liquids and produced water collection, storage, processing, and handling operations, regardless of size, must be designed, operated, and maintained so as to minimize emission of volatile organic compounds to the atmosphere to the maximum extent practicable (Colorado Regulation No. 7, Part D, Section I.C.1.b.). 10.3 Colorado Regulation No. 7, Part D, Section I.J. Requirements: Each compressor is subject to the following "Compressor Requirements" of Colorado Regulation No. 7, Part D, Section I, "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring,recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. Part D, Section I.J. Emission Control Requirements Operating Permit Number: 95OPWEI03 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 130 10.3.1 Beginning January 1, 2018,the rod packing on reciprocating compressors located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment must be replaced every 26,000 hours of operation or every thirty six (36) months (Colorado Regulation No. 7, Part D, Section I.J.2.a.). Part D, Section I.J. Recordkeeping Requirements 10.3.2 Owners or operators must maintain the following records for at least five (5) years and make records available to the Division upon request (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)): 10.3.2.1 Identification of each reciprocating compressor (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(A)). 10.3.2.2 The hours of operation or the number of months since the previous rod packing replacement(Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(B)). 10.3.2.3 The date of each rod packing replacement,or date of installation of a rod packing emissions collection system and closed vent system (Colorado Regulation No. 7, Part D, Section I.J.2.c.(i)(C)). Part D, Section I.J. Alternate Compliance Option 10.3.3 As an alternative to the emission control, inspection, repair, and recordkeeping provisions described in Sections I.J.2.a. (Condition 10.3.1) through I.J.2.c. (Condition 10.3.2), the owner or operator may comply with reciprocating compressor emission control, monitoring, recordkeeping, and reporting requirements of a New Source Performance Standard in 40 CFR Part 60 (Colorado Regulation No. 7, Part D, Section I.J.2.e.). 10.4 Colorado Regulation No. 7, Part D, Section I.L. Requirements: This facility is subject to the following "Leak detection and repair program for well production facilities and natural gas compressor stations located in the 8-hour Ozone Control Area"of Colorado Regulation No. 7, Part D, Section 1, "Volatile Organic Compound Emissions from Oil and Gas Operations": Conditions shown in italic text below represent monitoring,recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. 10.4.1 Beginning June 30, 2018, owners or operators of natural gas compressor stations must inspect components for leaks using an approved instrument monitoring method at least quarterly (Colorado Regulation No. 7, Part D, Section I.L.1.a). 10.4.2 If a component is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor the component until it becomes feasible to do so (Colorado Regulation No. 7, Part D, Section I.L.3.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 131 10.4.2.1 Difficult to monitor components are those that cannot be monitored without elevating the monitoring personnel more than two (2) meters above a supported surface or are unable to be reached via a wheeled scissor-lift or hydraulic type scaffold that allows access to components up to 7.6 meters (25 feet) above the ground (Colorado Regulation No. 7, Part D, Section I.L.3.a.). 10.4.2.2 Unsafe to monitor components are those that cannot be monitored without exposing monitoring personnel to an immediate danger as a consequence of completing the monitoring(Colorado Regulation No. 7, Part D, Section I.L.3.b.). 10.4.2.3 Inaccessible to monitor components are those that are buried, insulated, or obstructed by equipment or piping that prevents access to the components by monitoring personnel (Colorado Regulation No. 7, Part D, Section I.L.3.c.). 10.4.3 Leaks requiring repair: Only leaks from components exceeding the thresholds in this Section I.L.4. require repair under Section I.L.5 (Condition 10.4.4) (Colorado Regulation No. 7, Part D, Section I.L.4.). 10.4.3.1 For EPA Method 21 monitoring, repair is required for leaks with any concentration of hydrocarbon above 500 ppm not associated with normal equipment operation, such as pneumatic device actuation and crank case ventilation (Colorado Regulation No. 7, Part D, Section I.L.4.a.). 10.4.3.2 For infra-red camera monitoring, repair is required for leaks with any detectable emissions not associated with normal equipment operation, such as pneumatic device actuation and crank case ventilation (Colorado Regulation No. 7, Part D, Section I.L.4.b.). 10.4.3.3 For other approved instrument monitoring methods or programs, leak identification requiring repair will be established as set forth in an approval under Section I.L.8 (Condition 10.4.7) (Colorado Regulation No. 7, Part D, Section I.L.4.c.). 10.4.3.4 For leaks identified using an approved non-quantitative instrument monitoring method, owners or operators have the option of either repairing the leak in accordance with the repair schedule set forth in Section I.L.5. (Condition 10.4.4) or conducting follow-up monitoring using EPA Method 21 within five (5) working days of the leak detection. If the follow-up EPA Method 21 monitoring shows that the emission is a leak requiring repair as set forth in Section I.L.4.a. (Condition 10.4.3.1)the leak must be repaired and remonitored in accordance with Section I.L.5 (Condition 10.4.4) (Colorado Regulation No. 7, Part D, Section I.L.4.d.). 10.4.3.5 Owners or operators must maintain and operate approved nonquantitative instrument monitoring methods according to manufacturer recommendations (Colorado Regulation No. 7, Part D, Section I.L.4.e.). 10.4.4 Repair and remonitoring (Colorado Regulation No. 7, Part D, Section I.L.5.) 10.4.4.1 First attempt to repair a leak must be made no later than five (5) working days after Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 132 discovery and completed no later than thirty(30)working days after discovery, unless parts are unavailable, the equipment requires shutdown to complete repair, or other good cause exists (Colorado Regulation No. 7, Part D, Section I.L.5.a.). a. If parts are unavailable,they must be ordered promptly and the repair must be made within fifteen (15) working days of receipt of the parts (Colorado Regulation No. 7, Part D, Section I.L.5.a.(i)). b. If shutdown is required, a repair attempt must be made during the next scheduled shutdown and final repair completed within two (2) years after discovery (Colorado Regulation No. 7, Part D, Section I.L.5.a.(ii)). c. If delay is attributable to other good cause, repairs must be completed within fifteen (15) working days after the cause of delay ceases to exist (Colorado Regulation No. 7, Part D, Section I.L.5.a.(iii)). 10.4.4.2 Within fifteen (15) working days of completion of a repair the leak must be remonitored using an approved instrument monitoring method to verify that the repair was effective (Colorado Regulation No. 7, Part D, Section I.L.5.b.). 10.4.4.3 Leaks discovered pursuant to the leak detection methods of Section I.L.4. (Condition 10.4.3) are not subject to enforcement by the Division unless the owner or operator fails to perform the required repairs in accordance with Section I.L.5. (Condition 10.4.4) or keep required records in accordance with Section I.L.6 (Condition 10.4.5) (Colorado Regulation No. 7,Part D, Section I.L.5.c.). 10.4.5 Recordkeeping (Colorado Regulation No. 7, Part D, Section I.L.6.) 10.4.5.1 Documentation of the initial approved instrument monitoring method inspection for well production facilities and natural gas compressor stations (Colorado Regulation No. 7, Part D, Section I.L.6.a.); 10.4.5.2 The date, facility name, and facility AIRS ID or facility location if the facility does not have an AIRS ID for each inspection(Colorado Regulation No. 7, Part D, Section I.L.6.b.); 10.4.5.3 A list of the leaks requiring repair and the monitoring method(s) used to determine the presence of the leak (Colorado Regulation No. 7, Part D, Section I.L.6.c.); 10.4.5.4 The date of first attempt to repair the leak and, if necessary, any additional attempt to repair(Colorado Regulation No. 7, Part D, Section I.L.6.d.); 10.4.5.5 The date the leak was repaired and type of repair method applied(Colorado Regulation No. 7, Part D, Section I.L.6.e.); 10.4.5.6 The delayed repair list, including the date and duration of any period where the repair of a leak was delayed due to unavailable parts, required shutdown, or delay for other good cause, the basis for the delay, and the schedule for repairing the leak. Delay of repair beyond thirty (30) days after initial discovery due to unavailable parts must be reviewed,and a record kept of that review,by a representative of the owner or operator Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 133 with responsibility for leak detection and repair compliance functions. This review will not be made by the individual making the initial determination to place a part on the delayed repair list (Colorado Regulation No. 7, Part D, Section I.L.6.f.); 10.4.5.7 The date the leak was remonitored and the results of the remonitoring (Colorado Regulation No. 7, Part D, Section I.L.6.g.); and 10.4.5.8 A list of components that are designated as unsafe,difficult,or inaccessible to monitor, as described in Section I.L.3. (Condition 10.4.2), an explanation stating why the component is so designated, and the schedule for monitoring such component(s) (Colorado Regulation No. 7, Part D, Section I.L.6.h.). 10.4.5.9 Records must be maintained for a minimum of five years and made available to the Division upon request(Colorado Regulation No. 7, Part D, Section I.L.6.i.). 10.4.5.10 [Additional Monitoring: The owner or operator shall maintain records that document the categories of equipment operation that may result in emissions but are not considered to be leaks under Colorado Regulation No. 7, Part D, Section LL.4. (Condition 10.4.3) because they qualify as "normal equipment operation". This requirement shall not apply to pneumatic device actuation and crankcase ventilation, which are already explicitly defined in the rule as normal equipment operation. The records shall include a description of each category or type of "normal equipment operation"and a description of the component or equipment type associated with that category.] 10.4.6 Reporting: The owner or operator of each facility subject to the leak detection and repair requirements in Section I.L. (Condition 10.4) must submit a single annual report on or before May 31st of each year (beginning May 31st, 2019) that includes, at a minimum, the following information regarding leak detection and repair activities at their subject facilities conducted the previous calendar year(Colorado Regulation No. 7, Part D, Section I.L.7.): 10.4.6.1 The total number of well production facilities and total number of natural gas compressor stations inspected (Colorado Regulation No. 7, Part D, Section I.L.7.a.); 10.4.6.2 The total number of inspections performed per inspection frequency tier of well production facilities and the total number of inspections performed at natural gas compressor stations (Colorado Regulation No. 7, Part D, Section I.L.7.b.); 10.4.6.3 The total number of identified leaks requiring repair broken out by component type, monitoring method, and inspection frequency tier of well production facility as reported in Section I.L.7.b. (Condition 10.4.6.2) and the total number of identified leaks requiring repair at natural gas compressor stations broken out by component type and monitoring method (Colorado Regulation No. 7, Part D, Section I.L.7.c.); 10.4.6.4 The total number of leaks repaired for each inspection frequency tier of well production facilities as reported in Section I.L.7.b. (Condition 10.4.6.2) and the total number of leaks repaired for natural gas compressor stations (Colorado Regulation No. 7, Part D, Section I.L.7.d.); Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 134 10.4.6.5 The total number of leaks on the delayed repair list as of December 31st broken out by component type, inspection frequency tier of well production facility as reported in Section I.L.7.b. (Condition 10.4.6.2) or natural gas compressor station, and the basis for each delay of repair(Colorado Regulation No. 7, Part D, Section I.L.7.e.); 10.4.6.6 The record of all reviews conducted for delayed repairs due to unavailable parts extending beyond 30 days for the previous calendar year(Colorado Regulation No. 7, Part D, Section I.L.7.f.); and 10.4.6.7 Each report shall be accompanied by a certification by a responsible official that,based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate,and complete (Colorado Regulation No. 7, Part D, Section I.L.7.g.). 10.4,7 Alternative approved instrument monitoring methods may be used in lieu of, or in combination with an infra-red camera, EPA Method 21, or other approved instrument monitoring method to inspect for leaks as required by Section I.L. (Condition 10.4), if the following conditions are met (Colorado Regulation No. 7, Part D, Section I.L.8.): 10.4.7.1 The proponent of the alternative approved instrument monitoring method applies for a determination of an alternative approved instrument monitoring method or program. The application must include, at a minimum, the following(Colorado Regulation No. 7, Part D, Section I.L.8.a.): a. The proposed alternative approved instrument monitoring method manufacturer information (Colorado Regulation No. 7, Part D, Section I.L.8.a.(i)); b. A description of the proposed alternative approved instrument monitoring method including, but not limited to (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)): (i) Whether the proposed alternative approved instrument monitoring method is a quantitative detection method, and how emissions are quantified, or qualitative leak detection method (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(A)); (ii) Whether the proposed alternative approved instrument monitoring method is commercially available (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(B)); (iii) Whether the proposed alternative approved instrument monitoring method is approved by other regulatory authorities and for what application (e.g., pipeline monitoring, emissions detected) (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(C)); (iv) The leak detection capabilities, reliability, and limitations of the proposed alternative approved instrument monitoring method, including, but not limited to, the ability to identify specific leaks or Operating Permit Number: 95OPWE103 - FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 135 locations, detection limits, and any restrictions on use, as well as supporting data (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(D)); (v) The frequency of measurements and data logging capabilities of the proposed alternative approved instrument monitoring method (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(E)); (vi) Data quality indicators for precision and bias of the proposed alternative approved instrument monitoring method (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(F)); (vii) Quality control and quality assurance procedures necessary to ensure proper operation of the proposed alternative approved instrument monitoring method (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(G)); (viii) A description of where, when, and how the proposed alternative approved instrument monitoring method will be used (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(H)); and (ix) Documentation (e.g., field or test data, modeling) adequate to demonstrate the proposed alternative approved instrument monitoring method or program is capable of achieving emission reductions that are at least as effective as the emission reductions achieved by the leak detection and repair provisions in Section I.L. (Condition 10.4) (Colorado Regulation No. 7, Part D, Section I.L.8.a.(ii)(I)) c. The Division will transmit a copy of the complete application and any other materials provided by the applicant to EPA (Colorado Regulation No. 7, Part D, Section I.L.8.a.(iii)). d. Public notice of the application is provided pursuant to Regulation Number 3, Part B, Section III.C.4 (Colorado Regulation No. 7, Part D, Section I.L.8.a.(iv)). e. The Division and the EPA approves the proposal. The Division will transmit a copy of the application and any other materials provided by the applicant, all public comments, all Division responses and the Division's approval to EPA Region 8. If EPA fails to approve or disapprove the proposal within six (6) months of receipt of these materials,EPA will be deemed to have approved the proposal (Colorado Regulation No. 7, Part D, Section I.L.8.a.(v)). 10.5 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.B. Requirements This facility is subject to the following State-Only Enforceable "General Provisions" of Colorado Regulation No. 7, Part D, Section II, "Statewide Controls for Oil and Gas Operations": Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 136 Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this permit,but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. Part D, Section II.B. General Requirements 10.5.1 All hydrocarbon liquids and produced water collection, storage, processing, and handling operations, regardless of size, must be designed, operated, and maintained so as to minimize emission of VOCs and other hydrocarbons to the atmosphere to the extent reasonably practicable (Colorado Regulation No. 7, Part D, Section II.B.I.a.). 10.5.2 At all times, including periods of start-up and shutdown, the facility and air pollution control equipment must be maintained and operated in a manner consistent with good air pollution control practices for minimizing emissions.Determination of whether or not acceptable operation and maintenance procedures are being used will be based on information available to the Division, which may include, but is not limited to, monitoring results, opacity observations, review of operation and maintenance procedures, and inspection of the source (Colorado Regulation No. 7, Part D, Section II.B.1.b.). Part D, Section II.B. General Requirements for Air Pollution Control Equipment 10.5.3 All air pollution control equipment must be operated and maintained pursuant to the manufacturing specifications or equivalent to the extent practicable, and consistent with technological limitations and good engineering and maintenance practices. The owner or operator must keep manufacturer specifications or equivalent on file. In addition, all such air pollution control equipment must be adequately designed and sized to achieve the control efficiency rates and to handle reasonably foreseeable fluctuations in emissions of VOCs and other hydrocarbons during normal operations. Fluctuations in emissions that occur when the separator dumps into the tank are reasonably foreseeable (Colorado Regulation No. 7, Part D, Section II.B.2.a.). 10.5.4 If a combustion device is used to control emissions of VOCs and other hydrocarbons, it must be enclosed,have no visible emissions during normal operation,and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly (Colorado Regulation No. 7, Part D, Section II.B.2.b.). 10.5.5 Auto-igniters: All combustion devices used to control emissions of hydrocarbons must be equipped with and operate an auto-igniter as follows(Colorado Regulation No. 7, Part D,Section II.B.2.d.): 10.5.5.1 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(Colorado Regulation No. 7,Part D, Section Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE1.03 Page 137 II.B.2.d.(ii)). Part D, Section II.B.3. Requirements for Compressor Seals and Open-Ended Valves or Lines 10,5.6 Beginning January 1,2015,each open-ended valve or line at well production facilities and natural gas compressor stations must be equipped with a cap, blind flange, plug, or a second valve that seals the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt from the requirement to seal the open end of the valve or line. Alternatively, an open-ended valve or line may be treated as if it is a "component" as defined in Section II.A.6., and may be monitored under the provisions of Section II.E(Condition 10.6)(Colorado Regulation No.7,Part D, Section II.B.3.a.). [Compliance Monitoring: The owner or operator of affected operations shall maintain records documenting the location of each open-ended valve or line and whether each is: (1) capped, blind flanged, plugged or equipped with a second valve, (2) exempt due to location in an emergency shutdown system, or (3) treated as a "component"and subject to the Leak Detection and Repair Program requirements in Condition 10.6. These records shall be updated on an annual basis. Such records shall be maintained and made available for Division review.] 10.5.7 Beginning January 1, 2015,the rod packing on any reciprocating compressor located at a natural gas compressor station must be replaced every 26,000 hours of operation or every thirty six(36) months, unless the reciprocating compressor is subject to 40 CFR Part 60, Subpart OOOO on that date or thereafter. The measurement of accumulated hours of operation (26,000) or months elapsed (36)begins on January 1, 2015 (Colorado Regulation No. 7, Part D, Section II.B.3.c.). [Compliance Monitoring: The owner or operator shall record: 10.5.7,1 The number of hours of operation for each reciprocating compressor on a monthly basis and maintain a total of hours of operation for each reciprocating compressor since initial startup, January 1, 2015, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later; OR 10.5.7.2 The number of months since initial startup, January 1, 2015, or the date of the most recent reciprocating compressor rod packing replacement, whichever is later. The records required in Conditions 10.5.7.1 and 10.5.7.2 above shall be maintained and made available to the Division upon request.] 10.6 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section II.E. Requirements: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 138 This facility is subject to the following "Leak Detection and Repair Program for Well Production Facilities and Natural Gas Compressor Stations" of Colorado Regulation No. 7, Part D, Section II "Statewide Controls for Oil and Gas Operations": Conditions shown in italic text below represent monitoring,recordkeeping and recording provisions that are not included in Colorado Regulation No.7 as of the issuance date of this permit,but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. 10.6.1 Owners or operators of well production facilities or natural gas compressor stations that monitor components as part of Section II.E. (Condition 10.6)may estimate uncontrolled actual emissions from components for the purpose of evaluating the applicability of component fugitive emissions to Regulation Number 3 by utilizing the emission factors defined as less than 10,000 ppmv of Table 2-8 of the 1995 EPA Protocol for Equipment Leak Emission Estimates (Document EPA- 453/R-95-017). (Colorado Regulation No. 7, Part D, Section II.E.2.). 10.6.2 Beginning January 1, 2015, owners or operators of natural gas compressor stations must inspect components for leaks using an approved instrument monitoring method, in accordance with the following schedule (Colorado Regulation No. 7, Part D, Section II.E.3.): [Clarification: For the purposes of this condition, approved instrument monitoring method means an infra-red camera or EPA Method 21.] 10,6.2.1 Approved instrument monitoring method inspections must begin within ninety (90) days after January 1, 2015, or the date the natural gas compressor station commences operation if such date is after January 1,2015,for natural gas compressor stations with fugitive VOC emissions greater than zero (0) but less than or equal to fifty (50) tons per year, based on a rolling twelve-month total (Colorado Regulation No. 7, Part D, Section II.E.3.a.). a. Annual approved instrument monitoring method inspections at natural gas compressor stations with fugitive VOC emissions greater than zero(0)but less than or equal to twelve (12) tons per year, based on a rolling twelve-month total, must begin within ninety(90) days after January 1, 2015, or the date the natural gas compressor station commences operation if such date is after January 1, 2015. Annual inspections must be conducted through calendar year 2019 (Colorado Regulation No. 7, Part D, Section II.E.3.a.(i)). b. Beginning calendar year 2020, owners or operators of natural gas compressor stations with fugitive VOC emissions greater than zero (0) but less than or equal to twelve (12)tons per year, based on a rolling twelve-month total, must conduct semi-annual approved instrument monitoring method inspections (Colorado Regulation No. 7, Part D, Section II.E.3.a.(ii)). 10.6.2,2 Following the first approved instrument monitoring method inspection, owners or operators must continue conducting approved instrument monitoring method inspections in accordance with the Inspection Frequency in Table 2 (Colorado Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 139 Regulation No. 7, Part D, Section II.E.3.c.): Table 2—Natural Gas Compressor Station Component Inspections Fugitive VOC Emissions (rolling Inspection Frequency twelve-month tpy) > 0 and< 12 Semi-Annually > 12 and<50 Quarterly > 50 Monthly 10.6,2.3 For purposes of Section II.E.3. (Condition 10.6.2), fugitive emissions must be calculated using the emission factors of Table 2-4 of the 1995 EPA Protocol for Equipment Leak Emission Estimates (Document EPA-453/R-95-017), or other Division approved method (Colorado Regulation No. 7, Part D, Section II.E.3.d.). 10.6.3 If a component is unsafe, difficult, or inaccessible to monitor, the owner or operator is not required to monitor the component until it becomes feasible to do so (Colorado Regulation No. 7, Part D, Section II.E.5.). 10.6.3.1 Difficult to monitor components are those that cannot be monitored without elevating the monitoring personnel more than two (2) meters above a supported surface or are unable to be reached via a wheeled scissor-lift or hydraulic type scaffold that allows access to components up to 7.6 meters (25 feet) above the ground (Colorado Regulation No. 7, Part D, Section II.E.5.a.). 10.6.3.2 Unsafe to monitor components are those that cannot be monitored without exposing monitoring personnel to an immediate danger as a consequence of completing the monitoring(Colorado Regulation No. 7, Part D, Section II.E.5.b.). 10.6.3.3 Inaccessible to monitor components are those that are buried, insulated, or obstructed by equipment or piping that prevents access to the components by monitoring personnel (Colorado Regulation No. 7, Part D, Section II.E.5.c.). 10.6.4 Leaks requiring repair: Leaks must be identified utilizing the methods listed in Section II.E.6. (Conditions 10.6.4.1 through 10.6.4.3 below). Only leaks from components exceeding the thresholds in Section II.E.6. (Conditions 10.6.4.1 through 10.6.4.3 below) require repair under Section II.E.7. (Condition 10.6.5) (Colorado Regulation No. 7, Part D, Section II.E.6.). 10.6.4.1 For EPA Method 21 monitoring, at facilities constructed before May 1, 2014,repair is required for leaks with any concentration of hydrocarbon above 2,000 parts per million (ppm) not associated with normal equipment operation, such as pneumatic device actuation and crank case ventilation (Colorado Regulation No. 7, Part D, Section II.E.6.a., except for requirements that apply only to well production facilities). 10.6.4.2 For infra-red camera monitoring, repair is required for leaks with any detectable emissions not associated with normal equipment operation, such as pneumatic device Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 140 actuation and crank case ventilation (Colorado Regulation No. 7, Part D, Section II.E.6.c., except for requirements associated with AVO monitoring, which only apply to well production facilities). 10.6.4.3 For leaks identified using an approved non-quantitative instrument monitoring method, owners or operators have the option of either repairing the leak in accordance with the repair schedule set forth in Section II.E.7. (Condition 10.6.5) or conducting follow-up monitoring using EPA Method 21 within five (5) working days of the leak detection. If the follow-up EPA Method 21 monitoring shows that the emission is a leak requiring repair as set forth in Section II.E.6. (this Condition 10.6.4), the leak must be repaired and remonitored in accordance with Section II.E.7. (Condition 10.6.5). (Colorado Regulation No. 7,Part D, Section II.E.6.e.,except for requirements that apply only to well production facilities). 10.6.5 Repair and remonitoring (Colorado Regulation No. 7, Part D, Section II.E.7.): 10.6.5.1 First attempt to repair a leak must be made no later than five (5) working days after discovery and repair of a leak discovered on or after January 1, 2018, completed no later than thirty (30) working days after discovery, unless parts are unavailable, the equipment requires shutdown to complete repair, or other good cause exists(Colorado Regulation No. 7, Part D, Section II.E.7.a.). a. If parts are unavailable,they must be ordered promptly and the repair must be made within fifteen (15) working days of receipt of the parts (Colorado Regulation No. 7, Part D, Section II.E.7.a.(i)). b. If shutdown is required, a repair attempt must be made during the next scheduled shutdown and final repair completed within two (2) years after discovery (Colorado Regulation No. 7, Part D, Section II.E.7.a.(ii)). c. If delay is attributable to other good cause, repairs must be completed within fifteen (15) working days after the cause of delay ceases to exist (Colorado Regulation No. 7, Part D, Section II.E.7.a.(iii)). 10.6.5.2 Within fifteen (15) working days of completion of a repair, the leak must be remonitored using an approved instrument monitoring method to verify that the repair was effective (Colorado Regulation No. 7, Part D, Section II.E.7.b.). 10.6.5.3 Leaks discovered pursuant to the leak detection methods of Section II.E.6. (Condition 10.6.4) are not subject to enforcement by the Division unless the owner or operator fails to perform the required repairs in accordance with Section II.E.7. (this Condition 10.6.5)or keep required records in accordance with Section II.E.8. (Condition 10.6.6). (Colorado Regulation No. 7, Part D, Section II.E.7.c.). 10.6.6 Recordkeeping: The owner or operator of each facility subject to the leak detection and repair requirements in Section II.E. (Condition 10.6) must maintain the following records and make them available to the Division upon request(Colorado Regulation No. 7, Part D, Section II.E.8.): Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 141 [Clarification:Note that in accordance with the requirements in Section IV, Conditions 22.b and 22.c records shall be kept for a period of f rive years.] 10.6.6.1 The date, facility name, and facility AIRS ID or facility location if the facility does not have an AIRS ID for each inspection (Colorado Regulation No. 7, Part D, Section II.E.8.b.); 10.6.6.2 A list of the leaking components requiring repair and the monitoring method(s) used to determine the presence of the leak (Colorado Regulation No. 7, Part D, Section II.E.8.c.); 10.6.6.3 The date of first attempt to repair the leak and, if necessary, any additional attempt to repair the leak(Colorado Regulation No. 7, Part D, Section II.E.8.d.); 10.6.6.4 The date the leak was repaired and for leaks discovered and repaired on or after January 1, 2018, the type of repair method applied (Colorado Regulation No. 7, Part D, Section II.E.8.e.); 10.6.6.5 The delayed repair list, including the basis for placing leaks on the list (Colorado Regulation No. 7, Part D, Section II.E.8.f.); 10.6.6.6 For leaks discovered on or after January 1, 2018, the delayed repair list must include the date and duration of any period where the repair of a leak was delayed due to unavailable parts, required shutdown, or delay for other good cause, the basis for the delay, and the schedule for repairing the leak. Delay of repair beyond thirty (30) days after initial discovery due to unavailable parts must be reviewed, and a record kept of that review, by a representative of the owner or operator with responsibility for leak detection and repair compliance functions. This review will not be made by the individual making the initial determination to place a part on the delayed repair list; (Colorado Regulation No. 7, Part D, Section II.E.8.g.); 10.6.6.7 The date the leak was remonitored and the results of the remonitoring (Colorado Regulation No. 7, Part D, Section II.E.8.h.); and 10.6.6.8 A list of components that are designated as unsafe,difficult,or inaccessible to monitor, as described in Section 11.E.5. (Condition 10.6.3), an explanation stating why the component is so designated, and the schedule for monitoring such component(s) (Colorado Regulation No. 7, Part D, Section II.E.8.i.). 10.6.7 [Additional Monitoring: The owner or operator shall maintain records that document the categories of equipment operation that may result in emissions but are not considered to be leaks under Colorado Regulation No. 7, Part D, Section II E.6. (Condition 10.6.4)because they qual as "normal equipment operation". This requirement shall not apply to pneumatic device actuation and crankcase ventilation, which are already explicitly defined in the rule as normal equipment operation. The records shall include a description of each category or type of"normal equipment operation"and a description of the component or equipment type associated with that category.] Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 142 10.6.8 Reporting: The owner or.operator of each facility subject to the leak detection and repair requirements in Section II.E. (Condition 10.6) must submit a single annual report on or before May 31st of each year (beginning May 31st, 2019) that includes, at a minimum, the following information regarding leak detection and repair activities at their subject facilities conducted the previous calendar year(Colorado Regulation No. 7, Part D, Section II.E.9.): 10.6.8.1 The total number of well production facilities and total number of natural gas compressor stations inspected (Colorado Regulation No. 7, Part D, Section II.E.9.a.); 10.6.8.2 The total number of inspections performed per inspection frequency tier of well production facilities and inspection frequency tier of natural gas compressor stations (Colorado Regulation No. 7, Part D, Section II.E.9.b.); 10.6.8.3 The total number of identified leaks requiring repair, broken out by component type, monitoring method, and inspection frequency tier of well production facilities, as reported in Section II.E.9.b. (Condition 10.6.8.2), or inspection frequency tier of natural gas compressor stations(Colorado Regulation No. 7,Part D, Section II.E.9.c.); 10.6.8.4 The total number of leaks repaired for each inspection frequency tier of well production facilities, as reported in Section II.E.9.b. (Condition 10.6.8.2), or inspection frequency tier of natural gas compressor stations(Colorado Regulation No. 7, Part D, Section II.E.9.d.); 10.6.8.5 The total number of leaks on the delayed repair list as of December 31st broken out by component type, inspection frequency tier of well production facilities, as reported in Section II.E.9.b. (Condition 10.6.8.2), or inspection frequency tier of natural gas compressor stations, and the basis for each delay of repair(Colorado Regulation No. 7, Part D, Section II.E.9.e.); 10.6.8.6 The record of all reviews conducted for delayed repairs due to unavailable parts extending beyond 30 days for the previous calendar year(Colorado Regulation No. 7, Part D, Section II.E.9.f.); and 10.6.8.7 Each report must be accompanied by a certification by a responsible official that,based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete (Colorado Regulation No. 7, Part D, Section II.E.9.g.). 10.7 [State-Only Enforceable] Colorado Regulation No. 7, Part D, Section V. Requirements: This facility is subject to the following "Oil and Natural Gas Operations Inventory" requirements of Colorado Regulation No. 7, Part D, Section V.: Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that are not included in Colorado Regulation No.7 as of the issuance date of this permit,but are being included as per Colorado Regulation No 3, Part C, Section V.C.5.b. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 143 10,7.1 On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format(Colorado Regulation No. 7, Part D, Section V.A.). 10.7.2 General reporting requirements (Colorado Regulation No. 7, Part D, Section V.B.). 10.7.2.1 The following information must be reported in accordance with Section V.A (Condition 10.7.1) (Colorado Regulation No. 7, Part D, Section V.B.1.). a. Company name, physical street address, and name and contact information of the company representative, for reporting purposes (Colorado Regulation No. 7, Part D, Section V.B.1.a.). b. The date of submittal and the year covered by the report(Colorado Regulation No. 7, Part D, Section V.B.1.b.). c. A list of the activities or equipment, as specified in Section V.C. (Condition 10.7.3), for which emissions are reported (Colorado Regulation No. 7, Part D, Section V.B.1.c.). d. The company's monthly actual emissions of volatile organic compounds (VOC), oxides of nitrogen (NOx), carbon monoxide (CO), methane, and ethane for each month of May through September (Colorado Regulation No. 7, Part D, Section V.B.1.d.). e. The company's annual actual emissions of VOCs, NOx, CO, methane, and ethane for the entire calendar year(Colorado Regulation No. 7,Part D, Section V.B.1.e.). f. The actual emissions of VOCs, NOx, CO, methane, and ethane for each activity or equipment listed in Section V.C. (Condition 10.7.3) per facility, or per pipeline between facilities where the pipeline is not located at a stationary source (Colorado Regulation No. 7, Part D, Section V.B.1.f.). (i) The report must include the actual emissions from each activity or equipment per month for each month of May through September (Colorado Regulation No. 7, Part D, Section V.B.1.f.(i)). (ii) The report must include the actual emissions from each activity or equipment for the entire calendar year(Colorado Regulation No.7,Part D, Section V.B.1.f.(ii)). g. A certification by the company representative that supervised the development and submission of the inventory report that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete (Colorado Regulation No. 7, Part D, Section V.B.1.g.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 144 10.7.2.2 The owner or operator must submit a revised annual report after discovering that an annual report submitted within the previous two (2) years contained one or more substantive errors. A substantive error is a mass of emissions of any individual pollutant subject to reporting under Section V. (Condition 10.7) that is at least 10% higher or lower than the mass of emissions of the pollutant reported across the owner or operator's activity or equipment, as listed in Section V.C. (Condition 10.7.3), in Colorado. A refinement of or improvement to an emissions estimation technique or emission factor is not a substantive error but must be noted in the subsequent annual report after the refinement or improvement. Revised annual reports must be submitted by August 31 if the substantive error is discovered between January 1 and June 30, and by February 28 if the substantive error is discovered between July 1 and December 31 of the preceding calendar year(Colorado Regulation No. 7,Part D, Section V.B.2.). 10.7.3 Beginning July 1,2020,and each calendar year thereafter,owners or operators must maintain the following information for inclusion in the annual report (Colorado Regulation No. 7, Part D, Section V.C.). 10.7.3.1 AIRS number of the activity or equipment and associated facility or pipeline (if a pipeline between facilities) location, including latitude and longitude coordinates. If the activity or equipment does not have an AIRS number, a description of the activity or equipment(Colorado Regulation No. 7, Part D, Section V.C.1.). 10.7.3.2 Actual emissions from each activity or equipment listed in this Section V.C.2., unless otherwise specified in the Division-approved report format,and the emission factor(s), assumptions, and calculation methodology used to calculate the emissions (Colorado Regulation No. 7, Part D, Section V.C.2.). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199 RENEWED: DRAF Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE1 03 Page 145 11. Portable Monitoring(ver.6/26/2014) Emission measurements of nitrogen oxides (NOx) and carbon monoxide (CO) shall be conducted quarterly using a portable flue gas analyzer. At least one calendar month shall separate the quarterly tests. Note that if the engine is operated for less than 100 hrs in any quarterly period, then the portable monitoring requirements do not apply. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's website at: https://cdphe.colorado.gov/compliance-and-enforcement Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual or short term emission limit,the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year(8760), whichever applies. If the portable analyzer results indicate compliance with both the NOx and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOx and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOx or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOx and CO emission limitations or until the engine is taken offline. For comparison with the emission rates/factors, the emission rates/factors determined by the portable analyzer tests and approved by the Division shall be converted to the same units as the emission rates/factors in the permit. If the portable analyzer tests shows that either the NOx or CO emission rates/factors are greater than the relevant ones set forth in the permit, and in the absence of subsequent testing results to the contrary (as approved by the Division), the permittee shall apply for a modification to this permit to reflect, at a minimum, the higher emission rate/factor within 60 days of the completion of the test. Results of all tests conducted shall be kept on site and made available to the Division upon request. 11.1 The outlet oxygen content of the exhaust stream shall be measured during portable monitoring when measurement of the outlet CO content is being conducted. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 146 12. Compliance Assurance Monitoring (ver.4/16/2009) 12.1 The Compliance Assurance Monitoring(CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to the following units: 12.1.1 C-238, C-235, C-236 and C-234 — Four(4) Caterpillar Model G3612 Engines (3,550 hp) with respect to the VOC limitations identified in Condition 1.2. 12.1.1.1 Excursions,for the purposes of reporting, are defined as any catalyst inlet temperature reading that is less than 450°F or greater than 1350°F. 12.1.2 C-237 — One (1) Caterpillar Model G3616 Engine (4,735 hp) with respect to the CO emission limitation identified in Condition 2.1 and the VOC emission limitation identified in Condition 2.2. 12.1.2.1 Excursions, for the purposes of reporting, are defined as any catalyst inlet temperature reading that is less than 450°F or greater than 1350°F. 12.1.3 D-2—One (1) Forum TEG Dehydration Unit (110 MMscfd) with respect to the VOC limitation identified in Condition 3.1 and the HAP limitation identified in Condition 9.1. 12.1.3.1 Excursions, for the purposes of reporting, are defined as any absence of the enclosed combustion device pilot flame, except during periods of permitted downtime. 12.1.4 D-3—One (1)Custom TEG Dehydration Unit(145 MMscfd)with respect to the VOC limitation identified in Condition 4.1 and the HAP limitation identified in Condition 9.2. 12.1.4.1 Excursions, for the purposes of reporting, are defined as any absence of the enclosed combustion device pilot flame, except during periods of permitted downtime. The permittee shall follow the CAM Plan provided in Appendix G of this permit. Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 12.1.5 Operation of Approved Monitoring 12.1.5.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to,maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(b),as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 12.1.5.2 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities(including, as applicable,calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation(or shall collect data at all required intervals)at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs,and required quality assurance or control activities shall not be used for purposes of these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 147 applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions (40 CFR Part 64 § 64.7(c),as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). 12.1.5.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance,the owner or operator shall restore operation of the pollutant-specific emissions unit(including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance(other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device,associated capture system,and the process(40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.5.4 After approval of the monitoring required under the CAM requirements, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions,the owner or operator shall promptly notify the Division and, if necessary submit a proposed modification for this permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters (40 CFR Part 64 § 64.7(e),as adopted by reference in Colorado Regulation No. 3,Part C, Section XIV). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT { Air Pollution Control Division DCP Operating Company, L1 Colorado Operating Permit Enterprise Compressor Statio Permit# 95OPWE103 Page 141 12.1.6 Quality Improvement Plan (QIP) Requirements 12.1.6.1 Based on the results of a determination made under the provisions of Condition 12.1.5.3b, the Division may require the owner or operator to develop and implemen a QIP(40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation No 3, Part C, Section XIV). 12.1.6.2 The owner or operator shall maintain a written QIP, if required, and have it availablqi for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures,the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted b$ reference in Colorado Regulation No. 3, Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part Section XIV). e. More frequent or improved monitoring (only in conjunction with one or moil steps under Conditions a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), a$ adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.4 If a QIP is required, the owner or operator shall develop and implement a QIP a§ expeditiously as practicable and shall notify the Division if the period for completinf the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted b' reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.5 Following implementation of a QIP, upon any subsequent determination pursuant t Condition 12.1.5.3b, the Division or the U.S. EPA may require that an owner ci!• operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (4? CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 199? RENE WED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 149 air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.6.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal,state,or local law,or any other applicable requirements under the federal clean air act(40 CFR Part 64 § 64.8(e),as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.7 Reporting and Recordkeeping Requirements 12.1.7.1 Reporting Requirements: The reports required by Section IV, Condition 22.d shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) ((40 CFR Part 64 § 64.9(a)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); and b. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 12.1.6 of this permit. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring (40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.7,2 General Recordkeeping Requirements: In addition to the recordkeeping requirements in Section IV, Condition 22.a through 22.c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 12.1.6 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 150 recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8 Savings Provisions 12.1.8.1 Nothing in these CAM requirements shall excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal,state,or local law,or any other applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring,recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 12.1.8.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act(40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 151 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, I.A.4, V.D. & XIILB; 25-7-114.4(3)(a), C.R.S. 1. Specific Non-Applicable Requirements Based upon the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non-applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition,this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. Emission Unit Description& Number Applicable Requirement Justification C-238 Caterpillar G3612 3,550 hp C-235 Caterpillar G3612 3,550 hp Colorado Regulation No. 1,Section Internal combustion engines are not considered fuel burning C-236 Caterpillar G3612 3,550 hp III.A.1.b.-Particulate emissions from equipment for the purposes of the Colorado Regulation No. C-234 Caterpillar G3612 3,550 hp fuel-burning equipment 1 Particulate Matter Standards. C-237 Caterpillar G3616 4,735 hp Colorado Regulation No.7,Part B, These regulations are intended to apply to gasoline storage Sections IV.B.1 and IV.B.2-Storage of , and loading facilities and are therefore not applicable to Petroleum Distillates condensate at a natural gas compressor station. Facility-wide This regulation requires crude oil storage tanks over 40,000 Colorado Regulation No.7,Part B, gallons to comply with selected requirements from Colorado Section V.C-Crude Oil Storage Regulation No.7,Part B,Section IV.This natural gas compressor station does not store crude oil,and is therefore not required to comply with this requirement. Operating Permit Number: 95OPWEI03 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 152 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of§§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance. 2.3 The applicable requirements of the federal Acid Rain Program,consistent with § 408(a)of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7- 111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. 3. Streamlined Conditions 3.1 The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition I Streamlined(Subsumed)Requirements SECTION II-5.8.1.2c(v) Colorado Regulation No.7,Part D,Section II.C.5.a.(iii)(E)[only with respect to inspection frequency]—State-Only Requirement SECTION II-6.6.2.7e Colorado Regulation No. 7, Part D, Section II.C.1.d.(v) [only with respect to inspection frequency]—State-Only Requirement SECTION II - 10.6.2 Colorado Regulation No. 7, Part D, Section II.A.2. [definition of Approved Instrument Monitoring Method—only with respect to other Division-approved alternatives] —State- SECTION II- 10.6.4 Only Requirement Colorado Regulation No. 7, Part D, Section II.C.3. [only the requirement to maintain records for two years]—State-Only Requirement General Conditions Colorado Regulation No. 7, Part D, Section II.C.4.f. [only the requirement to maintain SECTION IV-22.b records for two years]—State-Only Requirement SECTION IV-22.c Colorado Regulation No. 7,Part D, Section II.C.5.a.(v) [only the requirement to maintain records for two years]—State-Only Requirement Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 153 Permit Condition , Streamlined(Subsumed)Requirements Colorado Regulation No. 7, Part D, Section II.E.8. [only the requirement to maintain records for two years]—State-Only Requirement Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 154 SECTION IV- General Permit Conditions(ver.,1/21/2020) 1. Administrative Changes Regulation No.3,5 CCR 1001-5,Part A,§III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3,Part A, § I.B.I. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No.3,5 CCR 1001-5,Part C,§§ III.B.9.,V.C.16.a.&e.and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No.3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry,the statements and information in the document are true,accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) method(s)used for determining the compliance status of the source,currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r)of the federal act,the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation,5 CCR 1001-2 §$ILA., 11.B.,ILC.,ILE.,II.F.,II.I,and ILJ a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line,such emissions shall not cause the air quality standards of the receiving State to be exceeded,provided reciprocal action is taken by the receiving State. b. Emission Monitoring Requirements Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 155 The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall,upon request of the Division,conduct performance test(s)and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s)shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases,the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance;or (iv) waives the requirement for performance test(s)because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25,Article 7,and pursuant to regulations promulgated by the Commission. Compliance test(s)shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility.The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide,or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s);and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method.Each run shall be conducted for the time and under the conditions specified in the applicable standard.For the purpose of determining compliance with an applicable standard,the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control,compliance may,upon the Division's approval,be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 156 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s)if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement,the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided,or planned for,and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions(including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact of the excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement;and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants.The affirmative defense provision does not apply to state implementation plan(sip)limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but not necessarily limited to, certain limits with 30-day or longer averaging times, limits that indicate they apply during malfunctions,and limits that indicate they apply at all times or without exception. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 157 e. Circumvention Clause A person shall not build, erect, install,or use any article, machine, equipment,condition,or any contrivance,the use of which,without resulting in a reduction in the total release of air pollutants to the atmosphere,reduces or conceals an emission which would otherwise constitute a violation of this regulation.No person shall'circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use,of any credible evidence or information,relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement, the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. g. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown.To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life,personal injury,or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation(if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times,the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator,and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible,but no later than two(2)hours after the start of the next working day,and shall submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, L Colorado Operating Permit Enterprise Compressor Statio Permit# 95OPWE103 Page 15 The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants, or an}'l other federally enforceable performance standard or emission limit with an averaging time greater than twenty-fouti hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the' excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention o Significant Deterioration(PSD)increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No.3,5 CCR 1001-5,Part C, &$ III.C.9.,V.C.11.& 16.d. and§25-7-122.1(2),C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally-enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state-only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under§304 of the federal act. Any such violation of the federal act,the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination,revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified,revoked, reopened,and reissued,or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of Regulation No.3,Part C. d. The permittee shall furnish to the Air Pollution Control Division,within a reasonable time as specified by the Division, any information that the Division may request in writing to determine whether cause exists for modifying,revoking and reissuing,or terminating the permit or to determine compliance with the permit. Upon request,the permittee shall also furnish to the Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of I'I permit issuance,the permittee shall submit,at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division,progress reports which contain the following: (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities,milestones,or compliance were achieved;and Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 159 (ii) an explanation of why any dates in the schedule of compliance were not or will not be met,and any preventive or corrective measures adopted. g. The permittee shall not knowingly falsify,tamper with,or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No.3,5 CCR 1001-5,Part C,§ VII An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology-based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation,or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology-based emission limitation if the permittee demonstrates,through properly signed,contemporaneous operating logs,or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s)of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards,or other requirements in the permit;and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions,and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10,Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8,Part B,"asbestos control." 7. Emissions Trading,Marketable Permits,Economic Incentives Regulation No.3,5 CCR 1001-5,Part C, § V.C.13. No permit revision shall be required under any approved economic incentives,marketable permits,emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S §§25-7-114.1(6)and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. §25-7-114.7. A 1%per month late payment fee shall be assessed against any invoice amounts not paid in full on the 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 160 b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours,it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance with the provisions of C.R.S. §25-7-114.1(6)for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1,5 CCR 1001-3, § III.D.I. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere,in accordance with the provisions of Regulation No. 1,§ III.D.1. 10. Inspection and Entry Regulation No.3,5 CCR 1001-5,Part C, V.C.16.b. Upon presentation of credentials and other documents as may be required by law,the permittee shall allow the Air Pollution Control Division,or an'y authorized representative,to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions-related activity is conducted,or where records must be kept under the terms of the permit; b. have access to,and copy,at reasonable times,any records that must be kept under the conditions of the permit; c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices,or operations regulated or required under the Operating Permit; d. sample or monitor at reasonable times,for the purposes of assuring compliance with the Operating Permit or applicable requirements,any substances or parameters. 11. Minor Permit Modifications Regulation No.3,5 CCR 1001-5,Part C, §§ X.&XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No.3, 5 CCR 1001-5,Parts B&D The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No.3,Parts B and/or D,as applicable,without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No.3, 5 CCR 1001-5,Part C,§V.C.1 l.d. This permit does not convey any property rights of any sort,or any exclusive privilege. 14. Odor Regulation No.2,5 CCR 1001-4,Part A Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 161 As a matter of state law only,the permittee shall comply with the provisions of Regulation No.2 concerning odorous emissions. 15. Off-Permit Changes to the Source Regulation No.3,5 CCR 1001-5,Part C, XII.B. The permittee shall record any off-permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permit shield shall not apply to any off-permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, §§ 1., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§I.- II. 17. Open Burning Regulation No.9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No.9. 18. Ozone Depleting Compounds Regulation No. 15,5 CCR 1001-19 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections I.,II.C., 1I.D.,III.IV.,and V.of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No.3,5 CCR 1001-5,Part C, §& II1.B.6., IV.C.,V.C.2. a. The permit term shall be five(5)years. The permit shall expire at the end of its term. Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted. b. Applications for renewal shall be submitted at least twelve months,but not more than 18 months,prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision,supplementing,or deletion,incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No.3,5 CCR 1001-5,Part C,§II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No.3,5 CCR 1001-5, Part C,§ V.C.7.b. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 162 The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit,the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt"is defined as follows: a. Any definition of"prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit;or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant(as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant,excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements,the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements,the report shall be submitted every six(6)months,except as otherwise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met,the source shall notify the Division by telephone(303- 692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit.] A written notice,certified consistent with General Condition 2.a.above(Certification Requirements),shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6-month report required above. "Prompt reporting"does not constitute an exception to the requirements of"Emergency Provisions"for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No.3,5 CCR 1001-5, Part A,§ II.;Part C,§§ V.C.6.,V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date,place as defined in the Operating Permit,and time of sampling or measurements; (ii) date(s)on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis;and (vi) the operating conditions at the time of sampling or measurement. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 163 b. The permittee shall retain records of all required monitoring data and support information for a period of at least five (5)years from the date of the monitoring sample, measurement, report or application. Support information, for this purpose, includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division,the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve(12) month period, as well as compliance certifications for the past five (5)years on-site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six(6)months,unless an applicable requirement,the compliance assurance monitoring rule,or the Division requires submission on a more frequent basis. All instances of deviations from any permit requirements must be clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice("APEN")prior to constructing,modifying,or altering any facility,process,activity which constitutes a stationary source from which air pollutants are or are to be emitted,unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § II.D or as provided for in Regulation No. 3,Part A, § II.A.2 for oil and gas well production facilities. A revised APEN shall be filed annually whenever a significant change in emissions,as defined in Regulation No. 3,Part A, §II.C.2.,occurs;whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified;or before the APEN expires. An APEN is valid for a period of five years.The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year.Where a permit revision is required,the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs, except an APEN shall be filed once per year for control equipment at condensate storage tanks located at oil and gas exploration and production facilities subject to Regulation No. 7,Part D§ I.Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No.3,5 CCR 1001-5,Part C, XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No.3,Part C,§III.,except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years,unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements(including excess emissions requirements)become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit#95OPWE103 Page 164 24. Requirements for Major Stationary Sources Regulation No.3,5 CCR 1001-5,Part D,$$V.A.7.c&d,VI.B.5&VI.B.6 The following provisions apply to projects at existing emissions units at a major stationary source (other than projects at a source with a PAL) that are not part of a major modification and where the owner or operator relies on projected actual emissions. The definitions of baseline actual emissions, major modification, major stationary source, PAL, projected actual emissions,regulated NSR pollutant and significant can be found in Regulation No.3,Part D, § ILA. a. Before beginning actual construction of the project,the owner or operator shall document and maintain a record of the following information: (i) a description of the project; (ii) identification of the emissions unit(s)whose emissions of a regulated NSR pollutant could be affected by the project;and (iii) a description of the applicability test used to determine the project is not a major modification for any regulated NSR pollutants,including the baseline actual emissions,the projected actual emissions,the amount of emissions excluded and an explanation for why such amount was excluded,and any netting calculations, if applicable. b. The owner or operator shall monitor emissions of any regulated NSR pollutant that could increase as a result of the project from any emissions units identified in paragraph a(ii) and calculate and maintain a record of the annual emissions, in tons per year on a calendar year basis, for a period of five (5) years following resumption of regular operation after the change,or for a period of ten(10)years following resumption of regular operation after the change if the project increases the design capacity or potential to emit of that regulated NSR pollutant at such emissions unit. c. For existing electric utility steam generating units the following requirements apply: (i) Before beginning actual construction,the owner or operator shall provide a copy of the information required by paragraph a above to the Division.The owner or operator is not required to obtain a determination from the Division prior to beginning actual construction. (ii) The owner or operate shall submit a report to the Division within sixty days after the end of each year during which records must be generated under paragraph b above setting out the unit's annual emissions during the calendar year that preceded submission of the report. d. For existing emissions units that are not electric utility steam generating units,the owner or operator shall submit a report to the Division if the annual emissions from the project,in tons per year,exceed the baseline actual emissions (documented and maintained per paragraph a(iii)) by a significant amount for that regulated NSR pollutant, and if such emissions differ from the preconstruction projection (documented and maintained per paragraph a(iii)). Such report shall be submitted to the Division within sixty days after the end of such year. The report shall contain the following: (i) The name,address and telephone number of the owner or operator; (ii) The annual emissions as calculated per paragraph b;and (iii) Any other information that the owner or operator wishes to include in the report. e. The owner of operation of the source shall make the information in paragraph a available for review upon request to the Division or the general public. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 165 25. Section 502(b)(10)Changes Regulation No.3,5 CCR 1001-5, Part C, §XII.A. The permittee shall provide a minimum 7-day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 26. Severability Clause Regulation No.3,5 CCR 1001-5,Part C,§V.C.10. In the event of a challenge to any portion of the permit,all emissions limits,specific and general conditions,monitoring,record keeping and reporting requirements of the permit,except those being challenged,remain valid and enforceable. 27. Significant Permit Modifications Regulation No.3,5 CCR 1001-5,Part C, § III.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No.3,Part B("Construction Permit"requirements)without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 28. Special Provisions Concerning the Acid Rain Program Regulation No.3, 5 CCR 1001-5,Part C, §§V.C.1.b.&8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act,40 Code of Federal Regulations(CFR)Part 72,both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder,40 CFR Part 72,are expressly prohibited. 29. Transfer or Assignment of Ownership Regulation No.3, 5 CCR 1001-5, Part C, § II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division-supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit,responsibility,coverage,and liability between the permittee and the prospective owner or operator has been submitted to the Division. 30. Volatile Organic Compounds Regulation No.7,5 CCR 1001-9,Part B, §§I&III. The requirements in paragraphs a,b and e apply to sources located in the Denver 1-hour ozone attainment/maintenance area, any nonattainment area for the 1-hour ozone standard and to the 8-hour Ozone Control Area and on a state-only basis to sources located in any ozone nonattainment area,which includes areas designated nonattainment for either the 1-hour or 8-hour ozone standard,unless otherwise specified in Regulation No.7,Part A,Section I.A.1.c.The requirements in paragraphs c and d apply statewide. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division DCP Operating Company, LP Colorado Operating Permit Enterprise Compressor Station Permit# 95OPWE103 Page 166 a. All storage tank gauging devices, anti-rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened,actuated,or used for necessary and proper activities(e.g.maintenance). Such opening,actuation,or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used,detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No.7,Part B,Section VI.C.3. b. Except as otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank,container,or vehicle compartment with a capacity exceeding 212 liters(56 gallons), shall be transferred using submerged or bottom filling equipment.For top loading,the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom-fill operations,the inlet shall be flush with the tank bottom. c. No person shall dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology(RACT)is utilized. d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7,Part B, Sections IV.C.2., IV.C.3. and VII.A.3., shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 psia actual conditions are exempt from the provisions of paragraph b,above. 31. Wood Stoves and Wood burning Appliances Regulation No.4,5 CCR 1001-6 The permittee shall comply with the provisions of Regulation No.4 concerning the advertisement,sale,installation,and use of wood stoves and wood burning appliances. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - COMPLIANCE ASSURANCE MONITORING H - AOS APPLICABILITY REPORTS DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in this permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 1 APPENDIX A Inspection Information 1. Directions to Facility: The station is in the Southwest quarter of the Southwest quarter Section of Section 30, Township 3 North, Range 63 West in Weld County. The station is one (1) mile North of US Highway 76 on the Gutterson Road between the towns of Keenesburg and Roggen. 2. Safety Equipment Required: • Hard Hat • Safety Shoes (Steel-Toed Boots) • Hearing Protection • Eye Protection • Fire Retardant Clothing 3. Facility Plot Plan: The attached figure below shows the plot plan as submitted in the May 17, 2019 construction permit application for 19WE0492. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 2 H+uemlel ..Cali....K.S sii, . I _ Ili it148 •JUNI ��I I ! ,$ L 10i i i g D ill I I I ell h. 6 i ,i7@ I tae (�� tie+_ !!!i I C :li " t I�sii e !i i nil g I @i1 iii39ii�r �4 " i '-iIIIiiIIiniIllI Taiii ! I I llt1iRI�i R9tia 6 ii nii. at °a 5tigi#tladifiel -#�1 -: N m;aria-imam m e E HMV!!!!i 04 r:mid mligiiHr 4`:' i . ! [° 1 C=1:8 Ngi r= ... f Ilil•.*' G e_ =- P r.,I IT 1 ifia i , i iF4 .. I • $ I I 1 IP , ! 3 Mill -A r-. !i , ,4,4 1, 1i TTT �`` _ tQ�l'1'It% . �;o ® r ..,,,..__.,. . . ___....._______ ....„.a A Art Joli'rill 4.- A. ��F�" I ° M I Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: ]].RAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 3 4. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. The asterisk (*) denotes an insignificant activity source category based on the size of the activity, emissions levels from the activity or the production rate of the activity. The owner or operator of individual emission points in insignificant activity source categories marked with an asterisk (*) must maintain sufficient record keeping verifying that the exemption applies. Such records shall be made available for Division review upon request(Colorado Regulation No. 3, Part C, Section II.E). *Colorado Regulation No. 3, Part C, Section II.E.3.a: Individual emission points in nonattainment areas having uncontrolled actual emissions of any criteria pollutant(as defined in Section I.B.17. of Part A of this Regulation Number 3)of less than one ton per year and individual emission points in attainment or attainment/maintenance areas having uncontrolled actual emissions of any criteria pollutant of less than two tons per year, and each individual emission point with uncontrolled actual emissions of lead less than one hundred pounds per year, regardless of where the source is located. • One(1) 16" Marla Pig Receiver Blowdown • One (1) 20" Inlet Pig Receiver Blowdown • One (1) 12" Inlet Pig Receiver Blowdown • One (1) 20" Pig Launcher Blowdown • One (1) 16"Pig Launcher Blowdown • One (1) 16" Roggen Pig Launcher Blowdown • Pressurized Condensate Loadout Rack • Two (2) 30,000 gal Pressurized Bullet Tanks (P014A, P014B) • Two (2) 80 bbl Sump Tanks (Sump 3, Sump 5) • One (1) 475 gal Sump Tank(Sump 4) • One (1) 80 bbl TEG/Cond Collection (Sump 6) • One (1) 80 bbl TEG Stormwater Collection (Sump 7) • Two (2) 10 acfm Remediation Skimmers/Bubblers *Colorado Regulation No. 3, Part C, Section II.E.3.k: Each individual piece of fuel burning equipment, other than smokehouse generators and internal combustion engines, that uses gaseous fuel, and that has a design rate less than or equal to five million British thermal units per hour. • One (1) 2.5 MMBtu/hr D-2 Dehy Reboiler Burner • One (1) 1.5 MMBtu/hr D-3 Dehy Reboiler Burner • One (1) 0.75 MMBtu/hr NG Fired Separator Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix A Inspection Information Page 4 • One (1) 0.006 MMBtu/hr 212950 Meter Shed Heater • One (1) 0.006 MMBtu/hr 214551 Meter Shed Heater Colorado Regulation No. 3, Part C, Section II.E.3.aaa: Storage tanks of capacity less than forty thousand gallons of lubricating oils or waste lubricating oils. • One (1) 210 bbl Lube Oil Tank • One (1) 68 bbl Used Oil Tank • Two (2) 475 gal Used Oil Tanks • Two (2) 300 gal Lube Oil Day Tanks • One (1) 80 bbl Slop Oil Sump (Sump 8) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 5 APPENDIX B Reporting Requirements and Definitions with codes ver 8/20/2014 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement,representation,or certification in,or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies,tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report#1: Monitoring Deviation Report(due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 6 Report#2: Permit Deviation Report(must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above,each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit are required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations,that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1 = Standard: When the requirement is an emission limit or standard 2 =Process: When the requirement is a production/process limit 3 =Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7 =Report: When the requirement is reporting Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 7 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring(CAM)Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Report#3: Compliance Certification (annually,as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act,which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit,and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. 1 For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 8 The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64(the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 9 Startup, Shutdown, Malfunctions and Emergencies, Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown,and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 10 APPENDIX B: Monitoring and Permit Deviation Report - Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: DCP Operating Company, LP—Enterprise Compressor Station OPERATING PERMIT NO: 95OPWE103 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Malfunction/Emergency Deviations noted Deviation Code 2 Condition Reported Operating During Period?' p Permit Unit During Period? ID Unit Description YES NO YES NO Caterpillar Model G3612 Turbocharged Natural Gas Fired 053 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp Caterpillar Model G3612 Turbocharged Natural Gas Fired 055 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp Caterpillar Model G3612 Turbocharged Natural Gas Fired 056 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp 063 Eight(8)300 bbl Stabilized Condensate Atmospheric Storage Tanks • 066 Stabilized Condensate Atmospheric Truck Loadout Forum Energy Technologies Custom TEG Dehydration Unit, 068 Rated at 110 MMscfd Leed Fabrication Model L30-0018-00 Enclosed Combustion Device Caterpillar Model G3612 Turbocharged Natural Gas Fired 070 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp Caterpillar Model G3616 Turbocharged Natural Gas Fired 071 Reciprocating Internal Combustion Engine, Site Rated at 4,735 hp Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 11 Deviations notedMalfunction/Emergency Operating During Period?' Deviation Code 2 Condition Reported Permit Unit During Period? ID Unit Description YES NO YES NO 075 Two(2)90 bbl Produced Water Atmospheric Storage Tanks 076 Natural gas venting from reciprocating compressor blowdowns TEG Dehydration Unit,Rated at 145 MMscfd 077 Leed Fabrication Model L30-0018-00 Enclosed Combustion Device General Conditions Insignificant Activities 1 See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. Use the following entries,as appropriate 1 = Standard: When the requirement is an emission limit or standard 2=Process: When the requirement is a production/process limit 3=Monitor: When the requirement is monitoring 4=Test: When the requirement is testing 5=Maintenance: When required maintenance is not performed 6=Record: When the requirement is recordkeeping 7=Report: When the requirement is reporting 8=CAM: A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. 9=Other: When the deviation is not covered by any of the above categories Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 12 APPENDIX B: Monitoring and Permit Deviation Report - Part II FACILITY NAME: DCP Operating Company, LP—Enterprise Compressor Station OPERATING PERMIT NO: 95OPWE103 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported(if applicable) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 13 Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 • RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 14 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1 800 4/10/06 Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 15 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix B Monitoring and Permit Deviation Report Page 16 APPENDIX B: Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: DCP Operating Company, LP—Enterprise Compressor Station FACILITY IDENTIFICATION NUMBER: 123-0277 PERMIT NUMBER: 95OPWE103 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi-Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and,based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub-Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub-Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 17 APPENDIX C Required Format for Annual Compliance Certification Report(ver 8/20/2014) Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: DCP Operating Company, LP - Enterprise Compressor Station OPERATING PERMIT NO: 95OPWE103 REPORTING PERIOD: I. Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit,each term and condition of which is identified and included by this reference,during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit,unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Deviations Monitoring Was compliance continuous p g Method per Permit Unit Unit Description Reported Permit?2 or intermittent?3 ID Previous I Current YES I NO Continuous I Intermittent Caterpillar Model G3612 Turbocharged Natural Gas Fired 053 Reciprocating Internal Combustion Engine,Site Rated at 3,550 hp Caterpillar Model G3612 Turbocharged Natural Gas Fired 055 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp Caterpillar Model G3612 Turbocharged Natural Gas Fired 056 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp 063 Eight (8) 300 bbl Stabilized Condensate Atmospheric Storage Tanks 066 Stabilized Condensate Atmospheric Truck Loadout Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 18 Deviations Monitoring Was com liance continuous Operating Method per p p Permit?- 2 �3 Permit Unit Unit Description Reported or intermittent. ID Previous I Current YES I NO Continuous I Intermittent Forum Energy Technologies Custom TEG Dehydration Unit,Rated at 110 MMscfd 068 Leed Fabrication Model L30-0018-00 Enclosed Combustion Device Caterpillar Model G3612 Turbocharged Natural Gas Fired 070 Reciprocating Internal Combustion Engine, Site Rated at 3,550 hp Caterpillar Model G3616 Turbocharged Natural Gas Fired 071 Reciprocating Internal Combustion Engine, Site Rated at 4,735 hp 075 Two(2)90 bbl Produced Water Atmospheric Storage Tanks 076 Natural gas venting from reciprocating compressor blowdowns TEG Dehydration Unit,Rated at 145 MMscfd 077 Leed Fabrication Model L30-0018-00 Enclosed Combustion Device General Conditions Insignificant Activities 4 ' If deviations were noted in a previous deviation report,put an"X"under"previous". If deviations were noted in the current deviation report(i.e.for the last six months of the annual reporting period),put an"X"under"current". Mark both columns if both apply. ' Note whether the method(s)used to determine the compliance status with each term and condition was the method(s)specified in the permit. If it was not,mark "no"and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore,if a source 1)conducts all of the monitoring and recordkeeping required in its permit,even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non- compliance,and if 3)the Responsible Official is not aware of any credible evidence that indicates non-compliance,then the Responsible Official can certify that the emission point(s)in question were in continuous compliance during the applicable time period. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix C Compliance Certification Report Page 19 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility is is not in compliance with all the requirements of section 112(r). 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix D Notification Addresses Page 20 APPENDIX D Notification Addresses (ver. 1/27/2020) 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Title V Unit Supervisor 2. United States Environmental Protection Agency Compliance Notifications: Enforcement and Compliance Assurance Division Air and Toxics Enforcement Branch Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10) Changes, Off Permit Changes: Air and Radiation Division Air Permitting and Monitoring Branch Mail Code 8ARD-PM U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 21 APPENDIX E Permit Acronyms Listed Alphabetically: AIRS - Aerometric Information Retrieval System AP-42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act(CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet(scf= Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute EPA - Environmental Protection Agency FR - Federal Register G - Grams Gal - Gallon HAPs - Hazardous Air Pollutants HP - Horsepower HP-HR - Horsepower Hour(G/HP-HR= Grams per Horsepower Hour) LAER - Lowest Achievable Emission Rate LBS - Pounds M - Thousand MM - Million MMscf - Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants NSPS - New Source Performance Standards PM10 - Particulate Matter Under 10 Microns PSD - Potential for Significant Deterioration PTE - Potential To Emit Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix E Permit Acronyms Page 22 RACT - Reasonably Available Control Technology SCC - Source Classification Code SIC - Standard Industrial Code SO2 - Sulfur Dioxide TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix F Permit Modifications Page 23 APPENDIX F Permit Modifications SECTION NUMBER, DATE OF REVISION CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 24 APPENDIX G Compliance Assurance Monitoring Plans Compliance Assurance Monitoring Plan - Engines Background a. Emission Unit Description: AIRS ID 053 (C-238) Reciprocating Internal Combustion Engine (3,550 hp) for VOC AIRS ID 055 (C-235) Reciprocating Internal Combustion Engine (3,550 hp) for VOC AIRS ID 056 (C-236) Reciprocating Internal Combustion Engine (3,550 hp) for VOC AIRS ID 070 (C-234) Reciprocating Internal Combustion Engine (3,550 hp) for VOC AIRS ID 071 (C-237) Reciprocating Internal Combustion Engine (4,735 hp) for CO and VOC b. Applicable Regulation, Emission Limit, Monitoring Requirements: Engines C-238, C-235, C-236, and C-234: Regulations: Operating Permit Condition 1.2 Emission Limitations: VOC 24.0 tons/year Monitoring Requirements: Catalyst inlet temperature Engine C-23 7: Regulations: Operating Permit Conditions 2.1 and 2.2 Emission Limitations: CO 36.6 tons/year VOC 32.0 tons/year Monitoring Requirements: Catalyst inlet temperature c. Control Technology: Each engine is equipped with an oxidation catalyst to control CO and VOC emissions. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 25 II. Monitoring Approach Indicator No. I I. Indicator Catalyst Inlet Temperature The temperature of the exhaust gas into the catalyst will be measured using an inline a. Measurement Approach thermocouple. Excursions, for the purposes of reporting,are defined as an inlet catalyst temperature below 450°F or above 1350°F. II. Indicator Range Excursions trigger the owner or operator to investigate the engine performance and make any repairs or adjustments necessary. Any adjustments or repairs shall be recorded in a log to be made available to the Division upon request. III. Performance Criteria a. Data Representativeness Temperature is measured at the inlet to the catalyst. The minimum accuracy is+/-5°F. b. Verification of Operational Status N/A. Thermocouples shall be calibrated annually and maintained and replaced in accordance c. QA/QC Practices and Criteria with manufacturer's recommendations. d. Monitoring Frequency Continuous. The catalyst inlet temperature shall be recorded daily in a log to be made available to the e. Data Collection Procedures Division upon request. f. Averaging Period None,unless more than one reading is taken,and then a daily average. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 26 Compliance Assurance Monitoring Plan TEG Dehydration Unit Background a. Emission Unit Description: AIRS ID 068 (D-2) TEG Dehydration Unit(110 MMscfd) for VOC and HAP b. Applicable Regulation, Emission Limit, Monitoring Requirements: TEG Dehydration Unit D-2: Regulations: Operating Permit Conditions 3.1 and 9.1 Emission Limitations: VOC 25.0 tons/year Individual HAP 8 tons/year Total HAP 20 tons/year c. Control Technology: Enclosed combustion device (COMB-1) for still vent emission control, and flash tank emission control during VRU downtime. Still vent emissions are routed to the enclosed combustion device (COMB-1)with a DRE of 95%. This enclosed combustion device is permitted 1% annual downtime for maintenance and malfunctions, during which time the D-2 still vent is routed to atmosphere. Flash gas emissions are routed to the enclosed combustion device during periods of VRU downtime. The VRU is permitted 5%annual downtime for maintenance and malfunctions,during which time the D-2 flash gas is routed to this enclosed combustion device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 27 II. Monitoring Approach Indicator No. 1 L Indicator Pilot Light Presence a. Measurement Approach The presence of a pilot light is continuously monitored with a thermocouple or equivalent heat sensing device, installed on the enclosed combustion device(COMB-1). Excursions,for the purposes of reporting,are defined as any absence of a pilot light,except II. Indicator Range during periods of permitted downtime. Excursions shall trigger an investigation and corrective action shall be performed as necessary. Any adjustments or repairs made shall be recorded in a log to be made available to the Division upon request. III. Performance Criteria a. Data Representativeness The presence of a pilot flame is required to initiate the destruction of emissions via combustion.The absence of a flame indicates that emissions are uncontrolled. b. Verification of N/A. Operational Status The thermocouple or equivalent heat sensing device shall be calibrated,maintained and c. QA/QC Practices/Criteria replaced per manufacturer specifications. In the event of a pilot light outage,an alarm is sent to the control room. d. Monitoring Frequency Continuous. The presence of the pilot light shall be monitored continuously using a thermocouple or e. Data Collection equivalent heat sensing device. In the event of a pilot light outage,an alarm is sent to the control room. All instances of pilot light absence and the duration of absence,except during Procedures periods of permitted downtime,shall be recorded in a log to be made available to the Division upon request. f. Averaging Time None. II. Justification a. Background: The pollutant specific emission unit is a TEG dehydration unit, which functions to remove water from the natural gas stream prior to pipeline transfer. Flash emissions from the dehydration unit are recycled via a vapor recovery unit (VRU), which is permitted 5% annual downtime. During periods of downtime,the flash emissions are routed to an enclosed combustion device(COMB-1). Still vent emissions are routed to this same enclosed combustion device or, during periods of enclosed combustion device downtime,to atmosphere. This CAM plan applies to the operation of the enclosed combustion device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 28 b. Rationale for Selection of Performance Indicators and Indicator Ranges: The enclosed combustion device (COMB-I) has a manufacturer's guaranteed VOC destruction efficiency of 98%, when operational. The Division has accepted a VOC destruction efficiency of 95% for enclosed combustion devices with a 98% manufacturer's guarantee. In order to achieve this destruction efficiency, the enclosed combustion device must have a pilot light that is continuously lit to ensure the still vent vapors from TEG dehydration unit D-2 are ignited. Verification of pilot light presence is accomplished by continuously monitoring the pilot light with a thermocouple or equivalent heat sensing device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 29 Compliance Assurance Monitoring Plan TEG Dehydration Unit Background a. Emission Unit Description: AIRS ID 077 (D-3) TEG Dehydration Unit(145 MMscfd) for VOC and HAP b. Applicable Regulation, Emission Limit, Monitoring Requirements: TEG Dehydration Unit D-3: Regulations: Operating Permit Conditions 4.1 and 9.2 Emission Limitations: VOC 22.1 tons/year Individual HAP 8 tons/year Total HAP 20 tons/year c. Control Technology: Enclosed combustion device (COMB-1) for still vent emission control, and flash tank emission control during VRU downtime. Still vent emissions are routed to the enclosed combustion device (COMB-1)with a DRE of 95%. This enclosed combustion device is permitted 1% annual downtime for maintenance and malfunctions, during which time the D-3 still vent is routed to atmosphere. Flash gas emissions are routed to the enclosed combustion device during periods of VRU downtime. The VRU is permitted 5%annual downtime for maintenance and malfunctions,during which time the D-3 flash gas is routed to this enclosed combustion device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 30 II. Monitoring Approach Indicator No. 1 I. Indicator Pilot Light Presence a. Measurement Approach The presence of a pilot light is continuously monitored with a thermocouple or equivalent heat sensing device, installed on the enclosed combustion device(COMB-1). Excursions, for the purposes of reporting,are defined as any absence of a pilot light,except during II. Indicator Range periods of permitted downtime. Excursions shall trigger an investigation and corrective action shall be performed as necessary. Any adjustments or repairs made shall be recorded in a log to be made available to the Division upon request. III. Performance Criteria a. Data Representativeness The presence of a pilot flame is required to initiate the destruction of emissions via combustion.The absence of a flame indicates that emissions are uncontrolled. The thermocouple shall be installed per manufacturer recommendations. Upon startup of TEG b. Verification of dehydration unit D-3,pilot light presence shall be verified visually to confirm the thermocouple or Operational Status equivalent heat sensing device output reading.Records of this verification shall be made available to the Division upon request. c. QA/QC Practices/Criteria The thermocouple or equivalent heat sensing device shall be calibrated,maintained and replaced per manufacturer specifications. In the event of a pilot light outage,an alarm is sent to the control room. d. Monitoring Frequency Continuous. The presence of the pilot light shall be monitored continuously using a thermocouple or equivalent e. Data Collection heat sensing device.In the event of a pilot light outage,an alarm is sent to the control room. All Procedures instances of pilot light absence and the duration of absence, except during periods of permitted downtime,shall be recorded in a log to be made available to the Division upon request. f. Averaging Time None. II. Justification a. Background: The pollutant specific emission unit is a TEG dehydration unit, which functions to remove water from the natural gas stream prior to pipeline transfer. Flash emissions from the dehydration unit are recycled via a vapor recovery unit (VRU), which is permitted 5% annual downtime. During periods of downtime,the flash emissions are routed to an enclosed combustion device (COMB-1). Still vent emissions are routed to this same enclosed combustion device or, during periods of enclosed combustion device downtime,to atmosphere. This CAM plan applies to the operation of the enclosed combustion device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix G Compliance Assurance Monitoring Plan Page 31 b. Rationale for Selection of Performance Indicators and Indicator Ranges: The enclosed combustion device (COMB-1) has a manufacturer's guaranteed VOC destruction efficiency of 98%, when operational. The Division has accepted a VOC destruction efficiency of 95% for enclosed combustion devices with a 98% manufacturer's guarantee. In order to achieve this destruction efficiency, the enclosed combustion device must have a pilot light that is continuously lit to ensure the still vent vapors from TEG dehydration unit D-3 are ignited. Verification of pilot light presence is accomplished by continuously monitoring the pilot light with a thermocouple or equivalent heat sensing device. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 32 APPENDIX H Applicability Reports ver. 10/12/2012 (with updated web links and Reg 3 citations as of 8/20/2014) Note: A MS Word version of this Appendix can be found at: https://www.colorad o.gov/pacific/cdphe/altern ate-operating-scenario-aos-reporting-forms DISCLAIMER: These are only example reports and do not cover all possible requirements. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 33 Engine AOS Applicability Report Certification Language All information for the Applicability Reports must be certified by either 1) for Operating Permits, a Responsible Official as defined in Colorado Regulation No. 3, Part A, Section I.B.40) for Construction and General Permits, the person legally authorized to act on behalf of the source. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Further, I agree that by signing and submitting these documents I agree that any new requirements identified in the Applicability Report(s) shall be considered to be Applicable Requirements as defined in Colorado Regulation No. 3, Part A, Section I.B.9., and that such requirements shall be enforceable by the Division and its agents and shall be considered to be revisions to the underlying permit(s) referenced in the Report(s) until such time as the Permit is revised to reflect the new requirements. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of§ 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed Operating Permit Number: 95OPWE103 FIRST ISSU1lD: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 34 Colorado Regulation No. 7 Sections XVI and XVILE DISCLAIMER: This is only an example report and does not cover all possible Reg 7 requirements. Company: Acme Gas Processing Source ID: 9991234 Permit#: 93OPXX999 Date: October 1, 2008 Determination of compliance and reporting requirements for a Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Construction date: July 1, 2007 Note: If the engine is exempt from a requirement due to construction date or was relocated from within Colorado, supporting documentation must be provided. Determination of Regulation No. 7 requirements: Regulation No. 7, § XVI ❑ Does not apply to this engine. Engine is not located in the ozone nonattainment area or does not have a manufacturer's design rate greater than 500 horsepower or did not commence operation on or after June 1, 2004. ❑ Does apply to this engine and applicable emissions controls have been installed. Regulation No. 7, § XVII.E ❑ Does not apply to this engine. Engine does not have a maximum horsepower greater than 100 or the construction or relocation date precedes the applicability dates. ❑ Does apply to this engine. The following emission limits apply to the engine: NOx (g/hp-hr): 2.0 CO (g/hp-hr): 4.0 VOC (g/hp-hr): 1.0 Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 35 Max Engine Construction or Emission Standards in g/hp-hr HP Relocation Date NOx CO VOC 100<Hp<500 January 1, 2008 2.0 4.0 1.0 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 2.0 4.0 1.0 July 1, 2010 1.0 2.0 0.7 Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED:DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 36 NSPS JJJJ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible JJJJ requirements. Note that as of August 20, 2015 that the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS JJJJ will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § I.C, upon adoption of NSPS JJJJ into Regulation No. 6, Part A, an internal combustion engine relocated from outside the State of Colorado into the Date of Colorado shall meet the most recent emission standard required in NSPS JJJJ. Engines with a manufacturer's rated horsepower of less than 500 and with a relocation date no later than 5 years after the manufacture date are exempt from this requirement per Regulation No. 6, Part B, Section I.C.2.a. Relocation is defined in Section I.C.1.a. NSPS Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit#: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Lean Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/manufacture date, supporting documentation must be provided. Upon adoption of NSPS Subpart JJJJ into Colorado Regulation No. 6, Part A, if the engine is exempt because the engine was relocated within the state of Colorado, supporting documentation must be provided. NSPS JJJJ does not apply to this engine. n NSPS JJJJ does apply to this engine. Note: Using the format below, the source must submit to the Division an analysis of all of the NSPS JJJJ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical engine that is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 37 Determination of NSPS JJJJ requirements: 60.4230 Applicability (a)(4)(i) Applies to this engine since it is a rich burn engine, greater than 500 HP, with a manufacture date after July 1, 2007. 60.4233 Emission Standards for Owners and Operators (e) Owners and operators of stationary SI ICE with a maximum engine power greater than 100 HP must comply with the standards in Table 1. Non-Emergency SI,Natural Gas, HP≥500, Manufactured after 7/1/2007 NO„ 2.0 g/HP-hr or 160 ppmvd@15% O2 • CO 4.0 g/HP-hr or 540 ppmvd@15% O2 VOC 1.0 g/HP-hr or 86 ppmvd@15% O2 Other Requirements for Owners and Operators 60.4234 Emission standards must be met for the lifetime of the engine. 60.4235 N/A - Sulfur content of gasoline. 60.4236 N/A (for now) - After July 1, 2009 owners and operators may not install engines with a power rating≥ 500HP that do not meet the emissions standards in 60.4233. 60.4237 N/A- Emergency Engines. 60.4238 -60.4242 Compliance Requirements for Manufacturers—(Not Applicable) 60.4243 Compliance Requirements for Owners and Operators (b)(2)(ii) To maintain compliance with the emission limits in 60.4233, owners of SI ICE≥ 500HP must: • Keep a maintenance plan; • Keep records of conducted maintenance; • Maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions; • Conduct an initial performance test; and • Conduct subsequent performance tests every 8,760 hours or every three years, which ever comes first, in order to demonstrate compliance with the emission limits. (g) Air to fuel ratio controllers (AFRCs) must be maintained and operated appropriately in order to ensure proper operation of the engine and control device to minimize emissions at all times. 60.4244 Testing Requirements for Owners and Operators Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 38 (a) Each performance test must be conducted within 10%of the highest achievable load and must comply with the testing requirements listed in 60.8 and Table 2 of NSPS JJJJ. (b) Performance tests may not be conducted during periods of startup, shutdown, or malfunction, as specified in 60.8(c). If the engine is non-operational when a performance test is due, the engine does not need to be started up just to test it, but will need to be tested immediately upon startup. (c) Three separate test runs must be conducted for each performance test as specified by 60.8(f). Each run must be within 10%of max load and be at least 1 hour in duration. (d) To determine compliance with the NON, CO, and VOC mass per unit output emission limitations, the measured concentration must be converted using the equations outlined in this section of NSPS JJJJ. 60.4245 Notification,Reports,and Records for Owners and Operators (a) Owners of all stationary SI ICE must keep records of the following: (1) All notifications submitted to comply with this subpart; (2) Maintenance conducted on the engine; (3) N/A - Manufacturer information for certified engines, and (4) Documentation that shows non-certified engines are in compliance with the emission standards. (b) N/A—For emergency engines only. (c) Owners of non-certified engines> 500HP must submit an initial notification as required in 60.7(a)(1) which includes the following information: (1) Name and address of the owner or operator; (2) The address of the affected source; (3) Engine information including make, model, engine family, serial number, model year, maximum engine power, and engine displacement; (4) Emission control equipment; and (5) Fuel used. CONCLUSION OF FINDINGS (EXAMPLE ONLY) In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non-selective catalytic converter(NSCR). These emission rates will be met throughout the life of the engine. A maintenance plan will be kept and all maintenance activities will be recorded. Compliance with the emission limits will be confirmed by the initial performance tests, which shall be conducted following the procedures outlined in 60.4244. Copies of performance test results will be submitted within 60 days of the completion of each test. Since this is an uncertified engine, an initial notification will be submitted including all of the requested information in 40.4245 within 30 days of startup. ACME will keep records of all compliance related materials. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 39 MACT ZZZZ Example Report Format DISCLAIMER: This is only an example report and does not cover all possible ZZZZ requirements. MACT Subpart ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Company: Acme Gas Processing Source ID: 9991234 Permit#: 93OPXX999 Date: October 1, 2008 Manufacturer: BestEngineCompany Model: 777 LowNox Nameplate HP: 1340 Engine Type: 2 Stroke Lean Burn Manufacture Date: July 1, 2007 Date Engine Ordered: April 1, 2007 Note: If the engine is exempt from a requirement due to construction/reconstruction date, supporting documentation must be provided. ❑ MACT ZZZZ does not apply to this engine. ❑ MACT ZZZZ does apply to this engine. Note: Using the format below,the source must submit to the Division an analysis of all of the MACT ZZZZ applicable requirements that apply to this specific engine. The analysis below is an example only, based on a hypothetical new engine located at an area source of HAP emissions. Determination of MACT ZZZZ requirements: 63.6585 Applicability This subpart is applicable to Acme's engine since they are going to be operating a new stationary reciprocating internal combustion engine (RICE) at a major source of HAP emissions. 63.6590 What Parts of My Plant Does This Subpart Cover? This subpart covers Acme's new stationary reciprocating internal combustion engine. 63.6595 When do I have to comply with this Subpart? Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 40 (a)(5) The engine must comply with the applicable emission limitations and operating limitations upon startup. 63.6600 Emission and operating limitations for RICE site rated at more than 500 hp (a) The engine is subject to the emission limits in table la and the operating limits in table lb. ACME will meet the emission limitations by reducing formaldehyde emissions by 76 percent and will maintain the catalyst such that the pressure drop does not change by more than 2 inches of H2O at 100 % load plus or minus 10 percent from the pressure drop measured during the initial performance test and will maintain the temperature of the engine exhaust so that the catalyst inlet temperature is greater than or equal to 750 °F and less than or equal to 1250 °F. The engine will be equipped with non-selective catalytic reduction and an air fuel controller to meet the emission limitations. 63.6601 & 63.6611 Requirements for 4SLB engines between 250 and 500 hp These requirements do not apply. 63.6605 General Requirements (a) The engine will comply with the emission and operating limitations at all times, except during periods of startup, shutdown and malfunction (SSM) (b) The engine, including air pollution control and monitoring equipment shall be operating in a manner consistent with good air pollution control practices for minimizing emissions at all times, including during SSM. 63.6610 Initial performance test (a) The performance tests specified in Table 4 (select sampling port and measure O2, moisture and formaldehyde at inlet and outlet of the control device) shall be conducted within 180 days of startup. (b) & (c) Not applicable. Construction did not commence between 12/19/02 and 6/15/04. (d) Previous performance tests have not been conducted on this unit within two years, therefore, this provision does not apply. 63.6615 Subsequent performance tests Subsequent tests will be conducted as specified in Table 3. No additional testing is required for 4SRB engines meeting the formaldehyde percent reduction requirements. 63.6620 Performance test procedures (b) Tests must be conducted at 100 % load plus or minus 10% Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 41 (c) Tests may not be conducted during periods of SSM. (d) Must conduct three 1-hr test runs (e) Equation (e)(1) shall be used to determine compliance with the percent reduction requirement. (f), (g) & (h) Not applicable (i) Engine load during test shall be determined as specified in this paragraph. 63.6625 Monitoring, installation, operation and maintenance requirements (a), (c) & (d) Not applicable (b) A continuous parameter monitoring system (CPMS) shall be installed to measure the catalyst inlet temperature. The CPMS will meet the requirements in § 63.8 63.6630 Demonstrating initial compliance (a) Initial compliance shall be determined in accordance with Table 5 (initial performance test must indicate formaldehyde reduction of 76 percent or more, a CPMS must be installed to measure inlet temperature of the catalyst and the pressure drop and catalyst inlet temperature must be recorded during the initial performance test). (b) Pressure differential will be established during the initial performance test. (c) Notification of compliance status will be submitted and will contain the results of the initial compliance demonstration. 63.6635 Monitoring to demonstrate continuous compliance (b) Except for monitor malfunctions, associated repairs, and required QA/QC activities monitoring must be continuous at all time the engine is operating. (c) Data recorded during monitoring malfunctions, associated repairs and required QA/QC activities must not be used in data averages and calculations to report operating levels, however, all the valid data collected during other periods shall be used. 63.6640 Demonstrating continuous compliance (a) Continuous compliance will be demonstrated as specified in Table 6 (collect catalyst inlet temperature data, reduce that data to 4-hr rolling average and maintain the 4-hr rolling averages to within the operating limitation and measuring the pressure drop across the catalyst once per month and demonstrating that the pressure drop meets the operating limitation). • (b) Deviations from the emission and operating limitations must be reported per § 63.6550. If catalyst is changed the operating parameters established during the initial performance test must be re-established. When operating parameters re-established a performance test must also be conducted. 63.6645 Notifications Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 42 (a) Submit notifications in §§ 63.7(b) & (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) thru(e) & (g) & (h)that apply by dates specified. (b) Not applicable. Acme unit started after effective dated for Subpart ZZZZ. (c) Submit initial notification within 120 days after becoming subject to Subpart ZZZZ. (d)thru (0 Not applicable. Acme engine greater than 500 hp and subject to requirements in Subpart ZZZZ. (g) & (h) Submit notification of intent to conduct performance test and notification of compliance status. 63.6650 Reports (a) Submit reports required by Table 7 (compliance report and SSM reports (if actions inconsistent with SSM plan) (b) Not applicable, an alternate schedule for report submittal has been approved. Reports will be submitted with Title V reports (c) Compliance reports to contain the following information: company name and address, statement by responsible official certifying accuracy, date of report and beginning and end of reporting period, if SSM the information in 63.10(d)(5)(i), if no deviations a statement saying that, if no periods when CPMS out of control a statement saying that. (d) Not applicable, using CPMS (e) For each deviation the information in (e)(1)thru (e)(12) shall be provided. (0 Applicable. Compliance reports are submitted with title v reports. Compliance reports under Subpart ZZZZ include all necessary info for title v deviation report with respect to Subpart ZZZZ requirements. (g) Not applicable. Acme engine not firing landfill or digester gas. 63.6655 Recordkeeping (a) Retain records as follows: copy of each notification and report(including all documentation supporting any initial notification or notification of compliance status), records in 63.6(e)(iii)thru (v) related to SSM, and records of performance tests and evaluations. (b) CPMS records including records in 63.10(b)(2)(vi)thru (xi), previous versions of the performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the relative accuracy test for CPMS as required by 63.8(f)(6)(i). (c) Not applicable. Acme engine not firing landfill or digester gas. (d) Will keep records required in Table 6 (monthly pressure drop readings, 4-hr averages of catalyst inlet temperature)to show continuous compliance with emission and operating limits. 63.6660 Form and length of records (a) Records must be in a form suitable and readily available for expeditions review. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT Air Pollution Control Division Colorado Operating Permit Appendix H AOS Applicability Reports Page 43 (b) Records must be retained for five years. (c) Records must be retained on-site for first 2 years, may be retained off-site for the remaining 3 years. 63.6665 General Provisions This engine must comply with the general provisions as indicated in Table 8. CONCLUSION OF FINDINGS (EXAMPLE ONLY) Since this engine is subject to the requirements of MACT Subpart ZZZZ. The engine will be installed with a non-selective catalyst to meet the formaldehyde reduction requirement of 76%or more. An initial performance test will be conducted within 180 days of startup to demonstrate compliance with the formaldehyde percent reduction requirement. During the initial performance test, the pressure drop across the catalyst will be measured. A CPMS will be installed to measure the catalyst inlet temperature. Continuous compliance will be demonstrated by keeping the 4-hr rolling averages of catalyst inlet temperature within the operating limitations and recording the pressure drop across the catalyst monthly and demonstrating that the pressure drop is within the operating limitation. Records, notifications and reports will be submitted as required. To that end required reports and notifications include initial notification, notice of intent to conduct performance test, notification of compliance status, SSM reports (if required) and semi-annual compliance reports. Operating Permit Number: 95OPWE103 FIRST ISSUED: May 1, 1999 RENEWED: DRAFT TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 95OPWE103 DCP Operating Company, LP — Enterprise Compressor Station Weld County Source ID 1230277 May 2018 — Date Operating Permit Engineer: Elie Chavez Operating Permit Supervisor review: Blue Parish Field Services Unit review: Craig Giesecke I. PURPOSE This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit for the Enterprise Compressor Station. The previous Operating Permit for this facility was issued on 5/1/1999, was renewed on 8/1/2012 and was last revised on 8/2/2012 and expired on 8/1/2017. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. The source submitted the following permit modification applications: • Administrative Modification (Rec'd 3/19/2014) — Request to update TEG Dehydration Unit D-2 (AIRS 068) serial number. • Minor Modification (Rec'd. 4/26/2016) — Request to remove 60 MMscfd dehydration unit D-3 (AIRS 073) from the operating permit as it was never constructed. Additional request to replace the enclosed combustion device (COMB-1) with a newer model that does not require supplemental fuel gas. • Minor Modification (Rec'd. 7/26/2016) — Request (received in addition to the renewal application) to add 5% downtime for the vapor recovery unit and 3% downtime for the enclosed combustion device (COMB-1), both controlling dehydration unit D-2 (AIRS 068), to allow for maintenance/malfunction events. • Minor Modification (Rec'd. 1/29/2018) — Request to reduce the vapor recovery unit downtime to 1% and to reduce the enclosed combustion device (COMB-1) downtime to 2.25%. It should be noted that this modification was cancelled on 11/13/2020 and therefore was not incorporated into the operating permit. • Minor Modification (Rec'd. 11/20/2018) — Request to increase the fuel gas consumption limitations for engines C-234, C-235, C-236, C-237 and C-238 based on an updated heat content. 123/0277 Page 1 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Significant Modification (Rec'd. 11/20/2018) — Request to permit 5% downtime for the vapor recovery unit, during which emissions are routed to the enclosed combustion device (COMB-1), and to permit 1% downtime for the enclosed combustion device (COMB-1), during which emissions are routed to atmosphere. Request to remove condenser conditions from operating permit as credit will no longer be claimed for condenser control in emission calculations. Additional request to incorporate the enclosed combustion device COMB-1 (previously AIRS 074) into the same AIRS point as dehydration unit D-2 (AIRS 068), and to permit assist gas for this combustion device. • Significant Modification (Rec'd. 6/1/2020)— Request to incorporate the produced water storage tanks (AIRS 075) into the operating permit, as these tanks are no longer permit exempt. • Significant Modification (Rec'd. 8/24/2020) — Request to incorporate Colorado Construction Permit 19WE0094 into the operating permit. Included in this permit are compressor blowdowns, COMP-BD (AIRS 076). • Significant Modification (Rec'd. 10/30/2020) — Request to modify the emission factors associated with compressor blowdowns, COMP-BD (AIRS 076). • Significant Modification (Rec'd. 11/19/2020) — Request to incorporate Colorado Construction Permit 19WE0492 into the operating permit. Included in this permit are the stabilized condensate storage tanks P013 (AIRS 063), stabilized condensate truck loadout P016 (AIRS 066) and TEG dehydration unit D-3 (AIRS 077). Each of these modifications, with the exception of the cancelled 1/29/2018 minor modification application were incorporated into this renewal of the operating permit. The review and procedures required for the renewal of an operating permit are in all cases more stringent than the minor modification procedures set forth in Colorado Regulation No. 3, Part C, Section X. This operating permit renewal therefore fulfills the minor modification requirements set forth in this Section X. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on 7/26/2016, comments on the draft permit submitted on 9/11/2020, a site visit on 6/25/2019, previous inspection reports and various email correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at www.colorado.gov/cdphe/airTitleV. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural 123/0277 Page 2 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. DESCRIPTION OF SOURCE The Enterprise Compressor Station is classified as a natural gas compressor station as set forth under Standard Industrial Classification Code 4922. This facility has a design natural gas throughput of 145 MMscfd and a stabilized condensate production rate of 202,848 bbl/year. The facility uses five (5) natural gas-fired internal combustion engines (AIRS 053, 055, 056, 070 and 071) to drive compressors to boost the inlet gas pressure from about 80 psig to about 1,050 psig, facilitating the movement of natural gas into pipeline transit. These compressors are periodically blown down for routine maintenance activities (AIRS 076). The station also includes one (1) triethylene glycol (TEG) dehydration unit (AIRS 077) which contacts"lean"TEG with the compressed natural gas stream to remove moisture. The "rich" TEG mixture is regenerated in a still for reuse in the process. The TEG dehydration system operates with a flash tank and a still vent. The flash tank emissions are routed back to the facility inlet using a vapor recovery unit (VRU), which is permitted 5% downtime, during which emissions are routed to an enclosed combustion device (COMB-1). The still vent stream is sent through a condenser to an enclosed combustion device (COMB-1, included under AIRS 077) where it is combusted. This enclosed combustion device is permitted 1% downtime, during which still vent emissions are routed to atmosphere. It should be noted that no emission control from the condenser is claimed for this dehydration unit. A condensate product is generated when the inlet gas is routed through the inlet scrubber and liquids generated via pipeline transit are separated out. This condensate is then stabilized, and transferred to eight (8) 300 barrel stabilized condensate storage tanks (AIRS 063). A loading system (AIRS 066) is provided for moving stabilized condensate from the tanks into a truck for transport offsite. The condensate tanks and loadout are controlled with an enclosed combustion device. Two (2) 90 barrel produced water tanks (AIRS 075) store any water separated from the condensate stream. Emission control devices include: five (5) oxidation catalyst beds to control the compressor engine exhaust emissions, one (1) vapor recovery unit(VRU) permitted 5% downtime to control the dehydration unit flash tank emissions, one (1) enclosed combustion device (COMB-1) permitted 1% downtime to control the dehydration unit still vent emissions, and permitted to control flash tank emissions during VRU downtime (permitted 5%), and one (1) enclosed combustion device to control the stabilized condensate storage tank and loadout emissions. This permit contains provisions for the existing 110 MMscfd TEG dehydration unit D-2 (AIRS 068), which will be decommissioned and replaced with the 145 MMscfd TEG dehydration unit D-3 (AIRS 077). Upon startup of D-3, the conditions governing D-2 set 123/0277 Page 3 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit forth in Section II, Condition 3 of this permit will no longer apply and the source shall operate D-3 pursuant to the requirements set forth in Section II, Condition 4. This facility is located one (1) mile north of US Highway 76 on the Gutterson Road between the towns of Keenesburg and Roggen, in Weld County, Colorado. This facility is located in an Area classified as attainment for all pollutants except ozone. It is classified as non-attainment for the 8-hr ozone standard and is part of the 8-hr Ozone Control Area as defined in Regulation No. 7, Part A, Section II.A.1. The 8-hr Ozone Control Area has been classified as a serious non-attainment area effective January 27, 2020. There are no affected states within 50 miles of the facility. Rocky Mountain National Park is a Federal Class I designated area within 100 kilometers of the facility. This facility is categorized as a NANSR major stationary source (Potential to Emit of VOC or NOx > 50 Tons/Year). Future modifications at this facility resulting in a significant net emissions increase (see Reg 3, Part D, Sections II.A.27 and 44) for VOC or NOx or a modification which is major by itself(i.e. a Potential to Emit of > 50 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. Based on the information provided by the applicant, this source is categorized as a minor stationary source for PSD as of the issue date of this permit. Any future modification which is major by itself (Potential to Emit of > 250 TPY) for any pollutant listed in Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Emissions (in tons/yr) at the facility are as follows: Controlled Emissions(tons/year) AIRS ID Facility ID Source Reportable NOx CO VOC HAP 053 C-238 Compressor Engine 24.00 27.42 24.00 3.58 055 C-235 Compressor Engine 24.00 27.42 24.00 3.58 056 C-236 Compressor Engine 24.00 27.42 24.00 3.58 063 P013 Condensate Storage Tanks -- -- 1.68 0.31 066 P016 Condensate Truck Loadout -- -- 0.94 0.02 068 D-2 TEG Dehydration Unit 1.43 6.51 26.82 14.21 070 C-234 Compressor Engine 24.00 27.42 24.00 3.58 071 C-237 Compressor Engine 32.01 36.58 32.01 4.99 075 SUMP-1/2 Produced Water Storage Tanks -- -- 1.85 0.17 076 COMP-BD Compressor Blowdowns -- -- 9.80 -- 077 D-3 TEG Dehydration Unit 1.49 6.72 23.94 11.78 Total Permitted Facility Emissions(D-2)(tons/year) 129.44 152.77 169.10 34.03 Total Permitted Facility Emissions(D-3)(tons/year) 129.50 152.98 166.22 31.60 2018 Actual Facility Emissions(tons/year) 108.98 124.70 116.49 17.95 123/0277 Page 4 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit It should be noted that Colorado Construction Permit 19WE0492 (issued 11/19/2019) authorized the construction of new TEG dehydration unit D-3 (AIRS 077) to replace existing TEG dehydration unit D-2. However, as of the issuance date of this operating permit on X)UXX/XXXX, TEG dehydration unit D-3 has not yet commenced operation. Until this new dehydration unit is operational, the Enterprise Compressor Station will continue to operate with TEG dehydration unit D-2 as requested in the significant modification application received on 11/20/2018. Upon startup of TEG dehydration unit D-3, D-2 will be decommissioned such that these two dehydration units do not operate simultaneously. To reflect this, the table above provides two facility-wide totals: one as permitted under the significant modification application submitted on 11/20/2018, and one as permitted under Colorado Construction Permit 19WE0492.This issuance of the operating permit on XX/XX/XXXX therefore includes requirements addressing both the operation of TEG dehydration units D-2 and D-3. Upon startup of TEG dehydration unit D-3, the requirements applicable to D-2 will no longer apply. III. APPLICABLE REQUIREMENTS Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the Rule. Based on the information provided by the applicant, the Enterprise Compressor Station is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Compliance Assurance Monitoring (CAM) The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre-control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: AIRS ID 053 (C-238) — Compressor RICE (3,550 hp) for VOC AIRS ID 055 (C-235) — Compressor RICE (3,550 hp) for VOC AIRS ID 056 (C-236) — Compressor RICE (3,550 hp) for VOC AIRS ID 068 (D-2) —TEG Dehydration Unit (110 MMscfd) for VOC and HAP AIRS ID 070 (C-234) — Compressor RICE (3,550 hp) for VOC AIRS ID 071 (C-237) — Compressor RICE (4,735 hp) for CO and VOC AIRS ID 077 (D-3) —TEG Dehydration Unit (145 MMscfd) for VOC and HAP 123/0277 Page 5 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit It should be noted that all engines at the Enterprise Compressor Station produce formaldehyde emissions in excess of the major source threshold of 10 tons/year for a single HAP. However, because the Enterprise Compressor Station is a major source of HAP (for Title V and MACT ZZZZ purposes; see Regulatory Applicability discussion below), HAP limitations were not included in the operating permit for these engines. As such, these engines are not subject to CAM for a HAP limitation. However, for the purposes of MACT HH, the Enterprise Compressor Station is considered to be an area source of HAP (see determination below). As such, emissions of HAP from the permitted TEG dehydration units are subject to a HAP emission limitation, put in place to ensure major source requirements of MACT HH are not inadvertently triggered. Because the permitted TEG dehydration unit has uncontrolled HAP emissions in excess of the major source HAP thresholds and utilizes a control device to comply with a HAP limitation set forth in the operating permit, these units are subject to CAM for HAP. The remaining permitted points at this facility are not subject to CAM per the following justifications: AIRS ID 063 (P013) - Eight (8) Stabilized Condensate Storage Tanks (300 bbl each) exempt due to pre-control emissions below major source thresholds. AIRS ID 066 (P016) - Stabilized Condensate Truck Loadout exempt due to pre-control emissions below major source thresholds. AIRS ID 075 (SUMP-1/2) — Two (2) Produced Water Storage Tanks (90 bbl each) exempt due to pre-control emissions below major source thresholds. AIRS ID 076 (COMP-BD) — Natural gas venting from reciprocating compressor blowdowns exempt as an uncontrolled emissions unit. Hazardous Air Pollutants (HAPs) The Enterprise Compressor Station emits HAP in excess of the major source thresholds of 10 tons/year individual HAP (formaldehyde) and 25 tons/year total HAP (facility- wide). As such, this facility is considered to be a major source of HAP emissions. Facility-wide HAP emissions are summarized in the following table: 0-2(11/20/2018 SM) D-3(19WE0492) Actual Pollutant Uncontrolled Controlled Uncontrolled Controlled Emissions Emissions Emissions Emissions Emissions tons/year tons/year tons/year tons/year tons/year Acetaldehyde 4.81 2.41 4.81 2.41 1.98 Acrolein 2.96 1.48 2.96 1.48 1.25 Methanol 1.44 0.72 1.44 0.72 0.60 Formaldehyde 73.14 14.63 73.14 14.63 12.46 n-Hexane 18.72 0.93 17.05 0.90 0.33 2,2,4-TMP 0.00 0.00 0.00 0.00 0.00 Benzene 76.80 4.42 67.08 3.91 0.71 Toluene 126.97 7.38 101.35 5.96 0.53 Ethylbenzene 4.10 0.24 3.11 0.18 0.01 123/0277 Page 6 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Xylenes 31.12 1.83 24.01 1.42 0.10 Facility Total 340.05 34.03 294.94 31.60 17.95 As previously discussed, Colorado Construction Permit 19WE0492 authorized the construction of new TEG dehydration unit D-3 (AIRS 077) to replace existing TEG dehydration unit D-2. Upon startup of TEG dehydration unit D-3, D-2 will be decommissioned such that these two dehydration units do not operate simultaneously. To reflect this, the table above provides two facility-wide HAP totals: one as permitted under the significant modification application submitted on 11/20/2018 (D-2 is operational; D-3 has not yet commenced operations), and one as permitted under Colorado Construction Permit 19WE0492 (D-3 is operational; D-2 is decommissioned). It should be noted that for the purposes of MACT HH, the Enterprise Compressor Station is considered to be an area source of HAP emissions since, as a "production field facility," only HAP emissions from the permitted TEG dehydration unit (either D-2 or D-3), stabilized condensate tanks, and produced water storage tanks are aggregated for the purposes of major source determination (see Regulatory Applicability discussion below). Therefore, the operating permit was updated to include a synthetic minor HAP limit of 8 tons/year individual HAP and 20 tons/year total HAP (applicable only to the storage tanks and dehydration units — either D-2 or D-3 — combined) to ensure major source requirements under MACT HH are not inadvertently triggered. For more information regarding this HAP emission limitation, refer to Section VII of this document. Regulatory Applicability 40 CFR Part 63 Subpart ZZZZ MACT — National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines This section addresses the final version of Subpart ZZZZ, last updated in the Federal Register on 2/27/2014. For the purposes of the Enterprise Compressor Station, this subpart applies to compressor engines. Affected facilities under this subpart include both area and major sources of HAP. A major source of HAP is defined in §63.2 as "any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants". Section §63.6675 of subpart ZZZZ lists four (4) clarifications to this definition: 1. Emissions from any oil or gas exploration or production well (with its associated equipment (as defined in this section)) and emissions from any pipeline compressor station or pump station shall not be aggregated with emissions from other similar units, to determine whether such emission points or stations are major sources, even when emission points are in a contiguous area or under common control 123/0277 Page 7 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Pursuant to the definition set forth in §63.6675, an "oil and gas production facility' is considered to be, for the purposes of major source determination, "oil and natural gas production and processing equipment that is located within the boundaries of an individual surface site as defined in this section." "Surface site" is further defined as "any combination of one or more graded pad sites, gravel pad sites, foundations, platforms, or the immediate physical location upon which equipment is physically affixed." Pursuant to this clarification, only emissions points from the Enterprise Compressor Station surface site were aggregated for the purposes of major source determination. Additionally, it should be noted that, based on the facility plot plan, there are no other nearby facilities, including well production sites, that could be grouped with the Enterprise Compressor Station. 2. For oil and gas production facilities, emissions from processes, operations, or equipment that are not part of the same oil and gas production facility, as defined in §63.1271 of subpart HHH of this part, shall not be aggregated Pursuant to the first exception above, no aggregation of processes, operations or equipment that were not part of the Enterprise Compressor Station surface site was undertaken. 3. For production field facilities, only HAP emissions from glycol dehydration units, storage vessel with the potential for flash emissions, combustion turbines and reciprocating internal combustion engines shall be aggregated for a major source determination Production field facilities are defined in §63.6675 as "oil and gas production facilities located prior to the point of custody transfer". Custody transfer is defined in this subpart as "the point at which such liquids or natural gas enters a natural gas processing plant". The Enterprise Compressor Station compresses and dehydrates field gas, which is then sent to the nearby Roggen Natural Gas Processing Plant for further refining. Therefore, for the purposes of Subpart ZZZZ, the Enterprise Compressor Station is, by definition, located upstream of the point of custody transfer. Therefore, this station is classified as a production field facility and this clarification applies. The Enterprise Compressor Station does not operate any combustion turbines. The condensate accumulated at the Enterprise Compressor Station is stored in atmospheric tanks, however, it is first stabilized in a condensate stabilization unit to a vapor pressure significantly less than atmospheric pressure. As such, flash emissions are not possible from these tanks and HAP emissions due to the working and breathing losses can be neglected for the purposes of major source determination pursuant to this clarification. In contrast, the produced water storage tanks can accept pressurized produced water and therefore have the potential for flash emissions. As such, HAP emissions from these storage tanks were included in the major source determination for the purposes of Subpart ZZZZ. Additionally, the Enterprise Compressor Station operates five reciprocating internal combustion engines and, at any given time, only one TEG dehydration unit. TEG dehydration units D-2 and D-3 are not permitted to operate simultaneously. Upon startup of new TEG dehydration unit D-3, D-2 will be shut down and decommissioned such that D-2 operations do not overlap with D-3 operations. Therefore, for the 123/0277 Page 8 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit purposes of major source determination, only one dehydration unit was aggregated with the five engines and produced water storage tanks to determine major source applicability. 4. Emissions from processes, operations, and equipment that are not part of the same natural gas transmission and storage facility, as defined in §63.1271 of subpart HHH of this part, shall not be aggregated A natural gas transmission facility is defined in subpart HHH as "the pipelines used for the long distance transport of natural gas (excluding processing)". A natural gas transmission and storage facility does not include compressor stations, pursuant to Subpart HHH §63.1270(a) where it is explicitly stated that the subpart applies to "owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user." As such, this clarification does not apply to the Enterprise Compressor Station. Pursuant to the definition of major source set forth in §62.3, the HAP emissions from this facility, when considering either glycol dehydration unit, the produced water tank and reciprocating internal combustion engines, are above the major source thresholds of 10 tons/year formaldehyde (individual HAP) and above the 25 tons/year threshold for total HAP. Therefore, for the purposes of Subpart ZZZZ, the Enterprise Compressor Station is considered to be a major source of HAP emissions.As such, applicable major source requirements under Subpart ZZZZ were incorporated into the operating permit. Affected engines under this subpart include existing, new or reconstructed engines. Pursuant to §63.6590(a)(2)(i), "a stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions is new if you commenced construction of the stationary RICE on or after December 19, 2002." Commenced construction dates for the engines pursuant to the most recent APENs received are summarized in the following table: 40 CFR 63 Facility Serial APEN Received Date of Commenced AIRS ID Subpart ZZZZ Identifier Number Date Construction Classification 053 C-238 BKE00356 4/16/2019 2/27/2008 New 055 C-235 1YG00047 4/16/2019 Before 1994 Existing 056 C-236 1YG00028 4/16/2019 Before 1993 Existing 070 C-234 1YG00029 4/16/2019 Before 1/1993 Existing 071 C-237 BLB00490 4/16/2019 Before 8/2012 New It should be noted that §63.6590(b)(3)(ii) of Subpart ZZZZ exempts "existing spark ignition 4 stroke lean burn (4SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions."As such, engines C-234, C-235 and C-236 are not subject to any requirements under Subpart ZZZZ. The applicable Subpart ZZZZ requirements to new engines located at a major source of HAP emissions were included in the operating permit for engines C-237 and C-238. 123/0277 Page 9 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit For a more detailed discussion on the incorporation of the requirements of MACT Subpart ZZZZ into the operating permit, refer to Section VII of this document. 40 CFR Part 60 Subpart JJJJ NSPS- Standards of Performance for Stationary Spark Ignition Internal Combustion Engines This section addresses the final version of Subpart JJJJ, last updated 8/30/2016. For the purposes of the Enterprise Compressor Station, this subpart applies to compressor engine C-237. Affected facilities under this subpart include engines that commence construction after 6/12/2006 and were manufactured "on or after July 1, 2007, for engines with a maximum engine power greater than or equal to 500 HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP and less than 1,350 HP)." (§60.4230(a)(4)(i)). For the purposes of Subpart JJJJ "the date that construction commences is the date the engine is ordered by the owner or operator." A summary of the date of order and the date of manufacture, as indicated by the most recently submitted APENs, are summarized in the table below: APEN 40 CFR 60 AIRS ID Facility Date of Received Date of Order Subpart JJJJ Identifier Manufacture Date Applicability 053 C-238 4/16/2019 2006 12/1/2006 No 055 C-235 4/16/2019 Before 1994 4/29/1994 No 056 C-236 4/16/2019 Before 1993 1/27/1993 No 070 C-234 4/16/2019 Before 1/1993 Before 1/1993 No 071 C-237 4/16/2019 Before 8/2012 Before 8/2012 Yes Pursuant to the dates listed in the table above, engine C-237 only is subject to the requirements of Subpart JJJJ. For a more detailed discussion on the incorporation of the requirements of NSPS Subpart JJJJ into the operating permit, refer to Section VII of this document. 40 CFR Part 63 Subpart HH MACT — National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities This section addresses the final version of Subpart HH, last updated in the Federal Register on 8/16/2012. For the purposes of the Enterprise Compressor Station, this subpart applies to the dehydration unit. Affected facilities under this subpart include both area and major sources of HAP. A major source of HAP is defined in 63.2 as "any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants". Section §63.761 of subpart HH lists three (3) clarifications to this definition: 123/0277 Page 10 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit 1. Emissions from any oil or gas exploration or production well (with its associated equipment (as defined in this section)) and emissions from any pipeline compressor station or pump station shall not be aggregated with emissions from other similar units, to determine whether such emission points or stations are major sources, even when emission points are in a contiguous area or under common control Pursuant to the "facility" definition set forth in §63.761, "for the purpose of a major source determination, facility (including a building, structure, or installation) means oil and natural gas production and processing equipment that is located within the boundaries of an individual surface site as defined in this section." "Surface site" is defined in §63.761 as "any combination of one or more graded pad sites, gravel pad sites, foundations, platforms, or the immediate physical location upon which equipment is physically affixed." Pursuant to this clarification, only emissions points from the Enterprise Compressor Station surface site were aggregated for the purposes of major source determination. Additionally, it should be noted that, based on the facility plot plan, there are no other nearby facilities, including well production sites, that could be grouped with the Enterprise Compressor Station. 2. Emissions from processes, operations, or equipment that are not part of the same facility, as defined in this section, shall not be aggregated Pursuant to the first exception of this subpart, no aggregation of processes, operations or equipment that were not part of the Enterprise Compressor Station surface site was undertaken. 3. For facilities that are production field facilities, only HAP emissions from glycol dehydration units and storage vessels shall be aggregated for a major source determination. For facilities that are not production field facilities, HAP emissions from all HAP emission units shall be aggregated for a major source determination Production field facilities are defined in §63.761 as "facilities located prior to the point of custody transfer." Custody transfer is defined in this subpart as "the point at which such liquids or natural gas enters a natural gas processing plant." The gas processed at the Enterprise Compressor Station is subsequently routed to the Roggen Natural Gas Processing Plant. Pursuant to the definition of custody transfer, the Enterprise Compressor Station is located upstream of the point of custody transfer. The Enterprise Compressor Station operates produced water storage tanks, condensate storage tanks and, at any given time, one TEG dehydration unit. TEG dehydration units D-2 and D-3 are not permitted to operate simultaneously. Upon startup of new TEG dehydration unit D-3, D-2 will be shut down and decommissioned such that D-2 operations do not overlap with D-3 operations. Therefore, for the purposes of major source determination, only one dehydration unit was aggregated with the stabilized condensate storage tank and produced water storage tank emissions to determine major source applicability. Pursuant to the definition of major source set forth in §62.3 and the clarifications in §63.761, the HAP emissions from either glycol dehydration unit, when aggregated with 123/0277 Page 11 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit the stabilized condensate storage tanks and produced water storage tanks, are below the major source thresholds of 10 tons/year individual HAP and 25 tons/year total HAP. Therefore, for the purposes of subpart HH, the Enterprise Compressor Station is considered to be an area source of HAP. Area sources under Subpart HH are subject to only TEG dehydration unit requirements per §63.760(b)(2). Therefore, fugitive emission and storage tank requirements set forth in this subpart have not been included in the operating permit. For more detailed applicability determinations, requirements and/or exemptions for the TEG dehydration unit, refer to Sections IV and VII of this document. 40 CFR Part 60 Subpart OOOO NSPS - Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced After August 23, 2011, and on or Before September 18, 2015 This section addresses the final version of Subpart OOOO, last updated in the Federal Register on 6/3/2016. For the purposes of the Enterprise Compressor Station, this subpart applies to the reciprocating compressor driven by engine C-237. Affected facilities under Subpart OOOO are those which include any of the following: natural gas wells, centrifugal compressors, reciprocating compressors, natural gas driven pneumatic controllers, storage vessels, process units, sweetening units and hydraulically fractured gas well facilities that commence construction, reconstruction or modification after August 23, 2011 and before September 18, 2015. Applicability for each of these units is addressed below: • Natural Gas Wells — The Enterprise Compressor Station does not operate any natural gas wells. • Centrifugal Compressors—The Enterprise Compressor Station does not operate any centrifugal compressors. • Reciprocating Compressors —The Enterprise Compressor Station does operate reciprocating compressors. The reciprocating compressor driven by engine C- 237 commenced construction in 2012, which is within the applicability date range of NSPS OOOO. The source submitted an initial notification of NSPS OOOO applicability for this compressor on 10/18/2012. As such, the reciprocating compressor coupled to engine C-237 is subject to the requirements of NSPS OOOO. No other compressors have undergone a modification within the NSPS OOOO applicability timeframe and are therefore not subject to this Subpart. • Natural Gas Driven Pneumatic Controllers—The Enterprise Compressor Station operates pneumatic controllers. However, pursuant to source correspondence received on 5/29/2018, all pneumatic controllers at the Enterprise Compressor Station are instrument air driven. As such, these controllers are not affected facilities for the purposes of the Subpart. • Storage Vessels — The Enterprise Compressor Station operates storage tanks onsite. Pursuant to the APEN submitted on 11/30/2016, four condensate storage 123/0277 Page 12 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit tanks were constructed in 1993, prior to the applicability date set forth in Subpart OOOO and are therefore not subject. However, four additional condensate tanks were permitted to be constructed with the 8/1/2012 issuance of the operating permit.These tanks commenced operation on 8/5/2013. The condensate storage tank point,therefore, was modified within the applicability timeframe of the NSPS OOOO. Uncontrolled emissions from these tanks exceed the 6 tons/year applicability threshold set forth in NSPS OOOO. However, these tanks were permitted with a federally enforceable limit of 1.7 tons/year, which, pursuant to §60.5365(e), may be considered potential to emit for the purposes of Subpart OOOO. As such, these tanks do not emit in excess of the 6 tons/year set forth under Subpart OOOO and are not subject to it. In addition to the condensate storage tanks, the Enterprise Compressor Station operates two produced water storage tanks. These storage tanks have an uncontrolled potential to emit of 1.9 tons/year VOC. Because these tanks do not emit in excess of the 6 tons/year threshold set forth under Subpart OOOO, these tanks are not subject to this Subpart. • Process Units—Process units, pursuant to§60.5430 are defined as"components assembled for the extraction of natural gas liquids from field gas, the fractionation of the liquids into natural gas products, or other operations associated with the processing of natural gas products." Based on the definition of natural gas processing plants set forth in §60.5430, these unit operations are specific to processing plants only. The Enterprise Compressor Station is not considered to be a natural gas processing plant because it does not engage in the extraction of natural gas liquids (NGLs) or the fractionation of these NGLs.As such, process units at the Enterprise Compressor Station are not affected facilities under Subpart OOOO. • Sweetening Units — The Enterprise Compressor Station does not operate any sweetening units. In summary, only the compressor driven by engine C-237 is an affected facility under Subpart OOOO. For more detailed applicability determinations, requirements and/or exemptions for the reciprocating compressor coupled to C-237, refer to Section VII of this document. Colorado Regulation No. 7, Part D,Section I—Volatile Organic Compound Emissions from Oil and Gas Operations This section addresses the final version of Colorado Regulation No. 7, Part D, Section I, last updated 2/14/2020. For the purposes of the Enterprise Compressor Station, this section applies on a facility-wide basis since the station is classified as an.oil and gas operation located within the ozone non-attainment area. Requirements applicable to the Enterprise Compressor Station are as follows: • Section I.C.1.a. — General Requirements, including good engineering practice requirements. 123/0277 Page 13 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Note that compliance with this condition is required to claim the Section I.I. exemption. See discussion below. • Section I.C.1.b. —All hydrocarbon liquid and produced water collection, storage, processing and handling operations shall be designed, operated and maintained to minimize VOC emissions. o Note that compliance with this condition is required to claim the Section I.I. exemption. See discussion below. • Section I.H. — Natural Gas Dehydration Units Requirements, addressing VOC emission reductions, monitoring and recordkeeping relating to the air pollution control equipment utilized, and semi-annual reporting. • Section I.I. — Exemption from the requirements to comply with Sections I.D through I.F. This section serves to exempt compressor stations or natural gas drip stations meeting the specific criteria set forth in this section from the storage tank control strategy (and, prior to 3/1/2020, condensate storage tanks subject to the system- wide control strategy). The Enterprise Compressor Station fulfills each of the exemption criteria identified in Part D, Section I.I. as follows: o Section 1.1.1. - Air pollution control equipment is installed and properly operated to reduce emissions of volatile organic compounds from all atmospheric condensate storage tanks (or tank batteries) that have uncontrolled actual emissions of greater than or equal to two tons per year. ■ The Enterprise Compressor Station operates a battery of eight (8) stabilized condensate storage tanks with actual, uncontrolled emissions of greater than 2 tons/year. These storage tanks are controlled by an enclosed combustion device, thereby fulfilling this requirement. It should be noted that the Enterprise Compressor Station also operates two (2) produced water storage tanks that are uncontrolled and have potential emissions of VOC of 1.9 tons/year. However, this exemption criterion is specific to condensate storage tanks only; there are no requirements for non-condensate storage tanks. As such, the status of the produced water storage tanks was not considered when evaluating the exemption criteria in Section I.I. o Section 1.1.2. - The air pollution control equipment is designed to achieve a VOC control efficiency of at least 95% on a rolling 12-month basis and meets the requirements of Sections I.C.1.a. and I.C.1.b. • The enclosed combustion device controlling the condensate storage tanks at the Enterprise Compressor Station has a manufacturer design destruction efficiency of 98%. It should be noted that for the purposes of establishing emission limitations, a 123/0277 Page 14 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit conservative 95% control efficiency is utilized. This enclosed combustion device must comply with the requirements of Section I.C.1.a. and I.C.1.b., thereby fulfilling this requirement. Sections I.C.1.a. and I.C.1.b. were therefore included in the operating permit. o Section 1.1.3. - The owner or operator of such natural gas compressor station or natural gas drip station does not own or operate any exploration and production facilities in the Ozone Nonattainment or Attainment- maintenance Area; and ■ DCP Operating Company, LP does not own or operate any E&P facilities within the ozone non-attainment area, thereby fulfilling this requirement. o Section 1.1.4. - The owner or operator of such natural gas compressor station or natural gas drip station does the following and maintains associated records and reports for a period of five years: maintenance of air pollution control equipment, annual opacity observations, maintenance of stabilized condensate throughput records and annual compliance reports submitted to the Division. • These conditions were included in the operating permit to ensure these requirements are met. o Section 1.1.5 -A natural gas compressor station or natural gas drip station subject to Section I.I. at which a glycol natural gas dehydrator and/or natural gas-fired stationary or portable engine is operated is subject to Sections I.H., I.J., and/or Part E, Section I. A natural gas compressor station subject to Section 1.1. is also subject to Section I.L. • The applicable requirements of Sections I.H., I.J., I.L., and Part E, Section I were explicitly included in the operating permit. This requirement Section 1.1.5 was not included in the operating permit because it is informative in nature and only refers to applicable substantive requirements. It should be noted that the storage tank control strategy set forth in Section I.D.3. applies to storage tanks in general, which, as defined in Part D, Section I.B.26. and 27., include both condensate and produced water tanks. These storage tanks are both exempted from I.D.3. if the condensate storage tanks only meet the requirements of Part D, Section 1.1. Because the condensate storage tanks at the Enterprise Compressor Station meet all of the criteria set forth in Part D, Section 1.1., all storage tanks, including condensate and produced water tanks, are exempted from the storage tank control strategy set forth in Section I.D.3., pursuant to Part D, Section I.D.3.b.(ix). Note, however, that the produced water storage tanks' potential to emit is 1.9 tons/year VOC. As such, the storage tank control strategy requirements would not apply to these tanks regardless of the Section 1.1 exemption, since actual uncontrolled emissions from these tanks would always be below the 2 tons/year applicability threshold of Section I.D.3. 123/0277 Page 15 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Section I.J.2. — Reciprocating compressor requirements, addressing periodic rod packing replacements. o Pursuant to the 2019 inspection report, compliance with the Section I.J.2. requirements is achieved by periodically replacing the compressor rod packing, as provided for under Section I.J.2.a. To reflect actual compliance practices at the facility, the alternative requirements related to installing a closed vent system and routing rod packing emissions to process (Section I.J.2.b.) were not included in the operating permit. • Section I.L. — Leak detection and repair requirements for natural gas compressor stations, including approved instrument monitoring methods (AIMM), leak identification, repair, remonitoring and recordkeeping requirements. For more detailed applicability determinations, requirements and/or exemptions in regards to Colorado Regulation No. 7, Part D, Section I., refer to Section VII of this document. The following requirements from Colorado Regulation No. 7, Part D, Section I were found to be non-applicable to the Enterprise Compressor Station pursuant to the provided justification: • Sections I.C.1.c-e — These conditions apply to control devices that are used to demonstrate compliance with the compressor requirements of Section I.J. Pursuant to the 2019 inspection report for this facility, the Enterprise Compressor Station complies with Section I.J. by periodically replacing the compressors' rod packing (Section I.J.2.a.), instead of installing a control device (Section I.J.2.b.). Therefore, these general requirements applicable to control devices were not included in the operating permit, as this compliance option is not practiced at this facility. • Section I.C.1.f. — This condition requires a surveillance system be installed for condensate storage tanks with uncontrolled actual emissions of VOC greater than 100 tons/year. Pursuant to the most recent APENs received on 5/17/2019 and 6/1/2020, actual uncontrolled emissions from both the stabilized condensate storage tanks and produced water storage tanks at the Enterprise Compressor Station are less than the 100 ton/year threshold and as such, are not subject to the surveillance system requirements of this section. • Section I.C.2. — This section sets forth emission factors to be used to monitor compliance with the requirements of Section I.D. The storage tanks at the Enterprise Compressor Station are not subject to Section I.D (see below determination). As such, the requirements of Section I.C.2 do not apply to this facility. • Part D, Section I.D.1. — This section sets forth control requirements for condensate storage tanks located within the 8 hour ozone control area through 4/30/2020. Because the operating permit will be issued after this date, the requirements of Part D, Section I.D.1 were not included in the operating permit. 123/0277 Page 16 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Part D, Section I.D.2. —This section sets forth control requirements for new and modified condensate storage tanks located within the 8 hour ozone control area through 3/1/2020. Because the operating permit will be issued after this date, the requirements of Part D, Section I.D.2 were not included in the operating permit. • Part D, Section I.D.3. — This section sets forth control requirements for storage tanks (including condensate and produced water tanks) with actual uncontrolled emissions of VOC greater than or equal to 4 tons/year(or 2 tons/year, as a state- only requirement) within the 8 hour ozone control area. Pursuant to the exemption in Part D, Section I.D.3.b.(ix), compressor stations subject to Part D, Section 1.1 are exempt from the requirements of Part D, Section I.D.3. As discussed above, the Enterprise Compressor Station is subject to Part D, Section 1.1 and is therefore exempt from Part D, Section I.D.3. • Part D, Section I.D.4. — This section sets forth requirements for alternative emissions control equipment for storage vessels subject to Section I.D. As noted above, no storage tanks at the Enterprise Compressor Station are subject to Section I.D. requirements. This section was therefore not included in the operating permit. • Section I.E. —This section addresses monitoring for condensate tanks operating in a non-attainment area that are "controlled pursuant to this Section l" and "any storage tank subject to Section 1.D.3.a.(ii)". Pursuant to the exemption in Section 1.1, the Enterprise Compressor Station is exempt from these Section I.E. requirements • Section I.F. — This section applies to storage tanks subject to the system-wide control strategy (through April 30, 2020) (Section I.F.1.), or Section I.D.3. (Sections I.F.2. and I.F.3.). Pursuant to the exemption in Section 1.1, the Enterprise Compressor Station is exempt from these Section I.F. requirements. • Section I.G.—This section applies to natural gas processing plants located in the 8-hour ozone control area. Although the Enterprise Compressor Station is located within the 8-hour ozone control area, this facility is not considered to be a natural gas processing plant for the purposes of Colorado Regulation No. 7 because it does not engage in the extraction or fractionation of NGLs (Section 113.21.). Therefore, this facility is not subject to the requirements of Section I.G. • Section I.K. — This section sets forth requirements for natural gas driven pneumatic pumps operating in the ozone non-attainment area. Per source correspondence received 5/29/2018, there are no natural gas driven pneumatic pumps present at the Enterprise Compressor Station. As such, Section I.K. does not apply to this facility. Colorado Regulation No. 7, Part D, Section II — Statewide Controls for Oil and Gas Operations This section addresses the final version of Colorado Regulation No. 7, Part D, Section II, last updated 2/14/2020. For the purposes of the Enterprise Compressor Station, this section applies to oil and gas operations located within the state of Colorado. 123/0277 Page 17 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Requirements applicable to the Enterprise Compressor Station are as follows: • Section II.B. — General Provisions, including good engineering practice requirements, air pollution control equipment operating and design requirements, combustion device requirements, open ended line requirements and compressor seal requirements. • Section II.C.1-4 — Storage Tank Requirements, addressing VOC reductions, control device requirements, audio, visual and olfactory (AVO) inspection requirements, capture requirements, STEM plan requirements and measurement system requirements. o The stabilized condensate storage tanks at the Enterprise Compressor Station are permitted to operate with uncontrolled actual emissions in excess of 6 tons/year VOC, and are therefore presumably subject to Section II.C.1.b. Although Section II.C.1.c., which sets forth control requirements for storage tanks with uncontrolled actual emissions of VOC greater than or equal to 2 tons/year, applies only to tanks that are not otherwise controlled pursuant to Section II.C.1.b., it is possible that the storage tanks operate with uncontrolled actual VOC emissions between 2 and 6 tons/year, depending on actual operations. In these situations, the storage tanks would not be controlled pursuant to Section II.C.1.b., and would therefore need to be controlled pursuant to Section II.C.1.c. As such, both requirements were included in the operating permit since the applicability of either requirement is dependent upon actual emissions for any given year. o It should be noted that the stabilized condensate storage tanks at the Enterprise Compressor Station store only stabilized condensate. As such, these tanks are not subject to the storage tank emission management (STEM) plan requirements, pursuant to Section II.C.2.b. o The produced water storage tanks at the Enterprise Compressor Station are not subject to any part of this Section II.C., as they have an uncontrolled potential to emit of 1.9 tons/year. The Section II.C. requirements are triggered upon uncontrolled actual emissions of 2 tons/year. Because these storage tanks' uncontrolled potential to emit (i.e., maximum emissions) is less than the Section II.C. threshold, these tanks are not subject to the requirements of Section II.C. • Section II.C.5 — Hydrocarbon Liquid Loadout Requirements, addressing equipment design, equipment operation, personnel training, loadout observations and recordkeeping. o It should be noted that this section applies only to hydrocarbon liquids, which are defined in Part D, Section II.A.12. as "any naturally occurring, unrefined petroleum liquid. Hydrocarbon liquid does not include produced water." Pursuant to the definition, the produced water loaded out from the produced water storage tanks is not subject to this section. The 123/0277 Page 18 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requirements of Section II.C.5. were therefore included for the stabilized condensate loadout point only. • Section II.D. — Dehydration Unit Requirements, addressing VOC and hydrocarbon emission reductions. • Section II.E. — Leak Detection and Repair Program for compressor stations, including approved instrument monitoring methods (AIMM), leak identification, repair, remonitoring and recordkeeping requirements. For more detailed applicability determinations, requirements and/or exemptions for the affected operations, please refer to Section VII of this document. The following requirements from Section II were found to be non-applicable to the Enterprise Compressor Station pursuant to the provided justification: o Section II.B.5. —This section allows for an exemption for dehydration units from complying with the Section II. requirements, provided these units "are subject to an emissions control requirement in a federal maximum achievable control technology ("MACT") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT") limit, or a New Source Performance Standard ("NSPS") under 40 CFR Part 60 are not subject to Section II., except for the leak detection and repair requirements in Section 11.E". The natural gas dehydration units are both subject to 40 CFR 63 Subpart HH (MACT). However, as an area source of HAP, each unit is subject to requirements which include compliance with the optimal lean glycol circulation rate (if they do not otherwise achieve the throughput or benzene exemption criteria; see Section VII for a more detailed discussion of the MACT HH requirements). The Division does not consider these requirements to be a qualifying "emissions control requirement" (i.e., numerical emissions limitation) for the purposes of the Section II.B.5 exemption. As such, the dehydration unit at the Enterprise Compressor Station is subject to the provisions of Section II. o Section II.F. — This section requires emissions control from well production facilities. The Enterprise Compressor Station does not own or operate any natural gas wells within the facility-and is therefore, for the purposes of Colorado Regulation No. 7, not considered to be a well production facility subject to the requirements of Section II.F. o Section II.G. — This section regulates venting during well maintenance. The Enterprise Compressor Station does not own or operate any natural gas wells within the facility and is therefore not subject to the requirements of Section II.G. Colorado Reciulation No. 7, Part D, Section V — Oil and Natural Gas Operations Emissions Inventory This section addresses the final version of Colorado Regulation No. 7, Part D, Section V, last updated 2/14/2020. For the purposes of the Enterprise Compressor Station, this section applies on a facility-wide basis. 123/0277 Page 19 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit These requirements are applicable to "oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado" (Section V.A).The Enterprise Compressor Station routes the compressed gas exiting this facility to the Roggen Natural Gas Processing Plant and, as such, is considered to be upstream of a natural gas processing plant for the purposes of this section and therefore subject to the applicable reporting requirements for various operation and equipment categories. For a more detailed discussion on the incorporation of the requirements of Colorado Regulation No. 7, Part D, Section V. into the operating permit, refer to Section VII of this document. Colorado Regulation No. 7, Part E, Section I — Control of Emissions from Engines This section addresses the final version of Colorado Regulation No. 7, Part E, Section I, last updated 2/14/2020. For the purposes of the Enterprise Compressor Station, this section applies to stationary engines. • Section I.B. — Air pollution control technology requirements for lean burn reciprocating internal combustion engines operating within the 8-Hour Ozone Control Area. o Pursuant to Section I.A., the requirements of Section I.B. apply to both new (commenced operations after 6/1/2004) and existing (commenced operation before 6/1/2004) natural gas fired stationary internal combustion engines with a manufacturer's design rating of greater than 500 hp that operate in the 8-Hour Ozone Control Area. The Enterprise Compressor Station is located within the 8-Hour Ozone Control area. Engine sizes based on the most recent APENs submitted are summarized in the following table: AIRS ID Facility APEN Received Manufacturer Identifier Date Design Rating 053 C-238 4/16/2019 3,550 hp 055 C-235 4/16/2019 3,550 hp 056 C-236 4/16/2019 3,550 hp 070 C-234 4/16/2019 3,550 hp 071 C-237 4/16/2019 4,735 hp Based on the engine sizes identified, all engines at the Enterprise Compressor Station are subject to the air pollution control technology requirements of Colorado Regulation No. 7, Part E, Section I.B. • Section I.D. — Control of emissions from new, modified, existing and relocated natural gas fired reciprocating internal combustion engines, addressing oxidation catalyst installation and good engineering practices for air pollution control equipment. The following table summarizes the applicability of the Section I.D. requirements for each engine: 123/0277 Page 20 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Facility APEN Date of Date of CO Reg. No.7, CO Reg. No.7, AIRS ID. Identifier Received Date Construction/ (re)Location Part E,Section Part E,Section Modification to CO I.D.2 Requirement I.D.3 Requirement 053 C-238 4/16/2019 2/27/2008 2/27/2008 7/1/2007 Limits Oxidation Catalyst 055 C-235 4/16/2019 Before 1994 9/30/1994 -- Oxidation Catalyst 056 C-236 4/16/2019 Before 1993 5/19/1993 -- Oxidation Catalyst 070 C-234 4/16/2019 Before 1/1993 Before 1/1993 -- Oxidation Catalyst 071 C-237 4/16/2019 Before 8/2012 Before 8/2012 7/1/2010 Limits Oxidation Catalyst o It should be noted that engines C-234, C-235, and C-236, pursuant to the most recent APENs submitted for these engines, predate the applicability of the numerical emission standards set forth in Section I.D.2. (7/1/2007). Therefore, these requirements were only included in the operating permit for engines C-237 and C-238. o Section I.D.3.b.(i) requires lean burn engines located in Colorado to install an oxidation catalyst by 7/1/2010. As such, this requirement is applicable to all engines. For a more detailed discussion on the incorporation of the requirements of Colorado Regulation No. 7, Part E, Section I. into the operating permit, refer to Section VII of this document. Colorado Regulation No. 7, Part E, Section II — Control of Emissions from Stationary and Portable Engines and Other Combustion Equipment in the 8-Hour Ozone Control Area This section addresses the final version of Colorado Regulation No. 7, Part E, Section II, last updated 2/14/2020. For the purposes of the Enterprise Compressor Station, this section applies to stationary engines located within the ozone non-attainment area. • Section ILA. — Requirements for Major Sources of NOx o The requirements of this section apply to affected combustion equipment located at a facility classified as a major source of NOx as of 6/3/2016 under the moderate non-attainment major source threshold of 100 tons/year. The Enterprise Compressor Station has a controlled potential to emit for NOx greater than 100 tons/year, and was designated as a major source of NOx under the 100 ton/year threshold prior to 6/3/2016. However, Section II.A.2. exempts natural gas fired reciprocating internal combustion engines subject to emission control requirements set forth in Part E, Section I.B. from the emission limitation (Section II.A.4.) and performance testing (Section II.A.5.) requirements, as well as the associated recordkeeping and reporting (Sections II.A.7 and II.A.8.), but not the combustion process adjustments (Section II.A.6.). Because all engines at the Enterprise Compressor Station are subject to Part E, Section I.B. (see above discussion), these engines are required to comply 123/0277 Page 21 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit only with the combustion process adjustment requirements and associated recordkeeping. For a more detailed discussion on the incorporation of the requirements of Colorado Regulation No. 7, Part E, Section II. into the operating permit, refer to Section VII of this document. Non-Applicable Regulations The Enterprise Compressor Station was determined to be totally exempt from the following regulations: MACT Subpart DDDDD — Subpart DDDDD applies to Industrial, Commercial and Institutional Boilers and Process Heaters and major sources of HAP. The Enterprise Compressor Station operates natural gas fired heaters as reboilers to provide sufficient heat to regenerate the TEG from the dehydration units and to facilitate condensate stabilization. Pursuant to §63.7485, a major source of HAP for the purposes of this subpart is defined to be any source with emissions of a single HAP in excess of 10 tons/year or total facility HAP in excess of 25 tons/year (§63.2) except for oil and gas production facilities, where only emissions from glycol dehydration units and storage tanks with the potential for flash are counted toward the facility HAP totals (§63.7575). "Production field facility' is not defined in Subpart DDDDD. However, similar language is utilized in Subpart HH and ZZZZ for the purposes of major source determination. In these subparts, "production field facility is defined as "those facilities located prior to the point of custody transfer" (Subpart HH §63.761; Subpart ZZZZ §63.6675). Custody transfer is further defined in these subparts as "the point at which such liquids or natural gas enters a natural gas processing plant." The Enterprise Compressor Station is located upstream from the Roggen Natural Gas Processing Plant and is therefore considered to be a production field facility. As such, only emissions from glycol dehydration units and storage tanks with the potential for flash emissions were considered for the major source determination. The atmospheric storage tanks at the Enterprise Compressor Station store only stabilized condensate. This condensate has been stabilized to a vapor pressure well below atmospheric, and, as such, there is not potential for flash emissions. Therefore, HAP emissions from the stabilized condensate storage tanks were not included in the major source determination for Subpart DDDDD. In contrast, the produced water storage tanks can accept pressurized produced water and therefore have the potential for flash emissions.As such, HAP emissions from these storage tanks were included in the major source determination for the purposes of Subpart DDDDD. The Enterprise Compressor Station operates, at any given time, only one TEG dehydration unit. TEG dehydration units D-2 and D-3 are not permitted to operate simultaneously. Upon startup of new TEG dehydration unit D-3, D-2 will be shut down and decommissioned such that D-2 operations do not overlap with D-3 operations. Therefore, for the purposes of major source determination, emissions from only one dehydration unit were aggregated with the produced water storage tanks to determine major source applicability. 123/0277 Page 22 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit The HAP emissions from either dehydration unit and the produced water storage tanks are below the major source thresholds of 10 tons/year individual HAP and 25 tons/year total HAP. Therefore, the Enterprise Compressor Station is considered to be an area source for the purposes of Subpart DDDDD, and is therefore not subject to this subpart. MACT Subpart JJJJJJ — Subpart JJJJJJ applies to Industrial, Commercial and Institutional Boilers located at area sources of HAP. The Enterprise Compressor Station operates natural gas fired heaters as reboilers to provide sufficient heat to regenerate the TEG from the dehydration units and to facilitate condensate stabilization. Pursuant to §63.11193, a major source of HAP for the purposes of this subpart is defined to be any source with emissions of a single HAP in excess of 10 tons/year or total facility HAP in excess of 25 tons/year(§63.2. It should be noted that, unlike Subpart DDDDD above, there are no clarifications to the §63.2 definition of major source). The Enterprise Compressor Station produces formaldehyde emissions that are greater than the 10 tons/year threshold and total HAP emissions in excess of the 25 tons/year threshold. As such, this facility is considered to be a major source of HAP and is not subject to the area source requirements of Subpart JJJJJJ. NSPS Subpart Dc — Subpart Dc applies to Small Industrial-Commercial-Institutional Steam Generating Units. Pursuant to §60.40c of this subpart, affected facilities include "steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts (MW) (100 million British thermal units per hour(MMBtu/h)) or less, but greater than or equal to 2.9 MW (10 MMBtu/h)." All natural gas fired heaters at the Enterprise Compressor Station are significantly below the 10 MMBtu/hr applicability threshold set forth in Subpart Dc. Therefore, the Enterprise Compressor Station is not subject to Subpart Dc. NSPS Subpart Kb — Subpart Kb applies to storage vessels with a capacity greater than 75m3 (-472 bbl) used to store volatile organic liquids for which construction/reconstruction/modification took place after July 23, 1984. The atmospheric stabilized condensate storage tanks at the Enterprise Compressor Station each have a design capacity of 300 bbl and the produced water storage tanks have a design capacity of 90 bbl, both of which are less than the applicability threshold for Subpart Kb. Therefore, Subpart Kb does not apply to these atmospheric storage tanks and is not applicable to the Enterprise Compressor Station. This facility also operates two 30,000 gallon (-714 bbl) pressurized bullet tanks that store unstabilized condensate just upstream of the stabilization unit. Based on a conversation with operations during the 2019 inspection, at no time do these storage vessels vent to atmosphere. If the stabilizer unit is not operating, these tanks are designed to hold pressure on the condensate until stabilizer operations resume. Bullet tanks of this type are typically designed with a maximum allowable working pressure (MAWP) of at least 250 psig (—1,724 kPa) As such, these storage vessels meet both of the exemption criteria set forth in NSPS Kb §60.110b(d)(2) and are therefore not subject to this Subpart. NSPS Subpart KKK — Subpart KKK applies to equipment leaks of VOC from onshore natural gas processing plants. The Enterprise Compressor Station is not considered to be a natural gas processing plant for the purposes of the Subpart. As such, the Enterprise Compressor Station is not subject to Subpart KKK. 123/0277 Page 23 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit NSPS 0000a—Subpart 0000a applies to crude oil and natural gas facilities for which construction, modification or reconstruction commenced after September 18, 2015. Affected facilities under this Subpart include: wells, centrifugal compressors, reciprocating compressors, natural gas driven pneumatic controllers, storage vessels, process units, sweetening units, pneumatic pumps, and fugitive emissions. Applicability for each of these units is addressed below: Applicability for each of these units is addressed below: • Wells — As noted in the NSPS OOOO discussion above, the Enterprise Compressor Station does not operate any wells. • Centrifugal Compressors — As noted in the NSPS OOOO discussion above, the Enterprise Compressor Station does not operate any centrifugal compressors. • Reciprocating Compressors — As noted in the NSPS OOOO discussion above, the Enterprise Compressor Station does operate reciprocating compressors, however, the most recent modification took place in 8/2012 for the compressor driven by engine C-237 and none of the other compressors have been modified. Because none of the compressors have been modified within the NSPS 0000a applicability date range, these compressors are not affected facilities for the purposes of this Subpart. • Natural Gas Driven Pneumatic Controllers — As noted in the NSPS OOOO discussion above, the Enterprise Compressor Station does operate pneumatic controllers, however, pursuant to source correspondence received 5/29/2018, all pneumatic controllers are instrument air driven. As such, these controllers are not affected facilities for the purposes of this Subpart. • Storage Vessels — The Enterprise Compressor Station operates storage tanks onsite. With the issuance of 19WE0492, throughput to the condensate storage tanks was increased due to the installation of the new, larger TEG dehydration unit D-3. Because a capital expenditure was undertaken at the facility, the increase in throughput resulting in increased emissions for which a standard (NSPS OOOOa) applies meets the modification definition of modification in 40 CFR Part 60 Subpart A. Therefore, the condensate storage tank point is considered to have been modified within the applicability timeframe of NSPS OOOOa. Uncontrolled emissions from these tanks exceed the 6 tons/year applicability threshold set forth in NSPS OOOOa. However, these tanks were permitted with a federally enforceable limit of 1.7 tons/year, which, pursuant to §60.5365a(e), may be considered potential to emit for the purposes of Subpart OOOOa. As such, these tanks do not emit in excess of the 6 tons/year set forth under Subpart 0000a and are not subject to it. In addition to the condensate storage tanks, the Enterprise Compressor Station operates produced water storage tanks, for which throughput also increased with the installation of the TEG dehydration unit D-3. Potential emissions from this uncontrolled storage tank are 1.9 tons/year VOC. Because this tank does not emit in excess of the 6 tons/year set forth under Subpart OOOOa, these tanks are not subject to this Subpart. 123/0277 Page 24 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Sweetening Units — As noted in the NSPS OOOO discussion above, the Enterprise Compressor Station does not operate any sweetening units. • Pneumatic Pumps — Affected pneumatic pump facilities, as defined under §60.5365a(h) include natural gas driven pneumatic pumps at well sites and natural gas processing plants only. Well site, as defined in §60.5430a is "one or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well." As noted above, the Enterprise Compressor Station does not operate wells and, as discussed in the NSPS OOOO section above, the Enterprise Compressor Station is not a natural gas processing plant. Because pneumatic pump affected facilities include only well sites and natural gas processing plants, the pneumatic pump requirements in NSPS 0000a are not applicable to the Enterprise Compressor Station. • Fugitive Emissions — Fugitive emissions from both well sites and compressor stations are regulated under Subpart OOOOa. As noted above, the Enterprise Compressor Station is not considered a well site. Compressor station, under the definition in §60.5430a includes"one or more compressors that move natural gas at increased pressure through gathering or transmission pipelines, or into or out of storage." As such, the Enterprise Compressor Station, for the purposes of Subpart OOOOa, is considered to be compressor station. Compressor station fugitive emissions, pursuant to §60.5365a(j), are affected facilities under Subpart OOOOa. However, as clarified in §60.5365a(j)(1) and (2), only certain events trigger fugitive emission requirements; i.e., the installation of a new compressor or the replacement of a compressor with greater total horsepower. Pursuant to the 6/3/2016 preamble to this rule, published in the Federal Register (81 FR 35864 — 35865), section h), the intent of fugitive emissions monitoring at compressor stations was to only affect such stations if a physical change in the compressors only resulted in increased emissions. Triggering events are specifically defined as the addition of a compressor or the replacement of one or more compressors with a new compressor of greater total horsepower than the replaced units. No additional compressors have been added to the Enterprise Compressor Station during the applicability timeframe of Subpart OOOOa; nor have there been any compressor replacements resulting in increased capacity. As such, fugitive emissions requirements for this facility have not been triggered. Pursuant to the justifications outlined above, there are no affected facilities under NSPS 0000a at the Enterprise Compressor Station, and, as such, this Subpart does not apply to this facility. Colorado Regulation No. 7, Part B, Section IV- Section IV establishes requirements for the storage and transfer of petroleum liquid. Per the definitions set forth in Section IV, petroleum liquids are defined as"crude oil, condensate and any finished or intermediate product manufactured or extracted in a petroleum refinery". The Enterprise Compressor Station stores condensate on its premises. However, the Division has determined that the original intent of this rule was to regulate sources not otherwise subject to requirements contained in Colorado Regulation No. 7. Because the Enterprise Compressor Station is an affected facility under Colorado Regulation No. 7, Part D 123/0277 Page 25 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Sections I. and II. for oil and natural gas operations, the requirements of Section IV do not apply to the Enterprise Compressor Station. Colorado Regulation No. 7, Part D, Section III — Section III pertains to natural gas- actuated pneumatic controllers associated with oil and gas operations. Per source correspondence received 5/29/2018, there are no natural gas-actuated pneumatic controllers present at the Enterprise Compressor Station. All pneumatic controllers are instrument air-driven. As such, this section does not apply to this facility. Colorado Regulation No. 7, Part D, Section IV— Section IV sets forth emissions control requirements and reporting for the natural gas transmission and storage segment. "Natural gas transmission and storage segment" is defined in Section IV.A.3. as "onshore natural gas transmission pipelines, onshore natural gas transmission compression, underground natural gas storage, and liquefied natural gas (LNG) storage, as these terms are defined in 40 CFR Part 98, Section 98.230 (October 22, 2015), that are physically located in Colorado." Subpart W (40 CFR Part 98 §98.230) defines "onshore natural gas transmission compression" as "any stationary combination of compressors that move natural gas from production fields, natural gas processing plants, or other transmission compressors through transmission pipelines to natural gas distribution pipelines, LNG storage facilities, or into underground storage." The Enterprise Compressor Station is a compressor station, but the final destination of the gas moved through this compressor station is a natural gas processing plant, not a distribution pipeline, LNG storage facility or underground storage cavern. As such, this facility is not included in the natural gas transmission and storage segment for the purposes of Colorado Regulation No. 7, Part D, Section IV and is therefore not subject to these requirements. Compliance Orders on Consent The following section addresses the Compliance Orders on Consent (COC) issued for the Enterprise Compressor Station: COC Case No. 2017-103: This COC was issued in response to formaldehyde emissions observed during stack testing conducted in 2017 that exceeded the MACT ZZZZ limitations for engines C-234 and C-237. The COC required that these engines return to compliance with the MACT ZZZZ emission limitations and an administrative penalty was assessed. The appropriate MACT ZZZZ requirements were included in the previous issuance of the operating permit. As such, no requirements from this COC were incorporated into the operating permit. IV. INCORPORATION OF CONSTRUCTION PERMITS A. Colorado Construction Permit 19WE0094 This section addresses the conditions established in Colorado Construction Permit 19WE0094, Issuance 1, for natural gas venting from reciprocating compressor blowdowns (AIRS 076). Operations began on 7/17/2019, per the Notice of Startup received 7/30/2019. 123/0277 Page 26 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Colorado Construction Permit 19WE0094 was issued for the reciprocating compressor blowdowns on 7/17/2019 as an initial approval permit. A self- certification package for this permit was submitted on 8/31/2020, however, the operator could not successfully self-certify due to the initial sampling requirement to obtain an extended gas analysis demonstrating the emission factors set forth in the permit were conservative. The initial sample returned emission factors in excess of those permitted. As required, the operator submitted a permit modification to correct those emissions factors, received by the Division on 10/30/2020, which included a compliance plan in accordance with Colorado Regulation No. 3, Part C, Section V.A.1. and Section III.C.8, 9 and 10. These updated emission factors, as well as a decreased throughput limit, were incorporated into the operating permit to address this issue of non-compliance with the emission factors. It should be noted, however, that actual blowdown VOC emissions did not exceed the permitted limitation set forth in 19WE0094. 1. Applicable Requirements The appropriate applicable requirements from Colorado Construction Permit 19WE0094 for the reciprocating compressor blowdowns are as follows: Condition 1: Notice of Startup (NOS) requirements • Not included: The notice of startup for this reciprocating compressor blowdown point was received on 7/30/2019. This one-time condition has been met and was therefore not included in the operating permit. Condition 2: Self-Certification requirements • Not included: Certification will occur via semi-annual reporting, as discussed above. Condition 3: Expiration for failure to construct/modify • Not included: Per the Notice of Startup received 7/30/2019, this point commenced operation on 7/17/2019. An expiration date is therefore not required. Condition 4: Requirement to conduct initial testing • Included: This condition was modified slightly to require that the initial testing be submitted as part of the first semi-annual report due after the initial testing is conducted in lieu of a self-certification package. Condition 5: Retain Final Authorization (FA) letter • Not included: The operating permit serves as an ongoing final approval to operate. Condition 6: Emission limits • Included: Note that although this emission point is new, monthly limitations were not included in the construction permit and will not be included in the 123/0277 Page 27 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit operating permit due to the intermittent nature of blowdown events. Blowdown events occur as maintenance is scheduled and are typically clustered into a few months per year. Process changes necessitating equipment blowdowns are typically clustered within a relatively short timeframe as well. As such, it was determined to be inappropriate to introduce monthly limits for intermittent operations since an elevated number of blowdown events in any one month is not necessarily an indication of non-compliance with the annual limit. Condition 7: Process limits • Included: This condition was modified to decrease the number of blowdown events permitted, pursuant to the significant modification received 10/30/2020. Note that monthly process limits were not included in the construction permit, pursuant to the discussion in Condition 6 above. Condition 8: Mark identifying information on equipment • Not included: This one-time condition has been met and was therefore not included in the operating permit. Condition 9: This source is subject to the odor requirements of Regulation Number 2. • Not included: This condition is included in the General Conditions of Section IV in the operating permit.A separate condition for this AIRS point in Section II was therefore not created. Condition 10: This source is located in the ozone non-attainment or attainment- maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, Section III.D.2.a. The following requirements were determined to be RACT for these sources: good work practices. • This condition was incorporated in its entirety into the operating permit. • The source indicated in correspondence received 5/30/2019 that RACT for this point was evaluated and was determined to be good work practices. When blowdowns occur, the instantaneous flowrate of emissions at the elevated pressure of the compressors as it is let down to a lower pressure is extremely large and would overwhelm the existing combustion devices (COMB-1 and the storage tank/loadout combustor). Both combustors were ordered in 2014 and designed solely to destruct emissions from the dehydration unit (COMB-1) or storage tanks/loadout emissions. Neither combustor was designed to accommodate the high instantaneous flowrate of emissions expected from compressor blowdowns. As such, it was determined to be technically infeasible to route blowdown emissions to an existing control device. Additionally, the installation of a new combustion device was evaluated in this correspondence. Because a brand new combustor would need to be relatively large to accommodate the high 123/0277 Page 28 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit instantaneous flowrate, and since actual blowdown events are projected to occur relatively infrequently, it was determined that the installation of a new control device would be economically infeasible. However, certain work practices can be utilized to reduce the amount of emissions released during each blowdown event. Avoiding "flat" blowdowns, or blowdowns evacuating the entire compressor volume to atmospheric pressure, can be avoided if the maintenance scheduled can be conducted safely on a semi-pressurized compressor, or if the process safely allows. As such, work practices such as this were established as RACT for this point. A requirement to record any work practices used to reduce emissions, as well as a justification for any blowdown events for which good work practices were not performed, was included in the operating permit to monitor compliance with RACT. Condition 11: O&M plan is not required • Not included: This condition does not contain substantive requirements and was therefore not included in the operating permit. Note that an O&M plan for this point was not required by the construction permit because it is uncontrolled. Condition 12: Initial testing requirement to conduct extended gas analysis • Included: This condition was modified slightly to require that the initial testing be submitted as part of the first semi-annual report due after the initial testing is conducted in lieu of a self-certification package. Condition 13: Periodic testing requirement to conduct annual extended gas analyses • Included: This condition was incorporated in its entirety into the operating permit. Condition 14: Revised APEN submittal requirements and deadlines • Not included: This condition is included in the General Conditions of Section IV in the operating permit.A separate condition for this AIRS point in Section II was therefore not created. Condition 15: Requirement to submit an operating permit application • Not included: This application was received on 8/24/2020 and, as such, this one time requirement has been met. Condition 16: Relaxation requirement for PSD/NANSR limits • Not included: This requirement is evaluated on a case-by-case basis that is dependent on specific parameters of undefined future modifications, and the requirement will be evaluated at that time. This condition was therefore not included. Conditions 17 through 23: General requirements 123/0277 Page 29 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Not included: These conditions are included in the General Conditions of Section IV in the operating permit. A separate condition for this AIRS point in Section II was therefore not created. 2. Emission Factors The emission factors included in the operating permit are based on the physical compressor volume only; a VOC-specific emission factor was not developed. To determine VOC emissions, an extended gas analysis shall be performed annually to obtain actual VOC content and the vapor molecular weight which, in conjunction with the compressor volume emission factors, will be used to determine actual VOC emissions. This method, as opposed to a static VOC emission factor, allows for process variability to be captured when estimating actual emissions. 3. Monitoring Plan The following requirements have been included in the operating permit to monitor compliance with the emission limitations set forth in this permit: • Blowdown Event Occurrence Monitoring Both the date and compressor facility identifier shall be recorded at each blowdown event. The quantity of events shall be used to calculate actual VOC emissions and monitor compliance with the event quantity limitation. The compressor identifier is required since the emission factors are specific to the emitting compressor, as the compressors at the Enterprise Compressor Station have different volumes. • Extended Gas Analysis Sampling An extended gas analysis shall be performed on a gas representative of compressor blowdowns annually. The VOC content and physical properties obtained from this analysis shall be used to calculate actual VOC emissions. • Good Work Practice Record keeping Any work practices performed to minimize the amount of gas being vented to atmosphere during blowdown events, as well as any explanation of why good work practices could not be performed, shall be recorded in a log during each blowdown event. These work practices are considered to be RACT for blowdown events. To assess compliance with RACT, records must be kept of the work practices performed. • Final Approval Requirements An extended gas analysis shall be performed on a gas representative of compressor blowdowns and submitted with the next semi-annual report due after the sample is taken. The VOC content and physical properties obtained from this analysis shall be used to calculate actual VOC emissions. 4. Compliance Status 123/0277 Page 30 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit The significant modification application received 10/30/2020 indicated that this source is not in compliance with all applicable requirements of 19WE0094. The initial extended gas analysis required pursuant to 19WE0094 resulted in emission factors in excess of those initially permitted. The operating permit includes the appropriate changes to address this issue, including updated emission factors, periodic sampling requirements and an initial sampling requirement to be conducted within 180 days of permit issuance. Therefore, no additional compliance plan or schedule is required. B. Colorado Construction Permit 19WE0492 This section addresses the conditions established in Colorado Construction Permit 19WE0492, Issuance 1. This permit was issued on 11/19/2019. This section applies to the following equipment: AIRS ID Facility ID Equipment Description Commenced Operation on: 063 P013 Stabilized Condensate Storage Tanks 1993 066 P016 Stabilized Condensate Loadout 1993 077 D-3 TEG Dehydration Unit TBD Note that this construction permit modification was not considered to be a "modification" pursuant to NSPS 0000a (as defined in NSPS 0000a and the NSPS general provisions set forth in 40 CFR 60 Subpart A) for any of these emission units, as discussed in Section III above. The due date of the first semi-annual monitoring report required by this operating permit will be more than 180 days after the initial approval construction permit 19WE0492 was issued and/or the equipment commenced operation: Therefore, under the provisions of Regulation No. 3, Part C, Section V.A.2, the Division is allowing the initial approval construction permit to continue in full force and effect and will consider the Responsible Official certification submitted with that report to serve as the demonstration required pursuant to Regulation No. 3, Part B, Section III.G.2 and no final approval construction permit will be issued. The appropriate provisions of the initial approval construction permit have been directly incorporated into this operating permit. 1. Applicable Requirements The appropriate applicable requirements from Colorado Construction Permit 19WE0492 were incorporated into the operating permit as follows: Condition 1: Notice of Startup (NOS) requirement (AIRS 077 only) • Included: This condition was amended slightly to require the NOS be submitted after commencement of operation of the dehydration unit. This dehydration unit is a new unit and therefore the appropriate NOS deadline is 15 days after startup. The NOS deadline based on permit issuance is for certain modifications to existing units only. 123/0277 Page 31 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Condition 2: Self-Certification requirements (AIRS 077 only) • Not included: Certification will occur via semi-annual reporting, as discussed above. Condition 3: Expiration for failure to construct/modify • Included: This condition was incorporated in its entirety into the operating permit. Condition 4: Requirement to conduct initial testing (AIRS 077 only) • Included: This condition was modified slightly to require that the initial testing be submitted as part of the first semi-annual report due after the initial testing is conducted in lieu of a self-certification package. Condition 5: Additional information required in Notice of Startup (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Condition 6: Retain Final Authorization (FA) letter • Not included: The operating permit serves as an ongoing final approval to operate, and a final approval letter is not required. Condition 7: Emission limits • Included: Note that the monthly limits are applicable only to AIRS 077 for the first 12 months of operation to establish a rolling twelve month total. The HAP limitations were included in a separate condition in the operating permit since the limits are applicable to multiple units. • Note that for major sources of HAP, it is standard operating permit practice to include conditions requiring the calculation of HAP emissions for the purposes of APEN reporting and payment of annual fees. As such, a requirement to calculate HAP emissions was included for the stabilized condensate truck loadout. Note that the TEG dehydration unit, condensate storage tanks and, as indicated in the operating permit, the produced water storage tanks are required to calculate HAP emissions to monitor compliance with the synthetic minor HAP limitations for the purposes of MACT HH area source applicability, in addition to APEN reporting and payment of fees. Condition 8: The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. • Not included: This condition is applicable to construction permits only and was therefore not included in the operating permit. It should be noted that all emission calculation methodologies and/or emission factors are incorporated directly into the operating permit. 123/0277 Page 32 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Condition 9: Compliance calculation requirements (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Condition 10: GLYCaIc input monitoring requirements (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Note that the requirement to retain records of these calculations for five years is required in the General Conditions of Section IV of the operating permit. As such, this retention length was not explicitly included in the Section II condition. Condition 11: VRU downtime (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Note that the requirement to retain records of downtime for five years is required in the General Conditions of Section IV of the operating permit. As such, this retention length was not explicitly included in the Section II condition. Condition 12: COMB-1 downtime (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Note that the requirement to retain records of downtime for five years is required in the General Conditions of Section IV of the operating permit. As such, this retention length was not explicitly included in the Section II condition. Condition 13: Operate and maintain control equipment • Not included: This condition does not contain substantive requirements or provide for compliance monitoring and was therefore not included in the operating permit. Explicit control device and, if applicable, downtime monitoring was included in the operating permit to ensure that emissions are reduced effectively. Condition 14: Operate and maintain VRU (AIRS 077 only) • Not included: This condition does not contain substantive requirements or provide for compliance monitoring and was therefore not included in the operating permit. Explicit control device and downtime monitoring was included in the operating permit to ensure that emissions are reduced effectively. Condition 15: Process limits • Included: This condition was supplemented with compliance monitoring methods as outlined below: o AIRS 063—As noted in source correspondence received 5/29/2018, condensate throughput is tracked using sales or haul tickets. The 123/0277 Page 33 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit operating permit was updated to specifically refer to this method of tracking. o AIRS 066—As noted in source correspondence received 5/29/2018, condensate throughput is tracked using sales or haul tickets. The operating permit was updated to specifically refer to this method of tracking. o AIRS 077: Note that the monthly limits are applicable only to AIRS 077 for the first 12 months of operation to establish a rolling twelve month total. Condition 16: Dry gas meter location (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Condition 17: VRU downtime (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Condition 18: COMB-1 downtime (AIRS 077 only) • Included: This condition was incorporated in its entirety into the operating permit. Condition 19: Lean glycol circulation limit (AIRS 077 only) • Included: This condition was modified slightly to require that the glycol meter be located downstream of all glycol injection points to ensure all glycol streams are captured by the meter. Note that the optimum glycol circulation rate was included in the MACT HH condition in the operating permit. The source must comply with this optimum circulation rate if the MACT HH benzene or throughput exemptions are not otherwise met. . Condition 20: Mark identifying information on equipment • Included: Compliance with this condition for the condensate storage tanks (AIRS 063) has been met and was therefore not included in the condensate storage tank condition. This requirement was included in the TEG dehydration unit condition to ensure that this unit is properly marked upon commencement of operation. Condition 21: Colorado Regulation No. 1 opacity • Included: Added explicit monitoring requirements including daily inspection periods and, if required, Method 22 (to monitor compliance with Colorado Regulation No. 7 no visible emissions requirements) and Method 9 (to monitor compliance with Colorado Regulation No. 1 opacity requirements). 123/0277 Page 34 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Condition 22: This source is subject to the odor requirements of Regulation Number 2. • Not included: This condition is included in the General Conditions of Section IV in the operating permit.A separate condition for this AIRS point in Section II was therefore not created. Condition 23: The storage tanks covered by this permit are subject to Regulation Number 7, Section XII.I. • Included: The applicable requirements of Section XII.1 were incorporated into the condensate storage tank condition in the operating permit. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section I.I. o The Section I.l.4.b. opacity limitation requirement was supplemented with a compliance monitoring method, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. The 20% opacity limitation shall be monitored with an annual EPA Reference Method 9 observation. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o The Section 1.1.4. recordkeeping requirements were supplemented with two additional requirements, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. Additional recordkeeping was included to require that manufacturer documentation of the design control efficiency by maintained to comply with the 95% VOC control efficiency requirement of Section 1.1.2. Additional recordkeeping was also included to maintain documents verifying the company does not own or operate any E&P facilities in the ozone non-attainment or attainment-maintenance area, if claiming that exemption. These additional recordkeeping requirements were clearly denoted in the permit with bold and italicized text. Condition 24: The combustion device controlling the condensate storage tanks covered by this permit is subject to Regulation Number 7, Section XVII.B.2. • Included: The applicable requirements of Section XVII.B.2 were incorporated into a separate Colorado Regulation No. 7 condition in the operating permit, which addresses those requirements that are applicable to multiple units or on a facility-wide basis. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section II.B.2. Conditions 25-26: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1 and XVII.C.2.a. 123/0277 Page 35 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Included: The applicable requirements of Section XVII.C were incorporated into the condensate storage tank condition in the operating permit. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section II.C. o The rule language was supplemented with a clarification that, for the purposes of this Section II.C, approved instrument monitoring methods (AIMM) mean IR camera or EPA Reference Method 21. Either of these methods are accepted by the Division for use in conducting AIMM inspections to monitor compliance with the Capture Requirements of Section II.C.2.a. This clarification was clearly denoted in the operating permit with bold and italicized text. o An explicit compliance monitoring method was added for Sections II.C.1.a, II.C.1.b. and II.C.1.c., which require a 95% VOC or hydrocarbon control efficiency be achieved for the storage tanks, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. Compliance with these requirements is presumed, provided the Section II.B. general requirements are met, as well as the specific control device requirements set forth in Condition 6.5 of the operating permit, including pilot light monitoring and visible emission observations. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o Added explicit compliance monitoring method for Section II.C.2.a., which requires that storage tanks be operated without venting, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. Provided records are maintained to demonstrate venting did not occur during normal operations, as required by Section II.C.3.b. and II.C.3.f., compliance with this requirement is presumed. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o An additional monitoring and clarification requirement was added to the AIMM inspection frequency requirements of Section II.C.2.b.(ii)(I), pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. It was clarified that 12 month rolling totals be used to determine the appropriate AIMM inspection frequency set forth in Table 1 and that if a different inspection frequency is triggered based on this rolling 12 month total, an inspection at the new inspection frequency be conducted within 30 days of discovery, or as previously scheduled, whichever occurs first. This additional monitoring was clearly denoted in the permit with bold and italicized text. o Included compliance monitoring requirement, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. that compliance with the utilization of a storage tank measurement system is presumed, provided records are maintained of the date of storage vessel 123/0277 Page 36 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit construction and a description of the storage tank measurement system, as required by Colorado Regulation No. 7, Part D, Section II.C.4.f. These compliance monitoring methods were clearly denoted in the permit with bold and italicized text. o Included compliance monitoring requirement, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. that compliance with the requirement to test liquid quantity and/or quality without opening a thief hatch, pressure relief device or other access point will be demonstrated by maintaining a log of each qualitative and/or quantitative monitoring event, including an indication of whether or not any thief hatch, access point or pressure relief device was open during each event. These compliance monitoring methods were clearly denoted in the permit with bold and italicized text. o Included clarification language, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. and based on the Frequently Asked Questions, Volume 1 published in response to the December 2019 Regulation No. 3 and No. 7 rulemaking that signage,for the purposes of Section II.C.4.d., may include a statement that the thief hatches, pressure relief devices and/or other access points may not be opened to monitor liquids quantity or quality, an identification of the appropriate location to obtain this data, and the location of more detailed information in regards to quantity and quality monitoring. This clarification was clearly denoted in the permit with bold and italicized text. o Included compliance monitoring requirement, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. that compliance with the requirement to develop an annual training program is presumed, provided records are maintained of that training program, as required by Colorado Regulation No. 7, Part D, Section II.C.4.f. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. Condition 27: This source is located in an ozone non-attainment or attainment- maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill (AIRS 066 only). • Included: Added requirement to maintain records of any standard loadout operating procedures or equipment design documentation that demonstrates submerged fill loading is conducted. Note that with the 2/14/2020 promulgation of Colorado Regulation No. 7, submerged fill is required for loadout operations with an actual annual throughput of 5,000 bbl/year. However, the RACT established by this construction permit applies at all times, regardless of throughput. As such, this RACT condition was included in the operating permit as set forth in the construction permit. A note was added to clarify that, pursuant to the construction permit, this 123/0277 Page 37 of 102 • DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requirement is applicable at all times, regardless of the loadout throughput threshold listed in Colorado Regulation No. 7. Condition 28: 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 (AIRS 066 only). • Included: Compliance with this requirement will be monitored by maintaining records of the loading procedures required by Conditions 29 and 30. Condition 29: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere (AIRS 066 only). • Included: This condition was modified to require recordkeeping to verify the loading procedures were followed and to identify any corrective measures performed. o It should be noted that the requirement to conduct monthly inspections of onsite loading equipment was incorporated in its' entirety into Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(E). As such, a reference to the Regulation No. 7 requirement was inserted in this condition. The regulatory language permits inspections to be conducted less frequently than monthly if loading activities are performed less often than monthly. Because the Enterprise Compressor Station is a manned facility and inspection of the loadout equipment is not precluded if loadout is not occurring, the 19WE0492 monthly frequency, regardless of quantity of loadout activities, was retained. The Colorado Regulation No. 7 allowance to perform loadout less frequently than monthly was therefore streamlined from the operating permit. Refer to Section VIII below for more information on the streamlining of this frequency. Condition 30: For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere (AIRS 066 only). • Included: This condition was incorporated in its' entirety into Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii) with the 2/14/2020 promulgation. However, these loading procedures as written into this construction permit are applicable at all times, whereas the requirements of Colorado Regulation No. 7 apply only if actual annual loadout throughput is greater than 5000 bbl/year. To avoid unnecessary duplication of conditions, these Colorado Regulation No. 7 requirements were referenced in the Operational Requirements Condition 5.5 of the operating permit.A note was added to clarify that, pursuant to the construction permit, these requirements are applicable at all times, regardless of the loadout throughput threshold listed in Colorado Regulation No. 7. 123/0277 Page 38 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Condition 31: This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII (AIRS 077 only). • Included: The applicable requirements of Section XII.H were incorporated into the dehydration unit condition in the operating permit. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section I.H. o The Section I.H.1. requirement to reduce VOC emissions by 90% was supplemented with a compliance monitoring method, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. A 90% reduction in VOC shall be presumed, provided the source is in compliance with the general requirements of Section I.C and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 4.9 of the operating permit. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o The Section I.4.H. requirement for calculating emissions from the dehydration unit was supplemented with additional monitoring, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. This. , was done to provide a timeline of compliance, should the dehydration unit's actual uncontrolled emissions drop below the applicability threshold of Section I.H.3. In the event the source drops below this applicability threshold and then subsequently exceeds it, the source shall have 60 days to comply with the applicable Section I.H. requirements. This additional monitoring was clearly denoted in the permit with bold and italicized text. Condition 32: The combustion device controlling dehydration unit covered by this permit is subject to Regulation Number 7, Section XVII.B.2. • Included: The applicable requirements of Section XVII.B.2 were incorporated into a separate Colorado Regulation No. 7 condition in the operating permit, which addresses those requirements that are applicable to multiple units or on a facility-wide basis. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section II.B.2. Condition 33: The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3 (AIRS 077 only). • Included: The applicable requirements of Section XVII.D were incorporated into the dehydration unit condition in the operating permit. Note that Colorado Regulation No. 7 citations were significantly altered with the 2/14/2020 promulgation. The new citation for these requirements is Part D, Section II.D. 123/0277 Page 39 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o The Section II.D.1. requirement to reduce VOC by 90% was supplemented with a compliance monitoring method, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. A 90% reduction in VOC shall be assumed, provided the source is in compliance with the general requirements of Section II.B. and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 4.9 of the operating permit. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o The Section II.D.3. requirement to reduce hydrocarbon emissions by 95% was supplemented with a compliance monitoring method, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b. A 95% reduction in hydrocarbon shall be assumed, provided the source is in compliance with the general requirements of Section II.B. and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 4.9 of the operating permit. Compliance with the destruction efficiency requirements for the combustion device shall be presumed, provided records are kept of the design destruction efficiency and proximity of the-closest building/outdoor activity area are kept. This compliance monitoring method was clearly denoted in the permit with bold and italicized text. o The Section II.D. requirements were further supplemented with additional monitoring requirements, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b., as follows: • Requirement to maintain a rolling 12 month calculation of total emissions for the dehydration unit to determine whether the control requirements of Section II.D.1., and/or II.D.3. apply. • Requirement to comply with Section II.D within 60 days for instances in which the dehydration unit had actual uncontrolled emissions below the thresholds set forth in Section II.D.2. and II.D.4., and then subsequently exceeds these thresholds. • Requirement to maintain records of whether or not the facility is located within 1,320 feet of a building unit or outdoor activity area. • Requirement to maintain records of the design destruction efficiency of the combustion device. This additional monitoring was clearly denoted in the permit with bold and italicized text. Condition 34: 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 (AIRS 077 only). 123/0277 Page 40 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Included: The applicable requirements of MACT HH were incorporated into the dehydration unit condition in the operating permit. Condition 35: 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. • Not included: The applicable requirements of the O&M plan for the dehydration unit were incorporated directly into the operating permit in accordance with Division-standard practices for operating permits. Since the O&M plan was absorbed by the operating permit, this reference condition was not included. Condition 36: Initial testing requirement to perform Method 22 (AIRS 077 only) • Included: Modified slightly to require the Method 22 be conducted within 180 days of startup and the results of that observation be included with the first semi-annual monitoring report due after the observation was conducted. Condition 37: Initial testing requirement to obtain an extended gas analysis on the dehydration unit inlet gas (AIRS 077 only) • Included: Modified slightly to require the results of the initial extended gas analysis be included with the first semi-annual monitoring report due after the observation was conducted. Condition 38: Initial testing requirement to obtain an extended gas analysis on the pilot/assist gas used for COMB-1 (AIRS 077 only) • Included: Modified slightly to require the results of the initial extended gas analysis be included with the first semi-annual monitoring report due after the observation was conducted. Additionally modified to remove the reference to "pilot" gas, as the pilot gas emission calculation does not require parameters obtained from an extended gas analysis, as requested in source comments received 9/11/2020. Condition 39: Periodic testing requirement to perform Method 22 • Included: This condition was modified slightly to require daily, six minute visible emissions observations for the presence of smoke, to be followed up with a Method 22 if smoke is observed. Condition 40: Periodic testing requirement to obtain an annual extended gas analysis of the dehydration unit inlet gas (AIRS 077 only) • Included: This condition was modified slightly to require that at least 8 months separate subsequent sampling events, pursuant to standard operating permit monitoring, recordkeeping and recording requirements. Condition 41: Periodic testing requirement to obtain an annual extended gas analysis of the gas used as pilot/assist gas (AIRS 077 only) 123/0277 Page 41 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Included: This condition was modified slightly to require that at least 8 months separate subsequent sampling events, pursuant to standard operating permit monitoring, recordkeeping and recording requirements. Additionally modified to remove the reference to "pilot" gas, as the pilot gas emission calculation does not require parameters obtained from an extended gas analysis, as requested in source comments received 9/11/2020. Condition 42: Glycol pump AOS allowance (AIRS 077 only) • Included: This condition was modified slightly to require that records of pump replacements made under this AOS provision be made available to the Division upon request. Condition 43: Requirement to maintain log of any glycol pump replacements made in accordance with the AOS (AIRS 077 only) • Included: Modified requirement slightly to require that the log be made available to the Division upon request. Condition 44: Any replacement pumps shall comply with the terms of the permit (AIRS 077 only). • Not included: The applicable requirements to glycol circulation pumps have been included in the permit and these requirements must be complied with, regardless of whether or not the pump is a replacement. Condition 45: Revised APEN submittal requirements and deadlines • Not included: This condition is included in the General Conditions of Section IV in the operating permit.A separate condition for this AIRS point in Section II was therefore not created. Condition 46: Requirement to submit an operating permit application • Not included: The operating permit application was received 11/19/2020, thereby satisfying this one-time requirement. Condition 47: Relaxation requirement for PSD/NANSR limits • Included: A reference to this condition was included in the operating permit noting that the relaxation provisions of Colorado Regulation No. 3, Part D, Section V.A.7.b. may be triggered with future modifications to the units contained in Colorado Construction Permit 19WE0492. Note that this requirement is evaluated on a case-by-case basis that is dependent on specific parameters of undefined future modifications to one or more of the units contained in this construction permit. Refer to the PSD/NANSR relaxation in (5) below for a more detailed discussion of this condition. Conditions 48 through 54: General Requirements 123/0277 Page 42 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Not included: These conditions are included in the General Conditions of Section IV in the operating permit. A separate condition for this AIRS point in Section II was therefore not created. 2. Emission Factors The following emission factors and calculation methods have been incorporated into the operating permit for each unit addressed in 19WE0492 as follows: • AIRS 063 - Stabilized Condensate Storage Tanks The static VOC emission factor established by 19WE0492 was incorporated into the operating permit. The condensate generated at the Enterprise Compressor Station is first routed through a stabilizer prior to being sent to the storage tanks. The stabilizer drives off lighter components of the condensate to meet a sub-atmospheric RVP specification. As such, flashing is not experienced at the storage tanks and the composition and physical properties of the condensate is not expected to vary significantly. Therefore, the static VOC emission factor set forth in 19WE0492 was incorporated into the operating permit. To ensure the continued validity of the emission factor listed in the permit, a condition was added to perform a verification analysis once every five years using the annual condensate throughput and most recent extended liquids analysis in conjunction with the methods set forth in EPA's AP-42: Compilation of Emission Factors, Chapter 7 for Liquid Storage Tanks to obtain an emission factor in terms of lb VOC / bbl condensate. If the verification analysis results in an emission factor greater than the emission factor listed in the permit, a requirement was included to submit a permit modification within 60 days of the verification analysis. To facilitate this verification analysis, a requirement to conduct an extended liquids analysis of the condensate once every five years was also included in the operating permit. Similarly, the static HAP emission factors calculated in the Preliminary Analysis (PA) associated with Colorado Construction Permit 19WE0492 were included in the operating permit to calculate HAP emissions for the purposes of monitoring compliance with the synthetic minor HAP emission limitations for MACT HH area source applicability, APEN reporting and payment of annual fees. • AIRS 066 - Stabilized Condensate Loadout The static VOC emission factor established by 19WE0492 was incorporated into the operating permit. The emission factor for the stabilized condensate loadout was originally permitted using Equation 1 of AP-42, Chapter 5.2 Transportation and Marketing of Petroleum Liquids. Pursuant to the discussion above, the stabilized condensate is not expected to vary significantly in composition. As such, the emission factor calculated using the AP-42 methodology was incorporated into the operating permit. To ensure the continued validity of the emission factor listed in the permit, a condition was added to perform a verification analysis once every five years 123/0277 Page 43 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit using the properties obtained from the most recent extended liquids analysis in the AP-42 Chapter 5.2 Equation 1 to obtain an emission factor in terms of lb VOC / bbl condensate. If the verification analysis results in an emission factor greater than the emission factor listed in the permit, a requirement was included to submit a permit modification within 60 days of the verification analysis. To facilitate this verification analysis, a requirement to conduct an extended liquids analysis of the condensate once every five years was also included in the operating permit. Similarly, the static HAP emission factors calculated in the Preliminary Analysis (PA) associated with Colorado Construction Permit 19WE0492 were included in the operating permit to calculate HAP emissions for APEN reporting and the payment of annual fees. • AIRS 077 —TEG Dehydration Unit D-3 Emissions from this TEG dehydration unit point include flash gas and still vent emissions from the dehydration unit and pilot and assist gas combusted at the enclosed combustion device COMB-1. A summary of the calculation method used for each of these sources is listed as follows: o Dehydration unit flash gas and still vent: Static VOC and HAP emission, factors were not included in the operating permit for D-3. To capture process variability when estimating actual emissions, a monthly GLYCaIc process model run shall be performed, using actual metered dry gas throughput, averages of the inlet and flash tank operating temperatures and pressures, the actual hours of dehydration unit operation and actual hours of control device downtime to calculate emissions. Static NOx and CO emission factors used to estimate combustion emissions from the still vent and flash gas (when not otherwise recycled with the VRU) were obtained from AP-42, Chapter 13.5 for industrial flares. The flowrate and heat content of the still vent and flash gas obtained from the GLYCaIc model run are used in conjunction with the emission factors and hours of control device operation to calculate combustion emissions. o Pilot Gas: Static NOx, VOC and CO emission factors for pilot gas combustion were obtained from AP-42, Chapter 1.4 for natural gas combustion sources. This emission factor, in conjunction with the monthly pilot gas flowrate, are used to calculate pilot combustion emissions. o Assist Gas: Static VOC and HAP emission factors were not included in the operating permit for the assist gas routed to COMB-1. To capture process variability when estimating actual emissions, the assist gas 123/0277 Page 44 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit throughput, in conjunction with the VOC content and molecular weight of the assist gas obtained from the most recent extended gas analysis shall be used to calculate emissions. Static NOx and CO emission factors used to estimate assist gas combustion emissions were obtained from AP-42, Chapter 13.5 for industrial flares. The flowrate and heat content of the assist gas obtained from the most recent extended gas analysis are used in conjunction with the emission factors to calculate combustion emissions. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future modification to this permit is not necessary upon assist gas line installation 3. Monitoring Plan The following requirements have been included in the operating permit to monitor compliance with the emission limitations set forth in this permit: • AIRS 063 - Stabilized Condensate Storage Tanks o Condensate Throughput Monitoring Condensate throughput is monitored monthly using sales or haul tickets. The throughput is used to calculate VOC emissions and to conduct the emission factor verification analysis. o Extended Liquids Analysis An extended liquids analysis is required once every five years to obtain the condensate VOC content, which is used to conduct the emission factor verification analysis. o Pilot Light Presence The pilot light is monitored continuously using a thermocouple. In the event the thermocouple is not functioning correctly, visual inspection of the pilot may be performed daily. Pilot light presence is required to ensure the storage tank emissions are ignited. Note that this requirement was not required by 19WE0492, but was included in the previous version of the operating permit. It was retained with this issuance to ensure pilot light monitoring is conducted. o Visible Emissions Observations Visible emissions observations are conducted daily for a period of 6 minutes to monitor for the presence of smoke. If smoke is observed, a Method 22 must be performed to monitor compliance with the no visible emissions requirement of Colorado Regulation No. 7, Part D, 123/0277 Page 45 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Section II.B.2.b. If visible emissions are detected pursuant to Method 22, a Method 9 shall be performed by a certified observer to monitor compliance against the Colorado Regulation No. 1 Section II.A.5 opacity limitations. In addition to this Method 9 required if visible emissions are observed, an annual Method 9 is required to ensure the 20% opacity requirement set forth in Colorado Regulation No. 7, Part D, Section I.I.4.b. is met. Note that this opacity observation must be performed during normal operations only, pursuant to Section I.I.4.b. Normal operation is not defined in Part D, Section I, but is defined in Part D, Section II.A.14 as "all periods of operation, excluding malfunctions as defined in Section I.G. of the Common Provisions regulation." Further, the Statement of Basis and Purpose (SBAP)for the 2/23/2014 rulemaking clarifies that"normal operation" is "considered to include all operation, including maintenance and other activities, as long as the operation does not meet the definition of "malfunction" as set forth in the Common Provision regulations." In the absence of a more pointed definition in Part D, Section I, it is presumed that this Part D, Section II definition, in conjunction with the SBAP clarification, applies to the "normal operation" referenced in Part D, Section I.I.4.b. • AIRS 066 - Stabilized Condensate Loadout o Condensate Throughput Monitoring Condensate throughput is monitored monthly using sales or haul tickets. The throughput is used to calculate VOC emissions. o Extended Liquids Analysis An extended liquids analysis is required once every five years to obtain the condensate VOC content, which is used to conduct the emission factor verification analysis. o Loading Procedures To ensure the proper loading procedures are performed, records shall be kept of the results and corrective actions performed in response to the monthly inspections of loading equipment, annual inspections of thief hatches and annual inspection of pressure relief devices. To verify vapor collection equipment was installed and operated properly, records shall be kept of the standard operating procedures used and control equipment design. o Pilot Light Presence The pilot light is monitored continuously using a thermocouple. In the event the thermocouple is not functioning correctly, visual inspection of the pilot may be performed daily. Pilot light presence is required to ensure the truck loading emissions are ignited. Note that this 123/0277 Page 46 of 102 DCP Operating Company, LP'—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requirement was not required by 19WE0492, but was included in the previous version of the operating permit. It was retained with this issuance to ensure pilot light monitoring is conducted. o Visible Emissions Observations Visible emissions observations are conducted daily for a period of 6 minutes to monitor for the presence of smoke. If smoke is observed, a Method 22 must be performed to monitor compliance with the no visible emissions requirement of Colorado Regulation No. 7, Part D, Section II.B.2.b. If visible emissions are detected pursuant to Method 22, a Method 9 shall be performed by a certified observer to monitor compliance against the Colorado Regulation No. 1 Section II.A.5 opacity limitations. o Reasonably Available Control Technology (RACT) RACT for this loadout is considered to be submerged fill. Records shall be kept of the standard operating procedures and equipment design to validate the loadout is designed and operated as submerged fill. • AIRS 077 —TEG Dehydration Unit D-3 o Dry Gas Processed Monitoring Dry gas processed by the dehydration unit is monitored using a meter located on the outlet of the dehydration unit. The dry gas processed is converted into an average daily throughput to be used as an input into the monthly GLYCaIc model run. It should be noted that the average daily throughput conversion was not included in 19WE0492, but was explicitly outlined in the operating permit for clarity. o Dry Gas Processed During VRU Downtime The amount of dry gas processed while the VRU is experiencing downtime is monitored and recorded monthly using the dry gas processing rate obtained at the outlet meter in conjunction with the VRU downtime records. The dry gas processed during VRU downtime is used to monitor compliance with the VRU downtime limitation of 5%. o Dry Gas Processed During COMB-1 Downtime The amount of dry gas processed while enclosed combustion device COMB-1 is experiencing downtime is monitored and recorded monthly using the dry gas processing rate obtained at the outlet meter in conjunction with COMB-1 downtime records. The dry gas processed during COMB-1 downtime is used to monitor compliance with the COMB-1 downtime limitation of 1%. 123/0277 Page 47 of 102 • DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Pilot Gas Throughput Monitoring Pilot gas throughput to enclosed combustion device COMB-1 is determined using the manufacturer specification of 50 scfh and the hours of COMB-1 operation. The pilot gas throughput is used to monitor compliance with the NOx, CO and VOC emission limitations, as well as the pilot gas throughput limitation. It should be noted this pilot gas monitoring was not included in 19WE0492 but was explicitly included in the operating permit. o Assist Gas Throughput Monitoring Assist gas throughput to enclosed combustion device COMB-1 is determined using a meter installed on the assist gas line routed to COMB-1. The assist gas throughput is used to monitor compliance with the NOx, CO and VOC emission limitations, as well as the assist gas throughput limitation. It should be noted this assist gas monitoring was not included in 19WE0492 but was explicitly included in the operating permit. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. . However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future modification to this permit is not necessary upon assist gas line installation o Lean Glycol Circulation Rate The lean glycol circulation rate is monitored using a meter and recorded daily. In the event the meter is malfunctioning, the maximum permitted glycol circulation rate may be used. A monthly average of the daily circulation rate is input to the monthly GLYCaIc model run. It should be noted that the averaging requirement was not included in 19WE0492, but was explicitly outlined in the operating permit for clarity. o Extended Gas Analysis of Inlet Wet Gas An extended gas analysis of the inlet wet gas to the dehydration unit is required annually to obtain the wet gas composition, which is used as an input to the monthly GLYCaIc model run. o Extended Gas Analysis of Assist Gas An extended gas analysis of the assist gas is required annually to obtain the assist gas composition and heat content, which are used to monitor compliance with the NOx, CO and VOC emission limitations. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future 123/0277 Page 48 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit modification to this permit is not necessary upon assist gas line installation o Parametric Monitoring The inlet wet gas temperature and pressure and flash tank operating temperature and pressure are monitored and recorded weekly. A monthly average of these values is used as inputs to the monthly GLYCaIc model run. o Dehydration Unit Hours of Operation Hours of dehydration unit operation are monitored and recorded daily and used to monitor compliance with the NOx, CO and VOC emission limitations, and to calculate an average daily gas throughput. o COMB-1 Hours of Operation Hours of operation of enclosed combustion device COMB-1 are monitored and recorded daily and used to monitor compliance with the pilot gas throughput limitations. Hours of operation are determined using the COMB-1 run status indication. As noted in operator correspondence received 11/13/2020, run status indication takes into account not only the pilot light presence, but various other parameters that indicate overall combustion device operability. As such, it was determined that the run status is a better indication of combustion device operation than pilot light presence alone, and was therefore used to determine COMB-1 hours of operation. o VRU Downtime Hours of VRU downtime are monitored and recorded daily as indicated by the VRU run status and used to monitor compliance with the NOx, CO and VOC emission limitations and VRU downtime limitation. o COMB-1 Downtime Hours of enclosed combustion device COMB-1 downtime are monitored and recorded daily and used to monitor compliance with the NOx, CO and VOC emission limitations and COMB-1 downtime limitation. Hours of downtime are determined using the difference between the D-3 run status and the COMB-1 run status indication. o VRU Valve Alignment Inspection Visual inspections of the valve alignment routing flash tank emissions from the dehydration unit to the VRU are conducted daily and recorded. Note that this requirement was not included in 19WE0492, but was added pursuant to standard operating permit 123/0277 Page 49 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit monitoring, recordkeeping and reporting requirements, as these emissions may be routed to multiple locations. o COMB-1 Valve Alignment Inspection Visual inspections of the valve alignment routing still vent (and, if the VRU is experiencing downtime, flash tank) emissions from the dehydration unit to enclosed combustion device COMB-1 are conducted daily and recorded. Note that this requirement was not included in 19WE0492, but was added pursuant to standard operating permit monitoring, recordkeeping and reporting requirements, as these emissions may be routed to multiple locations. o Pilot Light Presence The pilot light is monitored continuously using a thermocouple. In the event the thermocouple is not functioning correctly, visual inspection of the pilot may be performed daily. Pilot light presence is required to ensure the still vent, and, if the VRU is experiencing downtime, flash gas emissions are ignited. Note that this requirement was not required by 19WE0492, but was included in the previous version of the operating permit. It was retained with this issuance to ensure pilot light monitoring is conducted. o Visible Emissions Observations Visible emissions observations are conducted daily for a period of 6 minutes to monitor for the presence of smoke. If smoke is observed, a Method 22 must be performed to monitor compliance with the no visible emissions requirement of Colorado Regulation No. 7, Part D, Section II.B.2.b. If visible emissions are detected pursuant to Method 22, a Method 9 shall be performed by a certified observer to monitor compliance against the Colorado Regulation No. 1 Section II.A.5 opacity limitations. o Final Approval Requirements As of the issuance date of this permit on XX/XX/XXX, D-3 has not obtained final approval to operate. As such, a notice of startup shall be submitted to the Division, which must include the manufacturer name, model and serial number of the dehydration unit and manufacturer name and model of the glycol circulation pumps. Initial testing, including a Method 22 visible emissions test and extended gas analyses of the dehydration unit inlet wet gas and assist gas shall be completed within 180 days of startup, after which the periodic visible emissions monitoring and extended gas analysis requirements included in the operating permit shall take over. The initial testing results shall be submitted with the first semi-annual report due after the tests are conducted. 123/0277 Page 50 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Glycol Circulation Pump AOS Any glycol pump replacements made are to be noted in a log, which shall indicate the start and stop dates of the pump, and the manufacturer, model number, serial number and capacity of the replacement pump. 4. Compliance Status The compliance status for each unit addressed in 19WE0492 is summarized as follows: • AIRS 063 -Stabilized Condensate Storage Tanks The 8/8/2019 inspection report indicates that the stabilized condensate storage tanks are NOT in compliance with all applicable requirements. During the 2019 inspection, emissions from a storage tank thief hatch were observed and one tank had a missing bolt on the thief hatch assembly. Additionally, the source had observed emissions from the thief hatches twice within the compliance period during the AIMM inspections required under Colorado Regulation No. 7, Part D, Section II.C. The bolt was replaced on the thief hatch on 6/28/2019, thereby rectifying that issue. Thief hatches are periodically inspected pursuant to the fugitive emission requirements set forth in Colorado Regulation No. 7, Part D, Sections I.L and II.E. The applicable requirements of Sections I.L and II.E were included in the operating permit and therefore no additional compliance plan or schedule is required. • AIRS 066 - Stabilized Condensate Loadout The 8/8/2019 inspection report indicates that the stabilized condensate loadout is in compliance with all applicable requirements. • AIRS 077 —TEG Dehydration Unit D-3 As a newly permitted emissions source, this construction permit has not yet been inspected against, nor has an operating permit application requesting construction permit incorporation been submitted. 5. NANSR Relaxation With the issuance of 19WE0492, applicability of NANSR requirements were evaluated for the project requested, specifically for VOC. The installation of the larger TEG dehydration unit D-3 and associated permit and APEN exempt reboiler resulted in increased utilization of the stabilized condensate storage tanks, stabilized condensate loadout and the produced water tank. As a conservative approach, the source elected to evaluate each emission unit included in the project at full PTE (i.e.,baseline actuals were assumed to be zero and not calculated for the existing units, including the condensate storage tanks, condensate loadout and produced water loadout). The following table presents the project emissions increase: 123/0277 Page 51 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit AIRS Unit Pollutant NANSR Emissions ID Threshold Increase 063 Stabilized Condensate 1.68 Storage Tank 066 Stabilized Condensate 0.94 Loadout 075 100 bbl Produced VOC 40 2.11 Water Tank 077 145 MMscfd TEG 23.95 Dehydration Unit N/A 1.5 MMBtu/hr Reboiler 0.04 Project Total 28.72 As can be seen from the preceding table, this project was not a major modification for the purposes of NANSR. However, any future increase in the emissions of the above five units that would relax the limitations such that the project total exceeds 40 tons/year (for a modification in a moderate non-attainment area) may trigger the relaxation provisions set forth in Colorado Regulation No. 3, Part D, Section V.A.7.b. An evaluation of whether or not relaxation has occurred will be evaluated on a case-by-case basis at the time of the future modification. Note that since the issuance of Colorado Construction Permit 19WE0492 on 11/19/2019, the produced water storage tank point was modified in the significant permit modification application received 6/1/2020 to reflect the use of two 90 bbl produced water storage tanks. Additionally, a site-specific emission factor, in lieu of the state default factor used in the 19WE0492 permitting process, was developed. The emissions resulting from this change decreased to 1.9 tons/year VOC. This updated tank point was incorporated into the operating permit. V. New Emission Sources AIRS 075 —Two (2) 90 bbl Produced Water Storage Tanks The produced water tanks were previously a permit exempt source pursuant to Colorado Regulation No. 3, Part B, Section II.D.1.m which exempts "oil and gas production wastewater impoundments (including produced water tanks) containing less than one percent by volume crude oil on an annual average, with the exception of commercial facilities that accept oil and gas production wastewater for processing." A permit exempt letter was issued for these tanks (18WE0877.XP) on 11/19/2019. However, with the Colorado Regulation No. 3 modifications, effective 2/14/2020, Part B, Section II.D.1.m exemption was repealed. Because these produced water storage tanks emit VOC in excess of the APEN reporting threshold of 1 ton/year in the non- attainment area and do not meet any other permit exemptions set forth in Colorado Regulation No. 3, Part B, Section II.D, these storage tanks require a permit and were therefore incorporated into the XX/XX/XXXX issuance of this operating permit, as 123/0277 Page 52 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requested in the significant permit modification application received 6/1/2020 and modified in source comments received 9/11/2020. 1. Applicable Requirements Condition 7.1: VOC Emission Limitations & Compliance Monitoring • Included methodology for VOC and HAP emission calculations using the emission factors established via AP-42 Chapter 7 calculation methods for working and breathing emissions, a flash liberation analysis conducted 3/12/2020 for flash emissions and the monthly produced water throughput. Records of this calculation shall be maintained and used to monitor compliance against the VOC emission limitation for the produced water storage tanks and the HAP limitation required for MACT HH area source applicability. • To ensure the continued validity of the emission factor listed in the permit, a condition was added to perform an annual verification analysis using the annual produced water throughput, the most recent flash liberation analysis and the methods set forth in AP-42 Chapter 7 for Liquid Storage Tanks to obtain an emission factor in terms of lb VOC / bbl produced water. If the verification analysis results in an emission factor greater than the emission factor listed in the permit, a requirement was included to submit a permit modification within 60 days of the verification analysis. To facilitate this verification analysis, a requirement to conduct an annual flash liberation analysis of the produced water was also included in the operating permit. Condition 7.2: Produced Water Throughput Limitations & Compliance Monitoring • Produced water throughput shall be monitored using haul tickets. The monthly throughput will be used to monitor compliance with the annual throughput limitation and to calculate VOC and HAP emissions. Condition 7.3: Flash Liberation Analysis • A flash liberation analysis shall be conducted annually on the pressurized produced water routed to these storage tanks. Results of this analysis shall be used to verify the static emission factor listed in this permit for these tanks. Condition 7.4: Statewide Controls for Oil and Gas Operations The applicable requirements of Colorado Regulation No. 7, Part D, Section II.B. were incorporated into the operating permit as follows: • Colorado Regulation No. 7, Part D, Section II.B. The produced water storage tanks are subject to the following general requirements of Colorado Regulation No. 7, Part D, Section II.B.: 123/0277 Page 53 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Section II.B.1.a. (State-Only Enforceable) —All hydrocarbon liquids and produced water handling operations shall be designed to minimize leakage of VOC and other hydrocarbons. o Section II.B.1.b. (State-Only Enforceable) — The facility and air pollution control equipment shall be operated at all times using good air pollution control practices. It should be noted that all general facility requirements were grouped into a separate condition within the operating permit. The produced water storage tank condition references the applicable requirements, which are located in Condition 10 of the operating permit. 2. Emission Factors Static VOC and HAP emission factors used to estimate emissions from the produced water tank were obtained from AP-42 Chapter 7 calculation methods for the working and breathing losses and a flash liberation analysis conducted 3/12/2020 for the flashing losses. These emission factors, in conjunction with the produced water throughput to the storage tank, are used to calculate VOC and HAP emissions. 3. Monitoring Plan • Produced Water Throughput Monitoring Produced water throughput is monitored monthly using sales or haul tickets. The throughput is used to calculate VOC emissions. • Flash Liberation Analysis A flash liberation analysis is required to be performed annually on the pressurized produced water that is routed to these storage tank. The flash liberation analysis is required to perform the annual emission factor verification analysis to ensure the continued validity of the emission factor set forth in this permit. 4. Compliance Status As a newly permitted emissions source, this construction permit has not yet been inspected against, nor has an operating permit application requesting construction permit incorporation been submitted. VI. MODIFICATIONS REQUESTED BY THE SOURCE This section addresses each of the modification requests received for the Enterprise Compressor Station: The permit modification application received on 3/19/2014 requested the following changes: 123/0277 Page 54 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Replace the existing TEG dehydration unit D-2 (AIRS 068) with a new dehydration unit package, constrained to the exact same operating limitations as the previous dehydration unit. Additional note that the dehydration unit reboiler (which is considered to be an insignificant activity pursuant to Colorado Regulation No. 3, Part C, Section II.E.3.k.) had decreased in burner rating from 2.5 MMBtu/hr to 1.5 MMBtu/hr. It should be noted that this decrease in rating did not affect the insignificant status of this reboiler under Section II.E.3.k. The Division does not consider this "like-kind" replacement to be an execution of an alternative operating scenario, as described in the permit modification. This modification application received 3/19/2014 was determined to be administrative in nature, pursuant to the definition set forth in Colorado Regulation No. 3, Part A, Section I.B.1., as the only changes resulting from this modification include an update to the dehydration unit serial number and the alteration of the reboiler heat rating in the insignificant activity list. As such, this modification was treated as an administrative permit modification. The dehydration unit serial number and heat rating of the dehydration unit reboiler were updated in the operating permit as requested. The permit modification application received on 4/26/2016 requested the following changes: • Remove TEG dehydration unit D-3 (AIRS 073) from the operating permit. This dehydration unit was never constructed. A formal cancellation request for this unit was submitted on the Division's standard forms on 12/22/2016. • Replace the existing enclosed combustion device (COMB-1) used to control the dehydration unit D-2's (AIRS 068) still vent emissions with a different model that does not require the addition of supplemental fuel. This requirement effectively results in a decrease in NOx and CO emissions from enclosed combustion device COMB-1. Because the aforementioned modification application received 4/26/2016 does not: result in an increase in emissions above the significance threshold (40 tons/year), add or change applicable NANSR, PSD, MACT or NSPS requirements, require a case-by- case determination of emission limitations, require determinations for temporary sources, require or change a visibility or increment analysis, result in less stringent monitoring requirements, establish a limit with the purpose of avoiding an otherwise applicable requirement, or establish a plant-wide emission limitations, this modification is considered minor in nature and may be processed under the Colorado Regulation No. 3, Part C, Section X provisions for minor modifications. TEG dehydration unit D-3 was removed from the operating permit, and all requirements regarding supplemental fuel usage were removed from the operating permit, as requested in this modification. It should be noted, however, that the combustion device NOx and CO emission limitations requested in this 4/26/2016 modification were subsequently altered in the 7/26/2016 and 11/20/2018 permit modifications. Note that the dehydration unit D-3 (AIRS 073) cancelled in this modification request is a 60 MMscfd unit, intended to supplement the operation of dehydration unit D-2. This 60 MMscfd unit is not related to the new dehydration unit D-3, permitted under Colorado 123/0277 Page 55 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Construction Permit 19WE0942 on 11/19/2019, which will take the place of dehydration unit D-2 upon startup. The cancellation request applies only to the 60 MMscfd unit. The permit modification application received on 7/26/2016 requested the following changes: • Permit 5% downtime for the vapor recovery unit, which controls the flash tank emissions from dehydration unit D-2. During periods of downtime, emissions shall be routed to the enclosed combustion device COMB-1. This request effectively results in an increase in VOC emissions that is less than the significance threshold of 40 tons/year (Colorado Regulation No. 3, Part D, Section II.A.44). • Permit 3% downtime for the enclosed combustion device (COMB-1), which controls the still vent emissions from dehydration unit D-2. During periods of downtime, emissions shall be routed to atmosphere. This request effectively results in an increase in VOC emissions that is less than the significance threshold of 40 tons/year (Colorado Regulation No. 3, Part D, Section II.A.44). Because the aforementioned modification application received 7/26/2016 does not: result in an increase in emissions above the significance threshold (40 tons/year), add or change applicable NANSR, PSD, MACT or NSPS requirements, require a case-by- case determination of emission limitations, require determinations for temporary sources, require or change a visibility or increment analysis, result in less stringent monitoring requirements, establish a limit with the purpose of avoiding an otherwise applicable requirement, or establish a plant-wide emission limitations, this modification is considered minor in nature and may be processed under the Colorado Regulation No. 3, Part C, Section X provisions for minor modifications. It should be noted that parts of this application were superseded by the significant modification application submitted on 11/20/2018. The requirements of the 11/20/2018 application were included in the operating permit as discussed below. The permit modification application received on 1/29/2018 requested the following changes: • Permit 1% downtime for the vapor recovery unit, which controls the flash tank emissions from dehydration unit D-2. During periods of downtime, emissions shall be routed to atmosphere. This request effectively results in an increase in VOC emissions that is less than the significance threshold of 40 tons/year (Colorado Regulation No. 3, Part D, Section II.A.44). It should be noted, however, that with the decreased downtime requested for the enclosed combustion device COMB-1, the VOC emission limitation for the dehydration unit D-2 did not change. • Permit 2.25% downtime for the enclosed combustion device (COMB-1), which controls the still vent emissions from dehydration unit D-2. During periods of downtime, emissions shall be routed to atmosphere. This request effectively results in a decrease in VOC emissions. 123/0277 Page 56 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit This modification application was cancelled on 11/13/2020, since dehydration unit D-2 will be replaced with dehydration unit D-3, permitted under Colorado Construction Permit 19WE0492. As such, no part of this 1/29/2018 modification was incorporated into the operating permit. The (minor) permit modification application received on 11/20/2018 requested the following changes: • Increase the fuel gas consumption limitations for engines C-234, C-235, C-236, C-237 and C-238 based on an updated natural gas heat content of 1,020 Btu/SCF. This modification results in no change in emissions of NOx, CO or VOC. The aforementioned modification application received 11/20/2018 is considered minor in nature and may be processed under the Colorado Regulation No. 3, Part C, Section X provisions for minor modifications because it does not result in an increase in emissions above the significance threshold (40 tons/year); add or change applicable NANSR, PSD, MACT or NSPS requirements; require a case-by-case determination of emission limitations; require determinations for temporary sources; require or change a visibility or increment analysis; result in less stringent monitoring requirements; establish a limit with the purpose of avoiding an otherwise applicable requirement; or establish a plant-wide emission limitation. The request to increase throughput limitations for each of these engines was incorporated in its entirety into the operating permit. The (significant) permit modification application received on 11/20/2018 requested the following changes: • Remove the condenser as a control device for dehydration unit D-2. It should be noted, however, that the condenser is not physically being removed from service; only the associated control efficiency is being removed from the emission calculation methodology for the dehydration unit. The condenser will continue to operate, but its operation will not be accounted for in emission calculations. • Cancel the enclosed combustion device (COMB-1) AIRS point 074 and include the NOx and CO emissions from COMB-1 under AIRS point 068 for dehydration unit D-2, since COMB-1 is a dedicated combustor to D-2. It should be noted that this change does not, in itself, alter emissions for either the dehydration unit D-2 or enclosed combustion device (COMB-1). The Division commonly includes control equipment dedicated to a single emissions point onto one AIRS ID. • Permit assist gas and pilot gas throughput and emissions, which are required for enclosed combustion device (COMB-1) operation. • Permit 5% downtime for the vapor recovery unit (VRU), which controls flash tank emissions from dehydration unit D-2. During periods of downtime, flash tank emissions are routed to the enclosed combustion device (COMB-1). • Permit 1% downtime for the enclosed combustion device (COMB-1), which controls the still vent emissions from dehydration unit D-2, and, if the VRU is 123/0277 Page 57 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit experiencing downtime, flash tank emissions. During periods of downtime, emissions shall be routed to atmosphere. • Update the insignificant activities list pursuant to the list provided in the application. This modification application received 11/20/2018 was incorporated in its' entirety into the operating permit. The significant modification application received on 6/1/2020 requested the following modifications: • Inclusion of the produced water storage tanks (AIRS 075) in the permit. With the 2/14/2020 promulgation of Colorado Regulation No. 3, the categorical exemption for production wastewater impoundments containing less than 1% crude oil by volume was removed (Colorado Regulation No. 3, Part B, Section II.D.1.m). As such, these tanks are required to obtain a permit since they do not otherwise qualify for any other permit exemption listed in Colorado Regulation No. 3, Part B, Section II.D. This modification application received 6/1/2020 was incorporated in its' entirety into the operating permit. Note that the emission limitation and emission factors for these tanks were modified to include a 30% buffer for flash emissions, as requested in the source comments received 9/11/2020. The significant modification application received on 8/24/2020 requested the following modifications: • Incorporation of Colorado Construction Permit 19WE0094 into the operating permit. This modification application was incorporated into the operating permit as requested. Refer to Section IV of this document for a more detailed discussion on the incorporation of this construction permit. Note that the emission limitations, emission factors and blowdown event limitations were subsequently modified with the modification application received 10/30/2020, as discussed below. The significant modification application received on 10/30/2020 requested the following modifications: • Update emission factors and blowdown event quantity for compressors. This modification application received 10/30/2020 was incorporated in its' entirety into the operating permit. The significant modification application received on 11/19/2020 requested the following modifications: • Incorporation of Colorado Construction Permit 19WE0492 into the operating permit. 123/0277 Page 58 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit This modification application was incorporated into the operating permit as requested. Refer to Section IV of this document for a more detailed discussion on the incorporation of this construction permit. The renewal application received on 7/26/2016 requested the following modifications: • Incorporation of the minor permit modification submitted on 4/26/2016. This request was incorporated into the operating permit as described above. • Incorporation of the minor permit modification submitted in addition to the 7/26/2016 renewal application. This request was incorporated into the operating permit as described above. • Removal of C-239 (AIRS 072) from the operating permit. This engine was never constructed. A formal cancellation request on the Division-supplied forms was submitted on 12/22/2016. • Removal of P012 (AIRS 062; fugitive emissions) from the operating permit. As a compressor station, the Enterprise facility is permitted to use the lower emission factors of Table 2-8 from EPA's Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017) to estimate actual emissions, pursuant to Colorado Regulation No. 7, Part D, Section II.E.2. With these lower emission factors, the fugitive emissions at the Enterprise Compressor Station are below the APEN and permitting thresholds set forth in Colorado Regulation No. 3, Part A, Section II.D.1.a. and Part B, Section II.D.1.a. As such, the fugitive emissions point was removed from the operating permit. It should be noted, however, that fugitive emission monitoring is required for natural gas compressor stations producing any amount of emissions, pursuant to Colorado Regulation No. 7, Part D, Sections I.L and II.E. These requirements were included in the operating permit under the facility-wide general condition (see Section VII of this document, below). • Update serial numbers for the engines that had undergone an alternative operating scenario (AOS) execution since the previous permit issuance. These engines include: C-234 (AIRS 070), C-235 (AIRS 055), C-236 (AIRS 056) and C-238 (AIRS 053). This request was incorporated into the operating permit. The source's requested modifications were addressed as follows: Page Following Cover Page • Updated responsible official, permit contact and company name pursuant to the request received on 3/2/2017 and 5/22/2020. Section I — General Activities and Summary • Condition 1.1 — Permitted Activities 123/0277 Page 59 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Updated permitted activities description pursuant to the operational description listed in the 7/26/2016 renewal application and 11/20/2018 significant modification application. It should be noted that this description was further modified with the incorporation of Colorado Construction Permit 19WE0492 to address the newly permitted TEG dehydration unit D-3. • Condition 2.1 —Alternative Operating Scenarios o Included reference condition for TEG Dehydration Units D-2 and D-3 glycol circulation pump AOS provisions, as requested in source comments received 9/11/2020 for D-2 and as required by 19WE0492 for D-3. o Removed engine C-237 from table for allowable permanent replacements. Pursuant to operator correspondence received 9/18/2020, the NOx and VOC emission limitations for this engine will not be modified to achieve emissions below the significance threshold of 25 tons/year for serious non-attainment areas. Because the area in which the Enterprise Compressor Station is located was redesignated as a serious non- attainment area for ozone on 1/27/2020, engine C-237 is no longer permitted to execute permanent engine replacements in accordance with the engine AOS, as the potential to emit for this engine, when considering enforceable controls, is greater than the significance threshold of 25 tons/year VOC and NOx. Section II — Specific Permit Terms • Condition 3.3— Pilot Gas Throughput Limitation and Compliance Monitoring o Included requirement to calculate pilot gas throughput on a monthly basis. o Included requirement to calculate assist gas throughput on a monthly basis. • Condition 3.7.3— VRU Downtime o Included requirement to monitor VRU downtime on a monthly basis. This requirement is further discussed in Section VII below. • Condition 3.7.4 — COMB-1 Downtime o Included requirement to monitor COMB-1 downtime on a monthly basis. This requirement is further discussed in Section VII below. • Condition 3.10 — Glycol Pump AOS o Created condition pursuant to source comments received 9/11/2020 that the AOS provisions set forth in 19WE0492 for the D-3 glycol circulation pumps also be applied to the D-2 glycol circulation pumps. • Condition 7— Produced Water Storage Tanks 123/0277 Page 60 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Added condition to address the produced water storage tanks, including emissions calculation methods and throughput monitoring. These requirements are further discussed in Section V above. Appendices • Appendix G — Compliance Assurance Monitoring o Updated CAM plan to include provisions for COMB-1 downtime, during which time the requirements of CAM do not apply. o Removed condenser from CAM plan as control from the condenser is no longer claimed. The following requirements that were requested in the renewal application were not included in the operating permit pursuant to the following justifications: • Form 2000-604 — Recording highest condenser temperature value to be used in GLYCaIc o Pursuant to the 11/20/2018 significant modification application, control achieved by this condenser is no longer relied upon to meet the emissions limitations set forth in this permit. As such, the condenser monitoring requested in the renewal application was not included in the operating permit. • Form 2000-604 — Limiting hours of downtime for the VRU o Allowable downtime hours were based on a percentage of the dry gas processed by the dehydration unit. A hard hours limitation was not established. This alteration is discussed in the NOTES section under Condition 3 in Section VII below. • Form 2000-604 — Limiting hours of downtime for the ECD (COMB-1) o Allowable downtime hours were based on a percentage of the dry gas processed by the dehydration unit. A hard hours limitation was not established. This alteration is discussed in the NOTES section under Condition 3 in Section VII below. VII. OTHER MODIFICATIONS In addition to the source requested modifications, the Division has included changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this renewal. These changes are as follows: Page Following Cover Page 123/0277 Page 61 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Modified the language concerning postmarked dates for report submittals to reflect the Division's current standard language. Section I — General Activities and Summary • Condition 1 o Updated attainment status description language in Condition 1.1 to the most current Division standard (ver. 1/21/2020). o Revised the language in Condition 1.4 include current conditions that are state-only enforceable. • Condition 2 o Updated alternative operating scenario (AOS) language for natural gas fired engines to the most current Division standard (ver. 10/12/2012 updated to reflect regulatory citation changes). It should be noted that since the revision of the AOS language, some regulatory citations have changed. The updated citations were included in the operating permit as follows: • The significance levels, for the purposes of PSD/NANSR, are found in Colorado Regulation No. 3, Part D, Section II.A.44. • The RACT requirements are found in Colorado Regulation No.3, Part B, Section III.D.2. • Colorado Regulation No. 7, Part E, Section I was reorganized with the 2/14/2020 promulgation. The referenced Section XVI requirements are now included in Part E, Section I.B, and the Section XVII requirements are now included in Part E, Section I.D. • Relocation requirements for stationary internal combustion engines are found in Colorado Regulation No. 6, Part B, Section I.C. • Condition 3 o Updated NANSR/PSD description language to most current Division standard (ver. 1/21/2020). Section II — Specific Permit Terms Condition 1 — C-238 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 053; C-235 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 055; C-236 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 056; C-234 - Caterpillar G3612 3,550 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 070 • Condition 1.1 — NOx & CO Emission Limitations & Compliance Monitoring 123/0277 Page 62 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Added requirement to maintain records of the monthly NOx and CO calculations to be made available to the Division upon request. • Condition 1.2 —VOC Emission Limitations & Compliance Monitoring o Added requirement to maintain records of the monthly VOC calculations to be made available to the Division upon request. o Added requirement to calculate HAP emissions, for the purposes of APEN reporting, using the emission factors set forth in AP-42: Section 3.2 Table 3.2-2 for 4-stroke lean burn engines. The Enterprise Compressor Station is a major source of HAP. Although the engines do not have an associated HAP limit, HAP emissions must be quantified for the purposes of APEN reporting and the payment of annual emission fees. • Condition 1.3 — Natural Gas Consumption Limitations & Compliance Monitoring o Added requirement to maintain records of the monthly fuel gas consumption calculations to be made available to the Division upon request. o Updated equation to account for other fuel gas users (e.g., natural gas- fired heaters, pilot gas) to ensure the metered fuel gas is partitioned accurately among users. • Condition 1.4 — Natural Gas Heat Content o Supplemented condition with the numerical value of the heat content utilized to calculate the emission limitations set forth in the operating permit, for future reference. o Added requirement to separate sequential sampling events by at least 4 months, pursuant to standard operating permit monitoring, recordkeeping and reporting requirements. • Condition 1.5 — Hours of Operation o Updated to require that the hours of operation be recorded on the same day that the fuel gas consumption measurement is taken, pursuant to the requirement in Condition 1.3. • Condition 1.6 — Opacity o Updated condition to Division-standard format. It should be noted that the requirements of this condition remain the same. • Condition 1.7 — Control Device Requirements o Added requirement to maintain records of the catalyst pressure drop to be made available to the Division upon request. o Added requirement to maintain records of the catalyst inlet temperature to be made available to the Division upon request. 123/0277 Page 63 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Note that these requirements are not applicable to engine C-238 only, since this monitoring is totally encompassed by MACT ZZZZ for this engine. • Condition 1.8 — Portable Monitoring o Added condition to indicate that each engine is subject to quarterly portable monitoring. Included reference to specific portable monitoring requirements set forth in Condition 11 of the operating permit. • Condition 1.9 — Compliance Assurance Monitoring o Added condition to indicate that each engine is subject to Compliance Assurance Monitoring requirements. Included reference to CAM requirements set forth in Condition 12 of the operating permit. • Condition 1.10- Statewide Controls for Oil and Gas Operations o Colorado Regulation No. 7, Part E, Section I.B. These requirements, including the installation of an oxidation catalyst (Section I.B.2) and maintaining the engine according to manufacturer specification (Section I.B.3), were included in the previous issuance of the operating permit on 8/1/2012. However, these conditions were modified to exactly mirror the most current version of Colorado Regulation No. 7 to eliminate paraphrasing, pursuant to Division-standard practice. o Colorado Regulation No. 7, Part E, Section I.D. At the time of the previous issuance of the operating permit on 8/1/2012, the engine requirements of Colorado Regulation No. 7, Part E, Section I.D had not yet been promulgated. The applicable requirements were included as follows: ■ Section I.D.2. (State-Only Enforceable) — Requirement to comply with the Table 1 limitations. Note that based on the date of (re)location into Colorado that only Engine C-238 is subject to these limitations. • For clarity, compliance monitoring methods were included in the operating permit to specify how the operator is expected to demonstrate compliance with these limitations. Compliance with the NOx and CO limitations will be assessed using the quarterly portable analyzer test results. For the purposes of VOC, compliance is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations. • Section I.D.3. (State-Only Enforceable) — Requirement to install an oxidation catalyst on each lean burn engine. o Colorado Regulation No. 7, Part E, Section II.A. 123/0277 Page 64 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit At the time of the previous issuance of the operating permit on 8/1/2012, the combustion process adjustment requirements for engines of Colorado Regulation No. 7, Part E, Section II.A. had not yet be promulgated. These requirements apply to engines operating in the non-attainment area at a facility considered to be a major source of NOx emissions as of 6/3/2016, under the moderate non-attainment major source threshold of 100 tons/year. The Enterprise Compressor Station was a major source of NOx emissions prior to this date. As such, the engines at this facility are considered to be affected combustion equipment. The requirements of Section II.A. were incorporated into the operating permit as follows: ■ Section II.A.2. — This section lists exemptions from the requirements of Section II.A.4. (emission limitations), Section II.A.5. (compliance demonstration), certain parts of Section II.A.7. (recordkeeping) and Section II.A.8. (reporting). All engines included in this condition qualify for the Section II.A.2.e. exemption, as each engine is greater than 500 hp and located in the 8 hour ozone control area and are therefore subject to the emission control requirements of Colorado Regulation No. 7, Part E, Section I.B. As such, these engines are not required to comply with the aforementioned sections. ■ Section II.A.6. — This section sets forth the required combustion process adjustment procedures for combustion equipment with uncontrolled actual NOx emissions greater than or equal to 5 tons/year. Each engine included in this condition is permitted to produce NOx emissions in excess of this threshold and are therefore required to perform combustion process adjustments. Combustion process adjustments for engines include annual inspection of oil, filters, hoses, belts and spark plugs and maintaining the engines pursuant to manufacturer specification. ■ Section II.A.7. — This section sets forth the recordkeeping requirement to demonstrate compliance with Sections II.A.2. and II.A.6. Records must be kept of the combustion process adjustments performed (Section II.A.7.f.) and documentation must be maintained to demonstrate that an exemption set forth in Section II.A.2. applies (Section II.A.7.g). • Condition 1.11 —40 CFR Part 63 Subpart ZZZZ MACT o Added explicit Table 3 requirement to conduct performance tests semi- annually, or pursuant to the footnote, annually if two consecutive tests have demonstrated compliance (§63.6615). o Removed specific Table 4 performance testing requirements in favor of a condition referencing the required testing protocol. Added requirement that performance testing shall be conducted within 10% of 100% load (§63.6620(b)). This reference encompasses all applicable testing 123/0277 Page 65 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requirements within the rule (both Table 4 and §63.6620), not just those in Table 4. This was done to clarify that the source is subject to all applicable performance testing requirements, not just those listed in Table 4, and for brevity as the full testing requirements of Subpart ZZZZ are substantial. o Updated general requirement to comply with the applicable Monitoring, Installation, Collection, Operating and Maintenance requirements to explicitly include the installation of a CPMS to monitor the catalyst inlet temperature, pursuant to §63.6625(b) Table 5, Item 1. ■ Per the most recent MACT ZZZZ semi-annual report submitted for this engine, a CPMS has been installed and is used to monitor catalyst inlet temperature. o Included data monitoring requirements of §63.6635(a), (b) and (c), including continuous monitoring requirements and exclusion of data collected during malfunction events. These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-238. o Updated all Table 6 references to refer to Item 7 instead of Item 8. Item 7 is for engines that use an oxidation catalyst to comply with the formaldehyde concentration limits. Item 8 is for engines that do not use an oxidation catalyst. Engine C-238 utilizes an oxidation catalyst to comply with the formaldehyde limitation. As such, the correct reference is to Item 7 of Table 6. o Added the deviation reporting requirements for the emission and operating limitations (§63.6640(b)) and the general requirements (§63.6640(e)). Included exemption for deviations occurring within the first 200 hours of operation from engine startup (§63.6640(d)). These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-238. o Added requirement to submit notification of intent to conduct a performance test (§63.6645(g)), since engine C-238 must undergo periodic performance testing. o Condensed Table 7 reporting requirements to a referencing condition since reporting requirements are variable, depending on whether or not malfunctions were experienced during the reporting period.This was done to clarify that the source is subject to all applicable reporting requirements, depending on how the engine operated during each reporting period. o Added inclusion requirements and submittal schedule for compliance reports (§63.6650(b) and (c)). These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-238. 123/0277 Page 66 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Included requirements for deviation reporting for engines using a CMS (§63.6650(e)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-238. o Added allowance to submit the semi-annual monitoring reports required under MACT ZZZZ along with Title V monitoring reports (§63.6650(f)). o Included explicit recordkeeping requirements for engines using a CPMS (§63.6655(a)(1) through (5) and §63.6655(b)(1) through (3). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-238. o Included requirement to maintain records of all continuous compliance demonstration requirements under Table 6 (§63.6655(d)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-238. o Added form and length of recordkeeping conditions, including maintaining records in a form to be made readily available for review and keeping the records for 5 years (§63.6660(a), (b) and (c)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-238. o Removed requirement to maintain records that the engine was operated pursuant to its maintenance plan (§63.6655(e)). A maintenance plan is only required for existing engines. Engine C-238 is considered to be a new engine under Subpart ZZZZ. Therefore, this requirement is not applicable. • Condition 1.12 —40 CFR Part 63 Subpart A MACT o Added good air pollution control practices requirement of§63.6(e)(1). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-238. Condition 2 — C-237 - Caterpillar G3616 4,735 hp Compressor Engine with Oxidation Catalyst, AIRS ID: 071 It should be noted that this condition previously addressed Engine C-239 in addition to C-237. A cancellation request for C-239 was received on 12/22/2016 as this unit was never constructed. Therefore, all references to C-239 were removed from this condition. • Condition 2.1 — NOx & CO Emission Limitations & Compliance Monitoring o Added requirement to maintain records of the monthly NOx and CO calculations to be made available to the Division upon request. • Condition 2.2 —VOC Emission Limitations & Compliance Monitoring o Added requirement to maintain records of the monthly VOC calculations to be made available to the Division upon request. 123/0277 Page 67 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Added requirement to calculate HAP emissions, for the purposes of APEN reporting, using the emission factors set forth in AP-42: Section 3.2 Table 3.2-2 for 4-stroke lean burn engines. The Enterprise Compressor Station is a major source of HAP. Although engine C-237 does not have an associated HAP limit, HAP emissions must be quantified for the purposes of APEN reporting and the payment of annual emission fees. • Condition 2.3 — Natural Gas Consumption Limitations & Compliance Monitoring o Updated equation to account for other fuel gas users (e.g., natural gas- fired heaters, pilot gas) to ensure the metered fuel gas is partitioned accurately among users. • Condition 2.4 — Natural Gas Heat Content o Supplemented condition with specification of heat content utilized to calculate the emission limitations set forth in the operating permit, for future reference. o Added requirement to maintain records of the heat content verification to be made available to the Division upon request. o Added requirement to separate sequential sampling events by at least 4 months, pursuant to standard operating permit monitoring, recordkeeping and reporting requirements. • Condition 2.5 — Hours of Operation o Updated to require that the hours of operation be recorded on the same day that the fuel gas consumption measurement is taken, pursuant to the requirement in Condition 2.3. • Condition 2.6 — Opacity o Updated condition to Division-standard format. It should be noted that the requirements of this condition remain the same. • Condition 2.7 — Portable Monitoring o Added condition to indicate that this engine is subject to quarterly portable monitoring. Included reference to specific portable monitoring requirements set forth in Condition 11 of the operating permit. • Condition 2.8 — Compliance Assurance Monitoring o Added condition to indicate that each engine is subject to Compliance Assurance Monitoring requirements. Included reference to CAM requirements set forth in Condition 12 of the operating permit. • Condition 2.9 — Statewide Controls for Oil and Gas Operations o Colorado Regulation No. 7, Part E, Section I.B. 123/0277 Page 68 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit These requirements, including the installation of an oxidation catalyst (Section I.B.2) and maintaining the engine according to manufacturer specification (Section I.B.3), were included in the previous issuance of the operating permit on 8/1/2012. However, these conditions were modified to exactly mirror the most current version of Colorado Regulation No. 7 to eliminate paraphrasing, pursuant to Division-standard practice. o Colorado Regulation No. 7, Part E, Section I.D. At the time of the previous issuance of the operating permit on 8/1/2012, the engine requirements of Colorado Regulation No. 7, Part E, Section I.D had not yet been promulgated. The applicable requirements were included as follows: ■ Section I.D.2. (State-Only Enforceable) — Requirement to comply with the Table 1 limitations. • For clarity, compliance monitoring methods were included in the operating permit to specify how the operator is expected to demonstrate compliance with these limitations. Compliance with the NOx and CO limitations will be assessed using the quarterly portable analyzer test results. For the purposes of VOC, compliance is presumed provided the portable monitoring indicates compliance with the NOx and CO emission limitations. ■ Section I.D.3. (State-Only Enforceable) — Requirement to install an oxidation catalyst on lean burn engines. o Colorado Regulation No. 7, Part E, Section II.A. At the time of the previous issuance of the operating permit on 8/1/2012, the combustion process adjustment requirements for engines of Colorado Regulation No. 7, Part E, Section II.A. had not yet be promulgated. These requirements apply to engines operating in the non-attainment area at a facility considered to be a major source of NOx emissions as of 6/3/2016, under the moderate non-attainment major source threshold of 100 tons/year. The Enterprise Compressor Station was a major source of NOx emissions prior to this date. As such, the engines at this facility are considered to be affected combustion equipment. The requirements of Section II.A. were incorporated into the operating permit as follows: ■ Section II.A.2. — This section lists exemptions from the requirements of Section II.A.4. (emission limitations), Section II.A.5. (compliance demonstration), certain parts of Section II.A.7. (recordkeeping) and Section II.A.8. (reporting). The engine qualifies for the Section II.A.2.e. exemption, as it is greater than 500 hp and located in the 8 hour ozone control area and is therefore subject to the emission control requirements of Colorado 123/0277 Page 69 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Regulation No. 7, Part E, Section I.B. As such, this engine is not required to comply with the aforementioned sections. ■ Section II.A.6. — This section sets forth the required combustion process adjustment procedures for combustion equipment with uncontrolled actual NOx emissions greater than or equal to 5 tons/year. This engine is permitted to produce NOx emissions in excess of this threshold and is therefore required to perform combustion process adjustments. Combustion process adjustments for engines include annual inspection of oil, filters, hoses, belts and spark plugs and maintaining the engines pursuant to manufacturer specification. ■ Section II.A.7. — This section sets forth the recordkeeping requirement to demonstrate compliance with Sections II.A.2. and II.A.6. Records must be kept of the combustion process adjustments performed (Section II.A.7.f.) and documentation must be maintained to demonstrate that an exemption set forth in Section II.A.2. applies (Section II.A.7.g.). • Condition 2.10 - 40 CFR Part 60 Subpart JJJJ NSPS o Updated heading language to the most current Division-standard format, noting the most recent version of NSPS JJJJ adopted (8/30/2016) on which the regulatory language included in the permit is based and the fact that Colorado Regulation No. 6 has not yet adopted NSPS JJJJ. o Added relevant Table 1 footnotes, including exemption from complying with the CO emission limitations if the engine is complying with Table 2a of Subpart ZZZZ (Footnote b) and requirement to exclude emissions of formaldehyde when calculating VOC (footnote d). These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. o Included reference for performance testing requirements, as set forth in §60.4244. These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. • Condition 2.11 —40 CFR Part 60 Subpart OOOO NSPS This subpart was not included in the previous permit issuance, but is applicable to the reciprocating compressor driven by engine C-237 only. It should be noted that Subpart OOOO is applicable to the compressor driven by engine C-237. Subpart OOOO does not regulate engines. The following applicable requirements were included in the operating permit: o Standards for reciprocating compressors, including an option to either replace the rod packing every 26,000 hours or 36 months (whichever is first) or to install a closed vent system operating under negative pressure to return the packing emissions to process (§60.5385(a)). 123/0277 Page 70 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Initial compliance requirements, including continuously monitoring the number of hours or tracking the number of moths since the last packing replacement or, if routing the packing emissions to process, complying with the applicable closed vent requirements (§60.5385(b) and §60.5410). o Additional initial compliance requirements for closed vent systems, including designing the closed vent system to route all materials to a process (or control device), operate the system with no detectable emissions, and monitor all bypass devices to ensure proper emissions routing (§60.5385(c) and §60.5411(a)). o Continuous compliance demonstration requirements, including continuously monitoring hours of operating or tracking the number of months, replacing the packing within the allotted timeframe and submitting the required reports, or, if routing the packing emissions to process, complying with the applicable closed vent requirements (§60.5415(c)). o Initial and Continuous compliance demonstration requirements for closed vent systems, including inspections of the system and bypass devices, and operating with no detectable emissions (§60.5416(a) and (b)). o Notification, recordkeeping and reporting requirements, including the submission of annual reports, maintaining records of the hours/months of operation, each packing replacement, and deviations from these requirements or, if routing the packing emissions to process, the installation date of the closed vent system, deviations from these requirements, the monitoring conducted under the "no detectable emissions" requirements and all inspections performed on the system and bypass devices (§60.5385(d), §60.5420(a) through §60.5420(c)). • Condition 2.12 —40 CFR Part 60 Subpart A NSPS o Updated applicable sections to include the following: • §60.7 — Notification and Recordkeeping • §60.11 — Compliance with Standards and Maintenance Requirements • §60.19— General Notification and Reporting Requirements These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. • Condition 2.13—40 CFR Part 63 Subpart ZZZZ MACT o Removed requirement to comply with the applicable limitations upon startup (§63.6596(a)(1)). At the time of previous permit issuance on 8/1/2012, engine C-237 had not yet commenced operation. As such, this requirement was included to ensure this engine would comply with the applicable MACT Z777 requirements upon startup. Pursuant to the 2017 123/0277 Page 71 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit inspection report, the source has achieved compliance with this one-time requirement. As such, this startup requirement was removed from the operating permit. o Removed initial performance testing requirements of §63.6610. These initial testing requirements were completed in 2013. Because the source has complied with these one-time requirements, they were removed from the operating permit. These initial testing requirements were replaced with the semi-annual performance testing requirements of §63.6615 (see below). o Added explicit Table 3 requirement to conduct performance tests semi- annually, or, pursuant to the footnote, annually if two consecutive tests have demonstrated compliance (§63.6615). o Removed specific Table 4 performance testing requirements in favor of a condition referencing the required testing protocol. Added requirement that performance testing shall be conducted within 10% of 100% load (§63.6620(b)). This reference encompasses all applicable testing requirements within the rule (both Table 4 and §63.6620), not just those in Table 4. This was done to clarify that the source is subject to all applicable performance testing requirements, not just those listed in Table 4, and for brevity as the full testing requirements of Subpart ZZZZ are substantial. o Removed initial compliance demonstration requirements set forth in Table 5 of MACT ZZZZ. Per the most recent inspection report, a CPMS has been installed and C-237 has attained compliance with these one-time conditions. As such, these requirements were removed from the operating permit. These initial compliance demonstration requirements were replaced with the requirement to maintain and operate the CPMS system, pursuant to §63.6625 (see below). o Added requirement to install, maintain and operate a CPMS to continuously monitor catalyst inlet temperature (§63.6625(b)(1)). o Updated all Table 6 references to refer to Item 7 instead of Item 8. Item 7 is for engines that use an oxidation catalyst to comply with the formaldehyde concentration limits. Item 8 is for engines that do not use an oxidation catalyst. Engine C-237 utilizes an oxidation catalyst to comply with the formaldehyde limitation. As such, the correct reference is to Item 7 of Table 6. o Updated general requirement to comply with the applicable Monitoring, Installation, Collection, Operating and Maintenance requirements to explicitly include the installation of a CPMS to monitor the catalyst inlet temperature, pursuant to §63.6625(b) Table 5, Item 1. Per the 2017 inspection report, this CPMS system has been installed and is monitoring the catalyst inlet temperature. 123/0277 Page 72 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Included data monitoring requirements of §63.6635(a), (b) and (c), including continuous monitoring requirements and exclusion of data collected during malfunction events. These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. o Added the deviation reporting requirements for the emission and operating limitations (§63.6640(b)) and the general requirements (§63.6640(e)). Included exemption for deviations occurring within the first 200 hours of operation from engine startup (§63.6640(d)). These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. o Added requirement to submit notification of intent to conduct a performance test (§63.6645(g)), since engine C-237 must undergo periodic performance testing. o Condensed Table 7 reporting requirements to a referencing condition since reporting requirements are variable, depending on whether or not malfunctions were experienced during the reporting period.This was done to clarify that the source is subject to all applicable reporting requirements, depending on how the engine operated during each reporting period. o Added inclusion requirements and submittal schedule for compliance reports (§63.6650(b) and (c)). These requirements were not included in the 8/1/2012 issuance of the operating permit, but are applicable to Engine C-237. o Included requirements for deviation reporting for engines using a CMS (§63.6650(e)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-237. o Added allowance to submit the semi-annual monitoring reports required under MACT ZZZZ along with Title V monitoring reports (§63.6650(f)). o Included explicit recordkeeping requirements for engines using a CPMS (§63.6655(a)(1) through (5) and §63.6655(b)(1) through (3). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-237. o Included requirement to maintain records of all continuous compliance demonstration requirements under Table 6 (§63.6655(d)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-237. o Removed requirement to maintain records that the engine was operated pursuant to its maintenance plan (§63.6655(e)). A maintenance plan is only required for existing engines. Engine C-237 is considered to be a new engine under Subpart ZZZZ. Therefore, this requirement is not applicable. 123/0277 Page 73 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Added form and length of recordkeeping conditions, including maintaining records in a form to be made readily available for review and keeping the records for 5 years (§63.6660(a), (b) and (c)). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-237. • Condition 2.14 — 40 CFR Part 63 Subpart A MACT o Added good air pollution control practices requirement of§63.6(e)(1). This requirement was not included in the 8/1/2012 issuance of the operating permit, but is applicable to Engine C-237. • PREVIOUS Condition 2.12 — Construction Requirements o All requirements in this section are one-time only requirements included for new units. Per the 2017 inspection report, the notice of startup for C- 237 was received on 9/13/2012, engine C-237 was constructed within the required 18 month timeframe, and the initial stack test was completed on 12/13/2012. All applicable requirements have been met and were therefore removed from the operating permit. Condition 3 — D-2 — Forum Triethylene Glycol Dehydration Unit, AIRS ID: 068 This condition was modified significantly to incorporate the enclosed combustion device COMB-1 requirements,which were previously addressed in Condition 7 of the operating permit issued 8/1/2012. With the 11/20/2018 significant permit modification application, it was requested that COMB-1 no longer be a separate AIRS point, but be combined with D-2 onto AIRS point 068, since this combustion device solely controls the dehydration unit. To facilitate this, the COMB-1 requirements set forth in previous Condition 7 of this permit were combined into this Condition 3. It should be noted that the new 145 MMscfd dehydration unit D-3 addressed in Condition 4 (AIRS 077) is NOT the same D-3 unit that was addressed in the previous issuance of the operating permit (AIRS 073). The D-3 addressed by the previous operating permit was cancelled on 12/22/2016 because it was never constructed. The D-3 that was cancelled in 2016 was a 60 MMscfd unit intended to operate in conjunction with D-2, whereas the new D-3, permitted under Colorado Construction Permit 19WE0492 is a 145 MMscfd unit that will take the place of D-2. All references to the 60 MMscfd D-3 were therefore removed from the operating permit, as requested in the 2016 cancellation. • Condition 3.1 —VOC Emission Limitations & Compliance Monitoring o Relocated HAP limitations to a separate condition. To make the area source determination for a production field facility, both emissions from storage tanks and dehydration units are aggregated. The Enterprise Compressor Station is, pursuant to MACT HH, an area source of HAP (see Section III of this document). As such, synthetic minor HAP limits of 8 tons/year individual and 20 tons/year total HAP were established to ensure major source MACT HH requirements are not triggered. The 123/0277 Page 74 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit dehydration unit, produced water storage tanks and condensate storage tanks are subject to these limitations. As such, the HAP limits were relocated to a separate condition for clarity and to avoid duplication of requirements in the dehydration unit, produced water storage tanks and condensate storage tank conditions. o Added explicit requirement to calculate HAP emissions, referencing the limitations listed in the facility-wide HAP condition. o Relocated monitoring requirements for the inlet temperature and pressure and flash tank temperature and pressure to a separate condition for clarity. o Included explicit calculation methodology to calculate both flash gas and still vent emissions based on the control efficiency of the combustion device, the amount of VRU downtime, the amount of COMB-1 downtime, the runtime of the dehydration unit and the results of the monthly GLYCaIc model. These calculations are based on the different operating scenarios presented in the significant modification submitted on 11/20/2018 (see Section VI of this document). o Added requirement and methodology to calculate VOC emissions from the pilot gas. These emissions were included in the limitations requested by the 11/20/2018 significant modification application. As such, a calculation method for these emissions and the requirement to monitor compliance against the pilot gas VOC emission limitation were incorporated into the operating permit. o Added requirement and methodology to calculate VOC emissions from the assist gas, the inclusion of which was requested in the 11/20/2018 significant modification application. As such, a calculation method for these emissions and the requirement to monitor compliance against the assist gas VOC emission limitation were incorporated into the operating permit. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future modification to this permit is not necessary upon assist gas line installation. • Condition 3.2 — NOx & CO Emission Limitations & Compliance Monitoring o Added condition to address the methodology for calculating NOx and CO emissions from the destruction of the dehydration unit's still vent, and, if the VRU is experiencing downtime, the flash gas. As noted above, the applicable requirements to COMB-1, including these NOx and CO emission limitations, were relocated to this Condition 3, as requested in the significant permit modification received 11/20/2018. o Added requirement and methodology to calculate NOx and CO emissions from the pilot gas. These emissions were included in the limitations 123/0277 Page 75 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit requested by the 11/20/2018 significant modification application. As such, a calculation method for these emissions and the requirement to monitor compliance against the pilot gas NOx and CO emission limitations were incorporated into the operating permit. o Added requirement and methodology to calculate NOx and CO emissions from the assist gas. These emissions were included in the limitations requested by the 11/20/2018 significant modification application. As such, a calculation method for these emissions and the requirement to monitor compliance against the assist gas NOx and CO emission limitations were incorporated into the operating permit. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future modification to this permit is not necessary upon assist gas line installation. • Condition 3.3— Gas Throughput Limitations & Compliance Monitoring o Added requirement to limit the amount of dry gas processed by the dehydration unit during periods of VRU downtime to 5% of the total dry gas processed by the dehydration unit on a rolling 12 month basis. ■ In the permit modification received on 11/20/2018, it was requested that downtime be permitted for the VRU to accommodate maintenance and malfunction events. In order to monitor compliance with this requirement, the actual percentage of VRU downtime shall be calculated as a function of the total dry gas processed by the dehydration unit and the amount of time the VRU experienced downtime. The dry gas processed by the dehydration unit during VRU downtime is not to exceed 5% of the total dry gas processed by the dehydration unit on a rolling twelve month basis. The limitation listed in the permit is based on a percentage of actual dry gas processed. This was done pursuant to the justification presented in the "NOTES" section of this dehydration unit condition below. o Added requirement to limit the amount of dry gas processed by the dehydration unit during periods of COMB-1 downtime to 1% of the total dry gas processed by the dehydration unit on a rolling 12 month basis. • In the permit modification received on 11/20/2018, it was requested that downtime be permitted for COMB-1 to accommodate maintenance and malfunction events. In order to monitor compliance with this requirement, the actual percentage of COMB- 1 downtime shall be calculated as a function of the total dry gas processed by the dehydration unit and the amount of time COMB- 1 experienced downtime. The dry gas processed by the dehydration unit during COMB-1 downtime is not to exceed 1% of 123/0277 Page 76 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit the total dry gas processed by the dehydration unit on a rolling twelve month basis. The limitation listed in the permit is based on a percentage of actual dry gas processed. This was done pursuant to the justification presented in the "NOTES" section of this dehydration unit condition below. o Added requirement to limit the amount of pilot gas sent to COMB-1. Hours of COMB-1 operation, in conjunction with the manufacturer specification for hourly pilot gas throughput will be used to monitor compliance with this limitation and the VOC, NOx and CO emission limitations. o Added requirement to limit the amount of assist gas sent to COMB-1. A meter installed on the assist gas line to the combustion device will be used to monitor compliance with this limitation and the VOC, NOx and CO emission limitations. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were included in the permit such that a future modification to this permit is not necessary upon assist gas line installation. • Condition 3.4 — Lean Glycol Circulation Rate Limitations & Compliance Monitoring o Updated method of measuring the glycol circulation rate to reference the glycol flowmeter, which is being utilized pursuant to the Operating and Maintenance (O&M) Plan received on 7/26/2016 and the 2017 inspection report. o Added requirement to include all glycol streams in the reported glycol circulation rate recorded, pursuant to the Operating and Maintenance (O&M) Plan received on 7/26/2016. o Added allowance to use the maximum permitted glycol flowrate in the event the flowmeter cannot be used to monitor the glycol flowrate. • Condition 3.5 — Extended Gas Analysis o Included requirement to maintain records of the extended gas analyses to be made available to the Division upon request. o Updated condition to require subsequent samples be separated by 8 months, pursuant to standard operating permit monitoring, recordkeeping and reporting. o Added requirement to perform an extended gas analysis of the assist gas to obtain the composition and heat content. The heat content is used to monitor compliance with the VOC, NOx and CO emission limitations. It should be noted that as of the XX/XX/XXXX issuance of this permit, the assist gas line has not yet been installed. However, provisions for monitoring and emission calculation associated with the assist gas were 123/0277 Page 77 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit included in the permit such that a future modification to this permit is not necessary upon assist gas line installation. • Condition 3.6— Parametric Monitoring o Relocated monitoring requirements for the inlet temperature and pressure and flash tank temperature and pressure to this new condition for clarity. o Added requirement to maintain records to be made available to the Division upon request. • Condition 3.7 — Hours of Operation o Added requirement to monitor hours of COMB-1 operation, pursuant to the significant permit modification received on 11/20/2018 and source comments received 9/11/2020. Hours of COMB-1 operation are required to determine the amount of pilot gas sent to COMB-1, and used to monitor compliance with the pilot gas throughput limitation, and the VOC, NOx and CO emission limitations. Hours of operation are determined using the COMB-1 run status indication. As noted in operator correspondence received 11/13/2020, run status indication takes into account not only the pilot light presence, but various other parameters that indicate overall combustion device operability. As such, it was determined that the run status is a better indication of combustion device operation than pilot light presence alone, and was therefore used to determine COMB-1 hours of operation. o Added requirement to monitor hours of VRU downtime, pursuant to the significant permit modification received on 11/20/2018. Hours of VRU downtime are required to monitor compliance with the downtime throughput limitations and to monitor compliance with the VOC, NOx and CO emission limitations. o Added requirement to monitor hours COMB-1 downtime, pursuant to the significant permit modification received on 11/20/2018 and source comments received 9/11/2020. Hours of COMB-1 downtime are required to monitor compliance with the downtime throughput limitations and to monitor compliance with the VOC, NOx and CO emission limitations. Hours of downtime are determined using the difference between the D-2 run status and the COMB-1 run status indication. • Condition 3.8 — Opacity o Added condition to address the Colorado Regulation No. 1 opacity limitation of 30% for flares. As noted above, the applicable requirements to COMB-1, including this opacity limitation, were included in this Condition 3, as requested in the significant permit modification received 11/20/2018. • Condition 3.9— Control Device Requirements 123/0277 Page 78 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Added standard operating permit monitoring, recordkeeping and reporting for vapor recovery units, including ensuring valving is aligned in such a way that the flash gas emissions are routed to the VRU free of obstruction. Because this unit is now permitted downtime, emissions can be routed to either the VRU or to enclosed combustion device COMB-1. To ensure proper control of emissions, it is imperative that emissions are routed to the VRU when it is operating. Monitoring the valving configuration will ensure that emissions are routed appropriately and not inadvertently routed to COMB-1. o Added standard operating permit monitoring, recordkeeping and reporting for enclosed combustion devices, ensuring valving is aligned in such a way that emissions are routed to enclosed combustion device COMB-1 free of obstruction. Because this unit is now permitted downtime, emissions can be routed to either COMB-1 or to atmosphere. To ensure proper control of emissions, it is imperative that emissions are routed to COMB-1 when it is operating. Monitoring the valving configuration will ensure that emissions are routed appropriately and not inadvertently routed to atmosphere. o Included standard operating permit monitoring, recordkeeping and reporting requirement to conduct daily six minute visible emission observations to monitor for the presence of smoke. In the event smoke is observed, a Method 22 reading shall be taken to monitor compliance with the no visible emission standard set forth in Colorado Regulation No. 7, Part D, Section II.B.2.b. If visible emissions are observed pursuant to the Method 22, a Method 9 shall be conducted to monitor compliance with the Colorado Regulation No. 1 30% opacity standard for flares. • Condition 3.11 — Compliance Assurance Monitoring (CAM) o Included reference to the VOC and HAP limitations for which the dehydration unit is subject to CAM. • Condition 3.12 — Statewide Controls for Oil and Gas Operations It should be noted that at the time of previous permit issuance, the majority of the requirements of Colorado Regulation No. 7, Part D, Sections I.C., I.H., II.B. and II.D, all of which are applicable to dehydration units at oil and gas facilities, had not yet been promulgated. As such, this issuance of the operating permit incorporates the applicable requirements of Colorado Regulation No. 7, last updated on 2/14/2020. o Colorado Regulation No. 7, Part D, Section I.C. The dehydration unit and associated air pollution control equipment at the Enterprise Compressor Station is subject to the following general requirements of Colorado Regulation No. 7, Part D, Section 123/0277 Page 79 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Section I.C.1.a. — The facility and air pollution control equipment shall be operated pursuant to good engineering and maintenance practices, and all control equipment shall be appropriately sized to accommodate reasonably foreseeable fluctuations in unit operation. • Section I.C.1.b. — All hydrocarbon liquid and produced water handling operations shall be designed and maintained to minimize VOC leakage. It should be noted that all general facility requirements were grouped into a separate condition within the operating permit. The dehydration unit condition references these applicable requirements, which are located in Condition 10 of the operating permit. o Colorado Regulation No. 7, Part D, Section I.H. The dehydration unit and associated air pollution control equipment at the Enterprise Compressor Station is subject to the following dehydration unit requirements of Colorado Regulation No. 7, Part D, Section I.H.: • Section I.H.1. — Dehydration units shall reduce uncontrolled actual emissions of VOC by at least 90% using air pollution control equipment • This condition was supplemented with a compliance monitoring method. A 90% reduction in VOC shall be assumed, provided the source is in compliance with the general requirements of Section I.C and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 3.9 (see above). • Section I.H.3. — The 90% reduction in VOC applies where actual uncontrolled emissions of a single dehydration unit are in excess of 1 ton/year, or where a group of dehydration units produce actual uncontrolled emissions in excess of 15 tons/year. • Section I.H.4. — Emissions from any dehydration unit vent shall be calculated by methods approved in advance by the Division. • This requirement was supplemented with additional monitoring to provide a timeline of compliance, should the dehydration unit's actual uncontrolled emissions drop below the applicability threshold of Section I.H.3. In the event the source drops below this applicability threshold and then subsequently exceeds it, the source shall have 60 days to comply with the applicable Section I.H. requirements. • Section I.H.5. — Inspections of all air pollution control equipment shall be conducted weekly and records shall be kept that note the date of inspection, a description of problems found and a summary 123/0277 Page 80 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit of any corrective action taken. Weekly monitoring of the pilot light and valve alignment for the pilot gas is required. Records shall be kept documenting any air pollution control device maintenance. • Section I.H.6. — The operator shall submit semi-annual reports including a list of dehydration units subject to I.H., associated air pollution control equipment, and any dates on which inspections indicated that the control devices were not operating properly. o Colorado Regulation No. 7, Part D, Section II.B. The dehydration unit and associated air pollution control equipment at the Enterprise Compressor Station is subject to the following general requirements of Colorado Regulation No. 7, Part D, Section II.B.: • Section II.B.1.a. (State-Only Enforceable)—All hydrocarbon liquid and produced water handling operations shall be designed to minimize leakage of VOC and other hydrocarbons. • Section II.B.1.b. (State-Only Enforceable) — The facility and air pollution control equipment shall be operated at all times using good air pollution control practices. • Section II.B.2.a. (State-Only Enforceable) — Air pollution control equipment used to comply with Section II. shall be operated pursuant to good engineering and maintenance practices, and all control equipment shall be appropriately sized to accommodate reasonably foreseeable fluctuations in unit operation. • Section II.B.2.b. (State-Only Enforceable) — Combustion devices shall be enclosed, have no visible emissions and be designed so that an observer can conveniently determine whether or not the equipment is operating appropriately. • Section II.B.2.d. (State-Only Enforceable) — Combustion devices shall be equipped with an auto-igniter. It should be noted that all general facility requirements were grouped into a separate condition within the operating permit. The dehydration unit condition references the applicable requirements, which are located in Condition 10 of the operating permit. o Colorado Regulation No. 7, Part D, Section II.D. The dehydration unit and associated air pollution control equipment at the Enterprise Compressor Station is subject to the following dehydration unit requirements of Colorado Regulation No. 7, Part D, Section II.D.: • Section II.D.1. (State-Only Enforceable) — Uncontrolled actual emissions of VOC shall be reduced by at least 90% using air pollution control equipment. 123/0277 Page 81 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • This condition was supplemented with a compliance monitoring method. A 90% reduction in VOC shall be assumed, provided the source is in compliance with the general requirements of Section II.B. and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 3.9 (see above). • Section II.D.2. (State-Only Enforceable) — The 90% reduction in VOC applies where actual uncontrolled emissions of a single dehydration unit are in excess of 2 tons/year, or where a group of dehydration units produce actual uncontrolled emissions in excess of 15 tons/year. • Section II.D.3. (State-Only Enforceable) — Uncontrolled actual emissions of hydrocarbon shall be reduced by at least 95%. If a combustion device is used it shall have a design destruction efficiency of 98%, unless it was permitted prior to 5/1/2014 and the facility is not located within 1,320 feet of a building unit or designated outdoor activity area. • This condition was supplemented with a compliance monitoring method. A 95% reduction in hydrocarbon shall be assumed, provided the source is in compliance with the general requirements of Section II.B. and the specific control device requirements required by the dehydration unit O&M Plan, included in Condition 3.9 (see above). Compliance with the destruction efficiency requirements for the combustion device shall be presumed, provided records are kept of the design destruction efficiency and proximity of the closest building/outdoor activity area are kept. • It should be noted that the enclosed combustion device (COMB-1) was replaced with a new model, pursuant to the 4/22/2016 minor modification request. • Section II.D.4. (State-Only Enforceable) — The 95% reduction in hydrocarbon applies where actual uncontrolled emissions of a single dehydration unit constructed before 5/1/2015 are in excess of 6 tons/year, or, if the dehydration unit is located within 1,320 feet of a building unit or outside activity area, actual uncontrolled emissions of that dehydration unit are in excess of 2 tons/year. • Pursuant to the APEN submitted on 11/20/2018, this dehydration unit began operation in 2001. As such, only the requirements applicable to dehydration units constructed before 5/1/2015 were included in the operating permit. • The following additional monitoring requirements were included in the operating permit to ensure compliance with the Colorado Regulation No. 7, Part D, Section II.D requirements: 123/0277 Page 82 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • Requirement to maintain a rolling 12 month calculation of total emissions for the dehydration unit to determine whether the control requirements of Section II.D.1., and/or II.D.3. apply. • Requirement to comply with Section II.D within 60 days for instances in which the dehydration unit had actual uncontrolled emissions below the thresholds set forth in Section II.D.2. and II.D.4., and then subsequently exceeds these thresholds. • Requirement to maintain records of whether or not the facility is located within 1,320 feet of a building unit or outdoor activity area. • Requirement to maintain records of the design destruction efficiency of the combustion device. • Condition 3.13 —40 CFR Part 63 Subpart HH MACT o Included reference to the affirmative defense provisions. This requirement had not yet been promulgated at the time of the drafting process of the previous permit issued on 8/1/2012. o Added general requirement to comply with good air pollution control practices (§63.764(j)). Although not included in the previous revision of the operating permit, this requirement applies to all affected sources under MACT HH. As such, this requirement applies to the dehydration unit at the Enterprise Compressor Station. o Added requirement to maintain records of the actual annual average natural gas throughput (§63.774(d)(1)), if proving the throughput exemption in §63.764(e)(1)(i) is applicable to the dehydration unit. Because this exemption under §63.764(e)(1)(i) was included in the previous issuance of operating permit, the associated requirement to maintain records of the throughput was included in the renewal operating permit. This provides the source with the flexibility to apply the benzene or throughput exemption, without having to modify the permit. • PREVIOUS Condition 3.1.2 — Flash tank emissions shall be vented back to the process at all times o In the minor modification submitted on 7/26/2016 and significant modification submitted on 11/20/2018, the source requested that the vapor recovery unit (VRU), which routes these flash tank emissions back to process, be permitted downtime for maintenance and malfunction purposes. During periods of downtime, these flash tank emissions would be routed to the enclosed combustion device COMB-1. Because this requirement is no longer applicable to the operation of the flash tank at the Enterprise Compressor Station, it was removed from the operating 123/0277 Page 83 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit permit. It should be noted that the routing of flash tank emissions are now governed by the Control Device Requirements condition (see Condition 3.9 above). • PREVIOUS Condition 3.5.1 — Colorado Regulation No. 7, Part D, Section II.B.1.a. o These general requirements were relocated to a separate condition in order to consolidate them for clarity, since multiple permitted emissions units are subject to these requirements. The specific general requirements applicable to the dehydration unit were referenced in the Statewide Controls for Oil and Gas Operations condition (see above). • PREVIOUS Condition 3.9 — Construction Requirements o These one-time requirements were applicable to the construction and startup of 60 MMscfd dehydration unit D-3 (AIRS 073) only. This dehydration unit was never constructed, and was formally cancelled on 12/22/2016. Therefore, all construction requirements for D-3 were removed from the operating permit. • PREVIOUS Condition 7.3 — 95% Control Efficiency for COMB-1 o Since the previous issuance of the operating permit, the 95% control requirement for dehydration units has been promulgated into state regulations under Colorado Regulation No. 7, Part D, Section II.D.3. Because this requirement is now included in a state regulation, the duplicative permit condition was removed in favor of Colorado Regulation No. 7, Part D, Section II.D.3. It should be noted that the supporting requirements listed in the operating permit condition have been addressed in this renewal as follows: ■ Per the permit modification received on 4/26/2016, the combustion device was replaced with a model that did not require supplemental fuel. As such, this requirement was removed from the operating permit. ■ The lean glycol flowrate compliance and recordkeeping requirements are addressed in this dehydration unit condition (see Condition 3.4 above). As such, this duplicative requirement was removed from the operating permit. ■ The requirement to operate with a pilot light present was incorporated into this dehydration unit condition (see Condition 3.9 above) for the enclosed combustion device COMB-1. o PREVIOUS Condition 7.4 — Colorado Regulation No. 7, Part D, Section II.B.1.c. ■ These general requirements were relocated to a separate condition in order to consolidate them for clarity, since multiple permitted 123/0277 Page 84 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit emissions units are subject to these requirements. The specific general requirements applicable to the enclosed combustion device COMB-1 were referenced in the Statewide Controls for Oil and Gas Operations condition (see above). NOTES: Please note the following in regards to the permit modification application received on 11/20/2018: • This dehydration unit is permitted to operate with 5% VRU downtime, during which emissions from the flash tank are routed to the enclosed combustion device, COMB-1. This dehydration unit is also permitted to operate with 1% COMB-1 downtime, during which still vent emissions from the dehydration unit are routed to atmosphere. The intent of downtime is to allow for periods of VRU and COMB-1 maintenance in response to malfunctions, during which the dehydration unit emissions cannot be safely or practicably routed to the VRU or destructed by COMB-1, and are therefore routed to atmosphere. It has been determined that downtime should be permitted as a function of actual operating time, not as a hard numerical limitation based on the maximum number of operational hours and/or maximum throughput. Numerical limits on hours, throughput or VOC emissions would necessarily be based on maximum operating parameters, or 5% of 8,760 hours of operation for the VRU (1% of 8,760 for COMB-1) and/or 5% for the VRU (1% for COMB-1) of the maximum dry gas throughput. Permitting based on maximum operational parameters would result in hard numerical limitations that would seemingly allow the source to process that numerical amount dry gas, discharge that numerical amount of pollutant or vent emissions to atmosphere for that numerical quantity of hours, regardless of actual hours of operation.Therefore, operating over a shortened timeframe and/or operating at less than maximum capacity could result in actual downtime in excess of the allowable 5% for the VRU (i.e., an hours limitation on downtime of 438 hours, or 5% of a maximum 8,760 hours of operation, would theoretically permit the source to route flash gas emissions to atmosphere for 438 hours, even if the source only operates for 438 hours per year, effectively equating to 100% downtime. Similarly for COMB-1, an hours limitation on downtime of 88 hours, or 1% of a maximum 8,760 hours of operation, would theoretically permit the source to route still vent emissions to atmosphere for 88 hours, even if the source only operates for 88 hours per year, effectively equating to 100%downtime.).A permit limitation of this type would allow the source to operate in direct violation of the hydrocarbon and VOC emission reduction requirements of Colorado Regulation No. 7, Part D, Sections I.H. and II.D. for dehydration units. To ensure operating permit limitations do not contradict the requirements of these state regulations and generate a non-compliance situation for the source, the emission limitation for downtime was not based on maximum hours of operation and maximum dry gas processed by the dehydration unit. Instead, the limitation was based on a percentage of actual operating parameters, which allows for a prorated amount of downtime based on actual hours of operation and actual dry gas processed by the dehydration unit. The applicable downtime limitation was incorporated into the operating permit as a dry gas processing rate limitation. Dry gas processed by the dehydration unit during periods of VRU downtime (defined as periods of time during which flash gas 123/0277 Page 85 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit emissions are routed to COMB-1) shall not exceed 5% of the total dry gas throughput to the dehydration unit on a rolling twelve month basis. Similarly, dry gas processed by the dehydration unit during periods of COMB-1 downtime (defined as periods of time when still vent emissions from the dehydration unit are routed to atmosphere) shall not exceed 1% of the total dry gas processed by the dehydration unit on a rolling twelve month basis. Condition 4— D-3 —TEG Dehydration Unit, AIRS: 077 This new dehydration unit was first permitted under Colorado Construction Permit 19WE0492. Refer to Section IV above for the applicable requirements included in the operating permit. Condition 5 — P016 - Stabilized Condensate Truck Loadout Rack, AIRS: 066 The stabilized condensate truck loadout rack was permitted under 19WE0492 during the previous operating permit term. Refer to Section IV above for the applicable requirements included in the operating permit. PREVIOUS Condition 5 - P012 — Fugitive VOC Emissions A cancellation request for this fugitive emission point was received on 5/1/2015. Pursuant to Colorado Regulation No. 7, Part D, Section II.E.2, facilities subject to the LDAR requirements of Section II.E may estimate fugitive emission leaks using Table 2- 8 of EPA-453/R-95-017 EPA Protocol for Equipment Leak Emission Estimates, for the purposes of APEN and permitting applicability under Colorado Regulation No. 3. Since the Enterprise Compressor Station is subject to Section II.E, fugitive emissions are permitted to be estimated using the Table 2-8 factors in lieu of the higher Table 2-4 factors. With the Table 2-8 factors, the fugitive emissions at this facility fall below the 1 ton/year threshold for the purposes of APEN reporting (Colorado Regulation No. 3, Part A, Section II.D.1.a) and permitting requirements (Colorado Regulation No. 3, Part B, Section II.D.1.a). As such, the fugitive emissions at the Enterprise Compressor Station are both APEN and permit-exempt. It should be noted, however, that the fugitive emissions cannot be considered an insignificant activity under Colorado Regulation No. 3, Part C, Section II.E. The insignificant activity exemption cannot be claimed if "a source would avoid any specific federal or state applicable requirement, including, but not limited to, New Source Performance Standards, Regulation Number 7, Prevention of Significant Deterioration (Section VI., Part D of this Regulation Number 3), nonattainment New Source Review requirements (Section V. Part D of this Regulation Number 3), Title III, National Emission Standards for Hazardous Air Pollutants, Title V, and Colorado Maximum Achievable Control Technology or Generally Available Control Technology." Because the fugitive emissions are subject to Colorado Regulation No. 7, Part D, Sections I.L and II.E, these emissions cannot be classified as an insignificant activity. The applicable requirements of Sections I.L and II.E for fugitive emissions at compressor stations were included in the operating permit (refer to the Condition 10 discussion below). Condition 6— P013-Eight(8) 300 bbl Stabilized Condensate Storage Tanks, AIRS ID: 063 123/0277 Page 86 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit The stabilized condensate storage tanks were permitted under 19WE0492 during the previous operating permit term. Refer to Section IV above for the applicable requirements included in the operating permit. The following requirements included in the previous version of the operating permit have been removed or altered pursuant to the justifications provided: • PREVIOUS Conditions 6.3, 6.4.1 and 6.4.2—Colorado Regulation No. 7, Part D, Sections I. and II. General Requirements o These general requirements were relocated to a separate condition in order to consolidate them for clarity, since multiple permitted emissions units are subject to these requirements. • PREVIOUS Condition 6.4 — Colorado Regulation No. 7, Section XII.G.5.b. o This requirement was removed from Colorado Regulation No. 7. As such, it was removed from the operating permit. An analogous control requirement (95% control for VOC) exists in Colorado Regulation No. 7, Part D, Section II.C.1.a. This requirement was included in the operating permit. • PREVIOUS Condition 6.6 — Construction Requirements o The one-time requirements for the construction of four new condensate storage tanks were removed from the operating permit. Per the 2017 inspection report, these requirements were met on 8/19/2013. Condition 7-SUMP-1/2-Two (2) 90 bbl Produced Water Storage Tanks, AIRS ID: 075 These produced water storage tanks are a newly permitted point within this operating permit. Refer to Section V above for the applicable requirements included in the operating permit. PREVIOUS Condition 7 — COMB-1 — Leed Enclosed Combustion Device for Dehydration Unit, AIRS ID: 074 This condition was relocated and combined with Condition 3 addressing TEG dehydration unit D-2, as requested in the 11/20/2018 significant permit modification application. Refer to Condition 3 above for requirements associated with COMB-1. Condition 8 — COMP-BD — Reciprocating Compressor Blowdowns, AIRS ID: 076 This new compressor blowdown point was first permitted under Colorado Construction Permit 19WE0094. Refer to Section IV above for the applicable requirements included in the operating permit. Condition 9 — HAP Emission Limitations for the Stabilized Condensate Storage Tanks, AIRS ID: 063, Produced Water Storage Tanks, AIRS ID: 075 and TEG Dehydration Unit, AIRS ID: 068 or 077 123/0277 Page 87 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit The purpose of this condition is to ensure the source is tracking HAP to demonstrate that the facility is accurately designated as an area source of HAP for the purposes of MACT HH. Because this facility is an area source, it is subject to requirements under MACT HH for the TEG dehydration unit only. If facility-wide HAP emissions exceed the major source thresholds of 10 tons/year individual HAP and 25 tons/year total HAP, different requirements are triggered under MACT HH. Pursuant to MACT HH, major or area source status for production field facilities is determined from aggregate HAP emissions from glycol dehydration units and storage vessels only. The Enterprise Compressor Station, by definition, is classified as a production field facility (see discussion in Section III of this document). Therefore, the HAP emission limitations set forth in this condition are applicable to only the condensate storage tanks, produced water storage tanks and TEG dehydration units. Although there are two TEG dehydration units addressed in this permit, only one is permitted to operate at any given time. Colorado Construction Permit 19WE0492 authorized the construction of new TEG dehydration unit D-3 (AIRS 077) to replace existing TEG dehydration unit D-2. Upon startup of TEG dehydration unit D-3, D-2 will be decommissioned such that these two dehydration units do not operate simultaneously. As such, only HAP emissions from the permitted TEG dehydration unit (either D-2 or D-3), produced water storage tanks and stabilized condensate tanks are aggregated to monitor compliance with the 8 tons/year individual HAP and 20 tons/year total HAP limitations set forth in this condition. To facilitate the eventual permit modification required to remove conditions specific to dehydration unit D-2, the HAP condition was split into two separate sections, one addressing the D-2 HAP emission limitation and monitoring requirements, and one addressing the D-3 requirements. These conditions were included in the operating permit as follows: • Conditions 9.1.1/9.2.1 — These conditions require HAP emissions to be calculated on a monthly basis for any HAP above the de-minimis reporting threshold of 250 lb/year. The HAP calculation methodology is the exact same as the VOC calculation methods set forth in the dehydration unit, produced water storage tanks and condensate tank battery point-specific conditions. • Conditions 9.1.2/9.2.2 — These conditions require the monthly calculation of individual HAP emitted from the TEG dehydration unit, produced water storage tanks and condensate tank battery to be used in a rolling twelve month total to determine compliance with the 8 tons/year individual HAP limitation. Note that monthly HAP emission limitations will be required for the first 12 months of TEG dehydration unit D-3 (AIRS 077) operation to establish an initial 12 month rolling total. After the first 12 months of operation, only compliance with the annual HAP limitations are required. • Condition 9.1.3/9.2.3 — These conditions require the monthly calculation of total HAP emitted from the TEG dehydration units, produced water storage tanks and condensate tank battery to be used in a rolling twelve month total to determine compliance with the 20 tons/year individual HAP limitation. Note that monthly HAP emission limitations will be required for the first 12 months of TEG dehydration unit D-3 (AIRS 077) operation to establish an initial 12 month rolling 123/0277 Page 88 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit total. After the first 12 months of operation, only compliance with the annual HAP limitations are required. It should be noted that the limit of 8 and 20 tons/year allows for insignificant activities associated with the dehydration unit and storage vessels to be emitted without exceeding the major source threshold of 10 and 25 tons/year. If the 8 or 20 tons/year limit is exceeded, a higher limit of up to 10 and/or 25 tons/year may be requested, however, the source will then be required to track insignificant activities associated with the dehydration unit and storage vessels to ensure these activities, in addition to the permitted point emissions, do not exceed the major source threshold for the purposes of MACT HH. Condition 10: Statewide Controls for Oil and Gas Operations — Facility-Wide This condition was created to address the various facility-wide oil and gas requirements set forth in Colorado Regulation No. 7, Part D, Section I (for facilities operating in non- attainment areas) and Section II (for oil and gas facilities state-wide). This issuance of the operating permit incorporates the applicable facility-wide requirements of Colorado Regulation No. 7, last updated on 2/14/2020. • Colorado Regulation No. 7, Part D, Section I.C. — General Requirements o Section I.C.1.a. — Requirement to maintain air pollution control equipment used to comply with Section I. pursuant to manufacturer's specifications and good engineering practices, and to design such devices to accommodate foreseeable process changes. o Section I.C.1.b. — Requirement to maintain all hydrocarbon liquid and produced water handling operations to minimize VOC emissions. • Colorado Regulation No. 7, Part D, Section I.J. — Compressor Requirements o Section I.J.2.a. — Beginning 1/1/2018, the rod packing on reciprocating compressors at natural gas processing plants shall be replaced every 26,000 hours of operation, or every 36 months (whichever comes first). o Section I.J.2.c. — Records shall be kept of the reciprocating compressor identity, hours of operation/number of months since last packing replacement and the date of packing replacement. o Section I.J.2.e— Option to comply with a federal NSPS in lieu of the entire Section I.J.2. • Colorado Regulation No. 7, Part D, Section I.L. — LDAR Requirements o Section I.L.1. — Inspect facilities using approved instrument monitoring methods (AIMM) at least quarterly. o Section I.L.3. — Definition of"difficult to monitor" components. o Section I.L.4. — Definition of leaks requiring repair. 123/0277 Page 89 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit o Section 11.5. — Repair and remonitoring schedule. o Section I.L.6. — Recordkeeping requirements documenting AIMM, identifying facility, leaks detected, repair and remonitoring attempts, delayed repair components and unsafe components. ■ Included additional monitoring requirement, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b., to maintain documentation of the categories of equipment operation that result in emissions but are not defined as leaks under Section I.L.4. This condition was clearly denoted with bold and italicized text. o Section I.L.7. — Annual reporting requirements, identifying the facilities inspected, quantifying the number and type of leaks, summarizing the delayed repair list, and certification by the responsible official. o Section I.L.8. — Alternative AIMM proposition requirements, including application requirements and the approval process. • Colorado Regulation No. 7, Part D, Section II.B (State-Only Enforceable) — General Requirements o Section II.B.1.a. — General requirement to handle all hydrocarbon liquids and produced water in a manner that minimizes the emission of VOCs. o Section ll.B.1.b. — General requirement to operate facility in accordance with good air pollution control practices. o Section I1.B.2.a. —Requirement to maintain air pollution control equipment pursuant to manufacturer specifications and to design this equipment to handle foreseeable process fluctuations. o Section Il.B.2.b. — Requirement to operate enclosed combustion device with no visible emissions. o Section II.B.2.d. — Requirement to operate combustion device with an autoigniter. o Section I1.B.3.a. — Requirement to cap all open ended lines or valves. ■ Supplemented condition with a method to demonstrate compliance, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b., by maintaining records that document location of open-ended lines or valves and how each is treated for the purposes of emission control. This condition was clearly denoted with bold and italicized text. o Section li.B.3.c. — Requirement to replace all compressor rod packing every 26,000 hours of operation (or 3 years). ■ Supplemented condition with a compliance monitoring method, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b., to 123/0277 Page 90 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit maintain a record of the total number of hours of operation or the number of months since rod packing replacements, to be made available to the Division upon request. This condition was clearly denoted with bold and italicized text. • Colorado Regulation No. 7, Part D, Section II.E. (State-Only Enforceable) — LDAR Requirements o Section II.E.2. — Requirement to use EPA-453 in the estimation of fugitive emissions. o Section II.E.3. — Requirement to perform AIMM pursuant to the frequency specified based on calculated fugitive VOC emissions. ■ Supplemented condition with a clarification that approved AIMM consists of either IR camera inspections or EPA Method 21. o Section II.E.5. — Definition of"difficult to monitor" components o Section II.E.6. — Definition of leaks requiring repair o Section II.E.7. — Repair and remonitoring schedule o Section II.E.8. — Records requirements, including facility identification, leaks identified and repair attempts ■ Supplemented condition to note that although records are requirement to be retained for 2 years pursuant to Section II.E.8., records pertaining to Title V sources, including those mandated under Section II.E.8., must be retained for a period of 5 years. ■ Included additional monitoring requirement, pursuant to Colorado Regulation No. 3, Part C, Section V.C.5.b., to maintain documentation of the categories of equipment operation that result in emissions but are not defined as leaks under Section II.E.6. This condition was clearly denoted with bold and italicized text. o Section II.E.9. — Reporting requirements, including an annual report identifying the number of facilities inspected, leaks identified, leaks repaired, leaks on the delayed repair list and responsible official certification • Colorado Regulation No. 7, Part D, Section V. (State-Only Enforceable) — Inventory Reporting Requirements o Section V.A. — Requirement to submit an annual report including actual emissions and operating information on Division-supplied reporting forms. o Section V.B. — Requirement to include basic identifying information, company-wide monthly actual emissions of NOx, CO, VOC, methane and ethane (for ozone season only; May-September), company-wide annual 123/0277 Page 91 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit actual emissions of NOx, CO, VOC, methane and ethane, and a certification of accuracy of the information reported. o Section V.C. — Requirement to submit emissions and calculation information for the source categories listed in this section. Condition 11 — Portable Monitoring • Updated portable monitoring requirements to the most current Division-standard (ver. 6/26/2014). Condition 12 — Compliance Assurance Monitoring (CAM) • Updated CAM language to the most current Division-standard (ver. 4/16/2009). Section III — Permit Shield • The following changes were made to the permit shield table in the operating permit, pursuant to the following justification: o REMOVED Colorado Regulation No. 1, Section VI.B.5.a. ■ These requirements set forth the SO2 emission limitations for "any new source of sulfur dioxide not specifically regulated above". Engines are not "regulated above" in Colorado Regulation No. 1 Section VI. While engines are not considered fuel burning equipment for the purposes of the Colorado Regulation No. 1 particulate matter standard, the SO2 requirements in Colorado Regulation No. 1 are applicable to new and existing S02-emitting equipment, regardless of whether or not that equipment is classified as "fuel burning" under the Common Provisions Regulation. Therefore, since these engines could be subject to this SO2 limitation, the permit shield was removed from the operating permit. It should be noted, however, that the engines at the Enterprise Compressor Station are natural gas fired. As such, emissions of SO2 are significantly below the 2 tons/day requirement in Colorado Regulation No. 1 Section VI.B.5.a. Because it is highly unlikely that these engines will operate anywhere near this 2 tons/day limitation, this requirement was not included in the operating permit. o REMOVED Colorado Regulation No. 3, Section B.IV.D.3. — PSD Review Requirements • It should be noted that the condition number referenced for this permit shield request has been updated to Colorado Regulation No. 3 Part D. This source is currently classified as a minor stationary source for the purposes of PSD. Because a future modification to this source could trigger PSD review, the source 123/0277 Page 92 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit may become subject to the PSD requirements of this section. Therefore, this permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 3, Section B.X—Air quality modeling • It should be noted that the condition number referenced for this permit shield request no longer exists in the current form of the regulation. However, a future modification to this source may trigger the modeling requirements set forth in Colorado Regulation No. 3. Therefore, this permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 3, Section B.XI — Visibility requirements • The referenced section no longer exists in Colorado Regulation No. 3. As such, the permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 4—Wood-burning stoves • The requirements of Colorado Regulation No. 4 are not addressed by the operating permit program. Therefore, this permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 6, Part A — Federal NSPS Requirements • The Enterprise Compressor Station is subject to the requirements of NSPS JJJJ and OOOO. Because this facility is subject to a federal NSPS, this permit shield was removed to the operating permit. o REMOVED Colorado Regulation No. 6, Part B — State-Only Enforceable NSPS Requirements • Currently, the Enterprise Compressor Station is not subject to any state-only enforceable NSPS requirements. However, a future modification to this source may trigger these NSPS requirements. As such, this permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 7, Section V.C— Disposal of Volatile Organic Compounds • Since the previous issuance of this operating permit, Section V.C has been removed from Colorado Regulation No. 7. Therefore, this permit shield request is not applicable and the permit shield was removed from the operating permit. o REMOVED Colorado Regulation No. 10 — Criteria for Analysis of Transportation Conformity 123/0277 Page 93 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit • The requirements of Colorado Regulation No. 10 do not apply to stationary sources. Because this requirement could never apply to the Enterprise Compressor Station, the permit shield was not granted. Section IV— General Permit Conditions • Updated the general permit conditions to the most current Division-standard (ver. 1/21/2020) Appendices • Appendix A— Inspection Information o Included facility plot plan submitted with the 5/17/2019 construction permit application for 19WE0492. o Updated list of insignificant activities to reflect those submitted with source correspondence received 10/2/2019. • It should be noted that pursuant to Colorado Regulation No. 3, Part C, Section II.E, certain insignificant activities are required to be monitored to ensure the insignificant activity exemption continues to apply to each activity. This requirement was included in the operating permit and activities requiring tracking were designated with an asterisk (*). • The two, 30,000 gallon (-714 bbl) pressurized bullet tanks store pre-stabilized condensate. Based on a conversation with operations during the 2019 inspection, it was indicated that under no operational conditions (other than a severe upset during which a relief valve may lift)do these storage vessels vent to atmosphere. If the stabilizer unit is not operating, pressure is held on the storage vessels and no vapors are released to atmosphere. As such, they are not equipped with a control device. Because these storage vessels operate without emissions to atmosphere, they are not subject to NSPS Kb (as indicated in Section III above) and can therefore be considered to be an insignificant activity. • It should be noted that Colorado Regulation No. 7, Part D, Section II.C.1.c. requires control devices for storage tanks with uncontrolled actual emissions of VOC greater than or equal to 2 tons/year. Pursuant to the insignificant activities list received 10/2/2019, all insignificant storage tanks in aggregate produce a negligible amount of VOC emissions. As such, these tanks are not subject to the requirements of Colorado Regulation No. 7, Part D, Section II.C.1.c. • It should be noted that Colorado Regulation No. 7, Part D, Section II.C.5. requires hydrocarbon liquid loading operations from controlled tanks to transport vehicles with a throughput of greater 123/0277 Page 94 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No, 95OPWE103 Technical Review Document—Renewal Operating Permit than 5000 bbl/year be controlled. Pressurized condensate loadout occurs from two, 30,000 gallon pressurized bullet tanks (discussed above) that do not produce emissions to atmosphere and are therefore not controlled. As such, this pressurized liquid loadout, regardless of throughput, is not subject to the requirements of Coloraodo Regulation No. 7, Part D, Section II.C.5. because it is an uncontrolled loadout point. This loadout may therefore be considered to be an insignificant activity, provided VOC emissions from it remain below the 1 ton/year threshold such that the Colorado Regulation No. 3, Part C, Section II.E.3.a. exemption can be claimed. ■ As noted above, the two, 30,000 gallon pressurized bullet tanks operate without • Appendix B — Monitoring and Permit Deviation Reports o Updated monitoring and permit deviation reports to the most current Division standard (ver. 8/20/2014) • Appendix C — Compliance Certification Reports o Updated compliance certification reports to the most current Division standard (ver. 8/20/2014) • Appendix D — Notification Addresses o Updated addresses to the most current Division standard (ver. 1/27/2020) • Appendix F — Permit Modifications o Cleared table of previous modifications • Appendix G — Compliance Assurance Monitoring The following updates were made to the CAM plan based on the source- requested updates in the 7/26/2016 operating permit renewal application, the 11/20/2018 significant modification application and Division-standard practice: o Engines ■ Removed verification of operational status indication for catalyst inlet temperature. Pursuant to the CAM rule §64.6(d), verification of operational status is only required for new units commencing operation. The inline thermocouples at the Enterprise Compressor Station are not new pieces of equipment and have been operating since the installation of the engines. Therefore, verification of operational status is not required for the catalyst inlet temperature. ■ Updated monitoring frequency from daily to continuous for catalyst inlet temperature. Although a once-daily reading is required, the catalyst inlet temperature is continuously monitored with a 123/0277 Page 95 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit thermocouple, the output of which feeds into the distributed control system (DCS). From these continuous readings, the daily reading is recorded. For the purposes of CAM, the catalyst inlet temperature is monitored continuously. o TEG Dehydration Unit D-2 • Removed condenser outlet temperature indicator, as the condenser is no longer relied upon to meet the emission limitations set forth in this permit, as requested in the 11/20/2018 significant modification application. • Pilot Light Presence • Included allowances for downtime, during which the CAM reporting requirements do not apply, as requested in the 7/26/2016 operating permit renewal application. • Updated data representativeness to indicate that the presence of a pilot flame is required to initiate the destruction of emissions. The absence of a flame indicates that emissions are uncontrolled. • Removed verification of operational status indication. Pursuant to the CAM rule §64.6(d), verification of operational status is only required for new units commencing operation. The enclosed combustion device COMB-1 and thermal sensing device at the Enterprise Compressor Station are not new pieces of equipment and have been operating since the installation of the dehydration unit. Therefore, verification of operational status is not required for the COMB-1 pilot flame. o TEG Dehydration Unit D-3 • Included CAM plan for pilot light presence identical to the CAM requirements for TEG dehydration unit D-2. Note that because the emission control achieved using the condenser was not claimed when permitting D-3, the condenser outlet temperature was not used as a CAM indicator for this dehydration unit. • Because TEG dehydration unit D-3 is a new unit, verification of operational status was included for this CAM plan. Verification of operational status shall be accomplished by visually inspecting COMB-1 for presence of a pilot flame to confirm the thermocouple or equivalent heat sensing device output reading. • Appendix H —Applicability Reports o Updated AOS applicability reports to the most current Division standard (ver. 10/12/2012 w/ updated 2014 citations). 123/0277 Page 96 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit VIII. STREAMLINING OF APPLICABLE REQUIREMENTS This section addresses the conditions streamlined from this permit: • Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(E) The Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(E) requirement to inspect onsite loading equipment at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, was streamlined out of the operating permit with respect to the inspection frequency only. Pursuant to the analogous requirement set forth in Colorado Construction Permit 19WE0492, these inspections must occur monthly. Because the Enterprise Compressor Station is a manned facility and loadout not occurring in any given month does not preclude the inspection of the explicitly listed equipment, the monthly inspection frequency required by 19WE0492 was retained. As such, the Colorado Regulation No. 7, Part D, Section II.C.5.a.(iii)(E)frequency requirement was streamlined from the operating permit, in favor of monthly inspections as required by 19WE0492. • Colorado Regulation No. 7, Part D, Section II.C.1.d.(v) The Colorado Regulation No. 7, Part D, Section II.C.1.d.(v) requirement to inspect the flare controlling condensate storage tanks not more frequently than every 7 days, but at least every 31 days, was streamlined out of the operating permit with respect to the inspection frequency only. Pursuant to the current Division-standard operating and maintenance (O&M) plan for condensate storage tanks located at facilities with permitted VOC emissions greater than or equal to 80 tons/year, the enclosed combustion device shall be inspected daily for visible emissions. Because the Enterprise Compressor Station emits VOC in excess of 80 tons/year (Section IX of this document), the inspection frequency requirement for visible flare emissions was increased to daily. As such, the Colorado Regulation No. 7, Part D, Section II.C.1.d.(v) frequency requirement was streamlined from the operating permit, in favor of daily monitoring. • Colorado Regulation No. 7, Part D, Section II.A.2. The Colorado Regulation No. 7, Part D, Section II.A.2. definition of Approved Instrument Monitoring Methods (AIMM) was streamlined out of the operating permit with respect to other Division-approved alternatives ONLY. Other Division-approved alternatives must be submitted to the Division for approval and are not automatically approved by the Colorado Regulation No. 7 language included in the operating permit. Because this approval process is required prior to implementation of alternative AIMM, the allowance for these alternatives was streamlined from the operating permit. At such a time as an alternative method is requested and approved by the Division, the operating permit will be modified to reflect this approved monitoring method. • Colorado Regulation No. 7, Part D, Section II.C.3. 123/0277 Page 97 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit The Colorado Regulation No. 7, Part D, Section II.C.3. requirement to maintain records of storage tank parameters for 2 years only has been streamlined out in favor of the federally-enforceable Colorado Regulation No. 3 record retention requirement of five years. Because the five year period is more stringent and Colorado Regulation No. 3 is federally enforceable, the state-only enforceable records retention requirement of Section II.C.3. was streamlined out in favor of the five year requirement from Colorado Regulation No. 3, Part A, Section II and Part C, Sections V.C.6 and V.C.7. • Colorado Regulation No. 7, Part D, Section II.C.4.f. The Colorado Regulation No. 7, Part D, Section II.C.4.f. requirement to maintain records of storage tank measurement system design, inspections, manufacturer specifications and training for 2 years only has been streamlined out in favor of the federally-enforceable Colorado Regulation No. 3 record retention requirement of five years. Because the five year period is more stringent and Colorado Regulation No. 3 is federally enforceable, the state-only enforceable records retention requirement of Section II.C.4.f. was streamlined out in favor of the five year requirement from Colorado Regulation No. 3, Part A, Section II and Part C, Sections V.C.6 and V.C.7. • Colorado Regulation No. 7, Part D, Section II.C.5.a.(v) The Colorado Regulation No. 7, Part D, Section II.C.5.a.(v) requirement to maintain records of hydrocarbon liquid loadout inspections, throughput, training and infeasibility determinations for 2 years only has been streamlined out in favor of the federally-enforceable Colorado Regulation No. 3 record retention requirement of five years. Because the five year period is more stringent and Colorado Regulation No. 3 is federally enforceable, the state-only enforceable records retention requirement of Section II.C.5.a.(v) was streamlined out in favor of the five year requirement from Colorado Regulation No. 3, Part A, Section II and Part C, Sections V.C.6 and V.C.7. • Colorado Regulation No. 7, Part D, Section II.E.8. The Colorado Regulation No. 7, Part D, Section II.E.8. requirement to maintain records of fugitive emission inspections for 2 years only has been streamlined out in favor of the federally-enforceable Colorado Regulation No. 3 record retention requirement of five years. Because the five year period is more stringent and Colorado Regulation No. 3 is federally enforceable, the state-only enforceable records retention requirement of Section II.E.8. was streamlined out in favor of the five year requirement from Colorado Regulation No. 3, Part A, Section II and Part C, Sections V.C.6 and V.C.7. 123/0277 Page 98 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit IX. FACILITY-WIDE EMISSION SUMMARY Controlled Emissions(tons/year) Uncontrolled Emissions(tons/year) AIRS ID Facility ID Source Reportable Reportable NOx CO VOC HAP NOx CO VOC HAP 053 C-238 Compressor Engine 24.00 27.42 24.00 3.58 24.00 85.70 210.82 15.39 055 C-235 Compressor Engine 24.00 27.42 24.00 3.58 24.00 85.70 210.82 15.39 056 C-236 Compressor Engine 24.00 27.42 24.00 3.58 24.00 85.70 210.82 15.39 063 P013 Condensate Storage Tanks -- -- 1.68 0.31 -- -- 33.69 6.29 066 P016 Condensate Truck Loadout -- -- 0.94 0.02 -- -- 18.83 0.37 068 D-2 TEG Dehydration Unit 1.43 6.51 26.82 14.21 1.43 6.51 700.22 250.71 070 C-234 Compressor Engine 24.00 27.42 24.00 3.58 24.00 85.70 210.82 15.39 071 C-237 Compressor Engine 32.01 36.58 32.01 4.99 32.01 125.74 281.19 20.94 075 SUMP-1/2 Produced Water Storage Tanks -- -- 1.85 0.17 -- -- 1.85 0.17 076 COMP-BD Compressor Blowdowns -- -- 9.80 -- -- -- 9.80 -- 077 D-3 TEG Dehydration Unit 1.49 6.72 23.94 11.78 1.49 6.72 644.86 205.60 Total Permitted Facility Emissions(D-2)(tons/year) 129.44 152.77 169.10 34.03 129.44 475.05 1888.86 340.05 Total Permitted Facility Emissions(D-3)(tons/year) 129.50 152.98 166.22 31.60 129.50 475.26 1833.50 294.94 123/0277 Page 99 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Uncontrolled HAP Emissions (Reportable) Calculated Reportable HAP Uncontrolled Emissions(tons/year) AIRS ID Facility ID Source n- 2,2,4- Ethyl Acetaldehyde Acrolein Methanol Formaldehyde Benzene Toluene benzene Xylenes Hexane TMP 053 C-238 Compressor Engine 0.88 0.54 0.26 13.71 055 C-235 Compressor Engine 0.88 0.54 0.26 13.71 056 C-236 Compressor Engine 0.88 0.54 0.26 13.71 -- -- -- -- -- -- 063 P013 Condensate Storage Tanks -- -- -- -- 3.25 -- 0.41 1.52 -- 1.12 066 P016 Condensate Truck Loadout -- -- -- -- 0.37 -- -- -- -- -- 068 D-2 TEG Dehydration Unit -- -- 14.77 76,39 125.45 4.10 30.00 070 C-234 Compressor Engine 0.88 0.54 0.26 13.71 071 C-237 Compressor Engine 1.30 0.80 0.39 18.29 0.17 -- -- -- -- -- 075 SUMP-1/2 Produced Water Storage Tanks __ 0.17 __ __ __ __ __ 076 COMP-BD Compressor Blowdowns -- -- -- -- 077 D-3 TEG Dehydration Unit -- -- -- -- 13.10 -- 66.67 99.83 3.11 22.89 Total Permitted Facility Emissions(D-2)(tons/year) 4.81 2.96 1.44 73.14 18.72 0.00 76.80 126.97 4.10 31.12 Total Permitted Facility Emissions(D-3)(tons/year) 4.81 2.96 1.44 73.14 17.05 0.00 67.08 101.35 3.11 24.01 123/0277 Page 100 of 102 DCP Operating Company, LP—Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Controlled HAP Emissions (Reportable) Calculated Reportable HAP Controlled Emissions(tons/year) AIRS ID Facility ID Source n- 2,2,4- Ethyl Acetaldehyde Acrolein Methanol Formaldehyde Benzene Toluene Xylenes Hexane TMP benzene 053 C-238 Compressor Engine 0.44 0.27 0.13 2.74 -- -- -- -- -- -- 055 C-235 Compressor Engine 0.44 0.27 0.13 2.74 056 C-236 Compressor Engine 0.44 0.27 0.13 2.74 -- -- -- -- -- -- _ 063 P013 Condensate Storage Tanks -- -- -- -- 0.16 -- 0.02 0.08 -- 0.06 066 P016 Condensate Truck Loadout -- -- -- -- 0.02 -- -- -- -- -- 068 D-2 TEG Dehydration Unit - 0.49 -- 4.40 7.30 0.24 1.77 070 C-234 Compressor Engine 0.44 0.27 0.13 2.74 071 C-237 Compressor Engine 0.65 0.40 0.19 3.66 0.09 -- -- -- -- -- 075 SUMP-1/2 Produced Water Storage Tanks __ 0.17 __ 076 COMP-BD Compressor Blowdowns -- -- -- -- -- -- -- -- -- -- 077 D-3 TEG Dehydration Unit -- -- -- -- 0.46 -- 3.89 5.88 0.18 1.36 Total Permitted Facility Emissions(D-2)(tons/year) 2.41 1.48 0.72 14.63 0.93 0.00 4.42 7.38 0.24 1.83 Total Permitted Facility Emissions(D-3)(tons/year) 2.41 1.48 0.72 14.63 0.90 0.00 3.91 5.96 0.18 1.42 2018 Actual Facility Emissions(tons/year) 1.98 1.25 0.60 12.46 0.33 0.00 0.71 0.53 0.01 0.10 123/0277 Page 101 of 102 DCP Operating Company, LP— Enterprise Compressor Station Operating Permit No. 95OPWE103 Technical Review Document—Renewal Operating Permit Information Relied Upon AIRS ID Facility ID Information Source 053 C-238 APEN rec'd 11/20/2018;mfg.EFs for NOx,CO,VOC;uncontrolled HAP EFs from AP-42 Table 3.2-2;0%CE for NOx,68%CE for CO;89%CE for VOC;80%CE for CH2O; 50%CE for HAP 055 C-235 APEN rec'd 11/20/2018;mfg.EFs for NOx,CO,VOC;uncontrolled HAP EFs from AP-42 Table 3.2-2;0%CE for NOx,68%CE for CO;89%CE for VOC;80%CE for CH2O; 50%CE for HAP 056 C-236 APEN rec'd 11/20/2018;mfg.EFs for NOx,CO,VOC;uncontrolled HAP EFs from AP-42 Table 3.2-2;0%CE for NOx,68%CE for CO;89%CE for VOC;80%CE for CH2O; 50%CE for HAP 063 P013 APEN rec'd 5/17/2019;VOC and HAP EFs established by Colorado Construction Permit 19WE0492 Preliminary Analysis 066 P016 APEN rec'd 5/17/2019;VOC and HAP EFs established by Colorado Construction Permit 19WE0492 Preliminary Analysis 068 U-2 APEN recd 11/20/2018;VOC and HAP emissions based on 10/29/2018 GlYCalc model run and 9/22/2017 extended gas analysis from 11/20/2018 significant modification application;NOx and CO EFs from AP-42 Table 1.4-1 for pilot gas and Tables 13.5-1 and 13.5-2 for assist and waste gas 070 C-234 APEN rec'd 11/20/2018;mfg.EFs for NOx,CO,VOC;uncontrolled HAP EFs from AP-42 Table 3.2-2;0%CE for NOx,68%CE for CO;89%CE for VOC;80%CE for CH2O; 50%CE for HAP 071 C-237 APEN rec'd 11/20/2018;mfg.EFs for NOx,CO,VOC;uncontrolled HAP EFs from AP-42 Table 3.2-2;0%CE for NOx,71%CE for CO;89%CE for VOC;80%CE for CH2O; 50%CE for HAP 075 SUMP-1/2 APEN rec'd 6/2/2020;VOC and HAP emissions based on AP-42 Chapter 7 calculation methods and 3/12/2020 flash liberation analysis from 6/2/2020 permit modification application 076 COMP-BD APEN rec'd 10/30/2020;volumetric EF based on 10/30/2020 permit modification application and 8/12/2019 extended gas analysis 077 D-3 APEN rec'd 5/17/2019;VOC and HAP emissions based on 5/1/2019 GLYCaIc model run and 9/22/2017 extended gas analysis from 5/17/2019 19WE0492 construction permit application;NOx and CO EFs from AP-42 Table 1.4-1 for pilot gas and Tables 13.5-1 and 13.5-2 for assist and waste gas 123/0277 Page 102 of 102 INFO TO SUPPORT Enterprise Compressor Station 123-0277 95OPWE103 Renew 3 7/26/2016 Renewal Application DCP Midstream 370 17th St.,Suite 2500 Denver, Der CO 80202 m.. (303)605-2039 Midstream.. www.dcpmidstream.com July 26, 2016 Hand Delivered Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South Denver, CO 80246-1530 JUL 26 2011 Re: Enterprise Compressor Station Operating Permit 95OPWE103 Title V Renewal and Modification Application AIRS ID 123/0277 Dear Sir or Madam: DCP Midstream, LP (DCP) is submitting the attached operating permit renewal application for the Enterprise Compressor Station, located at Section 30,Township 2N, Range 63W in Weld County, Colorado. This renewal application also incorporates the changes in the recent Minor Modification Request submitted April 22, 2016 and requests additional changes under the minor modification provisions of Regulation Number 3, Part C. In general, application forms have only been included where there are changes from the operating permit issued in 2012. These changes are discussed below: 4/22/2016-Minor Modification Request Changes • D2: Natural Gas Dehydrator— Enclosed combustor(COMB-1) used for emissions control replaced with newer model, per review of Colorado Regulation Number 7 requirements. o Updated emissions (these emissions are updated further in the minor modification request below) o Updated supplemental fuel use and monitoring requirements, no minimum fuel requirements by design • D3: Natural Gas Dehydrator—Remove from Operating Permit; this equipment was never installed on site. • Remove D3 from equipment controlled by new enclosed combustor(COMB-1).This control device is exclusive to unit D2. Minor Modification Request Changes in Addition to Renewal Application D2: Natural Gas Dehydrator:equipment included in 2012 operating permit was replaced under alternate operating scenario(AOS)provisions; updated serial number. Additionally, DCP is requesting the following operating permit condition changes to the emission control methods used to control emissions from D2: • A 5%annual downtime for the Vapor Recovery Unit (VRU), for maintenance and malfunctions. This corresponds to 438 hours per year of downtime. This control device is used to control emissions from D2's flash tank. The enclosed combustor COMB-1 will be used as a backup control device during periods of VRU downtime. The following are the suggested permit condition changes to reflect this downtime. Additionally, please note that the requirement for the condenser outlet temperature recording has been changed to match the language in the attached CAM plan for this unit. o Revised Condition 3.1.1 --VOC and HAP emissions shall be calculated monthly using the Gas Research Institute's GLYCaic Model, Version 4.0 or higher, in addition to records of the time and duration of VRU downtime. The following parameters to be entered into the GLYCaIc Model shall be monitored weekly: condenser outlet temperature, flash tank temperature and pressure, and inlet (wet)gas pressure and temperature. The following parameters to be entered into the GLYCaIc Model shall be monitored daily: triethylene glycol circulation rate.- The condenser outlet temperature recorded shall be the daily average of condenser temperature readings. Values of parameters shall be representative of the unit's operation during the month. o Revised Condition 3.1.2 -Flash gas emissions shall be vented back into the process at all times, resulting in zero emissions from the flash tank during Vapor Recover Unit(VRU) operation. A maximum period of 438 hours (5%annual downtime) is reserved for malfunctions and maintenance on the VRU. All flash gas emissions will be routed to enclosed combustor COMB-1 during periods of VRU downtime. o Requested Condition -The owner or operator shall monitor and record VRU downtime. VRU downtime shall be defined as times when the flash tank gas is routed to the enclosed combustor. The total hours of downtime and volume of gas processed during VRU downtime shall be recorded on a monthly basis and used to calculate actual emissions to demonstrate compliance with the emission limits contained in this permit. • A 3%annual downtime for the enclosed combustor COMB-1, for maintenance and malfunctions. This corresponds to 263 hours per year of downtime. This control device is used to control emissions from D2's still vent and as a backup to control emissions from D2's flash tank. Emissions will be uncontrolled during periods of COMB-1 downtime. The following are the suggested permit condition changes to reflect this downtime. o Revised Condition 7.5 -The enclosed combustor shall be operated at all times when emissions are routed to it, except for a maximum annual downtime period of 263 hours (3%annual downtime) for malfunctions and maintenance. The enclosed combustor shall be operated with a pilot flame present at all times, except for these periods of downtime. •The presence of an enclosed combustor pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. The device shall be equipped with an alarm to indicate no ignition of the pilot flame. Records of the times and duration of all periods of pilot flame outages and estimated emissions shall be maintained and made available to the Division upon request. o Requested Condition- Records of the times and duration of all periods of enclosed combustor downtime and estimated emissions shall be maintained and made available to the Division upon request. • The changes in the potential-to-emit estimates associated with these requested downtimes have been calculated and the associated Title V Operating Permit Forms have been included in this permit renewal/modification application. A calculation for the overall control of emissions from this natural gas dehydrator D2 has also been included to show that overall control will remain greater than 95%with these included downtimes, as required by permit condition 3.5 of Operating Permit 95OP W E 103. Page 2 • An updated CAM plan and O&M plan for the natural gas dehydrator have been included as Appendix G and H respectively, reflecting the requested changes to equipment downtime. Other Requested Changes • C-239: Caterpillar G3616 Compressor Engine— Remove from Operating Permit; this equipment was never installed on site. • C-235:Caterpillar G3612S1 Compressor Engine: engine included in 2012 operating permit was replaced under alternate operating scenario(AOS)provisions; updated serial number • C-236: Caterpillar G3612S1 Compressor Engine: engine included in 2012 operating permit was replaced under alternate operating scenario(AOS)provisions; updated serial number • C-238: Caterpillar G3612SI Compressor Engine: engine included in 2012 operating permit was replaced under alternate operating scenario(AOS)provisions; updated serial number • C-234: Caterpillar G3612SI Compressor Engine: engine included in 2012 operating permit was replaced under alternate operating scenario(AOS)provisions; updated serial number • The fugitive emissions included in the 2012 issuance of 95OPWE103 have been removed and the APEN for this point cancelled. DCP has implemented the new Colorado Regulation Number 7 fugitives monitoring program and revised emissions based on updated emission factors show fugitive emissions less than the APEN threshold of 1 tpy VOC. The fugitive emissions have been added to the list of insignificant activities for this facility; please see Appendix E. Attachments Attached please find forms and attachments needed renew and to make the requested changes to operating permit 95OPWE103, as well as the required certifications signed by the Responsible Official, William L. Johnson, Vice President of Operations. Also included are: • Appendix A: Facility Plot Plan& Process Flow Diagram • Appendix B:Copies of most recent APENs for all equipment except Natural Gas Dehydrator D2 and enclosed combustor COMB-I • Appendix C: Updated APEN for Natural Gas Dehydrator D2 and enclosed combustor COMB-1 • Appendix D: APEN filing fees • Appendix E: Emission Calculations for replaced enclosed combustor and emission calculations reflecting the requested downtime for control device operation on the Natural Gas Dehydrator D2. includes an updated GlyCalc run and supporting documentation. • Appendix F: List of Insignificant Activities • Appendix G: Updated CAM Plan • Appendix H: Updated O&M Plan Page 3 Additionally, DCP would like to change the Responsible Official at this facility to William L. Johnson, Vice President of Operations. This is represented on the forms accompanying this renewal and minor modification application. The current Operating Permit 95OPWE103 was originally issued by the Colorado Department of Public Health and Environment, (CDPHE), Air Pollution Control Division on May I, 1999 and most recently reissued on August 2nd, 2012. This renewal application is being submitted to fulfill the 5-year renewal requirements under Regulation 3 Part C, as well as to incorporate the changes listed above. If you have any questions or require any additional information about this submittal, please contact me at (303) 605-2039 or RShankaran@dcpmidstream.com. Sincerely, DCP Midstream, LP Roshini Shankaran Environmental Engineer Attachments: • Page 4 1 Operating Permit Application SOURCE AND SITE DESCRIPTIONS FORM 2000-102 Colorado I.)cpartmcnt of Public I lcalth and Unvironmeat Rc'S 06-95 Pollution Control Division Facility Name: Enterprise Compressor Station Facility Identification Code: CO 123-0277 The operating permit must be prepared and submitted on forms supplied by the Division. I Ise of this form is required for all operating permit applications. The I)ivision will not consider or act upon your application unless each form used has been entirely completed. Completion of the information in the shaded area of this lirrrn is optional. Ilse "NA" Where necessary to identify an information request that does not apply and is not in the optional shaded area 1.Briefly describe the existing Unit(s)to be permitted. Attach copies of Form 2000-700 as needed to provide the information. Process flowsheets or line diagrams showing major features and locations of air pollution control equipment can be most effective in showing the location and relationships of the units. Providing mass flowrates/balances at critical points on the diagrams is very helpful when developing an understanding of the processes involved. Enterprise is classified as a natural gas compressor station as set forth under Standard Industrial Classification Code 4922. The facility uses five (5) gas-fired internal combustion engines to drive compressors boosting the inlet gas pressure from about 80 PSIG to 1,050 PSIG to facilitate movement of the gas in the pipeline. The station also includes a triethylene glycol (TEG)dehydrator unit which contacts "lean"triethylene glycol with the inlet natural gas stream to remove moisture. The "rich" glycol mixture is regenerated in a still for reuse in the process. The still vent exhaust stream is sent to an enclosed combustor where it is combusted. This enclosed combustor has an annual uptime of 97%, with downtime emissions releasing to atmosphere. The TEG dehydration system operates with a flash tank. The flash tank emissions are routed back to the process through the use of a Vapor Recovery Unit(VRU), with an annual uptime of 95%. Emissions during downtime events are routed to the enclosed combustor.A condensate product is generated when the inlet gas is routed through the inlet scrubber and transferred to eight(8) 300 barrel atmospheric storage tanks. A loading system is provided for moving the liquid condensate material from the tanks into a truck for transport offsite. The condensate tanks and loadout are controlled by an enclosed combustor. The facility has a natural gas throughput of 110 MMSCFD and a maximum stabilized condensate production rate of 153,884.4 bbl/yr. 2.Site Location and Description (Include instructions needed to drive to remote sites not identified by street addresses) Site location:SW SW Section 30,T2N, R63W The facility is located one (1) mile north of US Highway 76 on the Gutterson Road between the towns of Keenesburg and Roggen, Weld County, Colorado. 3. Safety Equipment Identify safety equipment required for performing an inspection of the facility: Protection X Other, specify Fire retardant clothing x Hard Hat x Safety shoes x Hearing Protection Gloves Operating Permit Application SOURCE DESCRIPTION-APENS FORM 2000-102A Colorado I)cpartmcnt of Public Health and Fn‘ironme t Re% 06-95 ,Air Pollution Control I)i%ision f actlit� Name- Enterprise Compressor Station Facility Identification Code. CO 123-0277 NOTE: Each new or updated Air Pollutant Emission Notice (APEN) submitted must be accompanied by payment of$152.90 per APEN. 1.For each emission unit enclose a copy of the most current complete Air Pollutant Emission Notice (APEN) on file with i the Division. If the most current APEN was not completely and correctly filled out, a revised APEN is required. List an APEN number, date, and a brief description of the unit/process covered by the APEN. (No filing fees are needed for these copies) Appendix B contains copies of the following APENs: Source AIRS ID Source Usage Source Description Date of last ID APEN C-235/ 055 Natural Gas 3,550 hp, Caterpillar G3612SI, Natural Gas Fired, 4/30/2015 P-005 Compressor Engine Reciprocating Internal Combustion Engine,4-cycle, Standard Lean Burn w/Oxidation Catalyst C-236/ 056 Natural Gas 3,550 hp, Caterpillar G3612SI, Natural Gas Fired, 7/09/2015 P-006 Compressor Engine Reciprocating Internal Combustion Engine,4-cycle, Standard Lean Burn w/Oxidation Catalyst C-238/ 053 Natural Gas 3,550 hp, Caterpillar G3612SI, Natural Gas Fired, 4/30/2015 P-003 Compressor Engine Reciprocating Internal Combustion Engine,4-cycle, Standard Lean Burn w/Oxidation Catalyst C-234/ 070 Natural Gas 3,550 hp,Caterpillar G3612SI, Natural Gas Fired, 4/30/2015 P-018 Compressor Engine Reciprocating Internal Combustion Engine,4-cycle, Standard Lean Burn wl Oxidation Catalyst C-237 071 Natural Gas 4,735 hp, Caterpillar G3616, Natural Gas Fired, 4/30/2015 Compressor Engine Reciprocating Internal Combustion Engine,4-cycle, Standard Lean Burn w/Oxidation Catalyst P-013 063 Stabilized 8- 300bb1 Atmospheric Vertical Stabilized Condensate 1/04/2012 Condensate Storage Tanks Controlled with a Combustor Storage P-016 066 Stabilized 153,884.4 bbl/yr Stabilized Condensate Truck Loading 1/04/2012 Condensate Truck Loading 2.No APEN exists for an emission unit. List the new APEN and the appropriate descriptive information here. Submit the APEN with a construction permit application. New APEN and permit application submitted Yes x No 3.A revised APEN was prepared and enclosed for an emission unit. List the APEN and the appropriate descriptive information here. A revised APEN is needed where a significant increase in emissions has occurred, or is planned; or a major modification of the unit has occurred or is planned; or the existing information needs correction or completion. A construction permit application may need to be submitted. Revised APEN submitted as part of this application: x Yes I No x Filing Fee Enclosed D-2 I 068 Dehydration of 110 MMSCFD, Forum Tri ethylene Glycol (TEG) Natural Gas Dehydration Unit, 35 gpm TEG Recirculation Rate, Flash Tank Routed to Reboiler, Equipped with a Condenser Routed to an enclosed combustor • COMB-1 074 Enclosed Enclosed combustor for control of Still Vent emissions from Combustor dehydrator D-2 New permit application enclosed: Yes x No Permit modification application enclosed: Yes x No Note: These revised APENs are being submitted as part of the attached application, which includes a Title V renewal, incorporates a previously submitted minor modification application, and includes a new minor modification request. I • Operating Permit Application SOURCE DESCRIPTION- INSIGNIFICANT ACTIVITIES FORM 2000-102B t'olorado l)epartmcnt of Public I lcalth and Environment ironment Rev 06-95 Air Pollution Control Division Facility Name. Enterprise Compressor Station FacilitA Identification Code: CO 123-0277 NOTE:The operating permit must he prepared and submitted on forms supplied by the Division. This is a supplemental form for use only when necessan to provide complete information in the operating permit application The Division kill not consider or act upon your application unless each form used has been entirely completed. Certain categories of sources and activities are considered to be insignificant contributors to air pollution and are listed below. A source solely comprised of one or more of these activities is not required to obtain an operating permit pursuant to Regulation 3, unless the source's emissions trigger the major source threshold as defined in Part A,Section I.B.58 of Regulation 3. For the facility, mark all insignificant existing or proposed air pollution emission units, operations, and activities listed below. ! (a) noncommercial (in-house)experimental and analytical laboratory equipment which is bench scale in nature including quality control/quality assurance laboratories, process support laboratories,environmental laboratories supporting a manufacturing or industrial facility, and research and development laboratories. (b) research and development activities which are of a small pilot scale and which process less than 10,000 pounds of test material per year. (c) small pilot scale research and development projects less than six months in duration with controlled actual emissions less than 500 pounds of any criteria pollutant or 10 pounds of any non-criteria reportable pollutant. Disturbance of surface areas for purposes of land development,which do not exceed 25 contiguous acres and which do not exceed six months in duration. (This does not include mining operations or disturbance of contaminated soil). x Each individual piece of fuel burning equipment,other than smokehouse generators and internal combustion engines,which uses gaseous fuel,and which has a design rate less than or equal to 5 million Btu per hour.(See definition of fuel burning equipment,Common Provisions Regulation). x Petroleum industry flares,not associated with refineries,combusting natural gas containing no H2S except in trace(less than 500 ppmw)amounts,approved by the Colorado Oil and Gas Conservation Commission and having uncontrolled emissions of any pollutant of less than five tons per year. x Chemical storage tanks or containers that hold less than 500 gallons,and which have a daily throughput less than 25 gallons. Landscaping and site housekeeping devices equal to or less than 10 H.R. in size (lawnmowers,trimmers, snow blowers, etc.). Crude oil or condensate loading truck equipment at crude oil production sites where the loading rate does not exceed 10,000 gallons per day averaged over any 30 day period. x Chemical storage areas where chemicals are stored in closed containers,and where total storage capacity does not exceed 5000 gallons. This exemption applies solely to storage of such chemicals. This exemption does not apply to transfer of chemicals from,to,or between such containers. Oil production wastewater(produced water tanks), containing less than 1%by volume crude oil, except for commercial facilities which accept oil production wastewater for processing. Storage of butane,propane, or liquified petroleum gas in a vessel with a capacity of less than 60,000 gallons, provided the requirements of Regulation No. 7, Section IV are met,where applicable. x Storage tanks of capacity<40,000 gallons of lubricating oils. Venting of compressed natural gas, butane or propane gas cylinders,with a capacity of 1 gallon or less. Fuel storage and dispensing equipment in ozone attainment areas operated solely for company-owned vehicles where the daily fuel throughput is no more than 400 gallons per day, averaged over a 30 day period. 5 Crude oil or condensate storage tanks with a capacity of 40,000 gallons or less. Storage tanks meeting all of the following criteria: (i) annual throughput is less than 400,000 gallons; and (ii)the liquid stored is one of the following: (A) diesel fuels 1-D, 2-D, or 4-D; (B) fuel oils#1 through#6; (C) gas turbine fuels 1-GT through 4-GT; (D) an oil/water mixture with a vapor pressure lower than that of diesel fuel (Reid vapor pressure of.025 PSIA). x Each individual piece of fuel burning equipment which uses gaseous fuel,and which has a design rate less than or equal to 10 million Btu per hour,and which is used solely for heating buildings for personal comfort. Stationary Internal Combustion Engines which: (i) power portable drilling rigs;or (ii) are emergency power generators which operate no more than 250 hours per year;or (iii)have actual emissions less than five tons per year or rated horsepower of less than 50. Surface mining activities which mine 70,000 tons or fewer of product material per year. A fugitive dust control plan is required for such sources. Crushers, screens and other processing equipment activities are not included in this exemption. x Air pollution emission units,operations or activities with emissions less than the appropriate de minimis reporting level. NOTE: Material Data Safety Sheets(MSDS)do not have to be submitted for any insignificant activities. USE FORM 2000-700 TO PROVIDE AN ITEMIZED LIST OF THE SOURCES OR ACTIVITIES BEING IDENTIFIED AS INSIGNIFICANT ACTIVITIES. DO NOT ITEMIZE INDIVIDUAL PIECES OF LANDSCAPING EQUIPMENT. THE LIST IS NEEDED TO ACCURATELY ACCOUNT FOR ALL ACTIVITIES AT THE FACILITY Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and linvironmcnt Rev 06-95 :fir Pollution Control Division SEE INS'FRUC'FIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2 Facility. identification code: Ct) 123-0277 3. Stack identification code:P005 3a.Construction Permit Number-97WE0553 4. Exhausting Unit(s),use Unit identification code from appropriate Forms)2000-300,301,302,303,304,305,3(16,307 2000-300 2000-301 2000-302 C-235 2000-303 20t10-304 20(10-305 2000-31)6 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ® Engine Location Identified 6. Indicate by checking: ® This stack has an actual exhaust point. The parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form ❑ When stack height Good Engineering Practice(GI�.P)exceeds 65 meters(Colorado Air Quality Reg 3.A.VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 52.5 (feet) 8. Inside dimensions at outlet(check one and complete): ® Circular 2.0 (feet) ❑ Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 124 (FPS) ❑ Calculated ❑ Stack Test 10. Exhaust gas temperature(normal): 858 (°F) 11. Does process modify ambient air moisture content? ❑ Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ® Up ❑ Down ❑ Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑ Yes ® No *****Complete the appropriate Air Permit Application Fonus(s) 2000-300,301. 302, 303,304. ***** 305,306,or 307 for each Unit exhausting through this stack. 7 INTERNAL COMBUSTION ENGINE OPERATION Operating Permit Application FORM 2000-302 Colorado I)epartment of Public I Icalth and Environment Rev(Ri-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: P005 4. Engine(Unit)code: C-235 4a. Date first placed in service: 1994 Date last modified: 5. Engine use: natural gas compression 6. Engine Features: 2-Cycle LI 4-Cycle 11 Spark-ignition ® Diesel ❑ Standard rich burn ❑ Standard lean burn Air/fuel ratio controller O Turbocharger Logy-NON design O Other(1)escribe): 7. Emission controls: ❑ No ® Yes-Attach control device form Non-Selective catalytic reduction ❑ Three-way catalyst ❑ Selective catalytic reduction O Ammonia injected ❑ ()xidation catalyst ® Other: S. Manufacturer:Caterpillar 9. Model No: G3612 S/N: IVG00047 10. Max Fuel Design Rate: 24.0 mmBTU/hr 11. I lorsepower Max Design:3,550 Site: 3,550 12. I feat Rate: 6,760 131'l l/I IP-hr 13. ()perating Temp: Min. Max. 14. Fuels: Primary Fuel Backup Fuel 41 Fuel Type: Natural Gas Heating Value B I'I I/SCF 1,136.3 Sulfur Content (Wt.'/0) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) Maximum Hourly Consumption(Ft'.gal) 21,119.99 sent- Maximum Yearly Consumption(Ft3.gal) 185.01 MMscf/yr NO'l E: Data entry below is N()'I OPTIONAL,if parametric monitoring is used for compliance demonstration 15.Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify, the method of compliance demonstration by completing Form 2000-500-***** DESCRIPTION OF MI';fI IODS I ISEI)FOR DETERMINING COMPLIANCE. Attach Form 2000-5110 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this Unit. ***** 9 Operating Permit:Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public I lealth and Environment Rc.ti6-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: P006 3a.Construction Permit Number:97WE0553 4. Exhausting Unit(s),use t nit identification code from appropriate Form(s)2000-300.301,302,303,304.305.306,307 2000-300 2000-301 2000-302 C-236 2000-303 2000-304 21)00-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ►il Engine Location Identified • 6. Indicate by checking: ® This stack has an actual exhaust point.The parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. Cio to next form. ❑ When stack height Good Engineering,Practice((iliP)exceeds 65 meters(Colorado Air Quality Reg 3.A-VIII.D)data entry is required for Item 7. 7. Discharge height above ground level: 52.5 (feet) 8. Inside dimensions at outlet(check one and complete): ® Circular 2.0 (feet) ❑ Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 124 (FPS) ❑ Calculated ❑ Stack Test 10. Exhaust gas temperature(normal): 858 (°F) 11. Does process modify ambient air moisture content? O Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ® Up O Down O Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑ Yes ® No *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301,302, 303, 304, ***** 305.306_or 307 for each Unit exhausting through this stack. 9 INTERNAL COMBUSTION ENGINE OPERATION Operating Permit Application FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: P006 4. Engine(Unit)code: C-236 4a.Date first placed in service: 1/01/1993 Date last modified: 5. Engine use: natural gas compression 6. Engine Features: 2-Cycle❑ 4-Cycle ® Spark-ignition ® Diesel ❑ Standard rich burn ❑ Standard lean burn LEI Air/fuel ratio controller ❑ Turbocharger Low-NOx design 0 ()ther(Describe): 7.Emission controls: ❑ No ® Yes-Attach control device form Non-Selective catalytic reduction 0 Three-way catalyst ❑ Selective catalytic reduction 0 Ammonia injected 0 Oxidation catalyst ® Other: 3. Manufacturer:Caterpillar 9. Model No: G-3612 S/N: 1YG00028 10. Max Fuel Design Rate: 24.00 mm13TU/hr 11. Ilorsepower Max Design:3,550 Site: 3,550 12. Heat Rate: 6,760 BTU/I IP-hr 13. Operating Temp: Min. Max. 14. Fuels: Primary Fuel Backup Fuel#1 Fuel Type: Natural Gas I tearing Value HTIJ/SCF 1,136.3 Sulfur Content (Wt.%) Neg. Ash Content, (Wt.%) Neg. Moisture Content (%) Maximum Hourly Consumption(Ft3,gal) 21,119.4 set/hr Maximum Yearly Consumption(Ft',gal) 185.01 MMscf/yr . NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15.Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify,the method of compliance demonstration by completing Form 2000-500,***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this IJnit. ***** 10 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public I Ieatth and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SII)1'. 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: P003 3a, Construction Permit Number:97WE0553 4. Exhausting Unit(s).use Unit identification code from appropriate Founts)2000-300. 301,302,303,304,305,306, 307 2000-300 2000-301 2000-302 C-238 2000-303 2000-304 2000-305 200(1-306 2000-307 �. Stack identified on the plot plan required on Form 2000-101 ® Engine Location Identified 6. Indicate by checking: ® This stack has an actual exhaust point.l he parameters are entered in Items 7-13. ❑ This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice((i1 1))exceeds 65 meters(Colorado Air Quality Reg 3.A.VI II.D)dtita entry is required for Item 7. 7. Discharge height above ground level: 52.5 (feet) 8. Inside dimensions at outlet(check one and complete): ® Circular 2.0 (feet) 0 Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 124 (FPS) 0 Calculated ❑ Stack Test 10. Exhaust gas temperature(normal): 858 (°F) 11. Does process modify ambient air moisture content? 0 Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ® Up O Down ❑ Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑ Yes ® No *****Complete the appropriate Air Permit Application Fonts(s) _2000-300,301,302,303, 304, ***** 305,306,or 307 for each Unit exhausting through this stack. INTERNAL COMBUSTION ENGINE OPERATION Operating Permit Application FORM 2000-302 Colorado Department of Public t lealth and Environment Rev 06-95 Air Pollution Control Division 'I':1•: INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2- Facility identification code:C() 123-0277 3. Stack identification code: P003 4. Engine(Unit)code: C-238 4a. Date first placed in service: 2/27/2008 bate last modified: 5. Engine use: natural gas compression 6 Engine Features: 2-Cycle 4-Cycle ® Spark-ignition ® I)iesel ❑ Standard rich burn ❑ Standard lean burn Air/fuel ratio controller 0 Turbocharger Low-N()x design 0 Other(Describe): 7 Emission controls: ❑ No ® Yes-Attach control device fonm Non-Selective catalytic reduction ❑ Three-tray catalyst ❑ Selective catalytic reduction ❑ Ammonia injected ❑ ()xidation catalyst ® Other: 8. Manufacturer: Caterpillar 9. Model No: G3612 SIN: BKE003S6 10. Max Fuel Design Rate: 24.00 mm13 fU/hr I I. I lorsepotyer Max Design: 3,550 Site:3,550 12. I feat Rate: 6,760 13TH/HP-hr 13. ()perating Temp: Mm. Max. 14. Fuels: Primary Fuel Backup Fuel #I Fuel Type: Natural Gas Heating Value IITU/SCF 1,136.3 Sulfur Content (Wt.%) Neg. Ash Content. (Wt.%) Neg. Moisture Content (%) Maximum I lourly Consumption(Ft3,gal) 21,119.9 scf/hr Maximum Yearly Consumption(Ft',gal) 185.01 MMsef/y r NO ll : Data entry below is NOT OPTIONAL,if parametric monitoring is used fur compliance demonstration 15.Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp. (EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify,the method of compliance demonstration by completing Font 2000-500, ***** DESCRIPTION()F MEltlODS USED FOR DETERMINING C()MPLIANCF. Attach Form 2000-500 to this fumy ***** Please complete the Air Pollution Control Permit Application Forms 21)00-600 and 2000-601 for this Unit. ***** 1 Operating Permit Application STACK IDENTIFICATION FORM 2000-200 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: P018 3a Construction Permit Number:97WE0553 4. Exhausting Unit(s),use Unit identification code from appropriate Form(s)2000-300,301,302,303,304, 305,306,307 2000-300 2000-301 2000-302 C-234 2000-303 2000-304 2000-305 2000-306 2000-307 5. Stack identified on the plot plan required on Form 2000-101 ® Engine Location Identified 6. Indicate by checking: ® This stack has an actual exhaust point.The parameters are entered in Items 7-13. O This stack serves to identify fugitive emissions. Skip items 7-13. Go to next form. ❑ When stack height Good Engineering Practice((iFP)exceeds 65 meters(Colorado Air Quality Reg 3.A.V1ll.D)data entry is required for Item 7. 7. Discharge height above ground level: 52.5 (feet) 8. Inside dimensions at outlet(check one and complete): ® Circular 2.0 (feet) O Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum (ACFM) Velocity 124 (FPS) ❑ Calculated O Stack Test 10. Exhaust gas temperature(normal): 858 (°F) 11. Does process modify ambient air moisture content? O Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ® Up O Down O Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑ Yes ® No *****Complete the appropriate Air Permit Application Forms(s)2000-300,301,302,303,304, ***** 305,306,or 307 for each Unit exhausting through this stack. • 13 INTERNAL COMBUSTION ENGINE OPERATION Operating Permit Application FORM 2000-302 Colorado Department of Public Health and Environment Rev 06-95 Air Pollution Control Division '.EE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: P018 4. Engine(Unit)code: C-234 4a. Date first placed in service: 1994 Date last modified: 5. Engine use: natural gas compression 6. Engine Features: 2-Cycle I7 4-Cycle ® Spark-ignition ® Diesel ❑ Standard rich burn ❑ Standard lean burn Air/fuel ratio controller ❑ "turbocharger Low-NOx design ❑ ()ther(Describe): 7. Emission controls: ❑ No ® Yes-Attach control device form Non-Selective catalytic reduction O Three-way catalyst O Selective catalytic reduction O Ammonia injected O Oxidation catalyst ® Other: 8. Manufacturer: Caterpillar 9. Model No: G3612 S/N: 1YG00029 10. Max Fuel Design Rate: 24.00 nunJ3"111/lir 11. Horsepower Max Design:3,550 Site: 3,550 12. Heat Rate: 6,760 RTU/tIP-hr 13. Operating Temp: Min. Max. 14. Fuels: Primary Fuel Backup Fuel 41 Fuel Type: Natural Gas Heating Value BTU/SCE 1,136 Sulfur Content (Wt.%) Neg. • Ash Content, (Wt.%) Neg. Moisture Content (%) Maximum Hourly Consumption(Ft3,gal) 21,119 scf/hr Maximum Yearly Consumption(Ft3,gal) 185.0 MMscf/yr NOTE: Data entry below is NOT OPTIONAL if parametric monitoring is used for compliance demonstration 15.Operational Parameters Low High REMARKS Ignition Timing(degrees) Speed(RPM) Intake Air Temp.(EF) Air and Fuel Manifold Pressure Exhaust Temperature(EF) Exhaust Oxygen(%) Waste Gate Position Fuel Regulator Setting ***** Identify,the method of compliance demonstration by completing Form 2000-500,***** DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE. Attach Form 2000-500 to this form. ***** Please complete the Air Pollution Control Permit Application Forms 2000-600 and 2000-601 for this a nit. ***** 14 ()perainu Permit:Applieation STACK IDENTIFICATION FORM 2000-200 Colorado 1)e irtment of Public Health and h:ncironment P� Rev 06.95 .fir Pollution Control Division SIT INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: D2 3a. Construction Permit Number:97WE0553 4.1xhausting Unit(s),use Unit identification code from appropriate Form(s)2000-300,301, 302,303,304,305,306,307 2000-300 2000-301 2000-302 2000-303 2000-304 2000-305 2000-306_ 2000-307 D2 5. Stack identified on the plot plan required on Form 2000-I01 • 6. Indicate by checking: ® This stack has an actual exhaust point.The parameters arc entered in Items 7-13. ❑ This stack serves to identity fugitive emissions_ Skip items 7-13. Go to next form. ❑ When stack height(food Engineering Practice(GEP)exceeds 65 meters(Colorado Air Quality Reg 3.A.VIILD)data entry is required for Item 7. 7. Discharge height above ground level: 25 (feet) 8. Inside dimensions at outlet(check one and complete): Circular 3.0 (feet) ❑ Rectangular length(feet) width(feet) 9. Exhaust flow rate: Normal (ACFM) Maximum Velocity (FPS) Calculated (ACFM) ❑ ❑ Stack Test 10. Exhaust gas temperature(normal): _ (°F) 11. Does process modify ambient air moisture content? ❑ Yes ® No If"Yes",exhaust gas moisture content: Normal percent Maximum percent 12. Exhaust gas discharge direction: ® Up ❑ Down• ❑ Horizontal 13. Is this stack equipped with a rainhat or any obstruction to the free flow of the exhaust gases from the stack? ❑ Yes ® No *****Complete the appropriate Air Permit Application Forms(s)2000-300, 301,302,303,304, ***** 305,306,or 307 for each Unit exhausting through this stack. 1.5 Operating Permit Application GLYCOL DEHYDRATION UNIT FORM 2000-307 Colorado Department of l'ublic Health and Environment Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name Enterprise Compressor Station 2 Facility identification code:CO 123-0277 3. Stack identification code: D2 4- Dehydrator 01111 )code: D2 5. Unit description: Natural gas dehydration system using triethylene glycol(TEG)for water removal. Includes VRU for capturing flash tank emissions and a condenser for still sent emissions,Which are controlled by an enclosed combustor.The VRU has an annual downtime of 5%for maintenance and malfunctions.The enclosed combustor has an annual downtime of 3%for maintenance and malfunctions.VRU downtime emissions are routed to the enclosed combustor,and combustor downtime emissions are uncontrolled,and released to atmosphere. 6. Indicate the dehydrator control technology status. ❑ Uncontrolled ® Controlled If the dehydrator is controlled,enter the control device number(s)front the appropriate forms: 2000-400 COMB-1 2000-4(13 7. Manufacturer: Forum 9. Regenerator heater 1.55 design rate or maximum continuous rating (nu)t13T11/hr): 3. Model&serial number: Custom I(1. Date first placed in service: 1/I 1/2001 Date of last modification: 11. Flash Tank: ® Yes ❑ No Flash tank vented to: ❑ atmosphere ® process or control device(flare) 12. Glycol Circulation rate:35.0 gallons per minute OR gallon per pound of Ii:() 13. Pipeline Capacity: (mmscf/day): 110.0 14. Glycol Type: ® Triethylene Glycol ❑ Ethylene(ilycol ❑ Other(specifi) 15. Glycol Make-up Rate(gallons/year): 16. Computer model input&output printout attached Ei 17. Gas Pressure(psi): 950 psig IS. Gas Temperature(°F): 120 19. Gas composition test results V()C 13TEX I IFXANE 'lest date: value units value units value units Pre-Dehy Inlet: 3/18/2011 10.02 Mol% 0.05 Mol% 0.11 Mol% *****For this emissions unit,identify the method of compliance demonstration by completing Form 2000-500, ***** DFSCRIPTI()N OF MI;'1 I IODS IJSED FOR DETERMINING C()MPLIANCE. Attach Form 2000-500 and its attachment(s)to this form. ***** Please complete the Air Pollution Control Permit Application Fonts 2000-000 and 2000-601 for this Unit. ***** NOTE: THE SPECIALIZED APEN FOR A GLYCOL DEHYDRATION UNIT MUST BE COMPLETED AND SUBMITTED IF THE STILL VENT EMISSIONS HAVE NOT BEEN REPORTED BEFORE 1r Operating Permit.Application CONTROL EQUIPMENT-MISCELLANEOUS FORM 2000-400 Colorado Department of Public I teallh and Environment Re%06-95 :Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE I • Facility name Enterprise Compressor Station 2. Facility identification code:C() 123-0277 Stack identification code: D2 4 Unit identification code D2 �. Control device code: COMB-1 6. Manufacturer and model number: GEED L30-0018-00 7. Date placed in service: 4/11/2016 I)ate of last modification: Describe the device being used. Attach a diagram of the system. VRU(closed loop)to control flash tank emissions.This control device has an annual uptime of 95%,with the enclosed combustor COMB-1 acting as a hack-up control device for the remaining 5% Enclosed Combustor COMB-1 with included condenser,to control still vent(control efficiency shown below for this device).This control device has an annual uptime of 97%,with uncontrolled emissions during any periods of downtime. 9_ List the pollutants to be controlled by this equipment and the expected control efficiency for each pollutant on the table below. Documentation attached EITHER the outlet pollutant concentration OR the control efficiency must be provided. Pollutant Inlet pollutant Emission capture Outlet pollutant Control Efficiency(%) concentration efficiency(%) concentration gr/acf ppmv grind' ppmv Volatile Organic 95% Compounds Benzene 95% Toluene 95% Xylene 95% n-Hexane 95% 10. Discuss how the collected material will be handled for reuse or disposal. 1 I. Prepare a malfunction prevention and abatement plan for this pollution control system.The plan does not have to be submitted with the application. It is suggested the plan include,but not be limited to the following: a. Identification of the individual(s),by title,responsible for inspecting,maintaining and repairing this device. b. Operation variables such as temperature that will be monitored in order to detect a malfunction or breakthrough,the correct operating range of these variables,and a detailed description of monitoring or surveillance procedures that will be used to show compliance. c. What type of monitoring equipment will be provided(temperature sensors,pressure sensors,CEMs). d. An inspection schedule and items or conditions that will he inspected. f. Where is this plan available for review? 7 Operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public I Icatth and I?ncironment DESCRIPTION OF METHODS USED Rey oG-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance with all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring,recordkeeping,and reporting requirements and test methods. In addition,the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually,and may need to be more frequent it'specified by the underly ing applicable requirement or by the Division. SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: D2 4. [Init.identification code: D2 5. For this Unit the following methods)tier determining compliance with the requirements of the permit will be used(check all that apply and attach the appropriate form(s)to this form). ❑ Continuous Emission Monitoring(CEM)-Fonn 2000-501 ['Ullmann s): ❑ Periodic Emission Monitoring Using Portable Monitors-Form 2000-502 Pollutant(s): ® Monitoring.Control System Parameters or Operating Parameters of a Process-Form 2000-503 Pollutant(s): Volatile Organic Compounds,Hazardous Air Pollutants(HAPs) ❑ Monitoring Maintenance Procedures-Form 20(10-5.04 Pollutant)s): ❑ Stack Testing-Form 2000-505 Pollutant(s): ❑ Fuel Sampling and Analysis(ESA)-Form 2000-506 Pollutant(s): ® Recordkeeping-Form 2000-507 Pollutant(s): Volatile Organic Compounds,Hazardous Air Pollutants(HAPs) ❑ ()(her(please describe)-Form 2000-50$ Pollutant(s): 6. Compliance certification reports will be submitted to the I)iyision according to the ing schedule: Start date: February 1st,2017 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: August 1st,2017 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. Operating Pcrmil Application COMPLIANCE DEMONSTRATION BY FORM 2000-503 Colorado Department of Public I lea lth and Environment MONITORING CONTROL SYSTEM PARAMETERS OR Rev 06-95 .\ir Pollution Control Division OPERATING PARAMETERS OF A PROCESS The monitoring of a control system parameter or a process may be acceptable as a compliance demonstration method provided that a correlation between the parameter value and the emission rate of a particular pollutant is established in the form of a curve of emission rate versus parameter values. Ideally stack test data that bracket the emission limit.if possible,could be used to define the emission curve. This correlation shall constitute the certification of the sv stem. ft should be attached for Division approx al. It'it is not attached,please submit it within 6))days of the startup of the system. SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Enterprise Compressor Station 2 Facility identification code:CO I 23-0277 3. Stack identification code:D2 4. Unit identification code: D2 5. Pollu4mt(s)being monitored: VOCs and HAPs 6. Name of manufacturer: 7. Model number: S. Is this an existing system'? ® Yes Li No 9 Reserved for future use 10. Describe the method of monitoring:, 1) Continuously monitor condenser outlet temperature with a thermocouple 2) Automatically or manually record temperatures on a daily basis.A minimum of 4 readings will he taken each day, at approximately 6 hour internals. 3) A daily average outlet temperature will be calculated from the above readings on a daily basis. 4) Keep records of actual lean glycol pumping rate 1 I. Backup system: 12. Quality Assurance/Quality Control: Any monitoring system used with the record keeping shall be subject to appropriate performance specifications,calibration requirements and quality assurance procedures. A quality assurance/quality control plan for the monitoring system is attached for Division revie�y- The plan is not attached_but will be submitted to the Division by 13. The applicant shall propose an appropriate averaging period. (i.e.a particular number of continuous hours)for the purpose of defining excess emissions. The Iivision may approve the proposed averaging period,or other period which the Division determines to be appropriate. Provide the proposed averaging periods)below. Parameter Averaging Period Operating Permit_Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Puhlie Health and Environment BY RECORDKEEPING Rev 06-95 Air Pollution Control Division Recordkeeping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter values. This correlation may constitute the certification of the system_ For an existing program,the correlation demonstration must be attached for Division consideration for approval. If the correlation information has not yet been developed,please submit it within 60 days of the startup of the systern. SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: D2 4. Unit identification code: D2 5. Pollutant(s)being monitored: VOCs and HAPs 6. Material or parameter being monitored and recorded: Gas processed,glycol circulation rate,control device downtime,extended gas analysis 7. Method of monitoring and recording(see infommation on hack of this page): Information will he obtained to use in conjunction with the GLYCale Model to estimate emissions from the Triethyiene Glycol Dehydration Unit.The information recorded and maintained will include an extended gas analysis of the natural gas delivered to the glycol dehydration unit,the natural gas throughput recorded on the first day of each month,the triethylene glycol circulation rate,inlet gas pressure,and inlet gas temperature. In addition to the above,downtime for the VRU and Enclosed Combustor COMB-1 will be tracked and recorded on a monthly basis.This will be used in conjunction with the information above to calculate rolling 12-month emissions for D2, and the hours of downtime will be compared monthly to the permitted annual limit. S. List any EPA methods used: NA • 9 Is this an existing method of demonstrating 10. Start date: May 1999 compliance? ® Yes ❑ No 11 Backup system: NA 12 a. Data collection frequency: D Daily ❑ Weekly ® Monthly ❑ Batch(not to exceed monthly) ❑ Other-specify: 12 b. Compliance shall be demonstrated: ❑ Daily ❑ Weekly ❑ Monthly ❑ 13atch(not to exceed monthly) ® Other— 12-month rolling 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate perfontiance specifications,calibration requirements,and quality assurance procedures. ❑ A quality assurance/quality control plan for the recordkeeping system is attached for I)iyision review. ❑ The plan is not attached,but vyill be submitted to the Division by DCP currently conducts recordkeeping associated with this facility. DCP uses an internal data base to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. DCP currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control Division as required.The format for these submittals can be found in the previous submittals from DCP. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or may cause an emission limit to be exceeded. ***** Malfunctions shall be reported to the Division the next business day Ilazardous air releases shall be reported to the Division immediately. ,,n Operating Permit Application EMISSION UNIT HAZARDOUS AIR POLLUTANTS FORM 2000-600 Colorado Department of Public I lealth and Incironment Re%06.95 Air Pollution Control Division SEE INSTRUCTIONS ON RFV1:RSF SIDE I. Facility name: Enterprise Compressor Station _' Facility identification code: CO 123-0277 3. Stack identification code:D2 4_ Unit identification code: D2 5. Unit material description:TEG Dehydration System 6. Complete the following summary of hazardous air emissions from this unit. Attach all calculations and emission('actor references. Attached El Pollutant CAS Common or Generic Actual emissions Allowable OR Potential to emit Pollutant Name Quantity Measurement Quantity Measurement Units Units 71-43-2 Benzene 7.73 TPY 108-88-3 Toluene 7.16 TPY 100-41-4 Ethylbenzene 0.11 TPY 1330-20-7 Xylene 1.28 TPY 110-54-3 n-Hexane 0.81 TPY NOTE: If there is a permit for this unit, the permit limits are the same as the potential to emit. Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code:D2 4. Unit identification code: D2 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached IZ Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides Volatile organic 1.66 7 33.27 compounds Carbon monoxide Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units (U)should be entered as follows: 1 =lb/hr 2=Ib/mmBTU 3=grains/dscf 4=lb/gallon 5=ppmdv 6=gram/HP-hour 7=lb/mmscf 8=other(specify) 9=other(specify) 10=other(specify) Operating Permit:application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public I lcalth and Environment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SII)1 .1 Facility name: Enterprise Compressor Station 2 Facility identification code CO 123-0277 3. Stack identification code: D2 4. Unit identification code: D2 Only includes permit limitations and compliance methods that have changed since the renewal of Title V Operating Permit 95OPWE103 on August 2,2012. 5_ Pollutant 6.Colorado Air Quality 7 R. Limitation 9.Compliance Regulations State Status or (lnh IN OUT Construction Permit Number VOC 33.27 TPY X Individual: 8.0 TPY HAPs X Total: 20 TPY 10.Other requirements(e.g.,malfunction reporting,special operating conditions from an existing State()nl}- Compliance permit such as material usage,hours of operation.etc_) Status IN OUT Requested-The owner or operator shall monitor and record VRU downtime.VRU downtime shall be defined as times when the flash tank gas is routed to the enclosed combustor.The total hours of downtime and volume of gas processed during VRU downtime shall be recorded X on a monthly basis and used to calculate actual emissions to demonstrate compliance with the emissions limits contained in this permit. Revised Condition 3.1.1—VOC and HAP emissions shall be calculated monthly using the Gas Research Institute's CLYCakc Model,Version 4.0 or higher,in addition to records of the time and duration of VRU downtime. The following parameters to be entered into the GLYCale Model shall be monitored weekly:condenser outlet temperature,flash tank temperature and pressure,and inlet(wet)gas pressure and temperature. The following parameters to be X entered into the GLYCale Model shall be monitored daily: triethylene glycol circulation rate,. The condenser outlet temperature recorded shall be the highest temperature reading recorded on the strip chart for any calendar day(midnight to midnight). Values of parameters shall be representative of the unit's operation during the month. Revised Condition 3.1.2- Flash gas emissions shall be vented back into the process at all times, resulting in zero emissions from the flash tank during Vapor Recover Unit(VRU)operation. A maximum period of 438 hours(5%annual downtime)is reserved for malfunctions and X maintenance on the VRU.All flash gas emissions will be routed to enclosed combustor COMB-I during periods of VRU downtime. *Unit has not yet operated for twelve months following modification. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise 2. Facility identification code: CO 123-0277 Compressor Station 3. Stack identification code: D2 4. Unit identification code: D2 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. • We will continue to operate and maintain this Unit in compliance with all applicable requirements. • Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. ❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Deadline Actions 1. 2.• • • 3. Progress reports will be submitted: Start date: and every six(6) months thereafter Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. 'phis form supplements Form 2000- 604 for Emission I!nit(e.g. 13001,P00I,etc.) D2 Permit I.mutation Compliance Methods Revised-VOC Emissions Limitation Records and calculations in DCP compliance database,Monthly GlyCale runs, Initial extended wet gas analysis(EGA),Annual EGA HAP limitations(unchanged) Records and calculations in DCP compliance database,Monthly GlyCalc runs,Initial extended wet gas analysis(EGA),Annual EGA Requested-The owner or operator shall monitor and record VRU Records and calculations in DCP compliance downtime.VRU downtime shall be defined as times when the flash tank database gas is routed to the enclosed combustor.The total hours of downtime and volume of gas processed during VRU downtime shall be recorded on a • monthly basis and used to calculate actual emissions to demonstrate compliance with the emissions limits contained in this permit. Revised Condition 3.1.1—VOC and HAP emissions shall be calculated Records and calculations in DCP compliance monthly using the Gas Research Institute's GLYCalc Model,Version 4.0 database or higher,in addition to records of the time and duration of VRU downtime. The following parameters to be entered into the GLYCalc Model shall be monitored weekly: condenser outlet temperature,flash tank temperature and pressure,and inlet(wet)gas pressure and temperature. Monitoring of tThe following parameters to be entered into the GLYCalc Model shall be monitored daily:triethylene glycol circulation rate,. The condenser outlet temperature recorded shall be the highest temperature reading recorded on the strip chart for any calendar day(midnight to midnight). Values of parameters shall be representative of the unit's operation during the month. Revised Condition 3.1.2-Flash gas emissions shall be vented back into the Plant design specifications, recordkceping process at all times,resulting in zero emissions from the flash tank(luring Vapor Recover Unit(VRU)operation.A maximum period of 438 hours (5%annual downtime)is reserved for malfunctions and maintenance on the VRU.All flash gas emissions will be routed to enclosed combustor COMB-1 during periods of VRU downtime. Records of the times and duration of all periods of VRU and enclosed combustor downtime(see Condition 7.5),and estimated emissions shall be maintained and made available to the Division upon request. operating Permit Application COMPLIANCE CERTIFICATION-MONITORING AND REPORTING FORM 2000-500 Colorado Department of Public Health and Environment DESCRIPTION OF METHODS USED Rev 06-95 Air Pollution Control Division FOR DETERMINING COMPLIANCE All applicants are required to certify compliance w ith all applicable air pollution permit requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring,recordkeeping,and reporting requirements and test methods. In addition,the application must include a schedule for compliance certification submittals during the permit term. These submittals must be no less frequent than annually,and may need to be more frequent if specified by the underlying applicable requirement or by the Division. Si;i INSTRUCTIONS ON REVERSE SIDE 2 Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: D2 4. Unit identification code: COMB-1 5. For this I(nit the following method(s)for determining compliance with the requirements of the permit tic ill be used(check all that apply and attach the appropriate form(s)to this Conn). ❑ Continuous Emission Monitoring(CFM)-Form 2000-501 Pollutant(s): ❑ Periodic Emission Monitoring )sing Portable Monitors- Form 2000-502 Pollutant(s): ® Monitoring Control System Parameters or Operating Parameters of a Process-Form 2000-5(13 Pollutant(s): Pilot Flame Monitoring ❑ Monitoring Maintenance Procedures-Form 2000-504 Pollutant(s): Stack Testing- Form 2000-505 Pollutant(s). ❑ Fuel Sampling and Analysis(FSA)-Form 2000-506 Pollutant(s): ® Recordkeeping-Form 2000-507 Pollutant(s): Nitrogen Oxide,Carbon Monoxide ® ()Cher(please describe)-Font)2000-5(18 Pollutant(s): Opacity 6. Compliance certification reports will be submitted to the Division according to the following schedule: Start date: February 1st,2017 and every 12 months thereafter. (12 month maximum interval) Compliance monitoring reports will be submitted to the Division according to the follow ing schedule: Start date:August 1st,2017 and every 6 months thereafter. (6 month maximum interval) NOTE: EACH APPLICABLE REQUIREMENT ON FORM 2000-604 NEEDS TO BE SPECIFICALLY ADDRESSED IN ITEM 5. 2F Operating Permit Application COMPLIANCE DEMONSTRATION BY FORM 2000-503 Colorado Department of Public Health and Environment MONITORING CONTROL SYSTEM PARAMETERS OR Res 06-05 Air Pollution Control Division OPERATING PARAMETERS OF A PROCESS The monitoring of a control system parameter or a process may be acceptable as a compliance demonstration method provided that a correlation between the parameter Value and the emission rate of a particular pollutant is established in the form of a curve of emission rate versus parameter values. Ideally stack test data that bracket the emission limit,if possible,could be used to define the emission curve. This correlation shall constitute the certification of the system- It should be attached for Division approval. If it is not attached,please submit it l%ithut 60 days of the startup of the system. SET, INSTRIJCT1( NS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station Z. Facility identification code:CO 123-0277 3. Stack identification code:D2 i. Unit identification code: COMB-1 S. Pollutant(s)being monitored: NON and CO 6. Name of manufacturer: LEED 7. Model number: L30-0018-00 8. Is this an existing system? ® Yes I No 9. Reserved for future use 10. Describe the method of monitoring: 1) Maintain manufacturer specification sheet on file with a destruction efficiency guarantee of 98% 2) Pilot flame monitored with thermocouple,or equivalent des ice,equipped with alarm to indicate no ignition. Keep records of times and durations of pilot flame outages,and estimate emissions. I I. 13ackup system: 12. Quality Assurance/Quality Control: Any monitoring system used with the record keeping shall be subject to appropriate performance specifications,calibration requirements and quality assurance procedures. A quality assurance/quality control plant for the monitoring system is attached for Division review. The plan is not attached,but will be submitted to the Division by 13. The applicant shall propose an appropriate averaging period,(i.e a particular number of continuous hours)for the purpose of defining excess emissions. The Division may approve the proposed averaging period,or other period which the Division determines to be appropriate. Provide the proposed averaging period(s)below. Parameter Averaging Period 21 operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-507 Colorado Department of Public Health and Environment BY RECORDKEEPING Rev 06-95 .Air Pollution Control I)i5 ision Recordkccping may be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the emission rate of a particular pollutant is established in the form of a curve or chart of emission rate versus parameter alues_ This correlation may constitute the certification of the system. For an existing program,the correlation demonstration must be attached for Division consideration for approval_ If the correlation information has not yet been developed,please submit it within (1)day s of the startup ot'the system. SEE INSTRUCTIONS ON REVERSE SIDE l_ Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code:D2 4. Unit identification code: COMB-1 5. Pollutant(s)being monitored: NO.,CO 6. Material or parameter being monitored and recorded: Fuel Used,control device downtime 7. Method of monitoring and recording(see information on back of this page): A fuel meter w ill be used to track fuel use in the enclosed combustor. Fuel meter data will be used to calculate NOx and CO emissions,along with the permitted emission factors,and waste gas parameters taken from monthly D2 GLYcalc runs. DCP will track and record downtime for enclosed combustor COMB-1 on a monthly basis,and use that information in conjunction with the above to calculate estimated emissions of NOx and CO. 8. List any El'A methods used: 9. Is this an existing method of demonstrating 10. Start date: 4/11/2016 compliance'? ® Yes ❑ No I I. Backup system: NA 12 a. I)ata collection frequency ❑ Dail} ❑ Weekly ® Monthly ❑ Batch(not to exceed monthly) ❑ Other-specify 12 b. Compliance shall be demonstrated: ❑ Dail} ❑ Weekly ❑ Monthly ❑ Batch(not to exceed monthly) VI Other— I 2-month rolling 13. Quality Control/Quality Assurance: The monitoring system shall be subject to appropriate performance specifications,calibration requirements,and quality assurance procedures ❑ A quality assurance/quality control plan for the recordkeeping,system is attached for Division review. ❑ The plan is not attached,but vg ill be submitted to the Division by DCP currently conducts recordkeeping associated with this facility. DCP uses an internal data base to ensure the recordkeeping is being conducted on the proper frequency and that the correct information is being gathered. 14. ❑ A proposed format for the compliance certification report and excess emission report is attached. DCP currently submits compliance certification reports and excess emission reports to the Colorado Air Pollution Control Dis ision as required.The format for these submittals can be found in the previous submittals from DCP. ***** The compliance records shall be available for Division inspection. ***** The source shall record any malfunction that causes or ma\ cause an emission limit to he exceeded. ***** Malfunctions shall be reported to the Division the next business day. Ilarardous air releases shall be reported to the Division immediately. 28 Operating Permit Application COMPLIANCE DEMONSTRATION FORM 2000-508 Colorado Department of Public Health and Environment BY OTHER METHODS Rev 06-95 .-Air Pollution Control Division 1. Facility Name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. Stack identification code: D2 4. Unit Identification code: COMB-I 5. Pollutant(s)or Parameter(s)being monitored: Opacity of effluent 6. Description of the method of monitoring: Method 22 with an observation period of 1 minute will be used to monitor opacity from enclosed combustor 7.Compliance shall be demonstrated:(Specify the frequency with ssInch compliance will be demonstrated) Opacity—Daily Method 22 observations 2.9 Operating Permit Application EMISSION UNIT CRITERIA AIR POLLUTANTS FORM 2000-601 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: D2 4. Unit identification code: COMB-1 5. Complete the following emissions summary for the following pollutants. Attach all calculations and emission factor references. Attached El Air pollutant Actual Potential to emit Maximum allowable Quantity U TPY Quantity U TPY Quantity U TPY Particulates (TSP) PM-10 Nitrogen oxides 0.068 2 0.64 Volatile organic compounds Carbon monoxide 0.37 2 3.49 Lead Sulfur dioxide Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric Acid Mist Fluorides Units(U)should be entered as follows: 1 =Ib/hr 2=Ib/mmBTU 3=grains/dscf 4=lb/gallon 5=ppmdv 6=gram/HP-hour 7=lb/mmscf 8=other(specify) 9=other(specify) 10=other(specify) 30 Operating Permit Application APPLICABLE REQUIREMENTS AND FORM 2000-604 Colorado Department of Public Health and t'ncironment STATUS OF EMISSION UNIT Rev 06-95 Air Pollution Control Di%ision SEE INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Stack identification code: D2 4. Unit identification code: COMB-1 Only includes permit limitations and compliance methods that have changed since the renewal of Title V Operating Permit 95OPWE103 on August 2,2012. S. Pollutant 6.Colorado Air Quality 7. R. I:imitation 9.Compliance Regulations State Status or ()nh IN O1JT Construction Permit Number NOx 0.64 TPY X CO 3.49 TPY X I0.Other requirements(e.g.,malfunction reporting,special operating conditions from an existing permit State Compliance such as material usage,hours of operation,etc.) Only Status IN O1.11 Requested-Annual Limit for gas routed to enclosed combustor— 10.96 MMscf/yr(Waste Gas+ X Fuel) Revised Condition 7.5-The enclosed combustor shall be operated at all times when emissions are routed to it,except for a maximum annual downtime period of 263 hours(3%annual downtime) for malfunctions and maintenance. The enclosed combustor shall be operated with a pilot flame present at all times,except for these periods of downtime.The presence of an enclosed combustor X pilot flame shall be monitored using a thermocouple or any other equisalent device to detect the presence of a flame.The device shall be equipped with an alarm to indicate no ignition of the pilot flame.Records of the times and duration of all periods of pilot flame outages,and estimated emissions shall be maintained and made available to the Division upon request. Requested-Records of the times and duration of all periods of enclosed combustor downtime,and estimated emissions shall be maintained and made available to the Division upon request. Unit has not yet operated for ell months following modification. **** USE FORM 2000-700 TO EXPLAIN HOW COMPLIANCE WAS DETERMINED FOR EACH APPLICABLE REQUIREMENT**** 31 Operating Permit Application EMISSION UNIT COMPLIANCE PLAN FORM 2000-606 Colorado Department of Public Health and Environment COMMITMENTS AND SCHEDULE 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise 2. Facility identification code: CO 123-0277 Compressor Station 3. Stack identification code: D2 4. Unit identification code: COMB-1 5. For Units that are presently in compliance with all applicable requirements, including any monitoring and compliance certification requirements of Colorado Air Quality Regulation 3, Part C that apply, complete the following. These commitments are part of the application for operating permits. We will continue to operate and maintain this Unit in compliance with all applicable requirements. Form 2000-604 includes new requirements that apply or will apply to this Unit during the term of the permit. We will meet such requirements on a timely basis. 6. For Units not presently fully in compliance, complete the following. ❑ This Unit is in compliance with all applicable requirements except for those indicated below. We will achieve compliance according to the following schedule(If more space is needed attach additional copies of Form 2000-700): Applicable Requirement Corrective Deadline Actions 1 2. 3. Progress reports will be submitted: Start date: and every six(6) months thereafter Operating Permit Application SUPPLEMENTAL INFORMATION FORM 2000-700 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SEE INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code:CO 123-0277 3. This Moroi supplements Form 2000- 604 for[mission Unit(e.g 13001.P001_etc} COMB-1 • Permit Limitation Compliance Methods Revised-NO\ Emission Limit Records and calculations in DCP compliance database, Initial extended wet gas analysis(EGA), Annual EGA Revised-CO Emission Limit Records and calculations in DCP compliance database, Initial extended net gas analysis(EGA), Annual EGA Requested-3%annual downtime limitation on COMB-1 operation,or Records in DCP compliance database 263 hours of annual downtime permitted. Requested-Annual Limit for gas routed to enclosed combustor— 10.96 Records and calculations in DCP compliance MMscf/s r(Waste Gas+Fuel) database Revised Condition 7.5-The enclosed combustor shall be operated at all Records and calculations in DCP compliance times when emissions are routed to it,except for a maximum annual database downtime period of 263 hours(3%annual downtime)for malfunctions and maintenance. The enclosed combustor shall be operated with a pilot flame present at all times,except for these periods of downtime.The presence of an enclosed combustor pilot flame shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame.The device shall be equipped with an alarm to indicate no ignition of the pilot flame.Records of the times and duration of all periods of pilot flame outages,and estimated emissions shall he maintained and made available to the Division upon request. Requested-Records of the times and duration of all periods of enclosed Records and calculations in DCP compliance combustor downtime,and estimated emissions shall be maintained and database made available to the Division upon request. 33 Operating Permit Application PLANT-WIDE HAZARDOUS AIR POLLUTANTS FORM 2000-602 Colorado Department of Public health and rn ironment Rev 06-95 Air Pollution Control Division SET? INSTRUCTIONS ON REVERSE SIDE I. Facility name: Enterprise Compressor Station 2 Facility identification code:CO 123-0277 3. Complete the following emissions summary for all hazardous air emissions at this facility. Calculations attached. Attach a copy of all calculations to this form. X Attached Pollutant CAS Common or Generic Actual emissions Allowable OR Potential to emit Pollutant Name Quantity Units Quantity Units 75-07-0 Acetaldehyde 2.4 TPY 107-02-8 Acrolcin 1.5 TPY 71-43-2 Benzene 9.0 TPY 50-00-0 Formaldehyde 15.2 TPY 67-56-1 Methanol 0.7 TPY 110-54-3 n-Hexane 0.9 TPY 108-88-3 Toluene 7.3 TPY 1330-20-7 Xv lenes 1.4 TPY 100-41-4 Ethylbenzene 0.1 TPY 540-84-1 2,2,4 Trimethv 1pentanc (l.0 TPY NOTE: If there is a permit for this unit,the permit limits are the same as the potential to emit. 3 4 7 Operating Permit Application PLANT-WIDE CRITERIA AIR POLLUTANTS FORM 2000-603 Colorado Department of Public Health and Environment 09-94 Air Pollution Control Division SF-1.: INSTRUCTIONS ON REVERSE SIDE 1. Facility name: Enterprise Compressor Station 2. Facility identification code: CO 123-0277 3. Complete the following emissions summary for the listed emissions at this facility. Air pollutant Actual Potential to Maximum allowable emit TPY TPY IVY Particulates(TSP) 5.8 5.8 PM-10 5.8 5.8 Nitrogen oxides 130.0 130.0 Volatile organic compounds 165.3 165.3 Carbon monoxide 151.0 151.0 Lead Sulfur dioxide 0.3 0.3 Total reduced sulfur Reduced sulfur compounds Hydrogen sulfide Sulfuric acid mist Fluorides 35 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division Facility Name: Enterprise Compressor Station Facility Identification Code:CO 123-0277 1. ADMINISTRATION This application contains the following forms: X Donn 2000-100,Facility Identification X Form 2000-101,Facility Plot Plan X Forms 2000-102,-102A,and-10213,Source and Site Descriptions IL EMISSIONS SOURCE Total Number DESCRIPTION of This Form This application contains the tollowing forms x Form 2000-200,Stack Identification 5 (one form for each ftcility boiler,printing L. Fonn 200(1-300,Boiler or Furnace Operation is Form 2000-301,Storage Tanks x Form 2000-302,Internal Combustion Engine 4 Form 2000-303,Incineration Form 2000-304,Printing Operations • Form 2000-305,Painting and Coating Operations X Form 2000-306,Miscellaneous Processes X Fonn 2000-307,Glycol Dehydration Unit 1 Ill. AIR POLLUTION CONTROL Total Number SYSTEM of This Form This application contains the following forms: X Form 2000-400,Miscellaneous 1 • Fonn 2000-401,Condensers • Form 2000-402,Adsorbcrs • Fonn 2000-403,Catalytic or Thermal Oxidation t Form 2000-404,Cyclones/Settling Chambers Form 2000-405,Electrostatic Precipitators Form 2000-406,Wet Collection Systems Fonn 2000-407,Baghouses/Fabric Filters IV. COMPLIANCE Total Number DEMONSTRATION of This Form This application contains the following Firms X Form 2000-500,Compliance Certification-Monitoring and 2 (one for each facility boiler,printing operation, Reporting Form 2000-501,Continuous Emission Monitoring Form 2000-502,Periodic Emission Monitoring Using Portable Monitors X Form 2000-503,Control System Parameters or Clpetation 2 Paramrters of a Process Form 2000-504,Monitoring Maintenance Procedures Form 2000-505,Stack Testing Form 2000-506,Fuel Sampling and Analysis X Form 2000-507,Recordkeeping 2 X Form 200)-508,Other Methods 1 36 V. EMISSION SUMMARY AND Total Number COMPLIANCE CERTIFICATION of This Form Ibis application contains the following forms x Form 2000-600,Emission Unit Ilazardous Air Pollutants 1 quantifying emissions,certifying compliance with applicable requirements,and developing a compliance plan X Dim 20(0-6(11,Emission Unit Criteria Air Pollutants 2 x Form 2000-602,Facility I lazardous Air Pollutants 1 X Fonn 2000-603,Facility Criteria Air Pollutants 1 X Form 20IXY604,Applicable Requirements and Status of 2 Emission knit Form 2000-605,Pennit Shield Protection Identification X Form 2000-606,Emission Unit Compliance Plan- 2 Commitments and Schedule Form 2000-607,Plant-Wide Applicable Requirements Form 2000-608,Plant-'.Wide Compliance Plan- ('onunitnmcnts and Schedule VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS ' I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry,I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS-FEDERAL/STATE CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I I I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement, representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title William L.Johnson Vice President of Operations Sign'ture Date Signed tv )perating Pennit Application CERTIFICATION FOR STATE-ONLY CONDITIONS FORM 2000-800 'olorado Department of I lealth 09-94 Air Pollution Control Division 3I f Facility Name: Enterprise Compressor Station Facility Identification Code:CO 123-0277 VI. SIGNATURE OF RESPONSIBLE OFFICIAL-STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true,accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE-ONLY CONDITIONS(check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements,except for the following emissions unit(s): (list all non-complying units) WARNING: Any person who knowingly,as defined in§ 18-1-501(6),C.R.S.,makes any false material statement, representation,or certification in,or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of§25-7 122.1,C.R.S. Printed or Typed Name Title William L.Johnson Vice President of Operations Signa^u�e Date Signed 2-51 2.43t Le SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-BI 4300 CHERRY CREEK DRIVE SOUTH DENVER,CO 80246-1530 38 Appendix A Facility Plot Plan & Process Flow Diagram Enterprise Compressor Station Enterprise Compressor Station Process Flow Diagram DCP Midstream, LP 0 Combustor A 8—300bb1 Stabilized Condensate Tanks > Truck Loading A Condensate Gas Stabilizer Back-up V r >0 COMB-1 A A VRU < n West Pressurized Bullet) < Gas Return to Inlet c BTEX t° Condenser L Condensate Condensate m A LL Slug Catcher — / East Inlet Gas V Gas Pressurized Bullet Gas > Comlpression > Dehydration > Outlet Gas >I Slug Catcher i l __ Appendix B Current APENs Enterprise Compressor Station AIR POLLUTANT EMISSION NOTICE (APEN) &Application for Construction Permit— Reciprocating Internal Combustion Engine' 'You will be charge an additional APEN fee if APEN is filled out incorrectly or missing information and requires re-submittal. Permit N umber: 95OPWE104 [Leave blank unless APCD has already assigned a permit n&AIRS ID] Emission Source AIRS ID: 123/0277/055 Facility Equipment ID: C-235 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01—Administrative Information Section 02—Requested Action(check applicable request boxes) Company Name: DCI'Midstream,LP NAICS,or ❑ Request for NEW permit or newly reported emission source SIC Code: 4922 Source Name: Enterprise Compressor Station0 Request for coverage under GENERAL PERMIT number GP02(Natural Gas Only) Source Location: SW Section 30,T2N,R63W County: Weld ❑ Request MODIFICATION to existing permit(cheek each box below that applies) Elevation: 4,788 Feet O Change fuel or equipment O Change company name Portable Source O Change permit limit O Transfer of ownership ❑ Other Home Base: O Request PORTABLE source permit Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 N Request APEN Update Denver,CO Eta issions data must be completed.Blank,4PEA's will nrot be accepted Person To Dana Stephens Phone Number: 303-605-1745 Contact: E-mail Address: dstephens@dcpmidstream.com Fax Number: 303-605-1957 O Notification of AOS permanent replacement Addl. Info.& Section 03—General information Notes: For existing sources,operation began on: 1994 For new or reconstructed sources,the projected startup date is: / / Normal hours of source operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment purpose: Natural Gas Compression Date the engine was ordered: Before 2002 Date engine construction commenced: Before 2002 Date the engine was relocated into Colorado: 9/30/1994 Date of any Colorado Department of Public Health and Environment reconstructionimodification: NAAir Pollution Control Division(APCD) Will this equipment be operated in any NAAQS nonauainment area? Don't This notice is valid for five(5)years. Submit a revised APEN prior to hlt //www.ctl he.state.co.us1aplattainntaintain.html © Yes O No ❑ know expiration of five-year(Ityp://www.cdphe.state.co.usian/attainmaintain.laml)) p year term, or when a significant change is made (increase production,new equipment,change in fuel type,etc). Section 04—Engine Information Mail this form along with a check for $152.90 per APEN and Engine date of manufacture: 4/29/1994 Engine displacement: 21.2 Ucyl $1,500 for each general permit registration to: Manufacturer: Caterpillar Model: G3612 Serial No.: 1YG90047 Colorado Department of Public Health&Environment APCD-SS-B1 Engine function: O Primary and/or peaking power O Emergency back-up power 4300 Cherry Creek Drive South Denver,CO 80246-1530 ® Compression ❑ Pump jack O Water pump O Other: For guidance on how to complete this APEN form: Manufacturer's maximum rated horsepower @ sea level: 3,550 BHP @ 1,000 RPMAir Pollution Control Division: (303)692-3150 Small Business Assistance Program(SBAP): (303)692-3148 or Manufacturer's maximum site rating: 3,550 BHP @ 1,000 RPM _ kW (303)692-3175 Engine Brake Specific Fuel Consumption @ 100%Load: 6,760 Btu/HP-hr APEN forms:Intp://eolorado,gov/edpbe/APENforms Cycle Type: O 2-Stroke ® 4-Stroke Combustion: i❑c Lean Bunt O Rich Burn Application status:http://wWw.colorado.gov/edohe/pennitstatus Ignition Source: ® Spark O Compression Aspiration: O Natural ® Turbocharged O Check box to request copy of draft permit prior to issuance. What is the maximum number of hours this engine is used for emergency back—up power? Hours/year O Check box to request copy of draft permit prior to public notice. FORM APCD-201 I Page I of 10 I AIR POLLUTANT EMISSION NO'T'ICE .-OPEN & Application ' _ gi 1 ( ) for Construction Permit— (ZCCIpt'pCtltlllZ, It1tC1'tla! Combustion Engine' Permit Number: 95OPWE104 Emission Source AIRS ID: 123/0277/055 Section 05 Stack Information (Attach a separate sheet with reles ant inlotntutiou in the event or multiple stacks:provide datum�l'•.either l.at/Ltmg or UTivi) 4 ivai,,, » .-.�W,{.li.u. ssLid..Dueh.u,c _. ..— _ _ • - _ { i I lorvont:1i l)atum t l I\1 1;TM\1 Fasting or 1:r\I Northing or Method of(olleerion for 1°cation IIer;lhl;\I >se 1lamRale I Vduein \1oi.unc i (NAD_'7,NAUti1. Zone 1tn,itudc LaGtudc I)attle,e nryt,ltl'S, ' 51.,,1. I.loation cm t.t`I') tilniIIIII I ekel IA(•PMI - (Ii See) (°"1 I - II)Nn I fret) It ( 14(1S14) 112 or I.4) (meters or degrees) (meters or degrees) tnxuticliartlil eo Po05 I 4.788 52.5' 858 1 23.461 [ 124 .\\lli I \\'GS84 13 -104.4877 40.191 (:Ps 1)irccuuu oI .task ont let(cheek one): El vertical ❑ Vertical wiIIIlh.nueliIIr.miscall ❑ Hui ❑ Do,it ❑ Other(Describe). I,shad>1 Ot,enrtt(2 Shape` `we(check one): ❑ Circular: liner Diameter(Indies) 24 ❑ Other: Length(melt:)== Width(inches)-- Section 1)6— Fuel Consumption Information . Annual )-eel Consumption l alryr or\1\4SCI'yrl Sulfur Seasonal Fuel the Co oh Annual l:se) reel I_.e• 12:11ee I IX) „load Fuel I Ieaung Value 1 I eel I spe Actual kcponed tin' , Content (SC hr.gal/hr) Requested Permit Limit (t3tu lb.I3uugal• Btu/SCE) Dec-Feb Mar-\lad Jun-Aug Sep-Noy Calendar Year (',�sst.! Natural(.as I 21.119.99 S( 1,Iii ISI.I \1\IS('I Isr 1 185.(11 \l\lS( 1 st• I 1136.3 Btu/S('I•' I Neg. 25 25 I 2:s j 2:+ I I.tl'i,cl1LIl1e d,Illi Nd 1'.ail an Ali I;Icl ratio controller'.' (J 1'e. El \tt Section 117— !':missions Inventors information S Emission Control Information ElLitt .tin 1 actor Documentation tit relied Data serer for actual calendar tr.enussiuns helutt S[lid.list':Move(e.g.2111(7) 2)114 L-..- (4111101 Des Ice Description Coneol Emission Pacior Actual Calendar''ear limu;loII.' Requested Permitted �Estimation Victims' I-missions or I'lrlIutant , Cffichmey Print try Secondary t Reductions Uncontrolled Basis I Unit, l:naaurulled Controlled Uncontrolled Controlled t:nus;lon factor (Tons/Year) (1 onsYetirl (Tons%)'car) (Tons1l'•ear) I source 1 SI' 9.99f:-3 Ibill\1Rtu 0.85 0.85 1.05 1.05 \l'-42_ 11\4 9.99E-3 Ib/\l\IRtu 0.85 0.85 1.05 1.(15 \I'-4_2 I'M 9.99(:3 Ib/111\IRU( 0.85 0.85 1.05 1.05 ! \I'-12 ., (),, 5.88E-4 Ibr\t\IIno 81.1)5 0.05 0.06 0.06 \P--12 \O. .7 g/bhp-hr 19.4 19.4 24.11 24.(1 \ianuf. Spec. I 11-.. \O(' Os.(alalst 87 6.15 /bitp-hr 149.23 19.4 210.8 24.0 l \latiuf. Spec. ('I) Os.Catalsst 63 6.50 g/1)10)-hr 69.33 22.2 I 85.7 I 27.4 \ianul. Spec.de Ox.Catalsst I ),\�rl,:Idrlt�Je Os.('atal\st �(1 I 0.4 8.,61:-3 ( ^/bhp-lu- 1 L11) 2.22 ' 13.71 2.74 \1;1nu1 Spec. Ih/M,Attu 0.72 0.36 11.88 0.44 .\P-42_ v o,ei:r Os.(:ualsst 5{1 5.141:-3 Ili/NIN1litii 0.44 0.22 0.54 0.27 \P-42 Iiertienc i Us.Catalsst 50 4.40'E-4 Ib!\1\1Rtu I AR NR 0.05 0.02 Al4--l_2 ) Please 1 use the:1I'C n N'on- ' Criteria Reportable Air Pollutant :\ddcndum forts to report pollutants not listed:drove. ------ 10144%01 he charged an additional.\l'I:\Ice if.(Pt.\is filled out incorrectic or mussing information and requires re-submittal. .,\mur,d.na,-•o,.1 Ice,will he h,,ed,n1 actual emission.'(polled Here. II Iclt blank,annual cnti„iuu Irc,will he based on rcyuc.lcd cuu>.u,rl.. Section 08—\pplic:nit Certification- I herel certify that all information contained herein and inho•nla(ion submitted with this application is complete.true and correct. `- ,` '1\— 1/ err .) 1)ana Stephens Air Permitting Manager Signature of Person I.et,all\'-1\utho(ized to Supply Data I)ale Name of I el all}'Authorized Person I Please print) Tills Pane 2 of 1(1 NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 95OPWE103 AIRS ID Number: 123/0277/055 Company Name: DCP Midstream, LP Plant Location: Enterprise Compressor Station County: Weld Zip Code: Person to Contact: Dana Stephens Phone Number: (303) 605-1745 ................- E-mail Address: clstephensAdcpmidstream.com Fax Number: (303) 605-1957 I Chemical I i I I i l su�3ct Service I Chemical Name , Control Equipment/ ' Emission Factor Emission Factor I Uncontrolled Actual Controlled Actual (CAS) Number Reduction(°o) (Include Units) 1 Source Emissions (lbs/year) Emissions (Ibs/year) I 67-56-1 Methanol I Ox. Catalyst/ r 2.5E-3 50°% } Ib/MMBtu AP-42 425.7 i 212.9 3 i Calendar_Year for which Actual Data Applies: 2014 Signature of Person Legat y Authorized to Supply Data Date - Dana Stephens Air Permitting Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14, 2014 AIR - JLLUTANT EMISSION NOTICE(APEN)&Application for Construction Permit— Reciprocating internal Combustion Engine' 'You will be charged an additional APEN fee if APEX is filled out incorrectly or missing information and requires re-submittal. Permit Number: 95OPWE103 (Leave blank unless A1k'U has already assigned a permit a&AIRS 11)1 Emission Source AIRS ID: 123 / 0277 / 056 Facility Equipment ID: C-236 1Provide Facility Equipment ID to identity how this equipment is referenced within your organization.] Section 01 —Administrative Information Section 02—Requested Action (check applicable request boxes) Company Name: DCP Midstream,LP NAICS.or O Request for NEW permit or newly reported emission source Source Name: Enterprise Compressor Station SIC Code: 4922 ❑ Request for coverage under GENERAL PERMIT number GP02(Natural Gas Only) Source Location: SWSW Section 30,T3N,R63W County: Weld ❑ Request MODIFICATION to existing permit(check each box below that applies) Elevation: 4,788 Feet ❑ Change fuel or equipment ❑ Change company name Portable Source ❑ Change permit limit ❑ Transfer of ownership ❑ Other IIomc Rase: ❑ Request PORTABLE source permit Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 ❑ Request APEX Update Denver,Colorado Emissions data ntust be completed. Blank APE ..s will not be accepted Person To Contact: Roshini Shankaran Phone Number. 303-605-2039 E-mail Address: RShankaran@DCPMidstream.com Fax Number: 303-605-1957 © Notification of AOS permanent replacement Addl. Info. Section 03—General Information Notes: Replacement engine started on 06/26/2015 For existing sources,operation began on: 01 01 1993 For new or reconstructed sources,the projected startup date is: Normal hours of source operation: 24 hours/day 7 days/week 52 weeks/year - General description of equipment purpose: Natural gas Compression Date the engine was ordered: Before 1/93 Date engine construction commenced: Before 1/93 Date the engine was relocated into Colorado: 05/19/1993 Date of any reconstruction modification: N/A Colorado Deparhnent of Public Health and Environment Air Pollution Control Division(APCD) Will this equipment be operated in any NAAQS nonattainment area? Don't (li!th ,"" r„l,a:,du_, .,Il,hr❑J:unn!rn!) Yes ❑ No ❑ know notice is valid for live(5)years. Submit a revised APEN prior to expiration of tine-year term, or when a significant change is made Section 04—Ermine Information (increase production,new equipment,change in fuel type,etc). Engine date of manufacture: 01/27/1993 Engine displacement: 21.2 Lrevl Mail this form along with a check for S152.90 per APEX and Manufacturer Caterpillar Model: G-3612 Serial No.: 1YG00028 S1,500 for each general permit registration to: Colorado Department of Public Health&Environment Engine function: D Priman'and or peaking power ❑ Emergency'back-up power APCD-SS-131 din 4300 Cherry Creek Drive South c•26,,,, ❑Q Compression ❑ Pump jack ❑ Water pump ❑ Other: Denver,CO 80246-1530 <NS For guidance on how to complete this APEN form: Manufacturer's maximum rated horsepower ir'sea level: 3,550 1311P!a' 1,000 RPM Air Pollution Control Division: (303)692-3150 Manufacturer's maximum site ratinc: 3,550 BHP!a 1,000 RPM kW Small Business Assistance Program(SBAP): (303)692-3148 or Engine Brake Specific Fuel Consumption a. 10000 Load: 6,760 Btu:HP-hr (303)692-3175 Cycle Type: ❑ 2-Stroke ❑ 4-Stroke Combustion: Q Lean l3um ❑ Rich Bum ITT ,AI'! vG+nr!,APEN forms: IT?. R�s�v u,urzd,� Ignition Source: '❑ Spark ❑ Compression Aspiration: ❑ Natural ❑Q Turbocharged Application status: hair a ki.e,'0rad,,.c,,s cdhhe pernnt,i:tI ❑ Check box to request copy of draft permit prior to issuance. What is the maximum number of hours this engine is used for emergency back-up power? 0 liours:year ❑ Check box to request copy of draft permit prior to public notice. r 7 . FORM APCD-201 Page 1 of 2 Form APCD-201-RICEAPEN-Ver.02.i 0.2014.doex AIR POLL.,t '''ANT EtI ISSION NOTICE (APEN)& Application for Construction Permit— Reciprocating Internal Combustion Engine' Permit Number: 95OPWE103 Emission Source AIRS ID: 123 / 0277 / 056 section 11;—Stack Information IAttiell a separate shcet with rcicvant Infornunlion ul the event of multiple stacks:provide daunt<<.either Lai/Long or I)Tlvli stack Discharge Upccatar Stack Base t lurtn>nlal Datum t TNI I.-IM I:astinr.or LTNI Northing or Methos!of Collection for Location height:\hot e flow Ham \'cloeiii \loistore stact, I.10.ation 'fcnq,.{"F;r (\.\U..7-V,\D33. /one Longitude 'Attitude Data(e.g.map.CPS, II) ..:o fleet) (amnia Les 0 (1CF\I) (Etta) (ter) \\liSlI4) (12 or 13) (meters ordegrees (feet ) (meters or degree,) Googlol?:nth) P006 4,788 52 5 858 23,461 124 AMB WGS84 13 104.4877 40.191 GPS I)iicelinn nl stack outlet(died:one): ill Vertical ❑ Vertical icilli m,hsuueling raineap ❑ Iluriiontal ❑ t)ooit ❑ )ther(Describe I: I.\haust I Tema";Shape sl Sve(check one): [J Circular: Inner Diameter(inches) 24 ❑ Other:Length(inches) Width(inches) section alb— Fuel Consumption Information Annual lrud Consumption(eat"\r or MMSCF er) Sulfur Seasonal Fuel Use(°U of Annual Use) Fuel Llse Rate tr I(t(r'n load fuel I[eating Value I eel Type Aeual Rcportcd for Content rSCF hr.gal•ltrj Permit ermit Limit !!hull),Hmel.im l3nrSCE) Dec-Feb Mar-May Jun-Aug Sep-Nov Calendar Year fun wt.) Natural Gas 21.115 4 SCFthr 152.7 MMSCF/yr 185.01 MMSCF/yr 1,136.3 Btu1SCF Neg. 25 25 25 25 , Is this engine equipped\vth an Air Fuel ratno controller' ❑ Yes Q Nu section 117— Emissions (mentor\ Information& Emission Control Information r.❑ I omission I..eater MN- ualalion al lachrd mat„yea,'for actual ralrndar .cr.emissions below&fuel ace ohnie(4%a.20117): 1201,1 Control Device Description Cunhul Emission Factor Actual Calendar Year Emissions' Requested Permitted Estimation Method '[missions or I'ullulant I':Iliciene\ - - I'rimar\ Scamdar\ ("n Reduction) tlucontrolled Basis Units Uncontrolled Controlled Uncontrolled Controlled lnuttssion factor (Tons Year) (Tuns:Ycar) (Tens:Year) (fons'YcarI Source I SP 9 99E-03 Ib/MMBtu 0.86 0.86 1.05 1.05 AP-42 _ I'N1„ 9.99E-03 Ib/MMBtu 0.86 0.86 1.05 1.05 AP-42 I'\t- 9.99E-03 Ib/MMBtu 0.86 0.86 1.05 1.05 AP-42 Su, 5.88E.04 b/MMBtu 0.05 0.05 0.06 0.06 AP-42 Nit). 0.70 q/hp-hr 19.62 19.62 24.00 24.00 Manuf.Data VI>C Ox.Catalyst 89 6.15 q/hp-hr 172,56 19.62 210.82 24.00 Manuf.Data CI I Ox.Catalyst GS 2 50 grhp-hr 70.15 22.46 85.70 27.42 Manuf.Data 1,aln:ash: i. Ox.Catalyst 80 04 yu/hN-hr 11.23 2.25 13.71 2.74 Manuf.Data \staldchsde Ox.Ca:alvst 50 8.36E-03 Ib/MMBIu 0.72 0.36 0.88 0.44 AP-42 Acrnlcin Ox Catalyst 50 5,14E-03 lb/MN/1611f 0.44 0.22 0.54 0.27 AP-42 Bensons Ox Catalyst 50 4.40E-04 IbMMBtu NR NR 0.05 0.02 AP-42 Please use the.U'('I)Non-('riieria Reportable Air Pollutant Addendum foram to report pollutants riot listed above. -1 ou still be rtiar2ell au additional.5PEN ter I 5N.;'is tilled out incorrectly or missi,,information and requires re-submittal. \nnual c,nr.o,o tee.ss iii 6c hascd nil ncluxl emissions reported here. If let) dank.annual emission lees silt!be based on rc,prested cmistunts. Sul-lion 0 —Applicant Certification - I licreh\ certiti than all information contained herein and iulitrutation Submitted _VI_t�jtis application is complete. true:Intl et1ITCCt I I this IS a leht>uallon fear 4.: ,1 ,o‘ under general permit(iPtf2. 1 further certify that this source is and\N III IX!operated in lull compll'<'IIIl t I1 each condition of general pet'nul(iP1)_2. �;,t•-• .':,.Z' ''—'/-•-'/ �'/' /�_'� I . Roshini Shankaran (1/6" Environmental Engineer St malt ire of Person I.egally Authorized to Supply Data I)ate Name of Legally Authorized Person(Please print) 'Fide ''age 2 of 2 Form APCI)-_'01-RICH.API:N-Ver.u_'.II)_2OI4.docx NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 95OPWE103 AIRS ID Number: 123/0277/056 Company Name: DCP Midstream, LP Plant Location: Enterprise Compressor Station-SWSW Sec 30,T3N; R63W County: Weld Zip Code: - Person to Contact: Roshini Shankaran Phone Number: 303-605-2039 E-mail Address: RShankaran@DCPMidstream.com Fax Number: 303-605-1957 Chemical Abstract i Uncontrolled Controlled Actual Service (CAS) Chemical Name Control Equipment Emission Factor Emission Factor Actual Emissions Emissions / Reduction (%) (Include Units) i Source Number (lbs/year) (lbs/year) 67-56-1 Methanol 50% 2.50E-031b/MMBtu EPA 430 215 i ! i _i. Calendar Year for which Actual Data Applies: 2014 Signature of Person Legally Authorized to Supply Data i6 Date Roshini Shankaran Environmental Engineer Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14, 2014 - AIR POLLUTANT EMISSION NOTICE (APEN) &Application for Construction Permit—Reciprocating Internal Combustion Enginet You will be charge an additional APEN fee if APEN is filled out incorrectly or missing information and requires re-submittal. Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit ti&AIRS ID] Emission Source AIRS Ill: 123/0277/053 Facility Equipment ID: C-238 (Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01—Administrative Information Section 02—Requested Action(check applicable request boxes) Company Name: DCP Midstream,LP NAICS or , 4922 SIC Code: ❑ Request for NEW permit or newly reported emission source Source Name: Enterprise Compressor Station ❑ Request for coverage under GENERAL PERMIT number CP02(Natural Gas Only) Source Location: SW Section 30,T2N,R63W County: Weld ❑ Request MODIFICATION to existing permit(check each box below that applies) Elevation: 4,788 Feet ❑ Change fuel or equipment ❑ Change company name Portable Source ❑ Change pennit limit E Transfer of ownership O Other Home Base: O Request PORTABLE source permit Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 ❑ Request APEN Update Denver,CO Emissions data tuttst be cotup/eted. Blank APENS will not be accepted Person To Dana Stephens Phone Number: 303-605-1745 Contact: E-mail Address: dstephens@dcpmidstream.com Fax Number: 303-605-1957 O Notification of AOS permanent replacement Addl. Section 03—General Information Info.& Notes: For existing sources,operation began on: 2/27/2008 For new or reconstructed sources,the projected startup date is: / / Normal hours of source operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment purpose: Natural Gas Compression Date the engine was ordered: 2006 Date engine construction commenced: 2/27/2008 Date of any Colorado Department of Public Health and Environment Date the engine was relocated into Colorado: 2/27/2008 reconstruction/modification: NA Air Pollution Control Division(APCD) Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes O No ❑ Don't This notice is valid for five(5)years. Submit a revised APEN prior to (http://www.cdphc.state.co.us/ap/attainrnaintain.html) know expiration of five-year term, or when a significant change is made (increase production,new equipment,change in fuel type,etc). Section 04—Engine Information Mail this form along with a check for S152.90 per APEN and Engine date of manufacture: 12/1/2006 Engine displacement: 21.2 Ucyl S1,500 for each general permit registration to: Manufacturer: Caterpillar Model: G3612 Serial No.: BKE00356 Colorado Department of Public Health&Environment APCD-SS-B1 Engine function: O Primary and/or peaking power O Emergency back-up power 4300 Cherry Creek Drive South f1 Denver,CO 80246-1530 fl 9 j ® Compression O Pump jack O Water pump 0 Other: For guidance on how to complete this APEN for>2P�6 Manufacturer's maximum rated horsepower @ sea level: 3,550 BHP(a; 1,000 RPM Air Pollution Control Division: (303)692-3150 Small Business Assistance Program(SBAP): (303)692-3148 or Manufacturer's maximum site rating: 3,550 BHP @ 1,000 RPM kW (303)692-3175 Engine Brake Specific Fuel Consumption a; 100%Load: 6,760 Btu/HP-hr APEN forms:http://colorado.gov/edphe/APENfiinns Cycle Type: O 2-Stroke ® 4-Stroke Combustion: 0 Lean Bum O Rich Burn Anolication status:luto://www.colorado.zovIedohc/Permitstatus Ignition Source: ® Spark O Compression Aspiration: O Natural ® Turbocharged ❑ Check box to request copy of draft permit prior to issuance. What is the maximum number of hours this engine is used for emergency back—up power? !-[ours/year ❑ Check box to request copy of draft permit prior to public notice. I FORM APCD-201 I Pane I of 10 ;VIZ POLLUTANT EMISSION NOTICE(APEN) & Application for Construction Permit— Reciprocating Internal Combustion Engine' Permit Number: 95OPWE103 Emission Source AIRS ID: 123/0277/053 Section((5— Stack Information (;\fiaeh a;.),nratc sheet t\itli relevant information in the cent of multiple slacks:provide datum& either La1-Lone or UTvI) Stack Discharge r i i rrat,n Stack Base. 1ltmzinNal Uutum t If\I 1 lid\I l astutg or ( U 1 hl Norihtnt.or I Method of Collaelion ter l.cation Ilogin AK,tc How Kate velocity \townie ;iaci Ilesaoon Iclop i'I t 1\\D'7•NADS3, /one Lun nude I.:Mtn Datale.g: Imp.t.,l'S, t,r,nutdtetei Al.( .1-bt) (lisrcl l'!'i !I)\,i. Ilecti ___ Ilrrl; tVliSJ4) (12 or 1 ) I 'meters or tl greys) (niter+ur&gle'es) j (nn,glct'a,tht 1 ht11-(}238 I 4.788 52.5 858 23.401 ( 124 ( :\I\IQ \1'( 58-1 13 ( 104.1377 40.191 ( (PI'S Direction of stack outlet(cheek one•). 0 vertical ❑ vertical\t ith t,h.truetim.raiucat, ❑ Horizontal ❑ I) \\n ❑ Other i Describe): I,\i:.iu,l I(i,r.un•'..Sit,,-TV,'. Siic(check one): ❑ C irt:ul:n': Inner Diumeier t inches i— N ❑ Other: Length(inches)= Width(inches} Section(16— Fuel Con\untption Information Annual Fuel Consumption IeaFvt or\INISC F;vr) Sulfur Seasonal Fuel Use i",,of Annual lase) i ucl l se Rate a ItiP"IV,load Fuel Heating Value Fuel 1 pe ,\etuaI Reported for Content • ttiCF•hr,g„I.hrJ C,ikndar\'car Requested Permit (jinn (13tu'Ib,Qtu. al.QurSChl ( 1v1 ) Dee-Feb Mar-\1ay Jun-Aug Sep-Neat • - 1.♦aival( as '1.119.')SC hr 155.3 \1\IsC'Phr 185.(il \1\ISCl/ r 1,136_1!!_u/tiCh 1e 25 25 '" I,tlr,c}r_me c.luippetl v.itlt,}n \tr I suet rata, controller.' ❑ Ye, Q \n Section I)7— Emissions Inventor Information& I•:tnission Control Information I.71 I.missinn Facia'li ,eu, ematinn attached - nata vear for actual calendar errs emissions helms l fuel use above(e.g.200 2(114 I Requested Permitted slinuuiun Ntethod ( omrid Doice Description (Fawn( Emission [actor Actual Calendar Year lanissions Fulluuuit l Ilieicnc\ I:m sutons or i ' Primary Secondary Co Reducnnni Uncontrolled Basis lams Uncontrolled Controlled Uncontrolled Controlled Frtissiun Factor II (Fons;N sir) (Tons'Ycar1 i (Tons-Year) ("fons'\'car) Source I SI' I 9.99E-3 Ibl\1\113tu 0.87 (1.87 1.05 1.05 \I'-42 pm E 9.99E-3 Ih/\t\ililu 11.87 0.87 1.05 1.1)5 \I'-41_2 I'\I- i '1,')9E-3 Ilr/\I\1131u 11.87 11.87 1.05 a 1.05 \I'--12 5.33E4 Ih1\l\hint 0.05 0.(1" j �' St.)-. � C--- ---- � I _ � i 11.116 I 11.116 AP-42 \O•, 1 I 11.7 giblip-hr 19.9 19.9 24,0 24.0 \taunt•. Spec. •t'(K' O\.C:ual\st ( 89 i 6.15 p/bhp-lie 180.91 19.9 210.82 24.0 \}slant'. Spec. (..O Os.('atalsst 6S I 6.5(1 pa/bhp-hr 71.25 22.8 I 85.70 27.4 \Lilur. Spec. aua,:hk: e O\.('alalsst 80 9.4 .,./hlip-hr 11.4(1 2.23 13.71 2.74 I\tanul1 'Tee. \ccluldchttti Os.C:Ilal\sl 5l) 8.36E-3 1h/\1\Mtn 0.74 0.37 0.88 11.44 .\I'--i2 1cro:ein , Os.C atalsst 50 5.14E-3 Ib/\1\llitu 0.44 11.22 0.54 0.27 \I'--I2 (3cnnnc I Os.('sl(at)s} ( 50 i.Iln:{ I!)/\1\Ilitu SR \R I 0.05 0.02 \l'-12 • Please use•Ike APC'D Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. l uu gill be charged au additional,\I'I'.N ice if.\1'f.\is filled out incorrectly or missing information and requires re-submittal. \,i u.,l ent:.>;on(„s will he h.r•ed or;actual Cat;„ton,ICP,alid lice. If(cli',laid,.annual emi]>loii lee,Will be based on res1ue.,ied emissions. Sec(fun I(8—Applicant Certification- I hereby certify that all information contained herein and information submitted%%ith this application is complete,true and correct. _ L// -:2,:.1/7 Dana Stephens AirPcrmiltino\Ianacer - Sienature ul Person \-egad\:Aug orized to Supply Data Date I Name n(1 egally Authorized Person (('lease print) Title • Page 2 of 10 NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 95OPWE103 AIRS ID Number: 123/0277/053 Company Name: DCP Midstream, LP Plant Location: Enterprise Compressor Station County: Weld Zip Code: Person to Contact: Dana Stephens Phone Number: (303) 605-1745 E-mail Address: dstephensadcpmidstream.com Fax Number: (303) 605-1957 Control Equipment/ Emission Factor Emission Factor Uncontrolled Actual Controlled Actual AbS?I Ict Service Chemical Name Reduction(%) (Include Units) Source Emissions(lbs/year) I Emissions (lbs/year) (CAS) Number 67-56-1 Methanol Ox. Catalyst / 2.5E 3 AP-42 437.3 218.7 50% Ib/MMBtu Calendar Year for which Actual Data Applies: 2014 - l 1 Signature of Person Legally Authorized to Supply Data Date Dana Stephens Air Permitting Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14, 2014 AIR POLLUTANT EMISSION NOTICE (APEN) &Application for Construction Permit—Reciprocating Internal Combustion Engine' You will be charge an additional APES Ice if APES is filled out incorrectly or missing information and requires re-submittal. Permit Number: 95OPWE103 (Leave blank unless APCD has already assigned a permit II&AIRS ID] Emission Source AIRS ID: 123/0277/070 Facility Equipment ID: C-234 [Provide Facility Equipment Ill to identity how this equipment is referenced within your organization.) Section 01—Administrative Information Section 02—Requested Action(check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or ❑ Request for NEW permit or newly reported emission source SIC Code: 1321 Source Name: Enterprise Compresor Station O Request for coverage under GENERAL PERMIT number GP02(Natural Gas Only) Source Location: SW Section 30,'F2N,R63W County: Weld 0 Request MODIFICATION to existing permit(check each box below that applies) Elevation: 4,783 Feet O Change fuel or equipment ❑ Change company name Portable Source O Change permit limit O Transfer of ownership O Other Ilonte Base: 0 Request PORTABLE source permit Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 ® Request APEN Update Denver,CO Emissions data must Le completer'.Blank APENs will not be accepted Person To Dana Stephens Phone Number: 303-605-1745 Contact: E-mail Address: dstephens@depmidstream.com Fax Number: 303-6605-1957 O Notification of AOS permanent replacement Addl. Section 03—General Information Info.& Notes: For existing sources,operation began on: 1994 - For new or reconstructed sources,the projected startup date is: / / Normal bouts of source operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment purpose: Natural Gas Compression Date the engine was ordered: • Before 1/1993 Date engine construction commenced: Before 1/1993 Date the engine was relocated into Colorado: Before 1/1993 Date of any NA Colorado Department of Public Health and Environment reconstruction/modification: Air Pollution Control Division(APCD) Will this equipment be operated in any NAAQS nonattainment area? ® Yes ❑ No O Don t This notice is valid for five(5)years. Submit a revised APEN prior to (http:://www.cdnhe.slate.co.us/ap/attaininaintain.html) know expiration of five-year term, or when a significant change is made (increase production,new equipment,change in fuel type,etc). Section 04—Engine Information Mail this form along with a cheek for $152.90 per APEN and Engine date of manufacture: Before 1/1993 Engine displacement: 254.4 Ucyl $1,500 for each general permit registration to: Manufacturer: Caterpillar Model: G3612 Serial No.: 1YG-00029 Colorado Department of Public Health& Environment APCD-SS-B1 Engine function: O Primary and/or peaking power O Emergency back-up power 4300 Cherry Creek Drive South Denver,CO 80246-1530 ® Compression 0 Pump jack ❑ Water pump O Other For guidance on how to complete this APEN form: Manufacturer's maximum rated horsepower @ sea level: 3,550 BHP @ 1,000 RPM Air Pollution Control Division: {303}692-3150 Small Business Assistance Program(SBAP): (303)692-3148 or Manufacturer's maximum site rating: 3,550 B1•IP @ 1,000 RPM kW (303)692-3175 Engine Brake Specific Fuel Consumption @ 100%Load: 6,760 Btu/HP-hr APEN forms;httn://colorado.gov/cdphe/APENforms Cycle Type: ❑ 2-Stroke ® 4-Stroke Combustion: ® Lean Bum O Rich Bunt Aoolication status:htto://www.colorado,eov/cdohc/oertnitstatus Ignition Source: ® Spark O Compression Aspiration: O Natural ® Turbocharged O Check box to request copy of draft permit prior to issuance. What is the maximum number of hours this engine is used for emergency back—up power? Hours/year ❑ Check box to request copy of draft permit prior to public notice. I FORM APCD-201 1 Page 1 of 10 :V R POLLI.: ANT EMISSION NOTICE (APEX) & Application for Construction Permit— Reciprocating Internal Combustion Engine' 1'erruit Number: 95OPWE103 Emission Source AIRS II): 123/0277/070 Beckon 05—titael fnforniation(.\Itach a separate sheet with reler;ml information in the e‘out or multiple stacks: provide datum&either Lat.Lone or UTi\9) t t eraa,r ',lack Ito,: Mari I)u h.i c I Lail, it.it I)atutu t,I\t I,I\1 Lasting or l.'I\I Northing.nr � i\lethod ii(bn ction tO I',cation IIcl'cht AIx�Y Ilow Rate \'elocits \lnisturc Stars: I lc%nirm Ica h-Ili iNAl)27.NAUTh3. /one Longitude Latitude • Data ie g snap,t,l' , nunutd l esci tM \1) III.cc) I'" II'l l8 1783 �?i 858 "� F61 124 11111 1\('.581 l �,�l3) hmtei's or 10IJ87rccs (nnetei�0»it��ticcn) (nn Icla.lh) i'crtr I _ s _ _ 7 t (.PS Direction of ',lila outlet(check one): ❑ vertical ❑ Vertical with ohstructin Faint:all ❑ Horizontal ❑ I)o\\n ❑ Other lDescribe): I \haust I),*rain_Slap,.. Size(check one): ❑ Circular: Inner Diameter tinches) 24 ❑ Other: Len th(inches)= \\'idth(inches) Section 116— Fuel Consumption Information Annu,d had Consumption( alive or\1\1S('f=r\.r) Sulfur Seasonal Fuel list(0„of Annual Use) Fuel l.se Rate fa 100",.load - Purl 1!eatin'Value Furl 1 y ,e Actual Retorted for Content (SCP lu.gal lir) I Requested Permit Limit (Btu lb, Btu/gat,t'.13tu,SC'F) Dec-Feb Mar-May Jun-;Aug Sep-Nov i r (alencl tr Year (" wt.) I Natural Gas 21.1 19 S 1 'hr 1 151.5 \1\lS(•Frr ( 185\1111SCF/ r 1.136 litu/SCI I tic,;. I 25 25 I 25 I 25 is this ert,eine equippeu tic iris an:\ir.l ucl rani.conttullCI.' ❑ Yes 0 Ni Section 117 -- Fn►issions Inventor\ Information& Emission Control Information 17 I niissiou Factor Uocuurenlation atached n I) t year for actual calendar y r.eniis.rrnrs ut•lu,c.S.,fuel I e iuose(e.g.2007): 1 201-1 Requested Permitted Estimation Method li Control Des ice Desertpnin Cannon: Emission Factor Actual Calendar fear Ltttisstons Cmi,..ion, or Pollutant I.Itieicnes Uncontrolled Controllcxl Uncontrolled Controlled Emission Factor I'titnars Secondary ("r.Reductions l.ncontiolled Basis Units ITun,liar) (lion '1'car) I lons'1'ear) ( lun. l'c.u) Source �'� __,_ _a. I Sp I 9.99E-3 Ib/,Al\lRtu 1).85 0.85 1.05 1.05 .1P--12 —I— _ fs1 999E-3 Ih/\l\1110i 0185 0.85 1.05 1.05 \I'-4' I'N'. 9.99F-3 Ib/\1\111ut 0.85 0.85 1.05 1.05 \1'--I, sO, i 5.8811:4 Ib/5l\1BUi I 0.05 (11)5 0.06 (1.06 \I'--1, Ni 1,. (1.70 ,4/blip-hr 19.5 19.5 24.0 21.0 \!,hula Spec. VOl- O .Catalyst { 87 6.15 u/bhp-lit 150.00 19.5 210.8 24.0 \1attu).Spec. CO (h.Catalyst ! 68 2.5 t,/blip-hr 69.69 22.3 85.7 27.4 \lams!. Spec. I r,imal,l:hsde Ox.C:ualist 80 _r 0.40 g/bli r-hr 11.15 2.23 13.71 2.74 \lanof. Spec I I' \ret.ddcIistic Os.C'atahsi 50 8.36F.-3 Ib/\1\!Btu (1.72 0.36 0.88 0.4-! :AI'--I, 1 .),croleir Os.Catalyst 50 5.14E-3 lb/11\111w ((.44 0.22 0.54 11.27 \I'--12 llennmr Os.Catalyst i 50 dun l.401r:t Ib/\I\lRui NR tilt 11,115 ((.1)2 V1'-!_ 1 I 1 Please use Ike:1P Criteria Reportable Air Pollutant/Addendum furor to report pollutants not listed above 1 out„ill he rliargcd an additional k PIA fee if\l'I N is titled not incorrectly or❑issing information and requires re-suhnutial. \nnuai eiln.,i,ai tr .t ill hr lasts tin aetu.uI cuts,non,rrl„nird hurl Ih tilt hl.:nk.:unnctl cnu.au,n Ices 19111 he ba.ed on requested',masons Section 08—Applicant Certification- 1 hereby certify that all information contained herein aitd information submitted with this application is complete. true and correct. \ e'';t�_ , ',:_. A / ;c.j/ Dana Stephens Air I'dt I itlitfg\ _tanager Signature of 1'arson Le.t._!ally Authorized to Supply Data Date Name of Legally Authorized Person(Please print) Title PtLtr'. of10 NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 95OPWE103 AIRS ID Number: 123/0277/070 Company Name: DCP Midstream, LP Plant Location: Enterprise Compressor Station County: Weld Zip Code: Person to Contact: Dana Stephens Phone Number: (303) 605-1745 E-mail Address: cistephens cAdcpmidstream.com Fax Number: (303) 605-1957 ChemicalI Control Equipment/ Emission Factor Emission Factor Uncontrolled Actual Controlled Actual ��:�: r act Service ; Chemical Name Reduction % (Include Units) Source Emissions Ibs/ ear Emissions lbs/ ear ICl,SlNumber ( ) (lbs/year)) Y ) Ox. Catalyst/ 2.5E-3 67-56-1 Methanol I AP-42 426.7 213.3 50% Ib/MMBtu { i Calendar Year for which,Actual Data Applies: 2014 Signature of Person Legally Adthorized thorized to Supply Data Date Dana Stephens Air Permitting Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date. April 14, 2014 AIR POLLUTANT EMISSION NOTICE (APEN)& Application for Construction Permit—Reciprocating Internal Combustion Engine' r You will be charge an additional APEN fee if APEN is filled out incorrectly or missing information and requires re-submittal. Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit u s AIRS ID] Emission Source AIRS ID: 123/0277/071 Facility Equipment ID: C-237 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01—Administrative Information Section 02—Requested Action(check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or O Request for NEW permit or newly reported emission source 4922 Source Name: Enterprise Compressor Station SIC Code: ❑ Request for coverage under GENERAL PERMIT number GP02(Natural Gas Only) Source Location: SW Section 30,T2N,R63W County: Weld ❑ Request MODIFICATION to existing permit(check each box below that applies) Elevation: 4,788 Feet O Change fuel or equipment O Change company name Portable Source O Change permit limit O Transfer of ownership ❑ Other Home Base: ❑ Request PORTABLE source permit Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 ® Request APEN Update Denver,CO Emissions data must be completed. /3lank.IPENs will not be accepted Person"I'o Dana Stephens Phone Number: 303-605-1745 Contact: E-mail Address: dstephenst edcpmidstream.cont Fax Number: 303-605-1957 O Notification of AOS permanent replacement Addl. Section 03—General Information Info.& Notes: For existing sources,operation began on: 8/31/2012 For new or reconstructed sources,the projected startup date is: / / Normal hours of source operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment purpose: Natural Gas Compression Date the engine was ordered: Before 8/2012 Date engine construction commenced: Before 8/2012 Date of any NA Colorado Department of Public Health and Environment Bate the engine was relocated into Colorado: Before 812012 reconstruction/modification: Air Pollution Control Division(APCD) Will this equipment he operated in any NAAQS nonattainmcnt area? Yes ❑ No ElDon't This notice is valid for five(5)years. Submit a revised APEN prior to (http://www.cdphc.state.co.us/ap/attainntaintain.html) know expiration of five-year term, or when a significant change is made (increase production,new equipment,change in fuel type,etc). Section 04—Emilie Information Mail this form along with a check for $152.90 per APEN and Engine date of manufacture: Before 8/2012 Engine displacement: 21.2 IJcyl S1,500 for each general permit registration to: Manufacturer: Caterpillar Model: G3616 Serial No.: BLB00490 Colorado Department of Public Health& Environment APCD-SS-B1 Engine function: O Primary and/or peaking power O Emergency back-up power 4300 Cherry Creek Drive South Denver,CO 80246-1530 ® Compression ❑ Pump jack ❑ Water pump O Other: For guidance on how to complete this APEN fora: Manufacturer's maximum rated horsepower @ sea level: 4,735 BHP @1,000 RPM Air Pollution Control Division: (303)692-3150 Small 13usiness Assistance Program(SBAP): (303)692-3148 or Manufacturer's maximum site rating: 4,735 BHP @ 1,000 RPM kW (303)692-3175 Engine Brake Specific Fuel Consumption @ 100%Load: 7,481 Btu/l-IP-hr APEN forms:http://colorado.gov/cdphe/APENforms Cycle Type: O 2-Stroke ® 4-Stroke Combustion: ® Lean Bunt O Rich Burn Aoolication status:htto//www.colorado.eoviedolte/nennitstatus Ignition Source: ® Spark ❑ Compression Aspiration: O Natural © Turbocharged ❑ Check box to request copy of draft permit prior to issuance. What is the maximum number of hours this engine is used for emergency back—up power? Hours/year O Check box to request copy of draft permit prior to public notice. I FORM APCD-201 Page I of 10 :'.1k POLLUTANT EMISSION NOTICE (AMEN) & Application for Construction Permit— Reciprocating Internal ('ombustion Engine' Permit number: 95OPWE103 Emission Source AIRS II): 123/0277/071 Section (IS—Stack Information (,\naclf :I separate sheet '.~.ith relevant inlorntation in the event of multiple stacks:provide datum&either l.at/I.ung or UT NI) tit3 in ilrtr r j i rctunn Stack R ui t n I Ii ud I) t al om III NI l I `1 Listing or C:I\t\orthutg.)t- \IcthuJ..1 Collection ti,r I()cation Height•\txni Flow Rale \ locty \hratur si,tt. I•lesati tt n,unJ I rte, Icntlt.( I I \(1:t1r It,cc1 1.1 h.11)'_',,\AIri;, Zunc i ungnudc t..atitudc Data le.g m,m.i,P,,. ID o dent t lcrt 1,•4'(,S41 I I�<+r t?) (meter,or&g ees) [ hnctci.,or&grec,$) (nn lerarth! 1 _ ( 237 4.785 52.5 S76 r 32,336 1 - :\\IR \\GSi4 i 13 -104.4877• _ J 40.191 GI'S 1); cit:on 01 ,t,uF,tub e,(chock otter ❑ Vertical ❑ Vertical V.ith ob,tructin't/,uncap ❑ I lorizontdi ❑ Down U Other(Describe), I- '..usr O4,cninr Shape,:s. Sue(check one}: ❑ Circular Inner Diameter(inches)• ❑ Other: Length 1 inches)- Width(inches) Section 116— Fuel Consumption Information Annual fuel Consumption(gal/yr or\1\1SCI':yr) Sulfur Seasonal Fuel Ilse(°'0 01 Annual t..e( Fuel l se Rate fa I(D"n load I Fuel I leating Value fuel Type \ctmil Reported for Permit Content ISCI hr•gabhr} Calendar Year Requested I emit Limit (Rt i1h, Rnt.gal, Rrtr SCP) wt.} Dec-Feb Mar-May Jon-Aug Sep-Nov • Natural Gas I 31.173.5 SCI.'/hr 225.5\I\ISCl/\r l 27;08 \1\ISCF/\'r 1,136.3 It)tt/SCF I Neg. 2_5 l 25 I. 25 25 I,:ht,engine equipped wit on .1ii Fuel ratio Limn-oiler.' E. Ye. ❑ No Section(17— Emissions Inventors Information & Emission Control Information E I:nti,sinn Ioclor Ducuutc•utatt,tu attached Data year for actual calendar I.emissions helots&fuel use.those(e.g.211071d 2_1)14 control I)ertee oc,cnpum I Control Emission Factor Actual C.'alendar Year Linissions' Requested I'enniued listinurtian Method Emission. or Pollutant i 'latency — Primary i mare Secondary I t'',,Reduction) Uncontrolled Basis Unit, Uncontrolled Controlled Uncontrolled Cunttolledl finis ion Factor (Tons'Year) I Iott,,Yearl (ions Year) ( Fons 'Itatri Sotrce 1 tie' : 9.99E-3 I(!\1\11311 1.27 1.27 f \I'-42 P\I- i 9.9913 Ib/A1\111tu 1.27 1.27 \I'--I` l'\I,. i 9.99E-3 Ib/nl\MBtn 1.27 1.27 AP-l2 tit-),. I 1 5.88E-4 Ib/\f\tutu 0.07 0.07 \It--L' \O,, i 1 , 0.7 grbhp-hr 26.2 26.2 32.01 32.01 Manor. Spec. VOC Ot,.Catalyst i 6.15 g/bhp-hr 26.2 26.2 32.01 • 32.01 \Limit. Spec. ('O O\.Catalyst 1 71 I 6.50 gihhp-hr 1(13.45 30.0 125.74 36.58 \lanul. Spec. I,ant,l,lehdr I O\.Catalyst uO (1.4 g/bhp-hr 14.95 2.99 111.29 j 3.84 \hull. Spec. , .\cetaljeh. .- Ow.(:atalsst 50 8.36E-3 11r/NI\IBtu 1.06 0.53 1.30 I 0.65 \P-42 Acnolcir Os.Catalyst 50 5.14E-3 Ib/\11\11Ru 0.66 0.33 (1.811 0.4(1 \I'--1 [hat/env ch.Catalyst 50 4.40E-4 Ib/,\1\lulu NR 1R 0.07 0.03 \P-I' ( Please use the A1'CU Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 1-mi,till hpchargt d an addinuual APIA lie if:\I'1 N is tilled nut incorrectly or missing informalion and requires re-snhntittal. 1onual rnu„urn to ill Pc h.i,ctl,m.1,iu.rl c;uustnu tchutiid(WIC (I leli plank.annual ctnu>iun fir.a it:hr h,tscJ un irquc,tcd cnu..,u,n. Seelion_((8--Applicant Certification- 1 hcreb�•certify that all information contained herein and information submitted with this application is contplete, true and correct. • ' i. _ f,- -•`• !/?i,/ l c. Dana Stephens Air Permiuino Mali tger Signature of Person Legally Arithorized to Supply Data Date Name of Legally Authorized Person(Please print) Title Pate 2 of I(1 NON-CRITERIA REPORTABLE AIR POLLUTANT EMISSION NOTICE ADDENDUM (See reverse side for guidance on completing this form) Permit Number: 95OPWE103 AIRS ID Number: 123/0277/071 Company Name: DCP Midstream, LP Plant Location: Enterprise Compressor Station County: Weld Zip Code: Person to Contact: Dana Stephens Phone Number: (303) 605-1745 E-mail Address: dstephens(c dcpmidstream.com Fax Number: (303) 605-1957 Control Equipment/ Emission Factor Emission Factor Uncontrolled Actual Controlled Actual Abstract Service Chemical Name Reduction (%) (Include Units) Source Emissions(lbs/year) Emissions (CAS; Number (lbs/year) Ox. Catalyst/ 2.5E-3 67-56-1 Methanol 50% Ib/MMBtu AP-42 635.0 31T5 -.-.-._..... Calendar Year for which Actual Data Applies: 2014 _ , ,/ _ Signature of Person LegallAuthorized to Supply Data Date Dana Stephens Air Permitting Manager Name of Person Legally Authorized to Supply Data (Please print) Title of Person Legally Authorized to Supply Data Form Revision Date: April 14. 2014 AIR POLLUTANT EMISSION NOTICE(APEN)&Application for Construction Permit—Midstream Condensate Tank Battery Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit#&AIRS ID] Emission Source AIRS ID: 123 / 0277 / 063 Facility Equipment ID: P013 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 01—Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or 4922 ❑ Request for NEW individual permit or newly reported emission source Source Name: Enterprise Compressor Station SIC Code: ® Request MODIFICATION to existing permit(check each hex below that applies) • Source Location: SW SW Setion 30.T2N,R63W - County: Weld ® Change process or equipment ❑ Change company name Elevation: 4,788 Feet ® Change permit limit El Transfer of ownership O Other Mailing Address: 370 17'6 Street,Suite 2500 ZIP Code: 80202 O Request for coverage under GENERAL PERMIT number GPO' Denver,CO O Request APEN update only(check the box below that applies) Person To Contact: Wesley Hill Phone Number: 303-605-1716 O Revision to actual calendar year emissions for emission inventory E-mail Address: wdbillCdcpmidstream.com Fax Number: 303.605-1957 ❑ Update 5-Year APEN term without change to permit limits or previously reported emissions Addl.Info. Update emissions Section 03—General Information &Notes: For existing sources,operation began on: / / 1993 For new or reconstructed sources,the projected startup date is: / / Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment and purpose: Stabilized Condensate Tanks p► Do any of the condensate storage tanks have a capacity≥10,000 bbl? ❑ Yes A ® No ► Are you requesting≥20 ton/yr VOC emissions,or arc uncontrolled actual emissions≥20 ton/yr? (If"Yes",Regulation No.7,Section XVII.C will apply) El Yes ® No ► Is this unit located at a stationary source that is considered a Major Source of Hazardous Air Pollutant(HAP)emissions? ® Yes O No ❑ Don't know ► Will this equipment be operated in any NAAQS nonattainment area? Qtttn://www.cdphe.state.co.us/ap/attaimnaintain.htinl) ® Yes° O No ❑ Don't know "If"Yes",the tankis)may be subject to Regulation No.7,Sections Ill,IV,&VI,and Regulation No.6,Part A.Subpart Kb or Ka. Provide an applicability determination of these rules "If"Yes",the tankts)may be subject to Regulation No 7,Section XII A or XII B Provide an applicability determination of these rules Colorado Department of Public Health and Environment Section 04—Tank Battery Information' Air Pollution Control Division IAPCD) This notice is valid for five(5)years. Submit a revised APEN prior to Number of tanks: 8(300bb1) Total tank capacity(bbl): 2,400 z expiration of five-year term, or when a significant change is made Condensate throughput: Requested: 153,884.4 bbl/year Actual calendar year: bbl/year (increase production,new equipment,change in fuel type.etc). Is actual annual average hydrocarbon liquid throughput?500 bbl/day? O Yes No • If"yes"above,identify the gas-to-oil ratio: m'/liter Mail this form along with a check for S152.90 per APEN and S250 a ® for each general permit registration to: Are"flash" emissions anticipated from the tank(s)? O Yes No Colorado Department of Public Health&Environment APCD-SS-BI API gravity: 65.4 degrees 4300 Cherry Creek Drive South Reid Vapor Pressure: 10 psi True Vapor Pressure: 7.25 psia L 60°F Denver,CO 80246-1530 For guidagcc on how to complete this APEN form: 'See PS Memo 05-01 for information on condensate tank permitting and identification of parameters used to calculate emissions Air Pollution Control Division: (303)692-3150 (http./,wow cdohestate co.uslao/down`vs05.dl edf) Small Business Assistance Program(SBAP): (303)692-3148 or Requested values will become permit limitations. 3 (303)692-3175 Hydrocarbons can"flash"into the vapor phase due to a reduction in pressure on the hydrocarbon liquids. APEN forms:http://www.edphe.state.co.us/ap/downloadfomts.hnnl Additional (a Attach a pressurized pre-flash condensate extended gas analysis,RVP&API analysis of the post-flash oil Information O Attach E&P Tanks input&emission estimate documentation(or equivalent simulation report/test results) ® Cheek box to request copy of draft permit prior to issuance. •Required: ', ® Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses ® Check box to request copy of draft permit prior to public notice. FORM APCD-204 Pagel of 2 03g MidstreamCondensateTantAPF.N-Ver 9-2R-2009 r i ummoomm AIR POLLUTANT EMISSION NOTICE(ADEN)&Application for Construction Permit—Midstream Condensate Tank Battery Permit Number: 95OPWE103 Emission Source AIRS ID: 123 / 0277 / 063 , Section OS—Stack Information(Combustion stacks must be listed here) Section 06—Stack(Source,if no combustion)Location(Datum&either Lat/Long or UTM) t?ptxator SntckBase Stack Drichttrgc__ , 3tzekr Elevation -Helght Above •Temp. Flow Rate !velocity Moisture Hortaottt 1.Datum tTMone UTh1.6as de or t.)7' Lalmiding or Method of eta(e.g.map, ID Ado- ({ ) i.Cnuund Level (°k") (ACT6,i) 4019ec) ,(%) (NAD27;N.AD83 Zone Lon tulle : latitude I ' Location Data(e.g.map, ' (feet) ,, WGS84) ' (12 or 13) (meters or degrees)� -(meterssirdegrees) r -_ GPSiC.00glc>;anh) P013 4,788 15 WGS 84 -104.4877 40.1910 GPS Direction of stack outlet(check one): Q Vertical ❑ Vertical with obstructing raincap ❑ Horizontal ❑ Down ❑ Other(Describe): Exhaust Opening Shape&Size(check one): 0 Circular:Inner Diameter(inches)_ Li Other:Length(inches)= Width(inches)_ Section 07—Control Device Information ❑ Condenser used for control of the tank battery. ® Combustion Device used for control of the tank battery. Rating: MMI3tu/hr Type: Make/Model: Type: Make/Model/Serial ft: Temperature(°F): Maximum: Average: VOC&HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: % Requested VOC&HAP Control Efficiency: % Minimum temp.to achieve requested control: °F Waste gas heat content Btu/scf ❑ V RU used for control of the tank battery. Constant pilot light? 0 Yes j] No Pilot burner rating: MMI3tw'hr Size: Make/Model: E) Closed loop system used for control of the tank battery. Requested VOC&HAP Control Efficiency: % Description: Annual time that VRU is bypassed(emissions vented): °Jo ❑ Describe Any Other: Section 08—Emissions Inventory Information&Emission Control Information ® Emission Factor Documentation attached Data year for actual calendar yr.emissions below Si throughput in See.04(e.g.2007): I Control I3evice Driptton Control Etiai�sion Factor Actual Calendar Year F, i9sions) ,Requested Permitted Estimation Method Pollutant F '':'.:Efficiency 'Uncontrolled Bests Units:. Emissions' E or Primary Secondary (° Y Uneontrolled Controlled Unconttnlled Controlled Etnission Factor (Torts/Year) (T ns/Y ) ((Tons/Year)- - o etv To ear) (Tarts/Year _ Source NO x 'r-t b IV—:,,,F4 k-',,,,'.'4,:',4!A-1. ) 0 VOC st a , 6.,.- - 0.332 lb/bbl ; # 3a, �y e y 25.57 1.28 Tanks 4.0.9d CO ;1V-,•,';:',::' 'rRrh 1 8 .* t' "Y Tye ,a., Benzene = ^'i �{ :' 0.004 lb/bbl 035 0.02 En Cale Toluene „.7.9-A40 1 n a y s% 7v 4.1"!'414"g"--- 0.015 lb/bbl g ,,�, C . 1..15 0.06 En Cale Ethy!benzene f * t g. r t UA9i !b/bbl 0.09 0,0t1 Eng.Cate Xylem s a: w .t.4 � � �', 0.011 [b/bbl 0.83 0.04 Eng.Cale n-Hexane °lk' ' s a �'"'"�< 0.032 lb/bbl 2.50 012 Eng.Cale , sty �* b t»s`. �r,..+,e"r t��_, Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. °Annual emission fees will be based on actual emissions reported here. If left blank,annual emission fees will be based on requested emissions. 'If Requested Permitted Emissions is left blank,the APCD will calculate emissions based on the information supplied in sections 03-08. Section 09—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 GPO I,I further certify that this source is and will be operated in full compliance with each condition of general permit GP01. 1/4/2012 Wesley 1-till Senior Env.Specialist ,Signature°of Person Legally-Aitthorized to Supply Una"-- -; Late Name pfLegall AutherizedPerson, 1, se =ti ,�,,,- y" �a.�- print) ,.k.. �� ., .r � ry��: Page 2 of 2 03g MidstreamCondensateTankAPEN-Ver.9-28-2009 f IIIIIIIIMINIMINI AIR POLLUTANT EMISSION NOTICE(APEN)&Application for Construction Permit—Hydrocarbon Liquid Loading Please use the Fuel Dispensing Station APEN to repon emissions from service stations and fleet refueling stations. Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit k&AIRS ID] Emission Source AIRS ID: 123 / 0277 / 066 Facility Equipment ID: P016 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization) Section 01—Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or O Request for NEW permit or newly reported emission source 4922 Source Name: Enterprise Compressor Station SIC Code: El Request MODIFICATION to existing permit(check each box below that applies) Source Location: SW SW Setion 30.T2N,R63W County: Weld 0 Change process or equipment ❑ Change company name Elevation: 4,788 Feet ® Change permit limit ❑ Transfer of ownership ❑ Other Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 O Request to limit HAPs with a Federally enforceable limit on FEE Denver,CO O Request APEN up date ptlate only(check the box below that applies) Person To Contact: Wesley Hill Phone Number. 303-605-1716 O Revision to actual calendar year emissions for emission inventory E-mail Address: wdhill@dcpmidstream.com Fax Number 303-605-1957 ❑ Update 5-Year APEN term without change to permit limits or previously reported emissions AddL Info. Update Emissions and Throughput Section 03—General Information &Notes: k or existing sources,operation began on: / / 1993 For new or reconstructed sources,the projected startup date is: / / Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment and purpose: Loadout of stabilized condensate ► Is this source located at an oil and gas exploration and production site? O Yes ® No O Don't know If yes.does this source load less than 10,000 gallons of crude oil per day on an annual average,splash fill less than 6750 BBL of condensate (hydrocarbon liquids that have an API gravity of 40 degrees or greater)per year or submerge fill less than 16,308 BBL of condensate per year? ❑ Yes ❑ No O Don't katow ► Is this source located at a facility that is considered a Major Source of Hazardous Air Pollutant(HAP)emissions? ® Yes" O No ❑ Don't know ► Will this equipment be operated in any NAAQS nonattainment area? (hito://www.c.dorw.state.co.us/apfaitaininaintain.hunl) n ® Yes O No O Don't know ► Does this source load gasoline into transport vehicles? O Yes( ® No O Don't know ^If"Yes",this source may be subject to 40 CFR 63,Subparts EEEE,CC,and R Provide an applicability determination of these rules °If"Yes",this source may be subject to Regulation No.3,Pan B,Section lll.D.2. Provide an applicability determination of these rules. tf"Yes",this source may be subject to Regulation No.7,Section VI C,40 CFR 63 Subpart BBBBBB or Subpart XX Provide an applicability determination of these rules Colorado Department of Public Health and Environment Section 04—Loadine Information Air Pollution Control Division(APCDI Product Loaded: Stabilized Condensate This notice is valid for five(5)years. Submit a revised APEN prior to This product is loaded from tanks at this facility into: Tank Trucks (e.g,"rail tank cars,"or"tank trucks") expiration of five-year term, or when a significant change is made Number of Loading Bays: 1 Pump Capacity in Each Bay: gallons/min (increase production,new equipment,change in fuel type,etc). ► If this APEN is being filed for vapors displaced from cargo carrier,complete the following: Mail this form along with a check for$152.90 to: Annual Volume Loaded: Requested': 153,884.4 bbl/year Actual calendar year: bbl/year Colorado Department of Public Health&Environment Saturation Factor2: 0.6 Average Temperature of Bulk Liquid Loaded: 58.16 °F APCD-SS-B1 4300 Cherry Creek Drive South True Vapor Pressure: 4.65 psia 42;60°F Molecular Weight of Displaced Vapors: 66 l.b/lb-mol Deaver,CO 80246-1530 ► If this APEN is being filed for vapor losses from pressurized loading lines,complete the following: For guidance on how to complete this APEN form: Loads per year. Requested': ft/yr. Actual Calendar Year: ft/yr. Product Density: Lb/ft' Air Pollution Control Division: (303)692-3150 Load Line Volume': Ft'/truckload Vapor Recovery Line Volume': Fe/truckload Small Business Assistance Program(SBAP): (303)692-31.48 or (303)692-3175 'Requesied values will become permit limitations. APEN forms:http://wvvw.cdphe.state.co.us/ap/dovvnloadfomts.html =Please refer to AP-42,Table 5.2-1 for information on saturation factors 4found online at http//wmv epa,govittritchicf/ar42!ch05/index.htnil) Application status:http://wvvvv.edphe.state.co.us/aplss!sspept.html 'List the total volume for all lines in each category and attach your calculations of these volumes. FORM APCD-208 Page 1 of 3 03k Enterprise Condensate Loading APEN H AIR POLLUTANT'EMISSION NOTICE(APEN)& Application for Construction Permit—Hydrocarbon Liquid Loading Please use the Fuel Dispensing Station APEN to report emissions from service stations and fleet refueling stations. Permit Number: 95OPWE103 Emission Source AIRS ID: 123 / 0277 / 066 Section 05-Stack Information(Combustion stacks must he listed here) Section 06—Stack(Source,if no combustion)Location(Datum&either Lat/Long or UTM) Snack t?tsChe _ Flow Horizontal IIFhi Fasting fq Sttu.k "" Owed Level (A Rare' (gP 1 `;''Moisture A WGsfd4 ar I2LonYe73) }c Longitude i .. t�d or Location on Data(egg 1l3Nu. n fiar Stack ' end I eyel F { , wt) ( _ tens o 1 r- ( er degrees) l,t 9PS;GoogleEarth) regrr P016 4,788 VYGSfl4 -104.4877 40.1910 GPS Direction of stack outlet(check one): ❑ Vertical 0 Vertical with obstructing raincap ❑ Horizontal ❑ Down ❑ Other(Describe); Exhaust Opening Shape&Size(cheek one): 0 Circular:Inner Diameter(inches)m 0 Other:Length(inches)- Width(inches) Section 07—Control Device Information 0 Vapor Recovery Unit(VRU)used for control of the loadout emissions. Al Combustion Device used for control of the loadout emissions. Rating: MMIltu/hr Size: Make/Model: Type: Make(ModeUSerial l: Requested VOC&HAP Control Efficiency: % VOC&HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: Annual time that VRU is bypassed(emissions ventral): % Minimum temp.to achieve requested control: °F Waste gas heat content. Htuisef The VRU recycles loadout emissions to: Constant pilot light? ❑ Yes O No Pilot burner rating: MMl3twhr ❑ Describe Any Other: Section 08—Emissions Inventory Information&Emission Control Information ® Emission Factor Documentation attached Data year for actual calendar year emissions below&throughput in Sec,04(e.g.2007): ( I Control Dc is on' Eatissiaut ^ ,as ' Requested Permitted ' _Estimati'Ptl !'actor Actual C `''ear Einimions Method or Pollutantantrol Efftcielacv ' ,' Uncontrolled ' Controlled Uncontrolled'. Co ttro Emission!; :: ; . 417 .,^' UncantmltedBasis :dlmts ast's e,v- Tons/Year . - , =<s Tons/Year „-'� ottnw/Year' Factor Source NOx yttliTOK ,A.41, 11:',.,' v,n7ir„:,, VOt. S" ,. , 4.42 lb/1000 gal 14.3 0.7 AP-42 CO :,r 1" Benzene ., a., rra ,4 Toluene , r� xt ,t"r —/t. Etltylbetuene r''''''.,k * Xyleate "- n-Hexane - Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. "Annual emission tees'sill be based on actual emissions reported here If left blank,annual emission fees will be based on requested emissions. ,If Requested Permitted Emissions is left blank,the APCD will calculate emissions based on the information supplied in sections 03-08. Section 09—Applicant Certification-I hereby certify that all information contained herein and information submitted with this application is complete,true and correct. 1/4/2012 Wesley Hill Senior Env.Specialist Signature,ofPerson Le Antbortzed,to Supply polo ,,;, ;'! ,,Date ,. Nam.glcsfLegalkAuthotaaeaPers Akf ease} tat) ,,,.„. ''-,Tile ''::'-'2.:' ., Page 2 of 3 03k Enterprise Condensate Loading APEN Appendix C Updated APENs: Natural Gas Dehydrator D2 & Enclosed Combustor COMB-I Enterprise Compressor Station COP General APEN - Form APCD-200 , . v Air Pollutant Emission Notice (APEN) and ,z,.,,. ,&_a Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source (e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD)website at www.cotorado.gov/pacific/cdphe/air-permits. 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: 95OPWE103 AIRS ID Number: 123 /0277/074 [Leave blank unless APCD has already assigned a per #and AIRS ID) Section 1 - Administrative Information Company Name': DCP Midstream, LP Site Name: Enterprise Compressor Station I Site Location Site Location: SW Sec. 30,T2N, R63W County: Weld NAICS or SIC Code: 4922 Mailing Address: (include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Permit Contact: Roshini Shankaran Phone Number: 303-605-2039 Portable Source E-Mail Address: rshankaran mdc ini.isiredm cum Home Base: �. p 'Please 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. 212O16 For APCD-200- General APRIL - Revision 7/2015 1 I :, -- 3 ' 4-) 3(O Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 Section 2- Requested Action ❑ NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source ❑ PORTABLE source -OR- E MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment El Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Please 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) ❑ APEN submittal for permit exempt/grandfathered source Additional Info a Notes: 2 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: Combustion device for TEG still vent control Manufacturer: Leed Model No.: L30-0018-00 Serial No.: Company equipment Identification No. (optional): COMB-1 For existing sources, operation began on: 4/11/2016 For new or reconstructed sources, the projected start-up date is: M 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 Seasonal use percentage: Dec-Feb: Mar-May: June-Aug: Sept-Nov: 26 2 *:.:' Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 Section 4 - Processing/Manufacturing Information & Material Use D Check box if this information is not applicable to source or process Design Process Actual Annual Requested Annual Description Rate Amount Permit Limit3 (Specify Units) (Specify Units) (Specify Units) Material Consumption: Finished Product(s): 3Requested values will become permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (LatitudelLongitude or UTM) 40.1910/-104.4877 El 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. Discharge Height Operator Temp. Flow Rate Velocity Stack ID No. Above Ground Level ( F) (ACFM) (ft/sec ) (Feet) Comb 1 25 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward ❑ Upward with obstructing raincap ❑ Horizontal ❑ Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 36 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): I .a: Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 i)., F f : ) P , Section 6 - Combustion Equipment &t Fuel Consumption Information ❑ 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 Limit3 (MMBTU/hr) (Specify Units) (Specify Units) 0.13 (Fuel Only) 3.2 MMscf/yr 10.96 MMscf/yr(Waste Gas+ Fuel) s tl .. 2015 Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) Field Natural Gas Heating value: 1,148 BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) O Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑ Coat Heating value: BTU/lb Ash Content: Sulfur Content: Other(describe): Waste Gas Heating value (give units): 1,990 Btu/scf 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 4 if fuel heating value is different than the listed assumed value,please provide this information in the"Other"field. Section 7- Criteria Pollutant Emissions Information Attach alt emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? O Yes ® No If yes, please describe the control equipment AND state the overall control efficiency (%reduction): Pollutant Control Equipment Description Overall Control Efficiency (%reduction in emissions) TSP (PM) PM,p PM2.s SO,, NO,, CO VOC Other: • i Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 Section 7(continued) I 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Emission Uncontrolled Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit (s)3 Pollutant Source Factor (Specify Units) (AP-42,Mfg. Uncontrolled Controlleds Uncontrolled Controlled etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP (PM) PMro PMz.s SOX NOX 0.068 lb/mmBtu AP-42 0.22 0.22 0.64 0.64 CO 0.37 lb/mmBtu AP-42 1.22 1.22 3.49 3.49 VOC Other: 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 5Annual emission 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 pollutants (e.g. HAP- hazardous air pollutant)emissions equal to or greater than 250 ❑ Yes ® No lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Overall Uncontrolled Uncontrolled Controlled CAS Emission Emission Factor Actual Actual Chemical Name Control Source Number Efficiency Factor (AP-42,Mfg.etc) Emissions Emissions5 (specify units) ((bs/year) (lbs/year) 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. �4�. Permit Number: 95OPWE103 AIRS ID Number: 123 10277i 074 ;r, , I I-_- T) Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. • It 612016 Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Environmental Engineer Name (please print) Title Check the appropriate box to request a copy of the: ❑ Engineer's Preliminary Analysis conducted ❑ 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 $152.90 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-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 www.colorado.gov/pacific/cdphe/air-permits Telephone: (303)692-3150 x.262016 6I c. AIR POLLUTANT EMISSION NOTICE (APEN)&Application for Construction Permit—Glycol Dehydration Unit1 Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit#&AIRS ID] Emission Source AIRS ID: 123 / 0277 / 068 Facility Equipment ID: D2 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01 —Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or ❑ Request for NEW permit or newly reported emission source SIC Code: 4922 Source Name: Enterprise Compressor Station E Request MODIFICATION to existing permit(check each box below that applies) Source location: SW Sec 30,T2N,R63W County: Weld ❑ Change process or equipment ❑ Change company name Elevation: 4,788 Feet E Change permit limit ❑ Transfer of ownership ❑ Other Mailing Address: 370 1711'Street,Suite 2500 ZIP Code: 80202 ❑ Request to limit HAPs with a Federally enforceable limit on PTE Denver,CO ❑ Request APEN update only(check the box below that applies) Person To Contact: Roshini Shankarait Phone Number: 303-605-2039 ❑ Revision to actual calendar year emissions for emission inventory E-mail Address: rshank mm ni ii'dcpmtidstreain.cont Fax Number: 303-605-1957 ❑ Update 5-Year APEN term without change to permit limits or previously reported emissions Addl.Info. Section 03—(,General Information &Notes: For existing sources,operation began on: 1 / 11 / 2001 For new or reconstructed sources,the projected startup date is: / / Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment and purpose: Dehydration unit for water removal Is Ihis unit subject to the 90".0 control requirement of Colorado Regulation No.7,XVILD(total uncontrolled actual VOC emissions from all dehydration units at this stationary source,including APEN Exempt units, 15 tonsiyr)? ® Yes ❑ No ❑ Don't know Will IIns equipment be operated in any NAAQS nonattainment area? (ir111 n..i.._ . iunn.-:u) E Yes ❑ No ❑ Don't know ► Is this unit located at a stationary source that is considered a Major Source of hazardous Air Pollutant(IlAP)emissions? ® Yes ❑ No ❑ Don't know Section 04—Dehydration Unit Equipment Information Manufacturer: Forum Model: Custom Unit Serial No.: Custom unit Colorado Dep:u'nnent of Public Health and Environment Reboiler Rating: 1.5 MMI3tuihr Air Pollution Control Division(APCD) Glycol Used: E TriEthyleue Glycol(PEG) ❑ Ethylene Glycol(EG) ❑ DiEthylene Glycol(DEG) This notice is valid for live(5)years. Submit a revised APEN prior to Glycol Pump Drive: Electric ❑ Gas If gas,injection pump ratio: actin/gpm expiration of live-scar term. or when a significant change is made (increase production,new equipment,change in fuel type.etc). Pump Make&Model: Rotes Tech GS2212 k of Pumps: f!,. Mail this form along with a check for$152.90 to: Glycol recirculation rate(gal/min): Max: Requested`: X35 Lean glycol water content: 1.5 wt. Colorado Department of Public I health&Environment Deity.Gas Throughput: Design Capacity: 110 0‘41MMSCF/day Vi..4 Requested': 40,150 MMSCF'vr. APCD-SS-III Calendar year actual: MMSCF/yr. 4300 Cherry Creek Drive South % / j•,' Inlet Gas: Pressure: 950 psig -fcntperature: 120 'F Denver,CO 80246-1530 f /- Water Content: Wet Gas: Ib/MMsef ® Saturated Dry n Gas: 7.0 Ib/MMscf For guidance on how to complete this.N.ir 6 1E Flash Tank: Pressure: 50 psig Temperature: 130 It ❑ None Air Pollution Control Division: 1 (303)692-3150 Cold Separator: Pressure: psig 'fern perature: 'F E None Small Business Assistance Program(S13AP): (303)692-3143 or 'tt3)692-3175 Stripping Gas E None ❑ Use flash gas ❑ Use dry gas: scfin ❑ Use N2: sclin APEN forms: r -_ 175 'You will be charged an additional AI>l;N tee if APEN is tilled out incorrectly or missing information and requires re-submittal. Application status l!i.: .N, 'i,. 'Requested values will become permit limitations. Additional El Attach a process flow diagram Information E Attach GRI-GLYCale 4.0 Input Report&Aggregate Report(or equivalent simulation report/test results) ® Check box to request copy of draft permit prior to issuance. Required: ❑ Attach the extended gas analysis(including BTEX&n-1-Iexane.temperature&pressure) E Cheek box to request copy of draft permit prior to public notice. FORM . '3-202 Pag' 3 55' 1 (-)3-4-- >d cited APEN AIR POLLUTANT EMISSION NOTICE (APEN) &Application for Construction Permit—Glycol Dehydration Unit' Permit Number: 95OPWE103 Emission Source AIRS ID: 123 / 0277 / 068 Section 05—Stack Information (Combustion stacks must be listed here) Section 06—Stack(Source,if no combustion) Location(Datum&either Lttt/Long or MI) Operator Suck Base Stack Discharge Horizontal Datum UTM UT lasting or UTM Notching or Methodof Collection for Height Above Temp. Flow Rate Velocity Moisture Stack Elevation (NAD27,NAD83. Zone Longitude Latitude Location Data(e.g.map, Ground Level (CF) (ACFM) (fl/sec) (g„) ID No. (feet) WGS34) (12 or 13) (meters or de ees) (meters or degrees) GPS,GoogleEanh) (feet) COMB1 4.788 25 I WGS 84 13 -104.4877 40.191 GPS Direction of stack outlet(check one): 0 Vertical ❑ Vertical with obstructing raincap ❑ Horizontal O Down ❑ Other(Describe): Exhaust Opening Shape&Size(check one): 0 Circular:Inner Diameter(inches)= 36 0 Other:Length(inches)= Width(inches)_ Section(17 —Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions) 0 Condenser used for control of: Still Vent Stream 0 Combustion Device used for control of: Still Vent Stream Rating: MM13tu/ r Type Make/Model: Enclosed Combustor- Leed Single Stage 36 High Efficienc Y Type: Make/Model/Serial{l: COMB-1 Combustor Temperature(°l'): Maximum: 140 Average: VOC&HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: 98 '%„ Requested VOC&HAP Control Efficiency: "U Minimum temp.to achieve requested control: °F Waste gas]teat content: Btu'scf Ej VRU used for control o£ Flash Tank vent stream Constant pilot light? ® Yes ❑ No Pilot burner rating: MMlttuhr Size: Make/Model: O Closed loop system used for control of: Requested VOC&HAP Control Efficiency: 100 % Description: Annual time that VRU is bypassed(emissions vented): 5 "ru ® Describe Any Other: During COMB-I downtime(3%),still vent stream routed to atmosphere I Section(18—Emissions Inventory Information& Emission Control Information 0 Emission Factor Onetime ntation attached Data year for actual calendar yr.emissions below&gas throughput above(e.g.211117): I 2015 Control Device Description Control Emission Factor Actual Calendar Year Emissions} Requested Permitted Estimation Method Pollutant Efficiency Emissions or Priorary Secondary (%Reduction) Uncontrolled Basis Units Uncontrolled Controlled Uncontrolled Controlled Emission Factor (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) Source NO\ VOC 43.15 lb/MMscf 581.71 3.12 866.19- 33.27 GrLYCalc CO l3enzene 5.96• lb/MMscf 40.76 0.75 119.65 7.73 GLYCaIc Identify in Section 07 Toluene 7.13 lb/MMscf 41.00 0.43 143.14 7.16 GLYCale Ethylbenzene 0.19 lb/MMscf 1.41 0.006 3.81 0.11 GLYCaIc Xylene 2.39 lb/MMscf 15.02 0.07 48.03 1.28 GLYCaIc n-Hexane 0.87 lb/MMscf 10.54 0.07 17.37 0.81 GLYCaIc Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 'You will be charged an additional APEN fee ifAP'LN is filled out incorrectly or missing information and requires re-submittal. Annual emission fees wilt be based on actual emissions reported here. If left blank,annual emission fees will be based on requested emissions. , Section 09 1pplicant Certification-I hereby certify that all information contained herein and information submitted with this application is complete,true and correct. -'' 2(O12 6 I 0' Roshini Shankaran Environmental Engineer Si ratite of Person Legally Authorized to Supply Data Date Name of Legally Authoriz t r case print) Title Page 2 D2 I AP N.doex Appendix D APEN Filing Fees Enterprise Compressor Station Appendix E Updated Emission Calculations: D2&COMB-1 Updated GLYcalc Parameters: D2 Enterprise Compressor Station r- -- -- -- -- C'olorido Department of Public neallh and 4:mironnlrnt u I Form APC'D-1112 Air Pollution Control Dhhton H 1 Facility Wide Emissions Inventory Foln1 r Apr O.'_nl' toutflow;F9 [Xi,Al ht I f :or ir Sourer Name.Imace Coupler-ray Ma'am %e mcee AIRS I10 I2 i 02-- <1 n.nn.nB.a 1'.neh.l to 4n.tPf F'.t <moon.Punc Yh to frt.tell •090, F1A1.(I4..,I .01911 11AP Itr.Trl AIRti 111 P:Ou 40.4.On,„ry.na: PCP x-1110 16Ca _ tpi .1 ncu0 .031 ♦ u 6] 1.1 .A<I nlf.< Merl: .2.Tin" 111' MAO PA0, `.Ox 0 10 111111') 6.n.l .r., 9/ '101 FB \rr oA¢ M. 2246613 1 "Ms < A 't FN P.m140616uxrn 114tn.f <,< < 01. 1!96.1 .`9111 .^.l I'1))' 9624 <91- _34.21' 199100 '1421 9'939 .196-•6 2.191) 1 . . . . 034 13104 1<.l2 149.^ 1464641111 4312 1.10.4 11.016 14,660 31 2.0140 1W 1.400 0 APRry 0nty-93,10 1,.309 4,990.0. APF'.0 6311,0.3030 00 00 00 00 00 00 00 0 0 0 0 0 0 0 0 00 00 00 0 U 0 0 p 0 0 0 00 00 00 0000 1 0 0 A YrY 1311111 111.0 46..11.bu,rn ma.,9,rlt»e Macaw 00 011 I 00 00 14 101 11 n 0 0 0 0 0 0 0 0 0 On 00 00 00 1211 10 1.9 0 0 0 0 0 0 0 0 0 1 oral,A11Ya0.n l <1 I <l I e9 I 01 1 rno I 1503 14613 I..a14 1 9414 1 Iar 1144,, '39n<nl-x1119,9,°1w2 1 13411 I 1 f 691 <11 I A9 I of I I.n0I 16.11 MI .10.4413 1 ♦Rc 1 19, I .040 11..6661 3,01 3"01 tin,I 1424 I n urean.taree nalaala.r,dell'l 61 I •9 I 40 1 .16. 1 .4,1 001 410 1 199 1 I. 1 ou 1 muen3we4Pamll.o.46rPVl I 1'1 I .4 1 tr 1 90 I -1 101 1 14 1 0e 1 101 I on 0,900011,91130.1111110.f1911 C•.I 1 4111004c1 1001 All NAP,0I'r1' *6 I Footndn: I Tho toil)rhaaM Ire..Ynplcted ha include both cvcll1,44Fun to 6110 ell prlxn.cd nnl to tnolditeholm II el hung 3116111611 rotate, _. !f the a00'I:no-<.Aucc 460Ian then enter propora 1"under the Pmint':o.all AIR,II)data cohahrer r If<\h'nbbrr9'Ixtiam arc hada N% f1en>rne 2241 SIP'='__,d:1rin,ethl!pentane Iol I ohmle Acrid A114410etndo LB I:Ur,-'benzene :5040 ;poker \.I ))late n Ile.-n-litxate 11('III) FommlfIchfde Meth-Methanol I..APIN Eenppf Ill 301 tinaOt Sam ea 1h1.dd he ulcluderl 0hen win ataml Company Name 7/25/2016 PaOe t of t • Natural Gas Dehydration Enterprise Compressor Station DCP Midstream, LP AIRS ID 123/0277 Source ID D2 Stripping Gas? N Y/N Description 110 MMSCFD Dehy What is Stripping Gas? N/A Manufacturer Stripping Gas Flow Rate N/A scfm Model Condenser?' Y Y/N • Serial# Condenser Temperature 140 deg F Operation Date Condenser Pressure 125 psia Operation 8760 hr/yr ECD? Y YIN Wet Gas Temperature 120 deg F ECD Ambient Air Temp 0 deg F Wet Gas Pressure 950 psig ECD Destruction Efficiency 9500% Wet Gas Water Content Saturated IbH2O/MMscf ECD Excess Oxygen 0 00% Dry Gas Flow Rate 110 MMscfd Combustor Downtime 3.00%Uncontrolled Dry Gas Water Content 7 0 IbH2O/MMscf Lean Glycol Water Content 1 5 wt%H2O 438 VRU downtime hours Lean Glycol Flow Rate 35 gpm 253 ECD downtime hours Cold Separator? N Y/N Cold Separator Temperature deg F Cold Separator Pressure psig Glycol Pump Make&Model Glycol Pump Type Electric Elec or Gas Glycol Pump Gas Flow Rate NIA acfrn/ppm Flash Tank? Y Y/N Flash Tank Temperature 130 deg F Flash Tank Pressure 50 psig Flash Tank Control 100 00%Recycled to Inlet VRU Downtime 5 00%Routed to COMB-1 Total Emissions from GRI-GLYCalc 4.0 Uncontrolled Emissions CAS Flash Emissions' Still Vent Emissions Total Dehy Emissions- Emission Factors Pollutant Number (tpy) (tpy) (tpy) (ib/yr) (IblMMsc n VOC 309 25 556.93 866.19 43 15 n-Hexane 110-54-3 17 37 34732 0 865 Benzene 71-43-2 _ 119.65 239307 5 960 Toluene 108-88.3 ._. _ 143.14 286272 7130 Ethylbenzene 100-41-4 . _- 381 7617 0 190 Xylene 1330-20-7 ___, 7 48 03 96064 2 393 Total HAP .-. 332.00 16 538 1 Flash emissions and still vent emissions(uncontrolied potential to emit)obtained from GlyCalc report dated July 20th,2016 1.Still Vent also refered to as Regenerator Emissions 2 Total dehy emissions calculated as a sum of Flash and Still Vent emissions Flash Tank Emissions Flash Tank VRU Flash Tank VRU Downtime Total Flash Tank Emissions` CAS Uptime Emissions Emissions' Pollutant Number (t4Y) (tPY) (tPY) VOC 000 0.77 0 77 n-Hexane 110-54-3 000 0 02 0 02 Benzene 71-43-2 000 0.01 001 Toluene 108-88-3 000 0.00 0 00 Ethylbenzene 100-41-4 000 000 000 Xylene 1330.20-7 000 0.00 000 Total HAP 000 003 003 3 No emissions during VRU uptime 100%recycled to process 4 VRU downtime emissions refer to emissions during a maximum of 6%VRU downtime for maintenance and malfunctions The VRU is backed up by the Enclosed Combustor with 95%DRE 5 Total flash tank emissions is the sum of flash tank VRU downtime emissions, Still Vent Emissions Still Vent COMB-1 Still Vent COMB-1 Downtime Total Still Vent Emissions CAS Uptime Emissions Emissions. Pollutant Number (tpy) (tpy) (tpy) VOC 20.313 12.188 32.50 n-Hexane 110-54-3 0 296 0 79 Benzene 71-43-2 2.895 7 72 Toluene 108-88-3 4 a' 2.682 7 15 Ethyibenzene 100-41-4 -_. 0041 011 Xylene 1330.20.7 0 480 1.28 Total HAP . 6 394 17 05 6 Still Vent COMB-1 control emissions refer to still vent emissions controlled by a condenser and the enclosed combustor(during 95%annual uptime) 7 COMB-1 downtime emissions refer to emissions during a maximum of 5%enclosed combustor downtime for maintenance and malfunctions 8 Total still vent emissions is a sum of still vent COMB-1 control and COMB-1 downtime emissions. Total Controlled Emissions IPTE[ CAS Dehy Emissions9 Overall System Control1° Emission Factors Pollutant Number (tpy) flblMMscf) VOC 33.27 1 66 n-Hexane 110-54-3 0 81 0 040 Benzene 71-43-2 773 0385 Toluene 108-88-3 7 16 - 0357 Ethylbenzene 100-41.4 0.11 0005 Xylene 1330-20-7 1 28 0 064 Total HAP 17 08 0 851 9 Total controlled dehydrator emissions calculated as a sum of controlled still vent emissions,combined with emissions during control device downtime 10 Demonstrating an overall system control of 95%,calculated as[100%-Total Controlled Dehy VOC Emissions/Total Uncontrolled Dehy Emissions] Natural Gas Dehydration • Condenser Vent Stream Detail from GRI-GLYCalc Description Vent Flow Rate .. scf/hr Hours of operation ,. hr/yr Annual Flow Rate 8 935 MMsc iyr Pure Component Pure Component Component Fraction Component Component Fraction • Component Vol% Mol Fraction Mol Weight Mol Weight Mass Fraction Heat Value Heat Value • (lb/lb-moll (Ib/lb-cool) (Btulscf) (Btufscf) Methane 0 0506 16 04 0 81 0.0200 1010 0 51 1 • • Ethane • 0.0779 30 07. 2.34 00578 1769 6 137.9 Propane 00886 4410 391 00965 2516.1 2229 i-Butane 00204 5812 1.19 00293 32519 663 • n-Butane , 0.0704 58 12 4 09 0.1011 3262.3 229 7 • i. Pentane 00181 72 15 131 00323 40009 724 • n-Pentane 0 0257 72 15 1.85 0.0458 4008 9 1030 Cyclopentane i .. 0 0082 70 13 0 57 0 0142 37633.9 30.8 n-Hexane 0 0098 88 18 0 84 0.0208 4755 9 46 5 Cyclohexane 0 0147 84 16 1 24 0.0306 44815 659 Other Hexa nes 00131 8618 1 13 00279 47559 623 Heptanes 0 0116 100 20 t 16 0.0287 5502 5 63 8 Methylcyclohexane ... 0 0000 98.19 000 0.0000 5215.7 0 0 • 2,2,4-T rimethylpentane .. 0 0000 11423 0 00 0 0000 6231.7 0 0 Benzene 0 1050 78 1 1 8 20 0 2026 3741 8 392 9 Toluene •, 0 0828 92 14 7 63 0.1884 4475.0 370.5 • Ethylbenzene 00011 100 17 0 12 0 0029 52222 5 7 • • • Xylenes 0 0128 318 50 4 08 0.1007 5208 8 66 7 • Octanes+ _• . 00002 11423 002 0.0006 6248.9 1 3 61.10 06110 4049 100 1990 • • Flash Tank Emissions Stream Detail from GRI-GLYCalc 4.0 • • Description• Vent Flow Rate ... sctlhr • • Hours of operation • hr/yr • Annual Flow Rate 21 287 MMscf/yr • • Pure Component Pure Component • Component Fraction Component Component Fraction Component Vol% Mol Fraction Mol Weight Mol Weight Mass Fraction Heat Value Heat Value • • (Ibllb-mol) (Ibllb-nwl) (Btu/scf) (Btu/scf) • Methane O4620 16.04 7.41 0.3008 10100 466.6 Ethane . . 0 2060 30 07 6.19 0 2514 1769 6 364 5 Propane . ._ .. 0.1080 44.10 4 76 0 1933 2516,1 271.7 • i-Butane -.•... 0 0166 58.12 0 96 0 0392 3251 9 54 0 n-Butane ... 0 0441 58.12 2 56 0 1040 3262.3 143.9 i-Pentane :.. 0 0102 72 15 0 74 0 02299 4000 9 40 8 • n-Pentane ... 0 0118 72.15 0.85 0.0345 4008.9 47 3 Cyclopentane 00010 70.13 0.07 00028 37639 3.7 n-Hexane O.0026 86.18 023 0 0092 4755 9 12 6 Cyclohexane 0.0011 84.16 0.09 0 0036 4481 5 4 7 Other Hexanes 0.0046 86.18 0.39 0 0159 4755.9 21 6 Heptanes 0.0D18 100.20 0.18 0 0073 5502 5 9.9 Methylcyclohexane - 00000 98.19 0,D0 0 0000 5215 7 0 0 2.2,4-T rimethylpentane 0.0000 114 23 0.00 0 0000 6231 7 0 0 Benzene .... 0 0011 78 11 0 09 0 0035 3741 8 4 1 Toluene _ 0 0007 92.14 0 07 0 0027 4475.0 3.3 Eth ylbenzene .. 0 0000 106 17 0.00 0 0000 5222 2 0.1 • Xylenes - . 00001 31850 003 00011 52088 04 Octanes* . .. 0.0002 114.23 0 02 0 0008 6248.9 1 1 87 18 0 8718 24 64 1 00 1450 • • • • • • Enclosed Combustor COMB-1 Emissions Enterprise Compressor Station DCP Midstream, LP Enclosed Combustor Fuel Usage 110 scf/hr Pilot Gas 1,148 BTU/SCF Fuel Healing Value 8 760 hr/yr Hours per Year 096 MMscf/yr Fuel Use 1,106 MMBtu/yr Fuel Use Enclosed Combustor Waste Gas Flow Usage 1990 Btu/scf Still Vent Gas Heat Value 8 94 MMscf/yr Worst-case Still Vent Gas Flowrate 17779 MMBtu/yr Still Vent To Combustor 1450 Btu/scf Flash Gas Heat Value 21 29 MMscf/yr Worst-case Flash Gas Flowrate 1544 MMBtu/yr Flash Gas To Combustor(5%during VRU Downtime) 1105 8 MMBtu/yr Fuel Heat 17,779 MMBtu/yr Still Vent Heat 1,544 MMBtu/yr Flash Gas Heat 18,884 MMBTU/yr 216 MMBtu/hr 10 96 MMscf/yr Combustion Emissions at COMB-1 EF Emissions lb/MMBlu ton/yr NOx 0 068 0 64 CO 0 37 3 49 AP-42 Table 13 5-1 II Glycalc inputs GRI-GLYCalc VERSION 4.0 - SUMMARY OF INPUT VALUES Case Name: Enterprise TEG Dehydration Unit D2_testl File Name: \\dennas00\data\Environmental\Air\Colorado\Enterprise\2016 Title V Renewal + Minor Mod\Dehy Mod\Updated Dehy Glycalc Run_test7.ddf Date: July 25, 2016 DESCRIPTION: Description: 110 MMscfd 35 gpm Glycol circ rate Inlet Gas Temp: 120 F Inlet Gas Pressure: 950 psig Old EGA Annual Hours of Operation: 8760.0 hours/yr WET GAS: Temperature: 120.00 deg. F Pressure: 950.00 psig Wet Gas Water Content: Saturated Component Conc. (vol %) Carbon Dioxide 2.6600 Nitrogen 0.3200 Methane 73.6091 Ethane 13.4435 Propane 5.7633 Isobutane 0.8119 n-Butane 1.8738 Isopentane 0.5005 n-Pentane 0.5144 Cyclopentane 0.0240 n-Hexane 0.1123 Cyclohexane 0.0286 Other Hexanes 0.2068 Heptanes 0.0782 Benzene 0.0251 Toluene 0.0204 Page 1 Glycalc inputs Ethylbenzene 0.0004 Xylenes 0.0038 C8+ Heavies 0.0227 DRY GAS: Flow Rate: 110.0 MMSCF/day Water Content: 7.0 lbs. H20/MMSCF LEAN GLYCOL: Glycol Type: TEG Water Content: 1.5 wt% H2O Flow Rate: 35.0 gpm PUMP: Glycol Pump Type: Electric/Pneumatic FLASH TANK: Flash Control: Recycle/recompression Temperature: 130.0 deg. F Pressure: 50.0 psig REGENERATOR OVERHEADS CONTROL DEVICE: Control Device: Condenser Temperature: 140.0 deg. F Pressure: 12.5 psia Control Device: Combustion Device Destruction Efficiency: 95.0 Page 2 - I Glycalc inputs Excess Oxygen: 0.0 Ambient Air Temperature: 0.0 deg. F Page 3 Page: 1 GRI-GLYCaic VERSION 4.0 - AGGREGATE CALCULATIONS REPORT Case Name: Enterprise TEG Dehydration Unit D2 testl File Name: \\dennas00\data\Environmental\Air\Colorado\Enterprise\2016 Title V Renewal + Minor Mod\Dehy Mod\Updated Dehy Glycalc Run_test7.ddf Date: July 20, 2016 DESCRIPTION: Description: 110 MMscfd 35 gpm Glycol circ rate Inlet Gas Temp: 120 F Inlet Gas Pressure: 950 psig Old EGA Annual Hours of Operation: 8760.0 hours/yr EMISSIONS REPORTS: CONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Methane 0.1085 2.604 0.4751 Ethane 0.3134 7.522 1.3728 Propane 0.5227 12 .545 2.2894 Isobutane 0.1582 3.798 0.6931 n-Butane 0.5472 13.133 2.3968 Isopentane 0.1749 4 .199 0.7663 n-Pentane 0.2476 5.943 1.0846 Cyclopentane 0.0769 1 .845 0.3367 n-Hexane 0.1126 2.703 0.4933 Cyclohexane 0.1655 3 .973 0 .7250 Other Hexanes 0.1515 3 .635 0.6635 Heptanes 0. 1553 3 .728 0.6804 Benzene 1.1016 26.440 4 .8252 Toluene 1.0207 24 .496 4 .4706 Ethylbenzene 0.0157 0 .377 0.0687 Xylenes 0.1825 4.381 0.7994 C8+ Heavies 0.0046 0.110 0.0201 Total Emissions 5.0596 121.430 22.1610 Total Hydrocarbon Emissions 5.0596 121.430 22.1610 Total VOC Emissions 4 .6377 111.305 20.3131 Total HAP Emissions 2.4332 58.396 10.6573 Total BTEX Emissions 2.3205 55.693 10.1640 UNCONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Methane 2.1704 52.090 9.5065 I.I.... Ethane 6.2781 150.676 27.4983 Propane 10.5271 252.650 46.1086 Isobutane 3.2064 76.953 14 .0440 n-Butane 11. 1394 267.346 48.7906 Isopentane 3 .6655 87.973 16.0551 n-Pentane 5.2523 126.055 23.0050 Cyclopentane 1.6500 39.601 7.2271 • Page: 2 n-Hexane 2.5094 60.225 10.9911 Cyclohexane 3.8631 92.714 16.9203 Other Hexanes 3.2888 78.932 14 .4051 Heptanes 4 .0388 96.932 17.6901 Benzene 26.7677 642.425 117.2426 Toluene 32.2503 774 .008 141,2565 Ethylbenzene 0.8628 20.707 3.7791 Xylenes 10.9080 261.793 47.7772 C8+ Heavies 7.2243 173 .383 31.6424 Total Emissions 135.6026 3254 .462 593 .9394 Total Hydrocarbon Emissions 135.6026 3254 .462 593.9394 Total VOC Emissions 127.1540 3051 .697 556.9346 Total HAP Emissions 73.2983 1759.159 321.0464 Total BTEX Emissions 70.7889 1698.933 310.0553 FLASH GAS EMISSIONS Note: Flash Gas Emissions are zero with the Recycle/recompression control option. FLASH TANK OFF GAS Component lbs/hr lbs/day tons/yr Methane 47.4149 1137.958 207.6774 Ethane 39.5651 949.561 173 .2949 Propane 30.4500 730 .799 133 .3709 Isobutane 6.1891 148 .540 27.1085 n-Butane 16.4154 393.970 71.8996 Isopentane 4 .7269 113.446 20.7039 n-Pentane 5.4557 130.936 23.8958 Cyclopentane 0.4386 10.527 1.9211 n-Hexane 1 .4554 34 .930 6.3747 Cyclohexane 0.5675 13.619 2.4855 Other Hexanes 2.5120 60.287 11.0024 Heptanes 1 .1527 27.664 5.0486 Benzene 0.5504 13.209 2.4107 Toluene 0 .4291 10.299 1.8797 Ethylbenzene 0.0067 0.160 0.0292 Xylenes 0.0582 1.396 0.2548 C8+ Heavies 0.1980 4 .751 0.8671 Total Emissions 157.5855 3782 .053 690.2247 Total Hydrocarbon Emissions 157.5855 3782.053 690.2247 Total VOC Emissions 70 .6056 1694.533 309.2524 Total HAP Emissions 2.4998 59.994 10.9490 Total BTEX Emissions 1 .0444 25.065 4 .5743 EQUIPMENT REPORTS: CONDENSER AND COMBUSTION DEVICE Page: 3 Condenser Outlet Temperature: 140.00 deg. F Condenser Pressure: 12.50 psia Condenser Duty: 4 .05e-001 MM BTU/hr Hydrocarbon Recovery: 2 .75 bbls/day Produced Water: 30.71 bbls/day Ambient Temperature: 0.00 deg. F Excess Oxygen: 0.00 % Combustion Efficiency: 95.00 % Supplemental Fuel Requirement: 4 .05e-001 MM BTU/hr Component Emitted Destroyed Methane 5.00% 95.00% Ethane 4 .99% 95 .01% Propane 4 .97% 95.03% Isobutane 4 .94% 95.06% n-Butane 4 .91% 95.09% Isopentane 4 .77% 95.23% n-Pentane 4 .71% 95.29% Cyclopentane 4.66% 95.34% n-Hexane 4.49% 95.51% Cyclohexane 4 .28% 95.72% Other Hexanes 4 .61% 95 .39% Heptanes 3 .85% 96.15% Benzene 4 .12% 95.88% Toluene 3.16% 96.84% Ethylbenzene 1.82% 98.18% Xylenes 1.67% 98.33% C8+ Heavies 0.06% 99.94% ABSORBER NOTE: Because the Calculated Absorber Stages was below the minimum allowed, GRI-GLYCalc has set the number of Absorber Stages to 1.25 and has calculated a revised Dry Gas Dew Point. Calculated Absorber Stages: 1 .25 Calculated Dry Gas Dew Point: 6.35 lbs. H2O/MMSCF Temperature: 120.0 deg. F Pressure: 950 .0 psig Dry Gas Flow Rate: 110.0000 MMSCF/day Glycol Losses with Dry Gas: 6.1074 lb/hr Wet Gas Water Content: Saturated Calculated Wet Gas Water Content: 106.26 lbs. H2O/MMSCF Calculated Lean Glycol Recirc. Ratio: 4 .58 gal/lb H2O Remaining Absorbed Component in Dry Gas in Glycol Water 5.96% 94 .04% Carbon Dioxide 99.62% 0.38% Nitrogen 99.96% 0.04% Methane 99.97% 0.03% Ethane 99.91% 0.09% Propane 99.87% 0 .13% Isobutane 99.84% 0.16% n-Butane 99.79% 0.21% Isopentane 99.81% 0.19% n-Pentane 99.76% 0.24% Cyclopentane 98 .97% 1.03% Page: 4 n-Hexane 99.66% 0.34% Cyclohexane 98.48% 1.52% Other Hexanes 99.73% 0.27% Heptanes 99.45% 0.55% Benzene 88.47% 11.53% Toluene 85 .61% 14.39% Ethylbenzene 83 .06% 16.94% Xylenes 77.50% 22.50% C8+ Heavies 98.41% 1.59% FLASH TANK Flash Control: Recycle/recompression Flash Temperature: 130.0 deg. F Flash Pressure: 50.0 psig Left in Removed in Component Glycol Flash Gas Water 99.95% 0.05% Carbon Dioxide 34 .76% 65.24% Nitrogen 4 .24% 95.76% Methane 4 .38% 95.62% Ethane 13 .69% 86.31% Propane 25.69% 74 .31% Isobutane 34 . 13% 65.87% n-Butane 40.43% 59.57% Zsopentane 43 .96% 56.04% n-Pentane 49.30% 50.70% Cyclopentane 79.10% 20.90% n-Hexane 63 .47% 36.53% Cyclohexane 87.60% 12.40% Other Hexanes 57.13% 42.87% Heptanes 77.91% 22.09% Benzene 98.09% 1 .91% Toluene 98.79% 1.21% Ethylbenzene 99.31% 0 .69% Xylenes 99.54% 0.46% C8+ Heavies 97.65% 2 .35% REGENERATOR No Stripping Gas used in regenerator. Remaining Distilled Component in Glycol Overhead Water 39 .16% 60.84% Carbon Dioxide 0.00% 100.00% Nitrogen 0.00% 100.00% Methane 0.00% 100.00% Ethane 0.00% 100.00% Propane 0.00% 100 .00% Isobutane 0.00% 100 .00% n-Butane 0.00% 100.00% Zsopentane 1. 14% 98.86% n-Pentane 1 .01% 98.99% Cyclopentane 0.63% 99.37% n-Hexane 0.79% 99.21% Page: 5 Cyclohexane 3.65% 96.35% Other Hexanes 1.75% 98.25% Heptanes 0.64% 99.36% Benzene 5.10% 94 .90% Toluene 8.00% 92.00% Ethylbenzene 10.48% 89.52% Xylenes 12.99% 87.01% C8+ Heavies 12.32% 87.68% STREAM REPORTS: WET GAS STREAM Temperature: 120.00 deg. F Pressure: 964 .70 psia Flow Rate: 4 .60e+006 scfh Component Conc. Loading (vol%) (lb/hr) Water 2.24e-001 4 .88e+002 Carbon Dioxide 2.65e+000 1.41e+004 Nitrogen 3.19e-001 1.08e+003 Methane 7. 34e+001 1.43e+005 Ethane 1.34e+001 4.89e+004 Propane 5.75e+000 3.07e+004 Isobutane 8.10e-001 5.70e+003 n-Butane 1.87e+000 1.32e+004 Isopentane 4 .99e-001 4 .36e+003 n-Pentane 5.13e-001 4 .49e+003 Cyclopentane 2 .39e-002 2.03e+002 n-Hexane 1.12e-001 1.17e+003 Cyclohexane 2.85e-002. 2.91e+002 Other Hexanes 2.06e-001 2. 15e+003 Heptanes 7.80e-002 9.47e+002 Benzene 2.50e-002 2.37e+002 Toluene 2.04e-002 2.27e+002 Ethylbenzene 3 .99e-004 5.13e+000 Xylenes 3 .79e-003 4.88e+001 C8+ Heavies 2 .26e-002 4 .67e+002 Total Components 100.00 2.71e+005 DRY GAS STREAM Temperature: 120.00 deg. F Pressure: 964 .70 psia Flow Rate: 4 .58e+006 scfh Component Conc. Loading (vol%) (lb/hr) Water 1.34e-002 2.91e+001 Carbon Dioxide 2.65e+000 1.41e+004 Nitrogen 3 .20e-001 1.08e+003 Methane 7.36e+001 1.43e+005 Ethane 1.34e+001 4 .88e+004 Propane 5.76e+000 3 .07e+004 Page: 6 Isobutane 8.11e-001 5 .69e+003 n-Butane 1.87e+000 1 .31e+004 Isopentane 5.00e-001 4 .36e+003 n-Pentane 5.13e-001 4 .47e+003 Cyclopentane 2.38e-002 2 .01e+002 n-Hexane 1 .12e-001 1.17e+003 Cyclohexane 2.82e-002 2 .86e+002 Other Hexanes 2.06e-001 2.15e+003 Heptanes 7.78e-002 9.42e+002 Benzene 2 .22e-002 2.10e+002 Toluene 1.75e-002 1.94e+002 Ethylbenzene 3 .32e-004 4 .26e+000 Xylenes 2.95e-003 3 .78e+001 C8+ Heavies 2.23e-002 4 .60e+002 Total Components 100.00 2.71e+005 LEAN GLYCOL STREAM Temperature: 120.00 deg. F Flow Rate: 3 .50e+001 gpm Component Conc. Loading (wt%) (lb/hr) TEG 9.85e+001 1.94e+004 Water 1 .50e+000 2.95e+002 Carbon Dioxide 2.70e-011 5.32e-009 Nitrogen 2.21e-013 4 .35e-011 Methane 8.46e-018 1.67e-01S Ethane 1. 10e-007 2.16e-005 Propane 8.47e-009 1.67e-006 Isobutane 1.43e-009 2.82e-007 n-Butane 3.47e-009 6.83e-007 Isopentane 2.14e-004 4 .22e-002 n-Pentane 2 .73e-004 5 . 38e-002 Cyclopentane 5.33e-005 1 .05e-002 n-Hexane 1.01e-004 1.99e-002 Cyclohexane 7.44e-004 1 .46e-001 Other Hexanes 2.98e-004 5 .86e-002 Heptanes 1.32e-004 2.61e-002 Benzene 7.30e-003 1.44e+000 Toluene 1.42e-002 2.80e+000 Ethylbenzene 5 .13e-004 1.01e-001 Xylenes 8.27e-003 1.63e+000 C8+ Heavies 5.15e-003 1.01e+000 Total Components 100.00 1 . 97e+004 RICH GLYCOL STREAM Temperature: 120.00 deg. F Pressure: 964.70 psia Flow Rate: 3.66e+001 gpm NOTE: Stream has more than one phase. • Component Conc. Loading (wt%) (lb/hr) TEG 9.46e+001 1 .94e+004 Water 3 .68e+000 7.55e+002 Page: 7 Carbon Dioxide 2.60e-001 5.32e+001 Nitrogen 2.13e-003 4 .36e-001 Methane 2.42e-001 4 .96e+001 Ethane 2.24e-001 4 .58e+001 Propane 2.00e-001 4 .10e+001 Isobutane 4 .59e-002 9.40e+000 n-Butane 1.34e-001 2.76e+001 Isopentane 4 .12e-002 8.43e+000 n-Pentane 5.25e-002 1.08e+001 Cyclopentane 1.02e-002 2 .10e+000 n-Hexane 1.94e-002 3 .98e+000 Cyclohexane 2.23e-002 4 .58e+000 Other Hexanes 2.86e-002 5.86e+000 Heptanes 2.55e-002 5.22e+000 Benzene 1.40e-001 2.88e+001 Toluene 1.73e-001 3 .55e+001 Ethylbenzene 4 .74e-003 9.70e-001 Xylenes 6.15e-002 1.26e+001 C8+ Heavies 4 .12e-002 8.44e+000 Total Components 100.00 2.05e+004 FLASH TANK OFF GAS STREAM Temperature: 130.00 deg. F Pressure: 64 .70 psia Flow Rate: 2.43e+003 scfh Component Conc. Loading ;vol%) (lb/hri Water 3 .12e-001 3.60e-001 Carbon Dioxide 1.23e+001 3.47e+001 Nitrogen 2.33e-001 4 .17e-001 Methane 4.62e+001 4 .74e+001 Ethane 2.06e+001 3.96e+001 Propane 1.08e+001 3.04e+001 Isobutane 1 .66e+000 6. 19e+000 n-Butane 4 .41e+000 1.64e+001 Isopentane 1.02e+000 4.73e+000 n-Pentane 1.18e+000 5.46e+000 Cyclopentane 9.77e-002 4.39e-001 n-Hexane 2.64e-001 1.46e+000 Cyclohexane 1.05e-001 5.67e-001 Other Hexanes 4 .55e-001 2.51e+000 Heptanes 1.80e-001 1. 15e+000 Benzene 1.10e-001 5.50e-001 Toluene 7.28e-002 4 .29e-001 Ethylbenzene 9.81e-004 6.66e-003 Xylenes 8.56e-003 5.82e-002 C8+ Heavies 1.82e-002 1.98e-001 Total Components 100.00 1.93e+002 FLASH TANK GLYCOL STREAM Temperature: 130.00 deg. F Flow Rate: 3 .62e+001 gpm Component Conc. Loading Page: 8 (wt%) (lb/hr) TEG 9.55e+001 1 .94e+004 Water 3 .72e+000 7.54e+002 Carbon Dioxide 9.11e-002 1 .85e+001 Nitrogen 9.09e-005 1 .84e-002 Methane 1.07e-002 2.17e+000 Ethane 3 .09e-002 6.28e+000 Propane 5 .19e-002 1.05e+001 Isobutane 1.58e-002 3 .21e+000 n-Butane 5.49e-002 1.11e+001 Isopentane 1.83e-002 3.71e+000 n-Pentane 2.61e-002 5.31e+000 Cyclopentane 8.18e-003 1 .66e+000 n-Hexane 1.25e-002 2.53e+000 Cyclohexane 1.98e-002 4 .01e+000 Other Hexanes 1.65e-002 3 .35e+000 Heptanes 2_00e-002 4 .06e+000 Benzene 1 .39e-001 2.82e+001 Toluene 1.73e-001 3.51e+001 Ethylbenzene 4 .75e-003 9.64e-001 Xylenes 6.18e-002 1.25e+001 C8+ Heavies 4 .06e-002 8.24e+000 Total Components 100.00 2.03e+004 FLASH GAS EMISSIONS Control Method: Recycle/recompression Control Efficiency: 100. 00 Note: Flash Gas Emissions are zero with the Recycle/recompression control option. REGENERATOR OVERHEADS STREAM Temperature: 212.00 deg. F Pressure: 14 .70 psia Flow Rate: 1.06e+004 scfh Component Conc. Loading (vol%) (lb/hr) Water 9.14e+001 4 .59e+002 Carbon Dioxide 1.51e+000 1.85e+001 Nitrogen 2.36e-003 1.84e-002 Methane 4 .85e-001 2.17e+000 Ethane 7.49e-001 6.28e+000 Propane 8.56e-001 1.05e+001 Isobutane 1.98e-001 3 .21e+000 n-Butane 6.87e-001 1.11e+001 Isopentane 1 .82e-001 3 .67e+000 n-Pentane 2.61e-001 5.25e+000 Cyclopentane 8.44e-002 1.65e+000 n-Hexane 1 .04e-001 2.51e+000 Cyclohexane 1 .65e-001 3 .86e+000 Other Hexanes 1 .37e-001 3.29e+000 Heptanes 1.45e-001 4 .04e+000 Benzene 1.23e+000 2.68e+001 Toluene 1.26e+000 3 .23e+001 Page: 9 Ethylbenzene 2.91e-002 8.63e-001 Xylenes 3.68e-001 1 .09e+001 C8+ Heavies 1.52e-001 7.22e+000 Total Components 100.00 6.13e+002 CONDENSER PRODUCED WATER STREAM Temperature: 140.00 deg. F Flow Rate: 8.96e-001 gpm Component Conc. Loading (wt%) (lb/hr) (ppm) Water 9.99e+001 4 .48e+002 999057. Carbon Dioxide 9.74e-003 4 .37e-002 97. Nitrogen 2.91e-007 1 .30e-006 0. Methane 6.29e-005 2 .82e-004 1. Ethane 1.99e-004 8.91e-004 2 . Propane 3.87e-004 1.73e-003 4 . Isobutane 6.24e-005 2.80e-004 1 . n-Butane 2.80e-004 1 .26e-003 3. Isopentane 6.14e-005 2.75e-004 1. n-Pentane 9.21e-005 4 .13e-004 1. Cyclopentane 1.88e-004 8.43e-004 2 . n-Hexane 3.35e-005 1.50e-004 0 . Cyclohexane 2.60e-004 1.17e-003 3. Other Hexanes 3 .68e-005 1.65e-004 0. Heptanes 2.50e-005 1.12e-004 0. Benzene 4 .42e-002 1.98e-001 442. Toluene 3.25e-002 1.46e-001 325. Ethylbenzene 3 .67e-004 1.64e-003 4 . Xylenes 5.78e-003 2.59e-002 58. C8+ Heavies 3.76e-007 1.69e-006 0. Total Components 100.00 4 .48e+002 1000000. CONDENSER RECOVERED OIL STREAM Temperature: 140.00 deg. F Flow Rate: 8.01e-002 gpm Component Conc. Loading (wt%) (lb/hr) Water 5.73e-002 1.95e-002 Carbon Dioxide 4.60e-002 1.57e-002 Nitrogen 2.35e-005 7.99e-006 Methane 1.57e-003 5.36e-004 Ethane 2.62e-002 8.92e-003 Propane 2.10e-001 7.15e-002 Isobutane 1.21e-001 4 .13e-002 n-Butane 5.69e-001 1.94e-001 Isopentane 4.88e-001 1.66e-001 n-Pentane 8.78e-001 2.99e-001 Cyclopentane 3.28e-001 1.12e-001 n-Hexane 7.53e-001 2.57e-001 Cyclohexane 1.62e+000 5.51e-001 Other Hexanes 7.61e-001 2.59e-001 Heptanes 2.74e+000 9.32e-001 Benzene 1.33e+001 4 .54e+000 Page: 10 Toluene 3.43e+001 1 .17e+001 Ethylbenzene 1.61e+000 5.47e-001 Xylenes 2.12e+001 7.23e+000 C8+ Heavies 2.09e+001 7.13e+000 Total Components 100.00 3 .41e+001 CONDENSER VENT STREAM Temperature: 140.00 deg. F Pressure: 12.50 psia Flow Rate: 1 .02e+003 scfh Component Conc. Loading (vol%) (lb/hr) Water 2.32e+001 1 .12e+001 Carbon Dioxide 1 .56e+001 1 .84e+001 Nitrogen 2 .46e-002 1 .84e-002 Methane 5 .06e+000 2 .17e+000 Ethane 7.79e+000 6.27e+000 Propane 8.86e+000 1 .05e+001 Isobutane 2.04e+000 3.16e+000 n-Butane 7.04e+000 1.09e+001 Isopentane 1 .81e+000 3.50e+000 n-Pentane 2 .57e+000 4 .95e+000 Cyclopentane 8.19e-001 1.54e+000 n-Hexane 9.77e-001 2.25e+000 Cyclohexane 1 .47e+000 3.31e+000 Other Hexanes 1 .31e+000 3.03e+000 Heptanes 1.16e+000 3. 11e+000 Benzene 1.05e+001 2.20e+001 Toluene 8.28e+000 2.04e+001 Ethylbenzene 1 .10e-001 3.14e-001 Xylenes 1.28e+000 3. 65e+000 C8+ Heavies 2.02e-002 9. 19e-002 Total Components 100.00 1 .31e+002 COMBUSTION DEVICE OFF GAS STREAM Temperature: 1000 .00 deg. F Pressure: 14 .70 psia Flow Rate: 3.10e+001 scfh Component Conc. Loading (vole) (lb/hr) Methane 8.27e+000 1.08e-001 Ethane 1 .27e+001 3.13e-001 Propane 1 .45e+001 5 .23e-001 Isobutane 3 .33e+000 1 .58e-001 n-Butane 1.15e+001 5.47e-001 Isopentane 2 .96e+000 1.75e-001 n-Pentane 4 .20e+000 2 .48e-001 Cyclopentane 1.34e+000 7.69e-002 n-Hexane 1 .60e+000 1 . 13e-001 Cyclohexane 2.40e+000 1.66e-001 Other Hexanes 2.15e+000 1.51e-001 Heptanes 1 .90e+000 1 .55e-001 Benzene 1.72e+001 1.10e+000 Toluene 1.35e+001 1.02e+000 Page: 11 Ethylbenzene 1.81e-001 1 .57e-002 Xylenes 2.10O+000 1 .83e-001 C8+ Heavies 3.30e-002 4 .59e-003 Total Components 100.00 5.06e+000 ►1'l MPACT ANALYTICAL) YSTEMS IN_c:_----- 365 S.MAIN ST. BRIGHTON,CO 80601 A__ L J_____►____ 303631-0150 EXTENDED NATURAL GAS ANALYSIS('DHA) MAIN PAGE PROJECT NO. : 201103130 ANALYSIS NO.: 02 COMPANY NAME: DCP MIDSTREAM-LP ANALYSIS DATE: MARCH 19,2011 ACCOUNT NO. : SAMPLE DATE : MARCH 18,2011 PRODUCER : CYLINDER NO.: 888 LEASE NO. : SAMPLED BY : STEPHEN ONDAK NAME/DESCRIP: ENTERPRISE INLET PRE DENY 014:33 "'FIELD DATA"' SAMPLE TEMP.: 100 SAMPLE PRES.: 900 AMBIENT TEMP.: VAPOR PRES. : GRAVITY . COMMENTS : SPOT;NO PROBE GPM 0 GPM O COMPONENT MOLE% MASS% 14.650 14.730 ALCOHOLS 0.0006 0.0018 HELIUM 0.01 0.00 --- --- HYDROGEN 0.00 0.00 --- -- OXYGENIARGON 0.01 0.01 --- -- NITROGEN 0.32 0.40 --• --- CARBON DIOXIDE 2.59 5.09 •-- -- METHANE 73.60980 52.69890 --- --- ETHANE 13.4435 18.0401 3.5886 3.6082 PROPANE 5.7633 11.3416 1.5851 1.5938 I-BUTANE 0.8191 2.1247 0.2672 0.2686 N-BUTANE 1.8738 4.8604 0.5894 0.5928 I-PENTANE 0.5245 1.6886 0.1901 0.1911 N-PENTANE 0.5144 1.6563 0.1861 0.1871 HEXANES PLUS 0.5210 2.0898 0.2930 0.2940 TOTALS 100.00000 100.00000 6.6995 6.7354 BTEN COMPONENTS MOLE% WT% BTU® 14.650 14.730 BENZENE 0.0251 0.0875 LOW NET DRY REAL: 1163.7 lief 1170.1/scf TOLUENE 0.0204 0.0839 NET WET REAL: 1143.4 lid 1149.7 lad ETHYLBEN2ENE 0.0004 0.0019 HIGH GROSS DRY REAL: 1260.8 Ad 1287.8 lid XYLENES 0.0038 0.0181 GROSS WET REAL: 1258.4 Ad 1265.4 het TOTAL BTEX 0.0497 0.1914 NET DRY REAL: 19719.6 8b 19827.3 fib GROSS DRY REAL: 21713.0/lb 21831.5 fib RELATIVE DENSITY(AIR=I): 0.7727 (CAC:cO..4 SW MS A TP-170414.6966160 A) COMPRESSIBILITY FACTOR : 0.99816 YDLTAILFJ3 HYDROCARBONANALYSTS'W I99J);AS7M 06730 MIS DATA HAS BEEN ACQUIRED DIROUGH M'PL(CATION OF CURRENT STAIE•OF-7Hf.-ARTANALI77CAL TiV//NIQUt3 THE USE OF MISINIVRAIATR7X IS THE REIPOYSIMJIYOF IRE USER£./PACTAII'ALITICALS13Tt.TIS ASSUMES NO IKSPOMIRLFTY FOR ACCURACY OF THE REP ORIEDU?0illAr IN NOR M TCONSEQUJ 5oi/7'SAIWICA77OK MPACT ANALYTICAL SYSTEMS INC. 365 S. MAIN ST. BRIGHTON,CO 806O1 303-637.0150 EXTENDED NATURAL OAS ANALYSIS(*PHA) OLYCALC INFORMATION PROJECT NO. : 201103130 ANALYSIS NO.: 02 COMPANY NAME: DCP MIDSTREAM-LP ANALYSIS DATE: MARCH 19,2011 ACCOUNT NO. : SAMPLE DATE : MARCH 18,2011 PRODUCER : CYLINDER NO.: 886 LEASE NO. : SAMPLED BY : STEPHEN ONDAK NAME/DESCRIP: ENTERPRISE INLET PRE DENY 1.14:30 "'FIELD DATA"' SAMPLE TEMP.: 100 SAMPLE PRES.: 900 AMBIENT TEMP.: VAPOR PRES. : GRAVITY . COMMENTS : SPOT;NO PROBE Componet Mole% WI% Helium 0.01 0.00 Hydrogen 0.00 0.00 Carbon Dioxide 2.59 5.09 Nitrogen 0.32 0.40 Methane 73.60980 52.69890 Ethane 13.4435 18.0401 Propane 6.7833 11.3418 Isobutane 0.8191 2.1247 n-Butane 1.8738 4.8804 Isopentane 0.5005 1.6115 n-Pentane 0.5144 1.6563 Cyclopentane 0.0240 0.0751 n-Hexane 0.1123 0.4319 Cyclohexane 0.0286 0.1074 Other Hexanes 0.2068 0.7920 Haptanes 0.0782 0.3486 Methycyctohexane 0.0227 0.0995 2,2,4 Trimethylpentane 0.0000 0.0000 Benzene 0.0251 0.0875 Toluene 0.0204 0.0839 Ethylbenzene 0.0004 0.0019 Xylenes 0.0038 0.0181 C8+Heavies 0.0227 0.1190 Subtotal 99.98940 99.98840 Oxygen/Argon 0.01 0.01 Alcohols 0.0006 0.0016 Total 100.00000 10 0® THE DATA PRESENTED HEREIN HAS BEEN ACQUIRED THROUGH JUDICIOUS APPLICATION OF CURRENT STATE•OF-THE ART ANALYTICAL TECHNIQUES. THE APPLICATIONS OF THIS INFORMATION IS THE RESPONSIBILITY OF THE USER. EMPACT ANALYTICAL SYSTEMS,INC.ASSUMES NO RESPONSIBILITY FOR ACCURACY OF THE REPORTED INFORMA HON NOR ANY CONSEQUENCES OF Irs APPLICATION. EMPACT EXTENDED NATURAL GAS ANALYSIS I"D11A1 PHA COMPONENT LIST PROJECT NO.: 201103130 ANALYSIS NO.: 02 COMPANY NAME: DCP MIDSTREAM-LP ANALYSIS DATE: MARCH 19,2011 ACCOUNT NO.: SAMPLE DATE: MARCH 18,2011 PRODUCER : CYLINDER NO.: 886 LEASE NO. : SAMPLED BY : STEPHEN ONDAK NAME#DESCRIP: ENTERPRISE INLET PRE DF11Y Q1430 '. ***FIELD DATA" SAMPLE TEMP.: 100 SAMPLE PRES.: 900 AMBIENT TEMP.: VAPOR PRES.: GRAVITY : COMMENTS : SPOT;NO PROBE GPM@ GPM® COMPONENT PIANOM MOLE% MASS% 14.650 14.730 lleliom --- 0.01 0.00 •-- --- Hydrogen •-- 0.00 0.00 --- ••- Oxygen/Argon -•- 0.01 0.01 --- --- Nitrogen •-- 0.32 0.40 --- --- Carbon Dioxide --- 2.19 5.09 -•- •-- Methane PI 73.60980 52.69890 --- --- Ethane P2 13.4435 18.0101 3.1886 3.6082 Propane P3 5.7633 11.3416 15851 1.3938 i-Butane 14 0.8191 2.1247 02672 02686 n-Butane P4 1.8738 4.8604 0.5894 0.3926 2,2-Dhnerhylpropane IS 0.0051 0.0164 0.0020 0.0020 Ethanol X2 0.0001 0.0002 0.0000 0.0000 i•Penraen IS 04954 15951 0.1811 0.1821 I-Prepasol X3 0.0004 0.0011 0.0000 0.0000 n-Penlaa. _ P5 0.5144 1.6563 0.1861 0.1871 2,2-Dintahytbagne I6 0.0072 0.0277 0.0030 0.0030 n•Ptopapo' X3 0.0001 0.0003 0.0000 0.0000 Cyclopcntane N5 0.0240 0.0751 0.0070 0.0070 2,-1•Dimet ylbutane 16 0.0160 0.0615 0.0070 0.0070 2-Methylpentane 16 0.0971 0.3735 0.0400 0.0102 3\lnhylpentane 16 0.0492 0.1892 0.0200 0.0201 n-Henna P6 0.1123 0.4319 0.0460 0.0163 2,2-Dienhylpentane 17 0.0022 0.0098 0.0010 0.0010 blethylcyclopentane 146 0.0373 0.1401 0.0130 0.0131 2,4•Dimerhylpentate 17 0.0041 0.0183 0.0020 0.0020 2,2,3-Trirnethylburane 17 0,!001 0.0018 0.0000 0.0000 Benzene A6 0.0251 0.0875 0.0070 0.0070 3,3•Dimethytpemane 17 0.0008 0,0036 0.0000 0.0000 Cyclobexure 146 0.0286 0.1074 0.0100 0.0101 2-Methylhexane 17 0.0146 0.0653 00070 0.0070 2,3-Dimethylpeatane 17 0.0036 0.0161 0.0020 0.0020 1,I-Dian ethylcydopenrane N7 0.0033 0.0145 0.0010 0.0010 3.1detitylhocano 17 0.0129 0.0377 0.0060 0.0060 lc,3-Dimethyleyclopentene 147 0.0033 0.0154 0.0020 0.0020 11,3-Ditnethyleyelopenleee N7 0.0031 0.0136 0.0010 0.0010 3•Elhylpeatene 17 0.0003 0.0013 0.0000 0.0000 11,2-Dimethyleyclopentane N7 0.0051 0.0224 0.0020 043020 ' a-Heptane P7 0.0233 0.1042 0.0110 0.0111 Ic,2-Dimcthyiryclopcniane N7 0.0001 0.0005 0.0000 0.0000 Page 1 IMPACT Analytical Systems,Inc 305 3.Main Slreal 8dghten,CO 60001 303431-0150 blethylcyclobexano N7 0.0227 0.0995 0.0090 0.0091 2,2-Dimethylhexattc 18 0.0009 0,0046 0.0000 0.0000 1.1,3-TrimcthytcycIopentene N7 0.0003 0.0015 0.0000 0.0000 Ethylcyclopemenn N7 0.0006 0.0026 0.0000 0.0000 2,5•DimethyIbesme 18 0-0007 0.0036 0.0000 0.0000 2,4•Dimethylhcseoe 18 0.0008 0.0041 0.0000 0.0000 1e,2t,4-Trimethylcyclopemane NO 0.0007 0.0035 0.0000 0.0000 3,3-Dimethylhexaae IS 0.0002 0.0010 0.0000 0.0000 It.2G4•Tlimethylcyclopetxane N8 0.0005 0.0025 0.0000 0.0000 Toluene Al 0.0204 0.0839 0.0070 0.0070 2.3•Dieuedtylbexane 18 0.0004 0.0021 0.0000 0.0000 2•hkthylbeptane 18 0.0028 0.0143 0.0010 0.0010 4-Methylheplane 18 0.0009 0.0046 0.0000 0.0000 3-hlethyl•3•ehyipentaae 18 0.0001 0.0005 0.0000 0.0000 3-lkihylheptane 18 0.0001 0.0005 0.0000 0.0000 10,2t,3•Trimethyieyetopemane NO 0.0035 0.0175 0.0020 0.0020 3-Edylherene It 0.0002 0.0010 0.0000 0.0000 1t4.Dimethyiryclehessee N8 0.0009 0.0045 0.0000 0.0000 1,1•Dime0ylcyckhesane NO 0.0001 0.0020 0.0000 0.0000 3t-Ethylmethylcyclopentme NO 0.0001 0.0005 0.0000 0.0000 2I-Ethylmethylcyclopentens NO 0.0001 0.0005 0.0000 0.0000 I,1 Meehylethylgelopentane N8 0.0001 0.0005 0.0000 0.0000 1L2•Dimetbylyclohexme N8 0.0006 0.0030 0.0000 0.0000 a Octane P8 0.0036 0.0183 0.0020 0.0020 Ie,4•DimethylcycIehexane N8 0.0002 0.0010 0.0000 0.0000 2,3,5-Trimdhylhesanc 19 0.0001 0.0006 0.0000 0.0000 2,3,4•Trimethylhcc no 19 0.0001 0.0006 0.0000 0,0000 Ic,2-Dimeth>lcyelobexano NO 0.0001 0.0005 0.0000 0.0060 1,1,4•Trireethykyclohecane 8151 0.0007 0.0039 0.0000 0.0000 2,2,3•Trimcihyihexene 19 0.0002 0.0012 0.0000 0.0000 Ethytcyclohcxano NO 0.0002 0.0010 0.0000 0.0000 e-Peopykyclopcntanc 1,18 0.0002 0.0010 0.0000 0.0000 tc,3c,5-Tdmcdtp1 yclu!exaue N9 0.0001 0.0006 0.0000 0.0000 Ethytbenzenc 18 0.0004 0.0019 0.0000 0.0000 Ieb,41•Trtmeehylcyvlohexenn N9 0.0001 0.0006 0.0000 0.0000 1,3•D[methylbeezeae(m-Xylene) A8 0.0023 0.0109 0.0010 0.0010 1.4-Dime thy1be0z40e(p•Xylene) AS 0.0009 0.0043 0.0000 00000 3,4•Dimedtylheptane 19 0.0002 0.0012 0.0000 0.0000 3.4-Dlmethylheptane(2) 19 0.0001 0.0006 0.0000 0.0000 4-EOry'Iheptane 19 0.0001 0.0006 0.0000 0.0000 4 Mctbylactaee 19 0.00112 0.0012 00000 0.0000 2•Mc0iyloctaae 19 0.0002 0.0012 0.0000 0.0000 3 MethylocUae t9 0.0002 0.0012 0.0000 0.0000 I,2-01mehylbenzene(o•XyIwo) AS 0.0006 0.0029 110000 0.0000 1•Hutylryelepentane N9 011001 0.0006 0.0000 0.0000 Unkn0wnCEs 02 0.0002 0.0010 00000 0.0000 n•Nonsee P9 0.0006 0.0034 0.0000 0.0000 n-Butylcyctopentane N9 0.0001 0.0006 0.0000 0.0000 n•Ptopylbeasene A9 0.0001 0.0005 0.0000 0.0000 I.3•Mtthyieth>4benune A9 0.0001 0.0005 0.0000 0.0000 I,3,S•Teimethylbenzene A9 0.0001 0.0005 0.0000 0.0000 t-Butylbenzene MO 0.0001 0.0006 0.0000 0.0000 Unto owuC9s 119 0.0003 0.0017 0.0000 0.0000 a-Deane NO 0.0001 0.0006 0.0000 0.0000 UnknownClOc U10 0.0001 0.0006 0.0000 0.0000 UnknownCISs UIS 0.0002 0.0023 0.0000 0.0000 TOTAL 100.00000 100.00000 6.6095 6.6454 BTEX COMPONENTS b10LE% %ph ETU Q 14.850 14.730 BENZENE 0.0261 0.087E LOW NET DRY REAL: 1163.7 het 1170.1 lid TOLUENE 0.0204 0 0839 NET WET REAL: 1143.4 fur 1149.7 Iscf ETHYLBENZENE 0.0004 0.0010 HIGH GROSS DRY REM.: 1280.8 het 12871 het XYLENES 0.0038 0.0181 GROSS WET REAL: 1268.4 lid 1265.4 het TOTAL BTEX 0.0407 0.1014 NET DRY REAL: 10710.8 he 19827.3 Oh GROSS DRY REAL: 21713.0 Ab 21831.5 Ms RELATIVE OENSITY(Al Rc 1); 0.7727 WNW-MA STD MIA fRU 3l4tf4A son) COMPRESSIBIUTY FACTOR: 0.09816 5DETAILOANnaeOL'La8'LVACU.0S1Sxi rase,Asn1D6140 tiff ROAMS*XVACQG'faED IesOGORAP,LK'.csamOf C UMMT STA(EOtippjE.1a1 A AL11 CAL ILYM1QGi3 MEMO, O SleUffOF 7MIMI LLTACt ALI CAL=TOM.45211.3.13.V2 aLV0.1S1aUfTf0/AMIGO'Of MEADVJUSDD4OALLITICWM71 AA'1COMEOVEACETOF/fYAPPLICAtlat Pees 2 ENPACT Artalytkat Systems,he 365 3.Math Sliest.Brighten,CO 80801 303.637-0160 Appendix F List of Insignificant Activities Enterprise Compressor Station I Enterprise Insignificant Emissions DCP Midstream.LP • Insignificant _ NOx CO VOC Emission Estimation Method Insignificant Per • FactlRywnde Fugitive Errnssions 0 72 Protocol for Equipment Leak Emission Estimates" • EPA Publication No 4531R-95-017.Table 2-8 Regulation No.3 Part C.Section II E 3 a • D2 Dehy Reboiler Burner 2 5 MMBtu/hr 0 96 0.81 0 05 AP-02 Regulation No 3 Part C.Section Ii E 3 k NG Fired Separator 0 75 MMBtu/hr 0.29 0.24 0.02 AP-42 Regulation No.3,Part C.Section 11 E 3 k 212950 meter shed heater 0.006 MMBtuih 0.00 0.00 0.00 PP-42 Regulation No 3.Part C.Section II E 3 k 214551 meter shed heater 0 004 MMBtu/h 0 00 0 00 0 00 AP-42 Regulation No.3 Part C Section II E 38 Engine Blowdown Vent 1 41 1 MSCF/yr 0 0 019 Engineering Estimate Regulation No.3 Part C.Section 11 E 3 a • Engine Blovdown Vent 2 41 1 MSCF/yr 0 '0 0 19 • Engine Blowdown Vent3 41.1 MSCF/yr 0 0 019 Engine Blowdown Vent 4 41 1 MSCF/yr 0 0 0 19 • Engine Blowdown Vent 5 41 1 MSCF/yr 0 0 019 • • Engine Blowdown Vent 6 41 1 MSCF/yr 0 0 0.19 • • P014A Pressurized Bullet Tank 30,000 gal 0 0 0 N/A-Not a source of emissions Regulation No.3 Part C,Section It E 3 a • • P0148 Pressurized Bullet Tank 30,000 gal 0 0 0 IJVA-Not a source of emissions Regulation No.3.Part C.Section II E 3 a Lube Oil Tank 210 bbl 0 0 neg. Regulation No 3.Part C.Section II E.3 aaa Produced Water Tank 100 bbl 0 0 01 PS Memo 09-G2 Regulation No 3 Part C.Section II E 3 a Sump Tank 1 80 bbl 0 0 neg Regulation No.3.Part C.Section II.E.3 a Sump Tank 2 80 bbl 0 0 neg Regulation No 3.Part C.Section II.E 3.a Sump Tank 3 80 bbl 0 0 neg Regulation No.3.Part C.Section It a Used Oil Tank 68 bbl 0 0 neg Regulation No 3.Part C.Section II E 3 aaa Sump 4 475 gal 0 0 neg Regulation No 3 Part C Section II E 3 a Sump 5 80 bbl 0 0 neg Regulation No 3.Part C.Section II E.3 a Sump 7 TEG Stornmater collection 80 bbl 0 0 neg. Regulation No.3,Part C.Section II E 3 a Sump 6 TEG/Cond 80 bbl 0 0 neg. No atmospheric emissions,vent routed to flare Regulation No.3.Part C.Section II E 3a Used Oil Tank 2 475 gal 0 0 neg Regulation No 3.Part C Section II E 3 aaa Used Oil Tank 1 475 gal 0 0 neg Regulation No 3.Part C Section It E 3 aaa Sump 8 80 bbl 0 0 neg Regulation No 3,Part C Section It E 3 a Lube Oil Day Tank 8Bgal 0 0 neg. Regulation No.3.Part C.Section II E 3 aaa Lube Oil Day Tank 88 gal 0 0 neg. Regulation No.3.Part C.Section II E 3 aaa Remediation Skimmer/bubbler 1 1O acfm 0 0 neg Regulation No 3.Part C Section II E 3 a Remediation Skunrrrer/bubbler 2 10 actor 0 0 neg Regulation No 3 Port C Section II E 3 a Tank Vapor Combustor 0.10 0 22 neg Regulation No.3.Part C.Section II E 3 a • Sum 1.35 1.28 2.01 • • • • • • • • DCP Midstream.LP 7/25/2016 Appendix G Updated CAM Plan: D2 Enterprise Compressor Station Compliance Assurance Monitoring Plan -Dehydrators Background a. Emission Unit Description: Natural Gas Dehydration System using triethylene glycol (D.-2); b. Applicable Regulation, Emission Limit, Monitoring Requirements: D-2: Regulations: Operating Permit Condition 3.1 Emission Limitations: VOC 33.27 tons/yr Individual HAP 8 tons/yr Total HAP 20 tons/yr e. Control Technology: Condenser and Enclosed Combustor for Still Vent emission control • IL Monitoring Approach Indicator No. 1 Indicator No. 2 i. indicator Condenser Outlet Temperature' Enclosed Combustor Measurement Approach The outlet temperature is measured with a resistance Presence of a flame is continuously monitored temperature detector(RTD). with thermocouple or equivalent temperature sensing device. Device senses heat and when there is an absence of a flame, then an alarm is sent to the control room. Ii. indicator Range An excursion is any calendar day(midnight to Any absence of a flame(apart from permitted midnight) in which an average temperature above periods of downtime or auto-igniter ignition 140°F is recorded. Excursions trigger an inspection attempts)will trigger an investigation to and corrective action. determine the problem and to perform corrective action,record keeping relating to the problem,and reporting of the problem when necessary. III. Performance Criteria a. Data Representativeness Temperature is measured at the outlet of the Device sensing heat will determine the presence condenser, The minimum accuracy is+/-5 F. or absence of the flame. b. Verification of RTD manufacturer guarantee. The observation of the presence of a flame will Operational Status indicate that the device is operational. c. QA/QC Annual verification or replacement. Sensor will be calibrated and maintained. Practices/Criteria d. Monitoring Frequency Daily. Heat sensor will be monitored continuously. e. Data Collection Outlet temperature automatically or manually Excursions and any adjustments or repairs made Procedures recorded daily if operating. to the flare following an excursion shall be recorded in a log. f. Averaging Time Daily average. Readings representative of the day Heat sensor will operate continuously and (24-hour period)will be collected(i.e.,a minimum averaging will not be necessary. of 4 readings will be taken throughout the day at approximately 6 hour intervals). Note:Absence of flame, except during auto- igniter ignition attemps, will count towards periods of permitted downtime. * = Proper ranges for the parametric monitoring in this plan are to be verified with actual testing data. Ranges may be modified dependent upon testing results. Appendix El Updated O&M Plan: D2 Enterprise Compressor Station Form APCD-302 Colorado Department of Public Health and Environment Air Pollution Control Division Colorado Deparun.ent of Public I Icaldi and E:nviroument Operating and Maintenance Plan Template for Glycol Dehydration Systems Ver.September 19,2013 The Air Pollution Control Division (Division) developed this Operating and Maintenance Plan (O&M Plan) for glycol dehydration systems that are permitted at synthetic minor facilities in the State of Colorado. An O&M Plan for each type of glycol dehydration system configuration,as described in Section i,shall be submitted with the permit application. One O&M Plan may be used for multiple glycol dehydration systems at one facility if each are controlled and monitored in the same manner. If the O&M Plan template is completed correctly, the Division will approve the O&M Plan and a construction permit will be issued with the requirement to follow the O&M Plan as submitted. If the template is not completed correctly, the Division will work with the facility to make corrections. Once a construction permit is issued, the facility operator must comply with the requirements of the O&M Plan upon commencement of operation. Operators are not required to use this template. Independent case specific O&M Plans may be developed and submitted for approval with the permit application. However,the Division encourages the use of this template to expedite the permit application approval process. Submittal Date: July 25,2016 Section I -Source Identification For new permits some of this information(i.e.Facility AIRS ID, Facility Equipment ID,Permit Number,and AIRS Point ID) may not he known at the time of application.Please only fill out those fields that are known and leave the others blank. Company Name: DCP Midstream,EP Facility Location: SWSW Section 30, T2N,R63W Facility Name: Enterprise Compressor Station Facility AIRS ID(for existing facilities) 123/0277 Units Covered by this O&M form Facility Equipment iD D2 Permit Number 95OPWE103 • AIRS Point ID 068 Glycol Type Used TEC "Glycol types include Ethylene Glycol(EG).Di-Ethylene Glycol(DEG),and-Fri-Ethylene Glycol(TEG) Emission Points and Control Status:Check the appropriate boxes indicating whether the dehydration system(s)are equipped with a flash tank and whether or not the flash tank(if present)and still tent emissions are controlled or recycled or ranted to atmosphere. ® Flash Tank ® Still Vent Control lediRecyc led ®Controlled:Recycled ❑Vented to atmosphere ❑ Vented to atmosphere Section 2- Maintenance Schedules Check one of the following: Facility shall follow manufacturer recommendations for the operation and maintenance of equipment and control I I devices.These schedules and practices,as well as any maintenance records showing compliance with these recommendations,shall be made available to the Division upon request. Page 1 of 5 Colorado Department of Public I lealth and Environment Air Pollution Control Division Facility shall follow individually developed maintenance practices and schedules for the operation and maintenance of equipment and control devices.These schedules and practices,as well as any maintenance records showing compliance with these recommendations,shall be made available to the division upon request and should be consistent with good air pollution control practices for minimizing emissions as defined in the New Source Performance Standard(NSPS) general conditions. Section 3- Monthly Emission Modeling or Calculations • The following box must be checked for O&M plan to be considered complete. The source will calculate emissions based on the methods and emission factors provided in the permit application and ® approved by the division,as reflected in the construction permit.Please see the operation and maintenance plan guidance document for furthe,.details and examples of emission calculations. Section 4—General Monitoring Requirements • Table 1 below details the schedule on which the source must monitor each of the listed operating parameters depending on the requested permitted emissions at the facility. Check the appropriate box based on facility wide permitted VOC emissions. Table 1 Monitoring Frequency Parameter ® Permitted Facility O Permitted Facility Emissions≥80 tpy VOC Emissions <80 tpy VOC Lean Glycol Circulation Rate Daily Weekly Wet Gas Inlet Temperature Weekly Monthly Wet Gas Inlet Pressure Weekly Monthly Volume of Gas Processed Monthly Monthly Chiller(Cold Separator) Pressure(EG units only) Weekly Monthly Chiller(Cold Separator)Temperature(EG units only) , Weekly Monthly Tables 2 and 3 outline the methods by which the source may monitor the lean glycol recirculation rate and the volume of gas processed,respectively. In Tables 2 and 3 the source must chose one primary monitoring method and,optionally,up to two backup monitoring methods. Check each box that applies. Table 2 Primary Back-up Lean Glycol Recirculation Rate Monitoring Method ® Glycol flow meter(s)— including flow from all injection points or pumps ❑ ❑ Record strokes per minute and convert to circulation rate—pump make/model and stokes per minute/circulation rate relationship must be made available to the division upon request ❑ ❑ Assume maximum design pump rate n pump make/model and circulation rate specifications must be made available to the division upon request h Note: if you are requesting to permit at a rate lower than the maximum design pump rate then this option should not be used as it will create de facto non-compliance. Table 3 Primary Back-up Volume of Gas Processed Monitoring Method Metered Inlet O Outlet❑Fuel,Gas❑Compressor Discharge❑Other: ❑ ❑ Metered❑Inlet❑Outlet O Fuel Gas❑Compressor Discharge❑Other. ❑ ❑ Assume maximum design rate`specifications shall be made available to the division upon request ❑ ❑ Other(to be approved by the division):attach method explanation and sample calculations `Note: if you are requesting to permit at a rate lower than the maximum contactor design rate then this option should not be used as it will create de facto non-compliance. Page 2 of 5 Colorado Department of Public Health and Environment • Air Pollution Control Division Section 5- Emission Control or Recycling Equipment Monitoring Requirements Table 4 below details the monitoring frequency for control equipment depending on the type of control equipment used and the requested permitted emissions at the facility. Check the appropriate box for"Monitoring Frequency"based on the facility- wide permitted VOC emissions. In addition, indicate still vent and flash tank emissions controls by checking the appropriate boxes. Table 4 Monitoring Frequency Emissions Control or Still Flash ® Permitted Facility ❑ Permitted Facility Parameter Recycling Method Vent Tank Emissions Emissions ≥80 tpy VOC <80 tpy VOC Condenser ® ❑ Condenser Outlet Weekly Monthly Temperature Combustion Chamber Thermal Oxidizer ❑ ❑ Daily Weekly Temperature Combustor or Flare ® ❑ Pilot Light Monitoring r Daily Weekly Method 22 Readings Daily 1 Weekly Recycled or Closed Loop System(Including ❑ ® To be determined by the source and approved by the division K Vapor Recovery Units) Re-routed to Reboiler Burner ❑ ElTo be determined by the source and approved by the division d Maximum Condenser Outlet Temperature If the equipment is controlled with a secondary control device and no control efficiency is being claimed for the condenser then the condenser outlet temperature does not need to be monitored and there will be no maximum condenser outlet temperature. For all other equipment the maximum condenser outlet temperature shall be:Select one of the following options from Table 5: Table 5 • 160°F 140"F (Upon approval from the division)—attach supporting documentation if a higher limit is requested 1 e Minimum Thermal Oxidizer Combustion Chamber Temperature If the facility uses a thermal oxidizer to control emissions then the minimum combustion chamber temperature shall be:Select one of the following options from Table 6: Table 6 1400" Based on manufacturer specifications. Specifications must be submitted with the permit application and made available to the Division upon request Based on testing performed. The test data shall be submitted and attached to the O&M Plan Page 3 of 5 • • • Colorado Department of Public Health and Environment Air Pollution Control Division • I Pilot Light Monitoring Options If the facility uses a Combustor or Flare then the source must indicate the method by which the presence of a pilot light will be monitored in Table 7. One primary method for Pilot Light Monitoring must be checked and,optionally,up to two backup methods can be checked. Table 7 • Primary Back-up Monitoring Method ❑ ® Visual Inspection ❑ ❑ Optical Sensor ❑ O Auto-Igniter Signal ® ❑ Thermocouple • Recycled or Closed Loop System Monitoring Plan In the space provided below please provide a brief description of the emission control or recycling system,including an explanation of how the system design ensures that emissions are being routed to the appropriate system at all times,or during all permitted runtime. VRU will route flash tank vapors back to the process. lithe VRU is down the flash tank emissions will be routed to the enclosed combustor (5%0 or 438 hours)at 95%DRE. DCP will record the hours of VRU downtime. h Reboiler Burner Control Monitoring Plan In the space provided below please provide a brief description of the emission control system, including an explanation of how the system design ensures that emissions are being held or rerouted when the reboiler is not firing. Section 6—Recordkeeping Requirements The following box must be checked for O&M plan to be considered complete. Synthetic minor sources are required to maintain maintenance and monitoring records for the requirements listed in ® sections 2,3,4 and 5 for a period of 5 years. If an applicable Federal NSPS,NESHAP or MACT requires a longer record retention period the operator must comply with the longest record retention requirement. Section 7-Additional Notes and O&M Activities Please use this section to describe any additional notes or operation and maintenance activities. Still vent to enclosed combustor downtime at 3%or 263 hours. If the combustor is down.the still vent emissions will be routed to the atmosphere. Note:The TEG system is capable of achieving over 95%system control with this downtime. DCP will record the hours of combustor downtime. In the event monitoring data for a daily recordkeeping requirement in this Operating and Maintenance Plan is missing,the missing data shall be filled as follows: if less than 10 percent of days for a given month(3 days)have missing data,the missing days shall be filled using the average of the value that is equal to number of days immediately preceding and following the missing period unless other data exists such that it is known the unit was not operational. If 10 percent or more of days in a given month are missing data,the data shall be filled using the maximum value recorded during that month.• In the event monitoring event data for a weekly recordkeeping requirements in this Operating and Maintenance Plan is missing,the missing data shall be filled as follows: if less than one(1)week in a given month is missing,the missing week shall be filled using the average of the value for the week immediately preceding and following the missing week unless other data exists such that it is known the unit was not operational. If more than one(1)week in a given month is missing,the data shall be filled using the maximum value recorded for the unit during the prior three(3)month period. Page 4 of 5 Colorado Department of Public Health and Environment Air Pollution Control Division In the event monitoring data for a monthly recordkeeping requirement in this Operating and Maintenance Plan is missing,the missing data shall be filled as follows: if no more than one(1)month in a given six (6)month period is missing,the missing month shall be filled using the average of the value for the month immediately preceding and following the missing month unless other data exists to show that the unit was not operational. If more than one(1)month in a given six(6)month period • is missing,the data shall be filled using the maximum value recorded for the unit during the prior six(6)month period. Note: These templates are intended to address operation and maintenance requirements of the State of Colorado for equipment operated at synthetic minor facilities. If the facility or equipment is subject to other state or federal regulations with duplicative requirements,the source shall follow the most stringent regulatory requirement • • Page 5 of 5 INFO TO SUPPORT 7/26/2016 Renewal *Note that a minor modification was included with the 7/26/2016 renewal application, but was processed separately from the renewal under the provisions of Colorado Regulation No. 3, Part C, Section X. The Responsible Official Signature for the minor modification was received 9/22/2017. A CDPHE COLORADO CO 11, Department of Public Health Et Environment I,t ,., ..I1r" 1 I 1.� February 10, 2016 Certified Mail No. 7014 0150 0000 6494 8887 Return Receipt Requested Roshini Shankaran Environmental Engineer DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80202 RE: DCP Midstream, LP - Enterprise Compressor Station, FID: 1230277, OP: 95OPWE103 SUBJECT: Application for Renewal of Title V Operating Permit Dear Ms. Roshini Shankaran: Colorado Air Quality Control Commission Regulation No. 3. Part C, Section V. C. states that the permit term for all operating permits is five years from the date of issuance. Your operating permit was last renewed on August 1. 2012 and expires on August 1 , 2017. Regulation No. 3. Part C, Section 111.8.6. states that sources shall submit an application for renewal of their operating permit at least twelve months, but no more that 18 months, prior to the expiration date of the permit. For the above referenced facility, the permit renewal application is therefore due no earlier than 'ebruary 1, 2016 and no later than August 1 , 2016. We would encourage you to submit the application as soon as possible within that timeframe. Section 111.8.6. also sets forth the required information to be submitted in the application for permit renewal. In accordance with this provision, you should submit the following: 1) A cover letter signed by the Company's Responsible Official. The letter should state that "no changes are being requested for the operating permit except as identified below or attached". All requested changes should be referenced by permit section and condition number. A brief explanation describing the requested change(s) must be included. The appropriate Operating Permit application forms shall be used to describe the requested changes (i.e. a form 2000-100 shall be submitted to identify a change in Responsible Official or Permit Contact). If appropriate, APENs and APEN filing fees should be included. 2) An Operating Permit application form 2000-800, signed by the Responsible Official, shall be submitted with all renewal applications. 3) Regulation No. 3, Part C, Section 11.8.6 requires that "A copy of any materials incorporated by reference must be included with the [renewal] application." The Division therefore requires that you submit any materials that are not otherwise on file with the Division. 4) Sources must indicate if they are major for greenhouse gas (GHG) emissions (i.e., potential to emit exceeds 100,000 tons/yr CO2e and 100 tons/yr of GHG emissions) in their Title V permit applications. A statement in a cover letter indicating facility status with respect to GHG emissions is sufficient to fulfill this requirement. If the Division determines that additional information on GHG is necessary (e•g, emission 4300 Cherry Creek Drive 5,. Denver, Co 80246-1530 P 303-692-2000 www,colerado.govlcdphe T' John W. Hickerloaper,Governor Larry Wolk_MD,:a5PH, Executive D.recto' and Chief meoral Officer i87r' Roshini Shankaran, DCP Midstream, LP - Enterprise Compressor Station February 10, 2016 Operating Permit Renewal for 95OPWE103 Page 2 estimates and calculations), such request will be made in writing and a reasonable deadline for a response will be set. In addition, the Division requests that you use this opportunity to review the list of insignificant activities in your permit and revise the list as necessary. The Operating Permit application forms are available for downloading on the Division's Operating Permit website at: www.colorado.gov/cdphe/airTitleV. Note that these are the same forms used for the original Operating Permit applications. You do not have to resubmit a copy of your original operating permit application in its entirety. The original plus three copies of the above information shall be submitted. If you choose to provide only one copy, the Division will make the additional three copies at the cost of $.25 per impression plus the time required to make the copies (@ $76.45/hr). Note that as part of the renewal processing the Division will update any standard language that has been revised since your permit was issued. Such changes will be identified when the permit is sent to you for a pre-public comment courtesy review. In addition, all renewal permits need to address the applicability of the Compliance Assurance Monitoring (CAM) rule. If the CAM rule applies to any of the emission points located at your facility, and a CAM plan is not already included in your permit for those emissions points, you are required to submit a monitoring plan as described in 40 CFR § 64.4 as part of the renewal application. Once the application for renewal is received, it will be processed under the same provisions and timelines as a new application. The Division will notify you within 60 days of receipt of the application whether or not the application is complete. If it is received by the due date and deemed complete, you will be granted thi application shield. Once the application is deemed complete, the Division has 18 months from receipt of the complete application to issue the permit. Failure to submit the application by the due date may result in the denial of the application shield. Failure to submit an application at all may result in enforcement action or revocation of your permit. Please submit your application to the following address: Jesse Snyder Colorado Dept. of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246.1530 If you have any questions please do not hesitate to contact me at 303-692-6332 or jesse.snyder®state.co.us. Sincerely, Jesse Snyder Engineer, Operating Permit Unit Stationary Sources Program Air Pollution Control Division Complete items 1,2,and 3.Also complete Ai Signature it e if P trieted F ii € .desir O Agent Print your name and address on the reverse so that we can return the card to yo r. Fwboied by penitd yams) nate of Dom Et ch this ear s t€ the back of the mallp€ace, or on the front if space permits. 4.''t a' . #,Article Addressed t : b.tsdeliVerYadc t CMet tfreat item 1? CI tea *YES,ente deli ty adder bei : U I Roshini Shankarat Environmental Engineer DCP Midstream, LP 3,; SmiceType 370 17th Street,Suite 2500 ,--SWertifled MalP fi Prime NiaTIi ` Denver, CO020 - ism Ci Returnenelptfor Morchoraffse D Insured Malt U Ciecten noway 4 Restricted Defntery7(€ .R4 yes Mkt Nuntier (Transfer frerr, - lam70114 0150 l l i i ? PS Fonn 3811,July 1M Domes*ids Receipt re Jr. CAI-FAAFee Pasttnerk Pawn Awetpt Fee i Here Rewtctatt Mtn Ft Ul r sueSp-... ¥° rF Roshini Shankaran Environmental Engineer I PO Bo;ae DCP Midstream, LP a ' .7-- 370 17th Street,Suite 2500 .., Denver CO 89202 CDPHE COLORADO Co Department of Public Health b Environment August 16, 2016 Ms. Roshini Shankaran Certified Mail No.7014 0150 0000 6494 9075 Environmental Engineer Return Receipt Requested DCP Midstream, LP Enterprise Compressor Station 370 Seventeenth Street, Suite 2500 Denver, CO 80202 RE: DCP Midstream Enterprise Compressor Station: 95OPWE103 SUBJECT: Application for Renewal of Title V Operating Permit Dear Ms. Shankaran: The Division received your application for renewal of the operating permit for your facility on July 26, 2016. Please take note of the following information related to the processing of your application: Application Shield In accordance with Colorado Regulation No. 3, Part C, Section 111.6.6, an application for renewal of an operating permit is due at least twelve months, but no more than 18 months, prior to, the expiration of the operating permit. The permit for your facility expires on August 1, 2017 and a renewal application is due no later than twelve (12) months prior to the expiration date. An administratively complete application received on or before the due date entitles the source to an application shield under the provisions of Colorado Regulation No. 3, Part C, Section II.B. The renewal application submitted on July 26, 2016 for the above referenced facility has been determined to be administratively complete in accordance with the requirements of Colorado Regulation No. 3, Part C, Sections III.B, C, and D. The application shield is hereby granted and is effective as of July 26, 2016. Fees The Colorado Legislature has directed the Division to inform sources if the time spent processing an application will exceed 30 hours. The Legislature has also set a fee of $76.45 per hour for activities related to the processing of an application. This fee was set to help recover the program costs. The Division has determined that the time required to process your application for renewal of the operating permit will exceed 30 hours. Based on our experience in processing operating permits, we estimate that the total time required to process your application will be between 25 and 100 hours. This letter fulfills the Division's obligation to inform you that the lf IfJ�V _1 D‘' ( ? t1G2+� 1317 P 3b3-64[ '1'QCi dehe J0"1 , I V1;. VSPH '‘, 3le A Dltreer • processing time for your operating permit renewal will exceed 30 hours and to provide you with an estimate of the processing time. Please note that the Division utilizes a quarterly billing system for all operating permits. The bills you receive will reflect chargeable time for the previous quarter. Timeline The Division has eighteen months after a complete application is received to either approve or disapprove the application for a renewal operating permit (Colorado Regulation No. 3, Part C, Section IV.C). In accordance with the provisions in Colorado Regulation No. 3, Part C, Section VI.C, if a timely and complete application is filed, but the Division fails to issue or deny a renewal operating permit prior to expiration of the operating permit for which a source is seeking renewal, the previously-issued operating permit, and all of its terms and conditions, shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. Required Additional Information The next step in reviewing the application is the Technical Review. If the Division determines that additional information is necessary to evaluate or take final action on an application, a request will be made in writing for the information and a reasonable deadline for a response set. If the applicant fails to provide the requested information or does not meet the deadline, the application shield will be revoked and the Division will be unable to continue with the processing and issuance of the renewal (Colorado Regulation No. 3, Part C, Section IV.D). Please note that in accordance with Colorado Regulation No. 3, Part C, Sections IV.B.3 and 4 that it is the sources' responsibility, without notification, to supplement the renewal application in the event that errors or omissions are discovered after the renewal application submittal. Additional information must be signed and certified by the responsible official as to its completeness and accuracy. As is the case with the application, an original and three copies of any additional information must be submitted. Please do not hesitate to contact me if you have any questions at 303-692-3256 or thang.nghiem@state.co.us Sincerely. / _ J Thang Nghiem Engineer, Operating Permit Unit Stationary Sources Program Air Pollution Control Division Vin..C, r,,. n tr,c r„r.. - 2. - '0 P+ 03 ry2. 3i.I w.rv,=.(n Gr�C ?u� fi '1)110 2 - ''` 1 • • ' v i . • I EiskiiititIF('s_ - •.. -;;;;1't .{dam-v '{-W.. }�y4 } , rg . „. - s aoffip at items,1t 2,and a �kc V'.'' Fi etei,:.1�.'a, r� +3p le�3 Y, item if Restri sd t etfver i dnsi d. ®Agent Print your name and idr� h the reverses Addr so that r c return the card to _ Yt f .k y nt d P a e et of t sve Attach this card to tb of the gip @ r r th the front spacepermits. e: D.is dew—,address d t₹�t ro ttem ? Q yes 1,�cAddressed t !f'f� utter dsfiv[ d� etov o Ms. Roshirti Shankaran DCP Midstream, LP Enterprise Compressor Station 370 Seventeenth Street,Suite 2500 s, ire rpe Denver, CORfl2C�2 lt° mrtorttt D t i r Cl turret R iptfor Mercb tdt e Insured ett:i €l tte cn l?ettveryr . :. t₹c€ed Setiv r t�aa�} `f 70114 0150 0000 %14914 9075 .. $8 �. �� t�Returtz Fidpt '',-e-,- Eger, _,i. .40 los. ianc-'4-c°:v.,..yetagem:—cpm-,,,...--s--•'ti'- �� rter � q 1 � t1r ' -,ti 11 Kvaco = awe Hers En cd r� �3 �rI Ms.Roshini Shankaran DCP Midstream, LP rlc3 `Enterprise Compressor Station N Wtilli 7f}5eunteent Street,Suite 2500 i INFO TO SUPPORT 7/26/2016 Modification *Note that the information presented in this modification application was subsequently modified with the 11/20/2018 significant modification application. Note also that this minor modification was included with the 7/26/2016 renewal application, but was processed separately from the renewal under the provisions of Colorado Regulation No. 3, Part C, Section X. The Responsible Official Signature for the minor modification was received 9/22/2017. fth=am DCP Operating Company,LP P370 17th Street.Suite 2500 Denver,CO 80202 Midstream ;03_<}tts„o; September 20, 2017 UPS: IZ F46 915 02 9428 0798 Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B I Denver,CO 80246-1530 (ATTN: Elie Schuchardt) Re: DCP Operating Company, LP; Enterprise Compressor Station Operating Permit 95OPWE103 Title V Renewal and Modification Application(Submitted 7/26/2016) - A I RS ID 123/0277 Dear Ms. Schuchardt: DCP Operating Company, LP (DCP) submitted a combined operating permit renewal and minor modification application for the Enterprise Compressor Station, Operating Permit 95OPWE103, on 7/26/2016. This combined application also incorporated the changes from an additional minor modification application, submitted 4/22/2016. The 4/22/2016 application requested updated emission limits and other minor updates for unit D2, a natural gas dehydrator, as well as the removal of unit D3, a 2m1 natural gas dehydrator that was never installed on site. The 7/26/2016 application requested the addition of downtime for the control devices used for emission control from unit D2, in addition to the renewal of Operating Permit 95OPWE103. Colorado Regulation 3, Part C, Section X.D.3 requires a Responsible Official (RO) to sign off on any minor modification application requests submitted to the state. This requirement is separate from the RO signature requirement on Form 2000-800, which accompanies all operating permit renewal applications. While the 4/22/2016 minor modification application included the required RO signature, the combined renewal / minor mod application submitted 7/26/2016 only included the necessary RO signature for the renewal portion of the application. This small addendum to the 7/26/2016 application includes the necessary RO signature page for the minor modification portion of the application, as required under Reg 3, Part C, Section X.D.3. If you have any questions or require any additional information about the project, please feel free to contact me at (303) 605-2039 or RShanharan DCPMid.trcam.com. Sincerely, DCP Operating Company, LP Roshini Shankaran Environmental Engineer /cp I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures by used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). David M. Jost Vice President of Northern Operations Printed or Typed Name Title..)42"tY Signature of esponsible Official Date CDPHE ' COLORADO Department of Public CO 71' Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Roshini Shankaran DCP Operating Company, LP 370 17th Street, Suite 2500 Denver, CO 80202 10/2/2017 RE: Complete Application for Minor Modification to Operating Permit 95OPWE103 Dear Ms. Shankaran: The Division received your request to modify the Operating Permit for the Enterprise Compressor Station on July 26, 2016. The modifications requested include updating the serial number for dehydration unit D2 and permitting 5% annual downtime for the VRU used to control the flash tank for dehydration unit D2. The Division agrees that the requested modifications meet the requirements of a minor permit modification (Reg 3, Part C, Section X.A) and considers that your submittal comprises a complete application for a minor permit modification. The Division considers your application for a minor operating permit modification to be complete as of July 26, 2016. As specified in Colorado Regulation 3, Part C, Section X.I, "a source shall be allowed to make the changes proposed in its application for minor permit modification immediately after it files such [complete] application." Note that if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit that Colorado Regulation 3, Part C, Section X.I requires that: "...the source must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time the source does not need to comply with existing permit terms and conditions it seeks to modify, but if the source fails to comply with its proposed permit terms and conditions during this period, the existing permit terms and conditions it seeks to modify shall be fully enforceable by the Division." In addition, if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit, the new or modified equipment shall be addressed in subsequent semi-annual monitoring and permit deviation reports and annual compliance certifications. The compliance status of the new or modified equipment shall be based on the provisions specified in the draft permit submitted with the minor permit application. If the Division has submitted a proposed permit to EPA for their 45-day review period, the compliance status of the new and/or modified equipment shall be based on the proposed permit beginning on the date the proposed permit was sent to EPA. Typically the next step for this permit modification is the EPA 45-day review. Although you submitted a complete application, the Division needs additional time to review the application. In 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.govlcdphe 4 /4.47' \got: John W. Hickenlooper,Governor ! Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer `*\ , 1*; the event that the Division does not use the draft permit language included in your application or makes additional changes to the permit, we will provide you with an opportunity to review the draft Operating Permit and any associated technical review document. Upon your acceptance of the Division's revised draft permit, the Division will forward the proposed permit to EPA for their 45-day review period. A copy of the proposed permit will be sent to you at that time. Upon completion of EPA's 45 day review period you will be issued a revised operating permit for your facility. If you have any further questions please contact me at (303) 692-6332. Sincerely, Elie Schuchardt Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division cc: Craig Giesecke, APCD inspector (electronic copy) A CDPHE COLORADO CO Department of Public I Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. D. J. Law Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U. S. EPA, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 October 17, 2017 Dear Mr. Law: The Division received a complete application for a minor modification to the Operating Permit for the following Colorado facility: Applicant/Facility Name: DCP Operating Company, LP - Enterprise Compressor Station AIRS ID#: 123-0277 Permit No: 95OPWE103 Facility Address: SW 1/4 of SW 1/4, Section 30, T3N, R63W Facility City, State, ZIP: Weld County The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. As required by Colorado Regulation No. 3, Part C, Section X.F, the Division is notifying you that a complete application for a minor permit modification has been submitted. The application was deemed complete on July 26, 2016. Please do not hesitate to contact me if you have any questions at 303-692-6332 or elie.schuchardt@state.co.us Sincerely, /r / 5Jtj / R Elie Schuchardt Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division • r aF c°to` 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer * !, CDPHE COLORADO Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Balaji Vaidyanathan Permit Section Manager Arizona Department of Environmental Quality - Air Quality Division 1110 West Washington Street Phoenix, AZ 85007 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Balaji Vaidyanathan, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, 4$44> — Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division cz co1 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 4 - "9 John W. Hickenlooper, Governor I Larry Wolk,MD, MSPH, Executive Director and Chief Medical Officer or A CDPHE COLORADO ACO y.,:, ,. Department of Public • Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ms. Marian Massoth Air Permitting Chief Kansas Dept. of Health Et Environment 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Ms. Massoth, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, "044:;'. ' Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division .ocot& 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,� ''u '7% John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I l,` *1 i coPHE COLORADO Co.vc Department of Public • Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NDEQ Air Permitting Section Supervisor Nebraska Dept. of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear NDEQ Air Permitting Section Supervisor, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, ib Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division eY cps 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer * ;" # \3 - , 4 COPPHE COLORADO " Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Robert Samaniego Major Source Unit Manager New Mexico Environment Department - Air Quality Bureau 525 Camino de los Marquez Suite 1 Santa Fe, NM 87505-1816 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Samaniego, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, ././Y:i? Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �� ' John W. Hickenlooper,Governor i Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer ,, ,,,, �1a15.f A COPHE COLORADO CQ r Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Richard Kienlen Oklahoma Department of Air Quality P.O. Box 1677 Oklahoma City, OK 73101-1677 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Kienten, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt®state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,Fe ';' John W. Hickentooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer �' , .t„r18 76 r CDPHE I COLORADO CO Department of Public Health€r Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Mark Hutson Acting Air Qaulity Program Manager Southern Ute Indian Tribe - Air Quality Program P.O. Box 737, MS #84 Ignacio, CO 81137 October 2, 2017 • RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Hutson, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe lea;` vi John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer 4 t raa6xl CDPHE- I COLORADO CO Department of Public Health It Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Jesse Chacon Manager - Title V Section Texas Natural Resources Conservation Commission P.O. Box 13087 Mail Code 163 Austin, TX 78711-3087 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Chacon, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe `; John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer *, rs'z6f' CDPHE COLORADO Co L Department of Public a. :_• Health V Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. David Beatty Section Manager - Operating Permits Utah Department of Environmental Quality - Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Beatty, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, 4/---r Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division ::::::: tC4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe IJohn W. Hickentooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer \ l \--- --...03:i65'./ CDPHE COLORADO Department of Public `` , Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ms. Lori Bocchino Air Quality Operating Permit Program Principal Wyoming Department of Environmental Quality - Air Quality Division 122 W 25th Street Cheyenne, WY 82002 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Ms. Bocchino, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on July 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Albiljr — Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division A6)'_7-:%-, 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I 4q` Q9.',, John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer `\* *; \. -Aa Enclosed Combustor COMB-1 Emissions Enterprise Compressor Station DCP Midstream, LP Enclosed Combustor Fuel Usage 110 scf/hr Pilot Gas 1,148 BTU/SCF Fuel Heating Value 8,760 hr/yr Hours per Year 0.96 MMscf/yr Fuel Use 1,106 MMBtu/yr Fuel Use Enclosed Combustor Waste Gas Flow Usage 1990 Btu/scf Still Vent Gas Heat Value 8.94 MMscf/yr Worst-case Still Vent Gas Flowrate 17779 MMBtu/yr Still Vent To Combustor 1450 Btu/scf Flash Gas Heat Value 21.29 MMscf/yr Worst-case Flash Gas Flowrate 1544 MMBtu/yr Flash Gas To Combustor(5%during VRU Downtime) 1105.8 MMBtu/yr Fuel Heat TV Cnc : it05,?) MMg11)tif 17,779 MMBtu/yr Still Vent Heat 1,544 MMBtu/yr Flash Gas Heat Stilt \' 18,884 MMBTU/yr 2.16 MMBtu/yr 1 t1C� �i� i�r 10.96 MMscftyr i UC) TV1rvt Combustion Emissions at COMB-1 EF Emissions Ib/MMBtu ton/yr NOx 0.068 0.64 CO 0.37 3.49 AP-42 Table 13.5-1 "veA Q c . t tO5.9 M W11JJc c t,tt ve)nt:f' 'a r{ /IM/le Ftabtn &It: 15144 >uY TU/4( Total; 20126.13 M /qr Em'tfo Ont .cOC `0x: 2.Q(i2b. Mi Xt�•1 - x-- - _ O.(09 t �( yr rT1%n) it0 1 yc ivoRT 2 r b 3/19/2014 Modification Application 123-0277 95OPWE103 RCVD 3/19/2014 EJC 9/18/2020 DCP 7 Midstream 370 {7th Street, Suite 2500 --...�.■.�,� Denver,CO 80202 Midstream. } March 17, 2014 {{EP: UPS Ground Tracking No. 1Z F46 915 02 9419 6399 --� Colorado Department of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Re: Enterprise Compressor Station—95OPWE103 TEG Dehydrator Like-Kind Replacement Notification. Dear Sir or Madam: DCP Midstream, LP(DC'P)currently owns and operates the Enterprise Compressor Station in Weld County,Colorado under Title V Permit Number 95OPWE103 most recently issued by the Colorado Department of Public Health and Environment(CDPHE)Air Pollution Control Division(APCD)on August 2, 2012. DCP is proposing to replace an existing triethylcne glycol (TEG)dehydrator, unit D2, AIRS ID 123/0277/068 with a like-kind dehydrator to improve reliability and performance of the dehydration process at the facility. The existing dehydrator is limited to process no more than 40,150 MMsef gas per year with a glycol recirculation rate of 35 gallons per minute(gpm). The reboiler associated with regenerating glycol is rated at 2.5 MMBtu/hr. The proposed dehydrator will also be limited to the same gas throughput of 110 MMsefd or 40,150 MMscf/yr with a glycol recirculation rate of 35 gpm. Therefore, no increases in emissions are expected from the like-kind replacement of the dehydrator. Additionally,the proposed reboiler is rated at 1.5 MMBtu/hr,therefore lowering overall combustion emissions from this process. DCP will retain the current permit limit of 11.95 tpy for VOC and a cumulative HAP emission limit for units D2 and 1.)3 of'8.0 tpy individual MAP and 20.0 tpy total I IAP. The proposed dehydrator still vent stream will continue to be controlled by the existing flare(Equipment ID Combl, AIRS 1D 123/0277/074) with a control efficiency of 95%and the flash tank stream will be recycled to inlet. The insignificant activity list is updated to reflect a reboiler rating of 1.5 MMBtu/hr and proportional emissions. The current dehydrator is subject to the National Emission Standards for Hazardous Air Pollutants (NEST IAP)Subpart HH for Source Categories from Oil and Natural Gas Production Facilities. There will be no change in the applicable requirements under this Subpart for the proposed dehydrator. No other change in regulatory applicability is expected with the proposed dehydrator swap. Included with this letter are the following attachments: * Check for APEN fee • APEN for proposed TEG dehydrator • Facility-wide emission inventory Form APCD-102 f _ • Updated insignificant activity list No other changes are being proposed with this replacement. If you have any questions, I can be reached by phone at (303)605-2039 or via email at tSIt uti -diro LIcrmidsircdin.•um. Sincerely, DCP,llidsiream, LP Roshini Shankaran Environmental Engineer Attachments r • Enterprise Insignificant Emissions DCP Midstream,LP Insignificant NOx CO VOC Emission Estimation Method Insignificant Per D2 DehyReboiler Sumer 15 MMBlu8ir 0.58 0 49 0 03 AP-42 Regulation No 3.Part C.Section II E 3 k 03 Dein/Reboiler Burner 1.5 MMBtuftr 0.58 0 49 0.03 AP-43 Regulation No.3.Part C.Section li E 3 k NG Fired Separator 0.75 MMttulltr 0.29 0 24 0.02 AP.42 Regulation No.3.Part C.Section 0 E 3.k 212950 meter shed heater 0.006 MMBtu/h 0.00 000 0.00 AP-42 Regulation No 3.Part C,Section II.E 3.k 214551 meter shed heater 0,004 MMbtuft 0.00 000 0.00 AP-42 Regulation No.3.Part C.Section II E 3 k Engine Slowdown Vent 1 41.1 MSCF/yr 0 0 0.19 Engineering Estimate Regulation No 3.Part C,Section II E 3.8 Engine Slowdown Vent 2 41.1 MSCF/yr 0 0 0 19 Engine Slowdown Vent 3 41.1 MSCF/yr 0 0 0.19 Engine Slowdown Vent 4 41 1 MSCF/yr 0 0 0.19 Engine Blowdown Vent 5 41 1 MSCF/yr 0 0 0 19 Engine Slowdown Vent 6 41.1 MSCF/yr 0 0 0 19 P014A Pressunzed Bullet Tank 30.000 gal 0 0 0 V N/A-Not a source of emissions Regulation No.3.Part C,Section u E 3 a P0148 Pressunzed Gullet Tank 30.000 gal 0 0 0 N/A-Not a source of emissions Regulation No 3.Part C,Section II E 3 a Lube Oil Tank 210 bbt 0 0 neg. Regulation No 3,Part.C.Section u.E 3 aaa Produced Water Tank 100 bbl 0 0 0.1 PS Memo 09-02 Regulation No 3 Part C.Section 0.E 3 a Sump Tank 1 80 bbl 0 0 neg Regulation No 3.Part C,Section II E 3 a Sump Tank 2 80 bbl 0 0 neg Regulation No 3.Part C.Section it E 3 a Sump Tank 3 80 bbl 0 0 neg. Regulation No.3,Part C,Section/.E.3.a Used Oil Tank 68 bbl 0 0 neg. Regulation No 3,Part C,Section e E 3.aaa Sump 4 475 gal 0 0 neg. Regulation No 3,Part C.Section ItE-3.a Sump 5 80 bbl 0 0 neg. Regulation No 3.Part C.Section it E.3.a Sump 7 TEG Stormwater collection 80 bbl 0 0 neg Regulation No 3.Part C.Section II E 3 a • Sump 6 TEGiCond 80 bbl 0 0 neg. ,No atmosphane emissions,went routed to flare Regulation No 3,Part C.Section 11.5.3.a Used Oil Tank 2 475 gat 0 0 neg. Regulation No.3.Part C.Section II.E.3.aaa Used Oil Tank 1 475 gal 0 0 neg. Regulation No :3.Part C.Section II.E.3aaa Sump 8 80 blot 0 0 neg. Regulation No 3.Part C,Section II.E.3 a tube Oil Day Tank 88 gal 0 0 neg. Regulation No.3,Part C.Section It E.3.aaa Lube Oil Day Tank 88 gal 0 0 neg Regulation No 3.Part C.Section It E.3.aaa Remediation Skimmer/bubbler 1 10 acfrn 0 0 neg Regulation No 3,Part C,Section It E.3 a Remediation Stemmer/bubbler 2 10 ache 0 0 neg Regulation No 3,Part C,Seam I1.E 3 a Tank Vapor Combustor 010 0.22 neg Regulation No 3.Part C.Section u E 3 a Sum 1.55 1.44 1.30 • • li • • • • DCP Mid ,LP /2014 Colorado Department of Public Health and Environment oP• Form APCD-102j Air Pollution Control Diviyion ,�5:�.��'.Ju �l Facility Wide Emissions Inventory Form `��:e_•r•••`� Ver.September 10,2008 ColttadoDepartment Company Name:DCP Midstream,LP of Public I teaith Source Name:Enterprise Compressor Station and Environment Source AIRS ID:123/0277 Uncontrolled Potential to Endt(PTE) Controlled Potential to Eton(PTE) Criteria MY) 1 1 APa06Vyr) CrllerlcfTPY) IIAPa(600yr) Equipment Description TSP P3110-PM23' SO3 NCO CO VOC I B2 Td En Xyl ITCHO Aceter Acre n-Hex Meth -324-TMP TSP P61I0 MILS SO2 NOa CO VOC BE -7'07 ER R7 11CR0 Acetal Acro a-Hex 01416 224-TAMP C733-CaterpillarG3612 SI .1 I.) 1.1 0.1_ 24.0 • 85.7 210.8 I 92 86 39 27 24 I,57 1,081-' 233 526 5 I.: 1.1 -' 1.1 0.1 24.0 27.4 24.0 46 43 4 19 3,485 879 540 117 263 6 0236-C41arpi11ar(136I2 SI .1 1.1 I.1 0,1 24.0 83.7 210.8E 92 _ 86 39 27,24 1,57 1,081 233 506 5 I.) 1.1 LI 0,1 24.0 27.4 24.0 46 _ 43 4 19 3.485 879 540 117 263 6 C238.Caterpillar G3612 SI .1 1.1 1.1_ 0.1 24,0 85.7 210.8 t 92 86 J 39 27,24 1.57 1,031 233 526 5 1.1 1.1 I.1 0.1 24.0 27.4 24.0 46 43 4 19 5.485 879 340 I 17 263 '6 P018-Caterpillar 63612 SI .1 1.1 I.1 0.1 _ 14.0 85.7 2108 t 92 86 _. 39 27.24 1.57 1.081 237 526 5 I.I 1.1 1.1 0.1 24.0 -27A 24.0 46 43 4 19 5.485 879 540 Ill 263 6 CeMryillor03616 .5 1.5 _ 1.5 0.1 32.0 125.7 320 _1 137 127 _ I 57 36,78 2,94 1,595 344_ 776 7 1.5 1.0 1.5 0.1 32.0 .76.6 32.0 68 63 6 29 7,681 1.297 7 7 172 3 8 9 Caterpillar 63616 .5 1.5 1.3 0.1 32.0 125.7„ 32.0 1 137 127 1 57 _36 78_2,94 1.595 344 776 7 1.5 _ 1.5 _1.5 0.1 32.0 36.6 32.0 68 63 6 29 7,681 1,297 7 7 172 1 8 9 O2-3EC De6ydraion Unit 0.0 0.0 0.0 0.0 0.0 0.0 846.71233.432 276,352 7,26 91,101 31,484 0 0.0 0.0 0.0 0.0 0.0 0.0 12.0 6.231 7,630 36 368 0 0 543 D.3-TEOD0leydralionUdt 0.0 0.0 0.0 00 0.0 0.0 '362.61100,994 119.893 3,18 40,137 14,186_ 0 0.0 0.0 OA 0.0 0.0 0.0 5.1 2.646 1,549 15 138 0 0 226 lat-Fugili,e Emissions 0.0 0.0 0.0 0.0 0.0 0.0 36.4 I 729 1331 94 687 3,120 D 0.0 0.0 0.0 0.0 0.0 0.0 76.4 529 1,931 94 887 0 0 3.420 P.013 Stabilized Condensate Tanks 0.0 0.0 0.0 0.0 0.0 0.0 25.6 1 692 2,302 17 1,653 4,991 0 0.0 0.0 0.0 0.0 0.0 0.0 1.3 35 113 9 8.3 0 0 250 P016 Stabilized Condensate Loadout 0.0 0.0 0.0 0.0 0.0 0.0 __14.37 0 0 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0 0 0 0 0 0 0 Flare 0.0 0.0 0.0 0.0 0.5 2,9 0.0 i 0.0 0.0 D. 0.0 0. 0.0 0. 0.0 0.0 00 0.0 0.0 0.0 0,0 0.5 2.9 OA 0 0 0 0 0 0 0 i Permitted Sources Sublolal- 7.3 7.3 7.3 0.4 160.5 597.2 2192.9 1336,389 400,494 10,61 134,067 182,841 12,218 7,512 57,704 3,654 365 73 7.3 7.3 0.4 160.5 185.8 215.4 9,762 6,963 182 1,630 37,302 6,109 3,756 3,231 1,827 13 _ APEN Only Sublotel- 0.0 0.0 0.0 0.0 0.0 0.0 0.0 I 0 0 0 0 0 0 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0 0 0 0 0 0 0 0 0 0 Insignificant Sources(See attached Liu) 0.0 00 0.0 0.0 1.5 1.4 1.3 0 0 0 0 0 0 0 0 0 0 0.0 0.0 0.0 0.0 1.5 1.4 1.3 0 0 0 0 0 0 0 0 0 0 insignificant SublMal^ 0.0 0.0 DO 0.0 IS 1.4 1.3 0 0 U 0 0 0 0 0 0 o. 0 0.0 0.0 U.0 U.0 1.5 1.4 l.3 U 0 0 0 0 0 0 0 0 0 Tool,All Sources^[. 7.3 I 7.3 I 7.3 I 0,4 I 162,1 I 598.6 1 2194,2 336,289 1400,494[10,681I-134,06'71 182,8511 12,238 I 7,512 157,704 13,654 I 365 I 7.3 I 7.3 I 7.3 I 0,4 I 162.1 I 187.2 I 216.7 9,762 1 6,963 I 182 11,630 I 37,302 1 6,109 13,796 15,251 11,827 I 183 P,Uncontrolled HA Summary(TPY)-I 168.1 1 200.2 1 5.3 J 67.9 1 91,4 1 6.1 I 3.8 I 28.9 1 l.6 I 0.2 i ControlledllAPa Summary(TPY)Ur 4.9 I 3.5 I II 1-0.8 ( 18.7 1 3.1 I 1.9 I 2.6 I 0.9 I 0.1 Uncontrolled Total,All HAP,(TPV)ttil Controlled Tool,Ali HAPs(TPY)= 36.3 HZ=Benzene 224-TMP=2,2,4-Toi,0eylpen(ane Tot=Toluene Acetal=Acetaldehyde EH=Eihylbenzene Acro-,Acmkin Xyl=Xylene n-Hex=n-Hexane HCHO=Formaldehyde Meth=Methanol DCP Midstream,LP 3/1712014 V AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit—Glycol Dehydration Unit' Permit Number: 95OPWE103 [Leave blank unless APCD has already assigned a permit#&AIRS ID] Emission Source AIRS ID: 123 / 0277 / 068 Facility Equipment ID: D2 [Provide Facility Equipment II)to identify how this equipment is referenced within your orgaiturtion.] Section 01—Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: DCP Midstream,LP NA ICS,or O Request for NEW permit or newly reported emission source SIC Code: 4922 Source Name: Enterprise Compressor Station ►e Request MODIFICATION to existing permit(check each box below that applies) Source Location: SWSNV Sec 30,T2N,R63W County: Weld 0 Change process or equipment ❑ Change company name Elevation: 4,788 Feet O Change permit limit O Transfer of ownership O Other Mailing Address: 370 17'1'Street,Suite 2500 ZIP Code: 80202 O Request to limit HAPs with a Federally enforceable limit on PTE Denver,CO O Request APEN update only(check the box below that applies) Person To Contact: Roshini Shankaran Phone Number: 305-605-2039 O Revision to actual calendar year emissions liar emission inventory Update 5-Year APEN term without change to permit limits or previously E-mail Address: rshankaran(ndcpmidstream.com Fax Number: 303-605-1957 ❑ reported emissions Add1.1°t°' Like-kind replacement of existing TUG dehydrator Section 03—General information &Notes: For existinc sources,operation began on: For new, or reconstructed sources,the projected startup date is: 09 / 01 / 2014 Normal Hours of Source Operation: 24 hours,%day 7 days/week 52 weeks;year General description of equipment and purpose: Natural Gas Dehydration ► Is this unit subject to the 90%control requirement of Colorado Regulation No,7,XVILD(total uncontrolled actual VOC emissions from all dehydration units at this stationary source,including APEN Exempt units.? 15 tonsrvr)'' ® Yes O No O Don't know D. Will this equipment be operated in any NAAQS nonattainment area? (imp .^. 1t.t.-,,k;_tkfu.!_u, cli:)i .;;;.;;,tw tt:1 0 Yes O No O Don't know ► Is this unit located at a stationary source that is considered a Major Source of Hazardous Air Pollutant(HAP)emissions? 1: Yes O No O Don't know Section 04—Dehydration Unit Equipment Information Manufacturer: Forum Model: TEG Dehydration Unit Serial No.: Custom Unit Colorado Department of Public Health and Environment Air Pollution Control Division(APCD) Reboilcr Rating: 1.5 MMBtuwhr Glycol Used: ® TriEthylene Glycol(TEG) O Ethylene Glycol(EG) O DiEthylene Glycol(DEG) This notice is valid for five(5)years. Submit a revised APEN prior to Glycol Pump Drive: expiration of five-year term, or when a significant change is made Y ® Electric O Gas If gas,injection pump ratio: aelin/gpm (increase production,new equipment,change in fuel type,etc). Pump Make&Model: Rotor Tech G52212 ;;of Pumps: Glycol recirculation rate(gahnin): Max: 35 Requested=: 35 Lean glycol water content: 1.5 wt.'!rh Mail this form along with a check for$15 Colorado Department of Public Healt o = eltt Deily.Gas Throughput: Design Capacity: 110 MMSCF/day Requested': 40,150 MMSCF/yr. APCD-SS-BI ��.VED Calendar year actual: MMSCF/yr. 4300 Cherry Creek Drive South Inlet Gas: Pressure: 1,000 psig Temperature: 120 t'F Denver,CO 80246-1530 ,t;L Water Content: Wet Gas: Ih/MMscf 0 Saturated Dry Gas: 7.0 Ib,/MMscf for guidance on how to complete thi A ,N lrf8hn: if Flash Tank: Pressure: 30 psig Temperature: 160 °F O None Air Pollution Control Division: . ,.. 692-3150 Cold Separator: Pressure: psig Temperature: °F None Small Business Assistance Program(SBAP): (303)692-3148 or 3U3)692-317S i Stripping Gas: None O Use flashUse dry 'as: scfm►:i' gas O b O Use\;: stun APEN forms:l,rtt, >„ ,,, , ,,, ,0,1; ,,;,�, ,,t,� ,yI!I , 'You will be charged an additional APEN fee if ADEN is tilled out incorrectly or missing intornwtion and requires re-submittal. Application status:HI, ss c,ss u ,ulo..4,,,, ---loi i 1N2riiiit i ,,ttu- 'Reyuested values will become permit limitations. Additional Attach a process flow diagram Information O Attach GRI-GLYCale 4,0 Input Report&Aggregate Report(or equivalent simulation reportitest results) O Check box to request copy of draft permit prior to issuance. Required: O Attach the extended gas analysis(including BTEX&n-Hexane.temperature&nressure) O Check box to request copy of draft permit prior to-- `-lie notice. FORM AP' 02 30760 Page 1 s..2 Form APCD-202 Glycol Dehydrator ADEN_t)2.,v2,doc AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit— Glycol Dehydration Unitt Permit Number: 95©PWE103 Emission Source AIRS ID: 123 / 0277 / 068 Section 05—Stack information(Combustion stacks must be listed here) Section 06—Stack(Source,if no combustion) Location(Datum&either L.at/Long or UTM) Stack Dsclur e Operator Stack Baseg Iorzontal Datum { UTM Urm lasting or UTM Northing or Method of Collection for Height Above Temp. Flow Rate F Velocity Moisture Stack elevation ° o (NAD27,NAL)$3. Zone Longitude Latitude Location Data(e.g.map, ID No. (feet) C%roundIsvcl 1°F) (ACFM) (1t,sec) (/o) WGSS4) (12 or 13) (meters or degrees) (meters or degrees) GPS.GoogleFarth) (feet) ... D2 4,788 20 700 545 106 Amb. WGS84 -104.4877 40.1910 CPS . �� Direction or stack outlet(check one): ® Vertical ❑ Vertical with obstructing raincap ❑ Horizontal ❑ Down ❑ Other(Describe): Exhaust Opening Shape&Size(check one): ❑ Circular:Inner Diameter(inches)= 4 O Other: Length(inches) - Width(inches)_ Section 07—Control Device information (Indicate if a control device controls the flash tank and/or regenerator emissions) ® Condenser used for control of: Still Vent Stream /:1 Combustion Device used for control of: Still Vent Stream Rating: MMMtltw'ty i Type: Make/Model: Type: Combustor Comb Make/Model'Serial#: Temperature(°f): Maximum: Average: VOC& HAP Control Etliciency: Requested: 95 0/.,,, Manufacturer Guaranteed' 98 % Requested VOC& I lAP Control Etliciency: "'° Minimum temp.to achieve requested control: °F waste gas heat content: lttwscf El VRU used for control of: Flash Tank Vent Stream Constant j ilot little ❑ Yes ID No Pilot burner rating: MMlttu,�hr Size: Make/Model: ❑ Closed loop system used for control of: Requested VOC& HAP Control Efficiency: 100 ',i, Description:. Annual time that VRI is bypassed(emissions vented): "'o ❑ Describe Any Other: Section 08—Emissions Inventory Information& Emission Control information Emission Factor Documentation attached Data year for actual calendar r r.emissions bcloss&gas throughput ahos c(e.g.21107): Requested Permitted Estimation Method Control Device Description Control Emission Factor Actual Calendar Year Emissions' Emissions or Pollutant Etliciency Uncontrolled Controlled Uncontrolled Controlled Emission Factor Primary Secondary (%Reduction) • Uncontrolled Basis Units (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) Source NO.. VOC 42.18 Ib/MMscf 46.69 11.95 GLYCaIc CO Benzene 5.81 lb/MMscf 116.72 3.12 GLYCale Identify in Section 07 Toluene 6.88 Ib/MMscf 138.18 1.83 GLYC'ale Ethylbenzene 0.18 Ib/MM.scf 3.61 0.02 GLYCalc Xvlcnc 2.27 lb/MMscf 45.55 0.18 GLYCaIc n-Hexane 0.83 Ib/MMscf 16.74 0.27 GLYCaIc Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. 1 You will he charged an additional At'FN lee if Al'I.N is tilled out inem:reedy or missing inlornuuion and requires re-submittal, 'Annual emission lees will he based on actual emissions reported litre Ilia blank.annual e1111..ssion lees will be fused on requested emissions. : _. Section 09—Applicant Certification- l hereby certify that all information contained herein and information submitted with a oh is complete, true and correct. }} 7:y !--- le , i 4 Roshini Shankaran J '? Environmental Engineer Sigiature of erson Legally Authorized to Supply Data Date Name of Legally Authorized Per4tn Pe . `lt.. / Title \`___.- Page _ ... 2 Form AI'CI)-202 Glycol Dehydrator Al'l s 1)2 v2.doc INFO TO SUPPORT 3/19/2014 Modification A COPHE COLORADO MN VW CoDepartment ot Public f Health&Environment Januar y 30, 2017 SUBJECT: TEG Dehydrator Like-Kind Replacement for DCP midst t v';r;ll, LP Enterprise Compressor Station: 950PWE 103 On Mardi 19. 201'1 the Division received a Like-Kind Replacement tr. f i .duon for the TEG Dehydrator ID2, AIRS ID: 123 0277 068) at DCP's Enter p'i's ' C rlrrttrr s',t r Static,n in Weld County, CO. The application requested the replacement ot an underpertoaning rit'llvdtator unit with a nevv dehydrator, The application stated that the new dehydrator vrould rr'tarrr the some gas throughput and glycol circulation rate limits as the existing dehydrator. arid that no increases in emissions from the D2 unit were expected as a result of this change-out. Au.lditlorralty. the' new rebolter"will have a rating of 1.5 MMBTU!hr, a decrease from the existing {chaffer r ing MMBTU'hr. DCP requested that the VOC and HAP limits for the detlydratom be !oLoHr',i, win that the insrgnific:anti activities list be updated to reflect the loser emission; fermi the siildher iehailer . Additionally, it as 5r, it'd that no iegultation applicability changes fesult from tire ri.fropri,frd rr'ptac:em '-it. the application package included a cover later detailing Hit' ctramn:e, t. ,1'f t ,' the riot. dehydrator vitli tilt' updated SC'fllt numbei and model of the new unit, arl i_;1t.,.._._'.1 `.feHllit alit dCii+'ItI05 1lst to iCC(?tltit for the lower rt'floiter rating, and an updated sit.' wrdt.' emissions inventor y form to reflect the slight decrease in overall emissions from the smaller r it-bolt: l DCP provided for then clarification on the actual scope of w'or k b'la c'rl!iit The old d''tly`aratoi was reported to he in immediate danger of failing and could not have p r:rt 'o safely and ette( ti:Oty for the duration of the more conventional Construction Permit pr(sc.c: ., As scr'.It DCP requested an expedited like-kind replacement in which the conta(:tot skid sas It-ptic.t'..l r inn a different model s;ll'lett t') the exact same design parameters as the previous ';c.)Itti' for iOll7 Ietatrllllo the saute operational and emission limits. Although dehydrators are not typically placed under ADS-like pity isrorls it .','as (leletmined that this change was immediately necessary and could he completed a'. .' etc' I,'iat.1k, Peril, 5rrlcc' the design Ilowldte, design Rlvcol Crrctllitlort Iare alit evc'ial! t`r?Ilti,; ti tilt:' =1,,'llydr,.ltot would not deviate frum the current design. The changes highlighted in Hit ,li',l?!i' Atli),,, including the rrrudel and serial RIM be! change and updated insignificant ar tl':'Itit ., Y ;l !Y i != !Li flit' Trtlt3 V per!nit as a Ieti'istorl. II (/30/2017 State.co.us Executive Branch Mail-Enterprise CS Dehy Replacement Notification 3-17-14 ,;,c,::-.�� _4", STATE OF COLORADO -CDPHE, Elie <elie.schuchardt@state.co.us> IA lb i G.nterprise CS Dehy Replacement Notification 3-17-14 Shankaran, Roshini <RShankaran@dcpmidstream.com> Thu, Jan 19, 2017 at 1:34 PM To: "Schuchardt -CDPHE, Elie" <elie.schuchardt@state.co.us> Hi Elie - Enterprise's dehy was "swapped" in the sense that the actuaI contactor p_;n of it was changed out- It's kind of a weird situation because the gas processing capacity, the TEG pumps. and the rrlii 005 horn that whole system did not change. However since the make/model changed, we thought t best to subrri i an APEN for that change. I do remember discussing this with Blue back in the day because it was tricky and I believe she agreed that since it is truly just a rebuild for reliability purposes because the old skid was performing poorly, we had to "swing" it (even though it doesn't have an AOS)to keep the booster station up and running If we were to wait for a CP for that change to occur, the dehy would have failed before they could have performed the change. So from what I recall Blue said that for this one-off it may be treated as a swing because of this explanation. Can you let me know if you are thinking this is different now? Also, in reviewing the Enterprise Title V renewal submittal horn tidy 2016 I r.'a me that we made an error on the APEN The TEC; glycol circulation rate for D2 is 35 gpm ( as indILated by pie roe_', APE N' the GlyCal( run submitted along with the renewal application, and the calculation page for D2), however the ADEN inLurrectly lists 10 gpm, I hope this is lust a quick typo hx, but can you please let me know if you agree with that change? We would be happy to submit a revised APEN or if you would like to red-line it that would work as well! Please let me know as we are Just about compiling our Title V semiannual certifications and realize that 10 to 35 is a pretty big difference(:-'). Thanks, Roshini Roshini Shankaran Environmental Engineer Weld County DCP Midstream 370 171 Street. Suite 2500 Denver. CO 80202 Office 303-O15-2039 39 Cell: 120-391-701)5 From: Schuchardt - CDPHE, Elie [mailto:elie.schuchardt ntate co us) Sent: Tuesday, January 17, 2017 12:20 PM 'o: Shankaran, Roshini Subject: Enterprise CS Dehy Replacement Notification 3-17-14 https dm at 1.goo gle.comlmai l/ui0Pui=2&rk=85031 f40e8&view=pt&cat=DC P%20-%20Enterpr rse&search=cat&m sg=15968702922491 a4&si m l=15968702922491 a4 1/2 4/26/2016 Modification Application CI� DCP 7tMidstream Stt, P, 370 17th Street,Suite 2500 --_...,■■�� Denver,CO 80202 Midstream 303-605-2039 April 22,2016 UPS Tracking No. 1ZF469150296182597 Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South,APCD-SS-B 1 Denver,CO 80246-1530 6 2,. Re: DCP Midstream,LP Enterprise Compressor Station Operating Permit Number 95OPWE103 Minor Modification Request—AIRS ID 123/0277/074(Comb-1) Dear Sir or Madam: DCP Midstream, LP (DCP) requests the following change to the Title V Operating Permit 95OPWE103 for the Enterprise Compressor Station located in Weld County, Colorado. Operating Permit Minor Modification Application forms have not been developed,therefore,this letter and attachments serve as the application. Per review of Colorado Regulation Number 7 (Reg. 7) requirements, DCP proactively opted to replace the enclosed combustor (Comb-1, AIRS ID 074) that serves as a control device for the TEG dehydrator (D2, AIRS ID 068). The new enclosed combustor will retain the same AIRS ID and Plant ID, and overall emissions will decrease as a result of this change. Additionally, D3 (AIRS ID 073) was never constructed and DCP seeks to remove this source from the Title V permit. The new enclosed combustor will serve as a control device for D2 only. Emissions reflecting this change in operation are attached to this application. Also,please note that there are no minimum supplemental fuel requirements for the new enclosed combustor by design. The following proposed language revisions are offered to complete this minor modification request: • Section 1,Condition 6,Table 6.1: AIRS Plant Pollution Stack Description Size Control Number Identifier Device 074 Comb-I Fiore Enclosed combustor used to control still vent N/A NiA emission from D2 both dehydrators • Section II,Condition 7: Permit Monitoring Condition Compliance Parameter Number Compliance Limits Emission Factor Method Interval NOx 7.1 p40.3 tons/yr 0.068lb/MMBtu Recordkeepingand Monthly calculation CO X31.8 tons/yr 0.37 lb/MMBtu 12 month rolling total �-? >0.106 MMBtu,hf Flow Meter Continuous Page 1 • Section II,Condition 7.2: Supplemental fuel to the flare shall not be less than 0.106 MMBtulhr. A flow meter shall be used to measure the gas flow rate.The heat rate shall be calculated from the fuel use rate and the heat content of the gas determined from the most recent gas analysis. The calculations shall be maintained and made available for inspection upon request. (Construction Permit 00WE0470) Fuel meter measurements will be recorded monthly and divided by the number of hours per month. • Section II,Condition 7.3: This control system that shall be capable of reducing the dehydrator emissions of volatile organic compounds by at least 95%. The flare shall be equipped with a heat sensing monitoring device, equipped with an alarm that indicates no ignition of the pilot flame. Records of the times and duration of all pilot flame outages shall be kept. (Construction Permit 00WE0470). Compliance with the 95%reduction shall be monitored using the combination of: 1) The total supplemental heat rate provided to the flare exceeding the supplemental heat rate required in Condition 7.2.,Maintaining manufacturer specification sheet on file with a destruction efficiency guarantee of 98%, 2) the pilot flame operation records required by Condition 7.5,and 3) the lean glycol flow rate records required by Condition 3.4. Records of the compliance monitoring results shall be maintained for Division inspection upon request. No other changes to the permit are requested as part of this minor modification. A comprehensive Title V renewal application package will be submitted in a timely fashion that will include removing D3 and other clean-up items associated at this facility. Also attached to this application is an APEN renewal for D2 which does not seek to modify any emission limits associated with D2. This Title V minor modification includes the following attachments: • Attachment A—Responsible official Certification; • Attachment B—APEN Filing Fees; • Attachment C—Revised APEN for Comb-1,and renewal APEN for D2; and • Attachment D—Emission Calculations and Supporting Documentation. A signed responsible official certification form is attached for this minor modification application. If you have any questions or require any additional information about this application,please feel free to contact me at 303-605-2039 or RShankaran@dcpmidstream.com. Sincerely, DCP Midstream, LP Roshini Shankaran Environmental Engineer Attachments Page 2 Attachment A Responsible Official Certification I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and,based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures by used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). William L. Johnson Vice President of Operations Printed or Typed Name Title 4 I 73 z‘,; ignature R ponsible Official Date Attachment B APEN Filing Fees Attachment C APEN Attachment D Emission Calculations and Supporting Documentation Enclosed Combustor Emissions Enterprise Compressor Station DCP Midstream, LP Enclosed Combustor Fuel Usage 50 scf/hr Pilot Gas 1,148 BTU/SCF Fuel Heating Value 8.760 hr/yr Hours per Year 0.44 MMscf/yr Fuel Use 503 MMBtutyr Fuel Use Enclosed Combustor Waste Gas Flow Usage 2445 Btu/scf Waste Gas Heat Value 10.1 Mscf/d Worst-case Waste Gas Flowrate 3.69 MMscf/yr Worst-case Waste Gas Flowrate 365 days/yr Permitted Days of Operation 9013 MMBtu/yr Waste Gas To Combustor 502.6 MMBtu/yr Fuel Heat 9,013 MMBtu/yr Waste Gas Heat 9,516.1 MMBTU/yr EF Emissions Ib/MMBtu ton/yr NOx 0.068 0.32 CO 0.37 1.76 AP-42 Table 13.5-1 Item/Tag No.: Page 1 I of I 3 Project No.: Revision:By: D Project: Date: 13 October 2014 L 4. , Enviromental Control Equipment P.O.No.: - Checked: SO Data Sheet RFQ No.: Approved: MS Client: Ref.P&ID: Site: Supplier: LEED FABRICATION Unit/Lease: Remarks: • Model No.: L30-0018-O0 GENERAL i Design Code: NDE: LEED Fabrication Standards 2 Service: Customer Specs: ❑ Yes 3 Description: Standard Single Stage 36 High Efficiency Combustor [f No PROCESS DATA Process Conditions:Gas Composition: mol% Variable Value Units 4 Methane Flow Rate Up to 99 Mscfd s Ethane Pressure Up to 12 oz/in2 6 Propane Temperature °F 7 I-Butane Molecular Weight a n-Butane Process/Waste Stream [] Gas ❑ Liquid 9 I-Pentane Detailed Process Description/Process Notes: 10 n-Pentane 1.Turndown 10:1.Based on an expected normal operating rate indicated above. 11 n-Hexane 2.ORE:93% operating at design conditions 12 CO2 3.Burner Pressure Drop:Min.0.10 oz/in2 13 N2 14 Helium 15 H2O 16 Cl 17 C8 18 C9 19 CIO 20 C11+ 21 TOTAL Other Components: PPMV Available Utilities: 22 H2S Fuel I Pilot Gas Min.30psig Natural Gas/Propane 40-50 SCFH 23 Benzene Instrument Air NA 24 Toluene Power 120 V/60 Hz or Solar Power 25 E-Benzene Steam NA 26 Xylene Purge Gas DESIGN DATA 27 Ambient Temperatures: Noise Performance Requirements: Under 85 dBA 28 Low,°F -20 Structural Design Code: 29 High,°F 123 Wind Design Code: ASCE 30 Design Conditions: Pressure/Temperature 31 Max.Relative Humidity,% 90 Pressure/Speed 32 Elevation(ASL),ft Category 33 Area Classification: Class I Div 2 Seismic Design Code: 34 Electrical Design Code: NEC Location EQUIPMENT SPECIFICATION 35 Type: ❑ Elevated [] Endosed Equipment Design: 36 ❑ Above Ground Component Material/Size/Rating/Other 37 ❑✓ Stack ❑ Multiple Stack Burner 38 ❑ Portable/Trailer Burner Tip/Assist Gas Burner 304 S5 39 Burner Body Carbon Steel 40 Smokeless By: ❑ Steam ❑ Assist Air pilot 41 [] Gas Assist [] Staging Pilot Tip 304 IS 42 Pilot Line(s) Carbon Steel 43 Stack: ❑✓ Self Supporting Firebox/Stack 44 Flare Burner: ❑ Non-Smokeless❑ Smokeless [] Gas Assist Shell Carbon Steel 45 Pilot: ' Intermittent ❑ Continuous Piping Carbon Steel 46 pilot Air inspirator. ❑ Local ❑ Remote Nozzles Carbon Steel 47 Pilot Flame Control: ❑ No ❑✓ Yes(Thermocouple) Flanges Carbon Steel 48 Insulation Blanket 49 Pilot Ignition: ❑ Flamefront Generator ❑ Inspirating Ignitor Insulation Pins 304 SS 50 ❑ Electronic ❑ Automatic ❑ Manual Refractory NA 51 ❑ With Pilot Flame Control Refractory Anchors NA 52 ❑ With Auto Pilot Re-Ignition Ladders and Platforms NA 53 Stack Sample Connections Per EPA requirements 54 pilot Ignition Backup: ❑ Manual Specify: i.e Piezo-Electric Sight Glass 2 55 ri Battery Pack Other Item/Tag No.: Page 2 1 of L 3 Project No.: Revision: D lar Ca+ Date: 13 October 2014 Project By: ___... FS Environmental Control Equipment P.O.No.: Checked: SG Data Sheet RFQ No.: - Approved: MS Client: Ref.P&lD: I Site: Supplier: LEE)FABRICATION Unit/Lease: I Remarks: Model No.: L30-0018-00 EQUIPMENT SPECIFICATION 56 Flame Detection: ❑ Thermocouple El Ionization Rod Auxiliary Equipment 57 ❑ UV Scanner Valves IA sa General Configuration: Blowers NA 59 r. • Dampers NA 60 , Inlet KO/Liquid Seal NA 61 _ Flame/Detonation Arrestor Yes 62 4,v " Instrumentation&Controls 63 - Solenoids/Shut-Off Valves Check with Sales for available cm-die. 64 Flow Meters NA 65 . Calorimeter NA 66 Pressure Switches/Transmitters NA 67 � ,fi, Thermocouples Check with Safes for available config. ea ",, Temperature Switches/Transmitters NA 69 ;k EMS Check with Sales for available conftp. '` • 70 e ' ►`' CEMS NA 71hl l 1` Other NA 72 73 i `�,ti≥ 4 r' 75 FABRICATION AND INSPECTION 76 Special requirements ❑ Skid Mounted 0 Concrete Pad Equipment Info 77 ❑ Other Component Weight/Dimensions 78 Burner 79 Inspection ❑ Vendor Standard Burner Assembly 80 ❑ Other.Specify: Stack as Material Certification Q Vendor Standard Stack Assembly 36"OD x 2"s`H.3500 Lbs 82 ❑ MTR Pilot Tip 83 ❑ Certificate of Compliance Pilot Line(s) 84 ❑ Other(Specify): Concrete Pad 81"s31"a 6".3420 Lbs as NDE Pi Vendor Standard Auxiliary Equipment 86 ❑ Radiography.Specify: Blowers 87 Li Ultrasonic.Spedfy: Inlet KO/Liquid Seal sa ❑ Liquid Penetrant. Flame/Detonation Arrestor 89 ❑ Magnetic Particles. Skid 90 ❑ PMI.Specify: instrumentation&Controls 91 - ❑ Other.Specify: EMS 92 Surface Preparation El Vendor Standard Control Panel 93 ❑ Other.Specify: 94 Paint System ❑ Vendor Standard 95 ❑ Other.Specify: 96 Finished Color 0 Vendor Standard 97 [ I Other.Specify: 98 99 Additional Notes: Item/Tag No.: Page 3 of j 3 2.1(E-141:4) Project No.: Revision: 0 Date: 13 October 2014 Project: By: is __ Environmental Control Equipment P.O.No.: Checked: SG Data Sheet RFQ No.: Approved: MS ' Client: Ref.P&ID: - Site: Supplier: LIED FABRl Ta;d Unit/lease: Remarks: Model No.: 130-001 GENERAL ARRANGEMENT 4 ?cF s �X° ^ , a, �, � t � I tom: I' �t a `, _r a ° �` &. B Rte} r General APEN - Form APCD-200 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. There may be a more specific APEN for your source(e.g. paint booths, mining operations, engines, etc.). A list of specialty APENs is available on the Air Pollution Control Division (APCD)website at www.colorado.gov/pacific/cdphe/air-permits. 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: 95OPWE103 AIRS ID Number: 123 /0277/074 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 1 - Administrative Information Company Name': DCP Midstream, LP Site Name: Enterprise Compressor Station Site Location: Site Location SW Sec.30,T2N, R63W County: Weld NAICS or SIC Code: 4922 Mailing Address: (Include Zip Code) 370 17th Street, Suite 2500 Denver, CO 80202 Permit Contact: Dana Stephens Phone Number: 303-605-1745 Portable Source Home Base: E-Mail Address: dstephens@dcpmidstream.com 'Please 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. 347270 eve.7 c3,9,20 Form APCD-200- General APEN - Revision 7/2015 1 I _A\i' Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 [Leave clank nntess APCD has atmadr assigned a permit a and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly-reported emission source(check one below) ❑ STATIONARY source ❑ PORTABLE source -OR- ❑✓ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment ❑ Change company name 0 Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership2 0 Other(describe below) -OR APEN submittal for update only(Please 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) ❑ APEN submittal for permit exempt/grandfathered source Additional Info&Notes: Replacement of existing enclosed combustor in order to meet Reg 7 2 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: Combustion device for TEG still vent control Manufacturer: Leed Model No.: L30-0018-00 Serial No.: Company equipment Identification No. (optional): COMB-1 For existing sources, operation began on: 4/11/2016 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 Seasonal use percentage: Dec-Feb: Mar-May: June-Aug: Sept-Nov: t c ^P,Aoo Form A?CD-2OO- General APEN - Re-,;s1,-;t1 72015 2 I .V Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 eta ave blank ur:ecs t-.PCD hss 1r_a y ass`;nod a permit and AIRS ID] Section 4 - Processing/Manufacturing Information ft 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 Limit3 (Specify Units) (Specify Units) (Specify Units) Material Consumption: Finished Product(s): 3Requested values will become permit limitations. Requested limit(s)should consider future process growth. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.1910/-104.4877 ❑ 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. Operator Discharge Height p Temp. Flow Rate Velocity Above Ground Level Stack ID No., CO (ACFM) (ft/sec) (Feet) Comb 1 25 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward O Upward with obstructing raincap ❑ Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter(inches): 36 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): O Other(describe): COLOR 4-:,`O r r APCD 2e0 G_re_st e sled_7/20 3 3 ' • Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 [t ea:e Nark r k.rtcss APCD has alr c d, ssig,E ci a pci rm t s 3„dAIR') !G) Section 6 - Combustion Equipment &t Fuel Consumption Information ❑ 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 Limit3 (MMBTU/hr) (Specify Units) (Specify Units) 0.06 (Fuel Only) 3.2 MMscf/yr 4.12 MMscf/yr(Waste Gas+Fuel) From what year is the actual annual fuel use data? 2015 Indicate the type of fuel used': ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/SCF) Q Field Natural Gas Heating value: 1,148 BTU/SCF ❑ Ultra Low Sulfur Diesel (assumed fuel heating value of 138,000 BTU/gallon) ❑ Propane (assumed fuel heating value of 2,300 BTU/SCF) ❑Coal Heating value: BTU/lb Ash Content: Sulfur Content: EU Other(describe): Waste Gas Heating value (give units): 2,445 Btu/scf 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 4 I fuel heating value is different than the listed assumed value,please provide this information in the"Other"field. Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑ Yes ® No If yes, please describe the control equipment AND state the overall control efficiency(%reduction): Pollutant Control Equipment Description Overall Control Efficiency (%reduction in emissions) TSP(PM) PM,o PM2.5 SO,, NO,, CO VOC Other: P e.0 3 m APC -;C0- Gel _. AP-EN - . sun=7/2C,'5 4 I , AV Permit Number: 95OPWE103 AIRS ID Number: 1 23 /0277/ 074 [Lea,e la k E,= ss A?C_D has al;e dy ass'i,mcd a pens t-a and AIRS ID] Section 7(continued) From what year is the following reported actual annual emissions data? 2015 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) i mssion Uncontrolled E Requested Annual Permit Emission Factor Actual Annual Emissions Emission .imit(s); Pollutant Source Factor(Specify Units) (AP-42 Mfg, Uncontrolled Controlled' Uncontrolled Controlled etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) TSP (PM) PMlo PM25 SOX NO,, 0.068 lb/mmBtu AP-42 0.22 0.22 0.32 0.32 CO 0.37 lb/mmBtu AP-42 1.22 1.22 1.76 1.76 VOC Other: 3 Requested values will become permit limitations. Requested limit(s)should consider future process growth. 'Annual emission 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 pollutants(e.g. HAP- hazardous air pollutant)emissions equal to or greater than 250 O Yes ® No lbs/year? I a If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Uncontrolled Uncontrolled Controlled Overall Emission Factor CAS Emission Actual Actual Chemical Name Control Source Number Factor Emissions Emissions' Efficiency (specify units) {AP-42,Mfg.etc) (lbs/year) (lbs/year) 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. CCLomO Po'm -.Pt r) 20l) _ 1,7,.E-;',aI t:P..h, ?s'or / °01 .*.5 ( Permit Number: 95OPWE103 AIRS ID Number: 123 /0277/ 074 [Leave blank unless APCD has already assigned a permit-and MRS ill Section 9 - Applicant Certification t hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 4-122 ire jib Signature of Legally Authorized Person (not a vendor or consultant) Date Roshini Shankaran Environmental Engineer Name(please print) Title Check the appropriate box to request a copy of the: ❑ Engineer's Preliminary Analysis conducted ❑ Draft permit prior to issuance O Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 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-B 1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 www.cotorado.gov/pacific/cdphe/air-permits Telephone: (303)692-3150 t6 7. �s;y COLORADO Form APES 200 - Gener R'al APEN , son 7 2015 �'`' 6 i .".'!a AIR POLLUTANT EMISSION NOTICE(APEN)& Application for Construction Permit—Glycol Dehydration Unit' "'Permit Number: 95OPW E103 (Leave blank unless APCD has already assigned a permit tf&AIRS ID) Emission Source AIRS ID: 123/0277/068 Facility Equipment ID: D-2 (Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] section 01 —Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: DCP Midstream,LP NAICS,or 0 Request for NEW permit or newly reported emission source SIC Code: 4922 Source Name: Enterprise Compressor Station ❑ Request MODIFICATION to existing permit(check each box below that applies) Source Location: SW Sec 30,T2N,R63W County: Weld 0 Change process or equipment 0 Change company name Elevation: 4,788 Feet 0 Change permit limit 0 Transfer of ownership 0 Other Mailing Address: 370 17th Street,Suite 2500 ZIP Code: 80202 ❑ Request to limit HAPs with a Federally enforceable limit on PTE Denver,CO ® Request APEN update only(check the box below that applies) Person To Contact: Dana Stephens Phone Number: 303-605-1745 ►r Revision to actual calendar year emissions for emission inventory Update 5-Year APEN term without change to permit limits or previously E-mail Address: dstephens(uldcpmidstream.com Fax Number: 303-605-1957 ❑ reported emissions Addl.Info. Section 03—General Information &Notes: For existing sources,operation began on: I/11/2001 For new or reconstructed sources,the projected startup date is: / / Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year General description of equipment and purpose: Dehydration unit for water removal ► Is this unit subject to the 90%control requirement of Colorado Regulation No.7,XVl1.D(total uncontrolled actual VOC emissions from all dehydration units at this stationary source,including APEN Exempt units,? 15 tons/yr)? ® Yes 0 No 0 Don't know ► Will this equipment be operated in any NAAQS nonattainment area? (hitp:%'www_coku ado.i.ov/cdphc-attainment) ® Yes O No 0 Don't know ► Is this unit located at a stationary source that is considered a Major Source of Hazardous Air Pollutant(HAP)emissions? CO Yes 0 No 0 Don't know Section 04—Dehydration Unit Equipment information Manufacturer: Forum Model: Custom Unit Serial No.: Custom Unit Colorado Department of Public Health and Environment Air Pollution Control Division(APCD) Reboiler Rating: 1.5 MMBtu/hr Glycol Used: Z TriEthylene Glycol(TEG) 0 Ethylene Glycol(EG) 0 DiEthylene Glycol(DEG) This notice is valid for five(5)years. Submit a revised APEN prior to Glycol Pump Drive: Electricexpiration of five-year term, or when a significant change is made y ❑ Gas If gas,injection pump ratio: acfinUgpm (increase production,new equipment,change in fuel type,etc). Pump Make&Model: Rotor Tech CS2212 #of Pumps: Glycol recirculation rate(gal/min): Max: 35 Requested-': 35 Lean glycol water content: 1.5 wt."/o Mail this form along with a check for$152.90 to: Colorado Department of Public Health&Environment , Dehy.Gas Throughput: Design Capacity: 110 MMSCF/day Requested: 40,150 MMSCF/yr. APCD-SS-81 Calendar year actual: 28,392 MMSCF/yr. 4300 Cherry Creek Drive South Inlet Gas: Pressure: 1,000 psig Temperature: 120 °F Denver,CO 80246-1530 „" Water Content: Wet Gas: lb/MMscf ® Saturated Dry Gas: 7 lb/MMscf For guidance on how to complete this APEN form: Flash Tank: Pressure: 30 psig Temperature: 160 °F O None Air Pollution Control Division: (303)692-3150 Cold Separator: Pressure: psig Temperature: °F ® None Small Business Assistance Program(SBAP): (303)692-3148 or p p' b p' (303)692-3175 Stripping Gas: ® None 0 Use flash gas 0 Use dry gas: scfin 0 Use N2: scfm APEN forms:http:Pwww.arklrado.ttov;cdphe'APF.Nft'rms 'You will be charged an additional ADEN fee if APEN is tilled out incorrectly or missing information and requires re-submittal. Application Status:hi;hHp(/w tit`w.t olos'ttdo.s ov'cdphc/lrerntitstattts 'Requested values will become permit limitations. Additional 0 Attach a process flow diagram Information 0 Attach GRI-GLYCaIc 4.0 Input Report&Aggregate Report(or equivalent simulation report/test results) 0 Check box to request copy of draft permit prior to issuance. _ Required: 0 Attach the extended gas analysis(including BTEX&n-Hexane,temperature&pressure) 0 Check box to request copy of draft permit prior to public notice. FORM 'D-202 347269 Page FormAPCD-202-GlycolDehydratorAPEN-Ver.1 2013.docx Jilt illp. AIR POLLUTANT EMISSION NOTICE (APEN)& Application for Construction Permit—Glycol Dehydration Unitl ` Permit Number: 95OPWE103 Emission Source AIRS ID: 123/0277/068 Section 05—Stack Information(Combustion stacks must be listed here) Section 06—Stack(Source,if no combustion)Location(Datum&either Lat/Long or UTM) Operator Stack Base Stack Discharge l� Horizontal Datum UTM UTM Easting or UTM Northing or Method of Collection for Stack Elevation Height Above Temp. Flow Rate Velocity Moisture Ground]eve! (°F) (ACF.M o (NAD27,NAD83, Zone Longitude Latitude Location Data(e.g.map, ID No. (feet) (f ) ) (ft/sec) (/o) WGSS4) (12 or 13) (meters or degrees) (meters or degrees) GPS,GoogleEarth) D2 4,788 20 700 545 106 AMB WGS 84 13 -104.4877 40.191 GPS Direction of stack outlet(check one): ® Vertical O Vertical with obstructing raincap O Horizontal O Down O Other(Describe): Exhaust Opening Shape&Size(check one): 0 Circular:Inner Diameter(inches)= 4 O Other:Length(inches)= Width(inches)= Section 07—Control Device Information (Indicate if a control device controls the flash tank and/or regenerator emissions) ® Condenser used for control of. Still Vent Stream ® Combustion Device used for control of. Still vent stream Rating: MMBtuthr Type: Make/Model: Type: Combustor Comb 1 Make/Model/Serial#/: Leed Single Stage 36 High Efficiency Combustor Temperature(°F): Maximum: Average: VOC&HAP Control Efficiency: Requested: 95 % Manufacturer Guaranteed: 98 % Requested VOC&HAP Control Efficiency: % Minimum temp.to achieve requested control: °F Waste gas heat content: Btu/scf ® VRU used for control of. Flash tank vent stream Constant pilot light? El Yes O No Pilot burner rating: MMBtu/hr Size: MakeiModel: O Closed loop system used for control of: Requested VOC&HAP Control Efficiency: 100 % Description: . Annual time that VRU is bypassed(etnissions vented): "/° O Describe Any Other: Section 08—Emissions Inventory Information& Emission Control Information O Emission Factor Documentation attached Data year for actual calendar yr.emissions below&gas throughput above(e.g.2007): I 2015 Control Device Description Control Emission Factor Actual Calendar Year Emissions3 Requested Permitted Estimation Method Pollutant • Efficiency Emissions or Primary Secondary (%Reduction) Uncontrolled Basis Units Uncontrolled Controlled Uncontrolled Controlled Emission Factor (Tons/Year) (Tons/Year) (Tons/Year) (Tons/Year) Source NOx VOC 40.98 16/MMsef 581.71 3.12 846.70 11.95 GLYCalc CO Benzene 2.87 Ib/MMsef 40.76 0.75 116.70 3.12 GLYCaIc identify in Section 07 Toluene 2.89 lb/MMsef 41.00 0.43 138.20 1.83 GLYCalc Fthylbenzene 0.10 Ib/MMsef 1.41 0.006 3.61 0.02 GLYCalc Xylene 1.06 lb/MMsef 15.02 0.07 45.55 0.18 GLYCalc n-Hexane 0.74 Ib/MMsef 10.54 0.07 16.74 0.27 GLYCalc Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. You will be charged an additional APLN fee if APEN is filled out incorrectly or missing information and requires re-submittal. 'Annual emission fees will be based on actual emissions reported here. If left blank,annual emission fees will be based on requested emissions. Section 09—A icant Certification-I hereby certify that all information contained herein and information submitted with,'4his application is complete,true and correct. - _' k. '17-7 Iwi 6 Roshini Shankaran ;.� Environmental Engineer Sign e of erson Legally Authorized to Supply Data ate Name of Legally Authorized Persons ase print) Title g Y Page FonnAPCD-202-GlycolDehydratorAPEN-Ver.1 2013.docx INFO TO SUPPORT 4/26/2016 Modification 41/4 COPHE ' COLORADO i CO i Department of Public .• , Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado RoshiniShankaran. DCP Operating Company, LP 370 17th Street, Suite 2500 Denver, CO 80202 10/2/2017 RE: Complete Application for Minor Modification to Operating Permit 95OPWE103 Dear Ms. Shankaran: The Division received your request to modify the Operating Permit for the Enterprise Compressor Station on April 26, 2016. The modifications requested include replacing the enclosed combustor Comb-1 with a new model that will result in an overall decrease in emissions. The Division agrees that the requested modifications meet the requirements of a minor permit modification (Reg 3, Part C, Section X.A) and considers that your submittal comprises a complete application for a minor permit modification. The Division considers your application for a minor operating permit modification to be complete as of April 26, 2016. As specified in Colorado Regulation 3, Part C, Section X.I, "a source shall be allowed to make the changes proposed in its application for minor permit modification immediately after it files such [complete] application." Note that if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit that Colorado Regulation 3, Part C, Section X.I requires that: "...the source must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time the source does not need to comply with existing permit terms and conditions it seeks to modify, but if the source fails to comply with its proposed permit terms and conditions during this period, the existing permit terms and conditions it seeks to modify shall be fully enforceable by the Division." In addition, if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit, the new or modified equipment shall be addressed in subsequent semi-annual monitoring and permit deviation reports and annual compliance certifications. The compliance status of the new or modified equipment shall be based on the provisions specified in the draft permit submitted with the minor permit application. If the Division has submitted a proposed permit to EPA for their 45-day review period, the compliance status of the new and/or modified equipment shall be based on the proposed permit beginning on the date the proposed permit was sent to EPA. Typically the next step for this permit modification is the EPA 45-day review. Although you submitted a complete application, the Division needs additional time to review the application. In the event that the Division does not use the draft permit language included in your application or k-6 q°�o 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe , ' _ \o`,. John W. Hickentooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer (*. )*i \� J _7 makes additional changes to the permit, we will provide you with an opportunity to review the draft Operating Permit and any associated technical review document. Upon your acceptance of the Division's revised draft permit, the Division will forward the proposed permit to EPA for their 45-day review period. A copy of the proposed permit will be sent to you at that time. Upon completion of EPA's 45 day review period you will be issued a revised operating permit for your facility. If you have any further questions please contact me at (303) 692-6332. Sincerely, Elie Schuchardt Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division cc: Craig Giesecke, APCD inspector (electronic copy) • A CDPHE COLORADO Co Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. D. J. Law Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P-AR U. S. EPA, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 October 17, 2017 Dear Mr. Law: The Division received a complete application for a minor modification to the Operating Permit for the following Colorado facility: Applicant/Facility Name: DCP Operating Company, LP - Enterprise Compressor Station AIRS ID#: 123-0277 • Permit No: 95OPWE103 Facility Address: SW 1/4 of SW /, Section 30, T3N, R63W Facility City, State, ZIP: Weld County The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. As required by Colorado Regulation No. 3, Part C, Section X.F, the Division is notifying you that a complete application for a minor permit modification has been submitted. The application was deemed complete on April 26, 2016. Please do not hesitate to contact me if you have any questions at 303-692-6332 or elie.schuchardt@state.co.us Sincerely, C1 (I atr0,,r2t Elie Schuchardt Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division / of Q l 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer '.;' CDPHE COLORADO Co Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Balaji Vaidyanathan Permit Section Manager Arizona Department of Environmental Quality - Air Quality Division 1110 West Washington Street Phoenix, AZ 85007 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Balaji Vaidyanathan, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, ii/b/72?' Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 'A:?-z of 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe mod„ John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer * _ A CDPHE COLORADO Co Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ms. Marian Massoth Air Permitting Chief Kansas Dept. of Health £t Environment 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Ms. Massoth, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt®state.co.us. Sincerely, -1/1")? — Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe I f Q` t� �G. John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer ;* f*; \J876_r A CDPHE COLORADO .� Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado NDEQ Air Permitting Section Supervisor Nebraska Dept. of Environmental Quality P.O. Box 98922 Lincoln, NE 68509-8922 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear NDEQ Air Permitting Section Supervisor, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe pc John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer *. 1g75,.: A CDPHE COLORADO CO % Department of Public • Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Robert Samaniego Major Source Unit Manager New Mexico Environment Department - Air Quality Bureau 525 Camino de los Marquez Suite 1 Santa Fe, NM 87505-1816 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Samaniego, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, dibt-j; - Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division w t�Y coy ,,,, 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe FQ ` John W. Hickentooper,Governor 1 Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer I * +I \,„'",:---,,,1/4/ '',...,1_87c,t ACDPHE COLORADO Department of Public 1 Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Richard Kienlen Oklahoma Department of Air Quality P.O. Box 1677 Oklahoma City, OK 73101-1677 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Kienlen, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe / �'• John W. Hickenlooper,Governor Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer * • A CDPHE COLORADO CO v.'" Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Mark Hutson Acting Air Qaulity Program Manager Southern Ute Indian Tribe - Air Quality Program P.O. Box 737, MS #84 Ignacio, CO 81137 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Hutson, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, /04-f' Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Ee John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer *' . I. A, CDPHE COLORADO Ark Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. Jesse Chacon Manager - Title V Section Texas Natural Resources Conservation Commission P.O. Box 13087 Mail Code 163 Austin, TX 78711-3087 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Chacon, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, 106 Matthew S.Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division c_cod 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer t* *; * %* -� ._ Cp *+E COLORADO co Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Mr. David Beatty Section Manager - Operating Permits Utah Department of Environmental Quality - Division of Air Quality P.O. Box 144820 Salt Lake City, UT 84114 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Mr. Beatty, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt®state.co.us. Sincerely, • Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 47 _�x 50; John W. Hickenlooper,Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer f #! CDPHE COLORADO Department of Public • I Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Ms. Lori Bocchino Air Quality Operating Permit Program Principal Wyoming Department of Environmental Quality - Air Quality Division 122 W 25th Street Cheyenne, WY 82002 October 2, 2017 RE: DCP Operating Company, LP - Enterprise Compressor Station Operating Permit No. 95OPWE103 SUBJECT: Notification to Affected States of Requested Operating Permit Modification Dear Ms. Bocchino, The Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment (CDPHE) received a complete application for a minor modification to the above referenced Operating Permit. The Division agrees that the requested modification can be processed under the minor permit modification procedures identified in Colorado Regulation No. 3, Part C, Section X. This facility is located between Keenesburg and Roggen, Colorado in Weld County. As required by Colorado Regulation No. 3, Part C, Section X.G, the Air Pollution Control Division is notifying you that a complete application for a minor permit modification has been submitted. As specified in Colorado Regulation No. 3, Part C, Section X.I, the source is allowed to make the changes proposed in its application for minor permit modification immediately after it files such [a complete] application. The application was deemed complete on April 26, 2016. If you have any questions or require any additional information, please contact Elie Schuchardt at 303-692-6332 or elie.schuchardt@state.co.us. Sincerely, Matthew S. Burgett Operating Permit Unit Stationary Sources Program Air Pollution Control Division 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I� John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer *. . * � K ,mot 1/29/2018 Modification Application d DCP Operating Company,LP P De th Street,Suite 2500 De nve e r,CO 80202 Midstream ,0 .605-1745 January 26, 2018 Sent via UPS Tracking No. 1Z F46 915 02 9426 7268 Ms. Elie Schuchardt Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-B11� Denver. CO 80246-1530 Re: DCP Operating Company, LP; Enterprise Compressor Station (123/0277) Title V Permit 95OPWE103 Minor Modification Application D-2 Natural Gas Dehydrator(AIRS 068) COMB-1 Enclosed Combustor(AIRS 074) Dear Ms. Schuchardt: DCP Operating Company, LP (DCP) is submitting the attached Tile V Minor Modification application for the Enterprise Compressor Station, located in SE Section 30, Township 2N, Range 63W, Weld County, Colorado. An initial minor modification application for this facility was submitted 4/22/2016. This was followed by a timely renewal application, coupled with an additional minor modification application, submitted 7/26/2016. The minor modification portion of the 7/26/2016 application requested a 5.0% annual downtime for the vapor recovery unit (VRU) used to control the emissions from the flash tank associated with TEG dehydrator D-2, during which times the flash tank emissions would vent to the enclosed combustor COMB-1 used for primary still vent control of this unit. DCP would like to reroute the VRU downtime emissions so that they vent to atmosphere during downtime events, rather than direct these emissions to COMB-1 as previously indicated. The following is a summary of all requested changes for unit D-2 and control device COMB-l: D-2: Natural Gas Dehydrator(AIRS 068)and COMB-1: Enclosed Combustor(AIRS 074) • Remove COMB-1 as a backup control device for the VRU used for flash tank emission control on unit D-2. The flash tank will vent to atmosphere during periods of VRU downtime. • Reduce the requested annual downtime for the enclosed combustor COMB-1 from 3.0% to 2.25%(197 hours/yr). o DCP is submitting a revised APEN for control device COMB-1, reflecting the change in combustion emissions from both the change in method of control for unit D-2, as well as the decrease in COMB-1 annual downtime • Reduce the requested annual downtime for the VRU from 5.0%to 1.0%(88 hours/yr). • Minor updates to the GLYCalc properties for unit D-2. ■ DCP is requesting no change in the VOC PTE emissions from unit D-2 based on the above changes to D-2 and COMB-1. The VOC emission limit will remain 33.27 TPY as requested in the 7/26/2016 application. VOC emission increases from the removal of COMB-1 as a backup control device for the VRU were balanced out by decreasing control device downtime for both the VRU, and COMB-1 when acting as a primary control device for the D-2 still vent. o Although the VOC emission limit will remain unchanged, DCP is submitting a revised APEN for unit D-2, reflecting the changes in method of control, associated control device downtime, updated GLYCaIc run, and slight changes to overall hazardous air pollutant(HAP)emissions from this unit. o DCP is submitting a revised O&M plan for unit D-2, reflecting the updates to the methods of control for this unit. • DCP has provided draft Title V permit language in Attachment G for both D-2 and COMB-1, in order to complete this minor modification request. These serve as corrections to the proposed conditions in the 7/24/2016 minor modification application, reflecting the revised methods of control and control device downtime for D-2. • The minor modification submitted alongside the timely renewal application on 7/26/2016 included a revised CAM plan for unit D-2. Since the requested VOC an HAP limitations for D-2 are not changing with this application, and the amount of downtime for the associated enclosed combustor COMB-1 was not specified in the 2016 revised CAM plan, DCP is not requesting any further changes to D-2's CAM plan with this application. Please find updated emissions calculations for units D-2 and COMB-1, and an updated GLYCalc run with associated extended gas analysis (EGA) for unit D-2 in Attachment D of this application. Additionally, please find an updated Operating and Maintenance (O&M) Plan for unit D-2 in Attachment F of this application. The existing O&M plan has been revised to reflect the above requested changes to the control of emissions from this source. Federal and State Regulatory Applicability Unit D-2 at this facility is subject to the Area Source provisions of MACT Subpart HH. There are no changes in the applicable requirements under this subpart, based on the changes proposed in this Minor Modification application. Unit D-2 is subject to the emission reduction requirements, as well as the control device operation requirements under Colorado Regulation 7, Section XII.H. DCP will continue to meet all applicable requirements under this section. Unit D-2 is also subject to the state-specific emission reduction and control requirements under Colorado Regulation 7, Section XVII. Specifically, the emission reduction requirements under Reg 7, Section XVII.D require at least a 95%reduction in actual emissions of hydrocarbons. The attached calculations in Attachment D of this application show that DCP will continue to meet this requirement after the updates to methods of control and associated changes to requested downtime. Control Device COMB-1 is subject to the State-Only control device requirements of Reg 7, ' Section XVII.B.I.c. DCP will continue to meet all applicable requirements under this section. This Title V Operating Permit Minor Modification application includes the following attachments: A. Responsible Official Acknowledgement B. APEN Fees C. Updated APENs(D-2, COMB-1) D. Emission Calculations and Supporting Documentation E. Form APCD-102 F. Updated O&M Plan (D-2) G. Proposed Title V revisions(D-2, COMB-1) If you have any questions or require any additional information about the project, please feel free to contact me at(303)605-2039 or RShankaran'a?DCPMidstream.com. Sincerely, DCP Operating Company,LP A C ---'-- Roshini Shankaran Environmental Engineer Enclosures I have reviewed this Minor Modification application supplied under authority of Regulation No. 3, Part C, Section X (5 CCR 1001-5) in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the proposed modification meets the criteria for use of minor permit modification procedures and request that such procedures by used to process this application. This certification conforms with Regulation No. 3, Part C, Section X.D.3 (5 CCR 1001-5). David M. Jost Vice President of Northern Operations Printed or Typed Name Title iJ Signature of Res onsible Official Date Natural Gas Dehydration Enterprise Compressor Station DCP Operating Company,LP AIRS ID 123/02771068 Source IR 02 Snipping Gas' N YIN Description 110 MMSCFD Deny What is Stripping Gas, NIA Manufacturer Four-; Stripping Gas Flow Rate WA scmv Mode anto,,, Condenser?' Y Yord Serial# csiatim Condenser Temperature 140 deg F Operation Date Condenser Pressure 12 5 Para Operation 8760 hrryr EGG? Y YIN We Gas Temperature 120 deg F EDD Ambient Air Temp 0 deg F Wet Gas Pressure 950 prig ECD Destruction Efficiency 65 00% Wet Gas Water Content Saturated lbS2O/MMscf EGD Excess OXygae 0 00% Dry Gay Flow Rate 110 MMscfd Combustor Downtime 2.25%Uncontrolled Dry Gas Water Content 7 0 IbH2O/MMsof Lean Glycol Water Content 1.5 wt%H2O VRU Downtime(1.0%). 87.6 hrstyr Lean Glycol Flaw Rate 35 gpm COMB-1(ECD)Downtime(225%): 196.9 hrsiyr Cold Separator? N YIN Cold Separator Temperature deg F Cold Separator Pressure psig Gl790l Pump Make 8 Model Rotor Tech GS2212 Glycol Pump Type Electra Elec.or Gas Glycol Pomp Gas Flow Rate N/A admlgpm Flash Tank? V We Flash Tank Temperaure 130 deg F Flash Tank Pressure 50 prig Flash Tally Control 100 00%Recycled to Inlet VRU Downtime 1 60%Routed to atmosphere • Total Emissions from GRI-GLYCorc 4.0 Uncontrolled Emissions CAS Flash Emissions' Still Vent Emissions' Total Deny Emissions' Emission Factors Pollutant Number Opy) ($Y) IWY1 1 (lb/yr) (111/51Mscf) MCC 309.30 557.70 867.00 I 43.19 n-Hexane- 110-54-3 It 01 17.37 34747 0.07' ' Benzene 71-43-2 2 2 1 117 32 119.72 239443 5 96 Toluene 108-88-3 168 III 33 14321 '. 286424 713 Ethytbeazene 100.41-4 603 378 361 7621 0.19 Xyene 1330-20-7 025 4781 4606 96123 239 Xylene 13330-20-7 006 000 0.00 0 000 / Total HAP to 93 32125 332.18 1655 fi 1 Flash omissions and still vent emissions(uncontrolled potential to emit)obtained from GyCalc report dated January 2018. 2 Total dehy emissions calculated as a sum of Flash and Still Vent emissions Flash Tank Emissions Flash Tank VRU Flash Tank 1/911 Downtime Total Flash Tank Emissions' CAS Upbme Emissions' Emisslons Pollutant Number (toy) 11011 11071 VOC 0.00 309 309 n-Hexane 110-54-3 0 00 006 0 06 Benzene 71-43-2 0 00 0 02 0 02 Toluene 108-88-3 0.00 002 002 Ethylbenzeno 160-41-4 0.00 0.00 0,00 Xylem, 1330-20-7 0 00 0 00 0 00 Xylene 1330-20-7 0.00 600 000 Total HAP 0.00 0.11 0 11 3 No emissions during VRU uphme,100%Traveled to process 4 VRU downtime emissions refer to emissions during a maximum 011%VRU downtime for maintenance and malfunctions The VRU vents to atmosphere during downtime erents 5 Total flash tank emissions are eamvilent to tiara tank VRU downtime emissions Still Vent Emissions Still Vent COMB-1 Still Vent COMB-1 Downtime Total 0911 Vent Emissions' , CAS Uptime Emissions` Emissions' Pollutant Number (tpyl (1011 I1pyl VOC 20.320 9,357 30.18 n-Hexane 110-54-3 0 100 0.225 0.73 Benzene 71-43-2 4 535 2 218 7 15 Tolumne 108-80-3 4 686 2.106 679 Emyberzene 100-41-4 0075 0.034 0.11 Xylene 1330.20-7 0575 0393 1227 Xylene 1330-20-7 0000 0.000 000 Total NAP 11 071 4 976 16.05 6.Still Vent COMB-1 control emissions refer to still vent emissions controlled by a condenser and the enclosed combustor Emisslons obtained from Glyealc report dated January 2011 100%uptime of COMB-1 assumed,lc achieve a conservative estimate of emissions 7 COMB-1 downtime emissions refer to emissions during a maximum of 2 25%enclosed combustor downtime for maintenance and malfunctions 8 Total still vent emissions is a sum of still vent COMB-1 optima and COMB-1 downtime emissions Total Controlled Emisslons(PTE) CAS Delay Emissions' Overall System Control'• Pollutant Number (tPY) VOC 33.27 n-Hexane 110-54-3 0.79 Benzene _ 71-43-2 7 18 Toluene • 106-863 651 2% Ethylbemane 100-41-4 011 Xylene 1330-20.7 1,27 Xylene 1330-20-7 0.00 Total HAP 16.16 9.Total controlled dehydrator emissions calculated as a sum of controlled still vent emissions,combined with emissions-during VRU and COMB-1 downtime 10 Demaestrasng an overall system censoi of 95%.calculated as 1100%-Total Controlled Dehy VOC Emissions I Total Uncontrolled Deny Emissions] Natural Gas Dehydration Condenser Vent Stream Detail from GRI-GCYCaic Gescnaten pony-antl,nue,j.,_ Vent F ow Rate 1 542 xx 1 sct/hr Hcur5 et eperabon 23 hrhr Annual Flow Rate 9.110 MMsdyyr Pure Component Pure Component Component Fraction Component Component Fraction Component Vol% Mal Fraction Mol Weight Mel Weight Mass Fraction Heat Value Heat Value (I1./lb-mot) 11beb-molJ 16tu/se1) (Btursct) Methane 4 0'' 00497 16.09 080 00195 10100 50.2 Emane 0 65 0,0765 3007 230 I 00563 1769,6 1355.4 Propane 570 00870 4410 384 0.0940 2516.1 218.9 -Butane 2v.. 0,0202 5812 117 00268 3251.9 657 n-6u ene 5 92 0.0692 56 12 4,02 0.0965 3262.3 225.6 I-Pentane ._ 00179 7215 1 29 0.0316 4000.9 - 7136 n-Pentane 2 33 0 0253 72.15 1 83 0 0447 4008.9 101.4 Cyclopentane =v. 0.0081 7013 0.57 00139 3763.9 304 ' a-Hexane 9 97 0 0097 66.18 0 84 0.0205 4755.9 46 1 Cyciohexane --. 00147 . 8416 124 00303 44815 659 Other Hexane .. 0.0130 8618 112 0.0274 47559 618 Heptanes _ 17 0 0117 100.20 1 17 0 0287 6502 5 .64.4 ' Memylcycichexace 0 33 00000 9819 0.00 0.0000 5215.7 0.0 ' 224-xnme`hylpen`.ane 0035 0.0000 114.23 000 0.0000 62317 00 Benzene 1060 0.1050 • 78,11 626 02028 37418 3966 Toluene 5 19 0.0849 82 14 7.82 0 1916 4475 0 379.9 Etrytbenrene ;10 0 0012 106.17 0.13 0.0031 5222.2 6 2 Xyienes 2.. 00138 31950 440 01077 52088 719 ' Octanes a Z.i%3 0 0002 114 23 0.03 0 0006 6246.9 1 4 60 91 0 6091 40.83 1.00 1994 Enterprise Compressor Station Process Flow Diagram DCP Midstream, LP 0 Combustor A 8—300bb1 Stabilized Condensate Tanks > Truck Loading Condensate , Gas Stabilizer V 0 COMB-1 A A VRU < A West Pressurized Bullet < Gas Return A ' BTEX to Inlet ° Condenser L Condensate Condensate m A >I Slug Catcher \ East Inlet Gas v Gas Pressurized Bullet J Gas Inlet > Compression > Dehydration > Outlet Gas Slug Catcher Inputs.txt GRI-GLYCalc VERSION 4.0 - SUMMARY OF INPUT VALUES Case Name: Enterprise TEG Dehydration Unit D2 File Name: \\dennas00\Data\Environmental\Air\Colorado\Enterprise\2018 Minor Mod\GLYCalc\Updated Dehy Glycalc Run 01.2018.ddf Date: January 19, 2018 DESCRIPTION: Description: 110 MMscfd 35 gpm Glycol circ rate Inlet Gas Temp: 120 F Inlet Gas Pressure: 950 psig 2011 EGA Annual Hours of Operation: 8760.0 hours/yr WET GAS: Temperature: 120.00 deg. F Pressure: 950.00 psig Wet Gas Water Content: Saturated Component Conc. (vol %) Carbon Dioxide 2.5900 Nitrogen 0.3200 Methane 73.6098 Ethane 13.4435 Propane 5.7633 Isobutane 0.8191 n-Butane 1.8738 Isopentane 0.5005 n-Pentane 0.5144 Cyclopentane 0.0240 n-Hexane 0.1123 Cyclohexane 0.0286 Other Hexanes 0.2068 Heptanes 0.0782 Benzene 0.0251 Toluene 0.0204 Page 1 Inputs.txt Ethylbenzene 0.0004 Xylenes 0.0038 C8+ Heavies 0.0227 DRY GAS: Flow Rate: 110.0 MMSCF/day Water Content: 7.0 lbs. H2O/MMSCF LEAN GLYCOL: Glycol Type: TEG Water Content: 1.5 wt% H2O Flow Rate: 35.0 gpm PUMP: Glycol Pump Type: Electric/Pneumatic FLASH TANK: Flash Control: Recycle/recompression Temperature: 130.0 deg. F Pressure: 50.0 psig REGENERATOR OVERHEADS CONTROL DEVICE: Control Device: Condenser Temperature: 140.0 deg. F Pressure: 12.0 psia Control Device: Combustion Device Destruction Efficiency: 95.0 % Page 2 Inputs.txt Excess Oxygen: 0.0 Ambient Air Temperature: 60.0 deg. F Page 3 Aggregate.txt GRI-GLYCalc VERSION 4.0 - AGGREGATE CALCULATIONS REPORT Case Name: Enterprise TEG Dehydration Unit D2 File Name: \\dennas00\Data\Environmental\Air\Colorado\Enterprise\2019.01 - TV Minor Mod (Remove ECD as backup for VRU)\Attachment D - Calculations and Supporting Documentation\GLYCalc\Updated Dehy Glycalc Run 01.2018.ddf Date: January 19, 2018 DESCRIPTION: Description: 110 MMscfd 35 gpm Glycol circ rate Inlet Gas Temp: 120 F Inlet Gas Pressure: 950 psig 2011 EGA Annual Hours of Operation: 8760.0 hours/yr EMISSIONS REPORTS: CONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Methane 0.1089 2.614 0.4770 Ethane 0.3145 7.549 1.3777 Propane 0.5246 12.589 2.2976 Isobutane 0.1603 3.847 0.7021 n-Butane 0.5496 13.191 2.4074 Isopentane 0.1763 4.231 0.7722 n-Pentane 0.2500 5.999 1.0949 Cyclopentane 0.0776 1.862 0.3399 n-Hexane 0.1143 2.742 0.5004 Cyclohexane 0.1687 4.048 0.7388 Other Hexanes 0.1532 3.677 0.6711 Heptanes 0.1602 3.845 0.7017 Benzene 1.1268 27.042 4.9353 Toluene 1.0698 25.674 4.6855 Ethylbenzene 0.0171 0.410 0.0748 Xylenes 0.1999 4.796 0.8752 C8+ Heavies 0.0053 0.127 0.0231 Total Emissions 5.1768 124.244 22.6746 Total Hydrocarbon Emissions 5.1768 124.244 22.6746 Total VOC Emissions 4.7534 114.092 20.8199 Total HAP Emissions 2.5277 60.664 11.0712 Total BTEX Emissions 2.4134 57.922 10.5708 UNCONTROLLED REGENERATOR EMISSIONS Component lbs/hr lbs/day tons/yr Methane 2.1787 52.289 9.5428 Ethane 6.2996 151.191 27.5924 Propane 10.5560 253.343 46.2352 Isobutane 3.2428 77.827 14.2035 n-Butane 11.1645 267.947 48.9004 Isopentane 3.6734 88.160 16.0893 n-Pentane 5.2627 126.304 23.0505 Cyclopentane 1.6519 39.645 7.2352 n-Hexane 2.5132 60.318 11.0080 Cyclohexane 3.8665 92.797 16.9354 Other Hexanes 3.2946 79.070 14.43O2 Page 1 Aggregate.txt Heptanes 4.0432 97.036 17.7391 Benzene 26.7845 642.829 117.3163 Toluene 32.2687 774.450 141.3370 Ethylbenzene 0.8634 20.721 3.7815 Xylenes 10.9150 261.959 47.8075 C8+ Heavies 7.2286 173.486 31.6612 Total Emissions 135.8072 3259.372 594.8354 Total Hydrocarbon Emissions 135.8072 3259.372 594.8354 Total VOC Emissions 127.3288 3055.892 557.7002 Total HAP Emissions 73.3448 1760.276 321.2504 Total BTEX Emissions 70.8316 1699.958 310.2424 FLASH GAS EMISSIONS Note: Flash Gas Emissions are zero with the Recycle/recompression control option. FLASH TANK OFF GAS Component lbs/hr lbs/day tons/yr Methane 47.4483 1138.760 207.8237 Ethane 39.5769 949.846 173.3468 Propane 30.4428 730.628 133.3396 Isobutane 6.2409 149.780 27.3349 n-Butane 16.4036 393.686 71.8477 Isopentane 4.7229 113.349 20.6862 n-Pentane 5.4502 130.804 23.8718 Cyclopentane 0.4378 10.507 1.9175 n-Hexane 1.4533 34.879 6.3655 Cyclohexane 0.5662 13.590 2.4802 Other Hexanes 2.5088 60.212 10.9887 Heptanes 1.1505 27.611 5.0391 Benzene 0.5491 13.178 2.4050 Toluene 0.4281 10.275 1.8751 Ethylbenzene 0.0066 0.160 0.0291 Xylenes 0.0580 1.393 0.2542 C8+ Heavies 0.1975 4.740 0.8650 Total Emissions 157.6415 3783.397 690.4699 Total Hydrocarbon Emissions 157.6415 3783.397 690.4699 Total VOC Emissions 70.6163 1694.791 309.2994 Total HAP Emissions 2.4952 59.884 10.9289 Total BTEX Emissions 1.0419 25.005 4.5634 EQUIPMENT REPORTS: CONDENSER AND COMBUSTION DEVICE Condenser Outlet Temperature: 140.00 deg. F Condenser Pressure: 12.00 psia Condenser Duty: 3.93e-001 MM BTU/hr Hydrocarbon Recovery: 2.57 bbls/day Produced Water: 30.66 bbls/day Ambient Temperature: 60.00 deg. F Excess Oxygen: 0.00 % Combustion Efficiency: 95.00 % Supplemental Fuel. Requirement: 3.93e-001 MM BTU/hr Page 2 Aggregate.txt Component Emitted Destroyed Methane 5.00% 95.00% Ethane 4.99% 95.01% Propane 4.97% 95.03% Isobutane 4.94% 95.06% n-Butane 4.92% 95.08% isopentane 4.80% 95.20% n-Pentane 4.75% 95.25% Cyclopentane 4.70% 95.30% • n-Hexane 4.55% 95.45% Cyclohexane 4.36% 95.64% Other Hexanes 4.65% 95.35% Heptanes 3.96% 96.04% Benzene 4.21% 95.79% Toluene 3.32% 96.68% Ethylbenzene 1.98% 98.02% Xylenes 1.83% 98.17% C8+ Heavies 0.07% 99.93% ABSORBER NOTE: Because the Calculated Absorber Stages was below the minimum allowed, GRI-GLYCaic has set the number of Absorber Stages to 1.25 and has calculated a revised Dry Gas Dew Point. Calculated Absorber Stages: 1.25 Calculated Dry Gas Dew Point: 6.35 lbs. H2O/MMSCF Temperature: 120.0 deg. F Pressure: 950.0 psig Dry Gas Flow Rate: 110.0000 MMSCF/day Glycol Losses with Dry Gas: 6.1070 lb/hr Wet Gas Water Content: Saturated Calculated Wet Gas Water Content: 106.24 lbs. H2O/MMSCF Calculated Lean Glycol Recirc. Ratio: 4.58 gal/lb H2O Remaining Absorbed Component in Dry Gas in Glycol Water 5.96% 94.04% Carbon Dioxide 99.62% 0.38% Nitrogen 99.96% 0.04% Methane 99.97% 0.03% Ethane 99.91% 0.09% Propane 99.87% 0.13% Isobutane 99.84% 0.16% n-Butane 99.79% 0.21% Isopentane 99.81% 0.19% n-Pentane 99.76% 0.24% Cyclopentane 98.97% 1.03% r.-Hexane 99.66% 0.34% Cyclohexane 98.48% 1.52% Other Hexanes 99.73% 0.27% Heptanes 99.45% 0.55% Benzene 88.47% 11.53% Toluene 85.62% 14.38% Ethylbenzene 83.06% 16.94% Xylenes 77.50% 22.50% C8+ Heavies 98.41% 1.59% FLASH TANK Flash Control: Recycle/recompression Flash Temperature: 130.0 deg. F Page 3 • Aggregate.txt Flash Pressure: 50.0 psia Left in Removed in Component Glycol Flash Gas Water 99.95% 0.05% Carbon Dioxide 34.83% 65.17% Nitrogen 4.25% 95.75% Methane 4.39% 95.61% Ethane 13.73% 85.27% Propane 25.75% 74.25% Isobutane 34.19% 65.81% n-Butane 40.50% 59.50% Isopentane 44.03% 55.97% n-Pentane 49.38% 50.62% Cyclopentane 79.15% 20.85% n-Hexane 63.54% 36.46% Cyclohexane 87.63% 12.37% Other Hexanes 57.20% 42.80% Heptanes 77.96% 22.04% Benzene 98.09% 1.91% Toluene 98.79% 1.21% Ethylbenzene 99.32% 0.68% Xylenes 99.54% 0.46% C8+ Heavies 97.66% 2.34% REGENERATOR No Stripping Gas used in regenerator. Remaining Distilled Component in Glycol Overhead Water 39.17% 60.83% . Carbon Dioxide 0.00% 100.00% Nitrogen 0.00% 100.035 Methane 0.00% ].00.00% Ethane 0.00% 100.00% Propane 0.00% 100.00% Isobutane 0.00% 100.00% n-Butane 0.00% 100.00% Isopentane 1.14% 98.86% n-Pentane 1.01% 98.99% Cyclopentane 0.63% 99.37% n-Hexane 0.79% 99.21% Cyclohexane 3.65% 96.35% Other Hexanes 1.75% 98.25% Heptanes 0.64% 99.36% Benzene 5.10% 94.90% Toluene 8.00% 92.00% Ethylbenzene 10.48% 89.52°% Xylenes 12.99% 87.01% C8+ Heavies 12.32% 87.68% STREAM REPORTS: WET GAS STREAM Temperature: 120.00 deg. F Pressure: 964.70 psia Flow Rate: 4.60e+006 scfh Component Conc. Loading Page 4 Aggregate.txt (vol%) (lb/hr) Water 2.24e-001 4.88e+002 Carbon Dioxide 2.59e+000 1.38e+004 Nitrogen 3.19e-001 1.08e+003 Methane 7.35e+001 1.43e+005 Ethane 1.340+001 4.89e+004 Propane 5.75er000 3.070+004 Isobutane 8.18e-001 5.76e+003 n-Butane 1.87e+000 1.32e+004 Isopentane 5.00e-001 4.37e+003 n-Pentane 5.13e-001 4.49e+003 Cyclopentane 2.40e-002 2.04e+002 n-Hexane 1.12e-001 1.17e+003 Cyclohexane 2.85e-002 2.91e+002 Other Hexanes 2.06e-001 2.16e+003 Heptanes 7.81e-002 9.48e+002 Benzene 2.51e-002 2.37e+002 Toluene 2.04e-002 2.27e+002 Ethylbenzene 3.99e-004 5.14e+000 Xylenes 3.79e-003 4.88e+001 C8+ Heavies 2.27e-002 4.68e+0O2 Total Components 100.00 2.71e+005 DRY GAS STREAM Temperature: 120.00 deg. F Pressure: 964.70 psia Flow Rate: 4.58e+006 scfh Component Conc. Loading (vol%) (lb/hr) Water 1.34e-002 2.91e+001 Carbon Dioxide 2.58e+000 1.37e+004 Nitrogen 3.20e-001 1.08e+003 Methane 7.37e+001. 1.43e+005 Ethane 1.34e+001 4.88e+004 Propane 5.76e+000 3.070+004 Isobutane 8.19e-001 5.75e+003 n-Butane 1.87e+000 1.31e+004 Isopentane 5.00e-001 4.36e+003 n-Pentane 5.14e-001 4.48e+003 Cyclopentane 2.38e-002 2.01e+002 n-Hexane 1.12e-001 1.170+003 Cyclohexane 2.82e-002 2.870+002 Other Hexanes 2.060-001 2.15e+003 Heptanes 7.792-002 9.42e+002 Benzene 2.22e-002 2.10e+002 Toluene 1.75e-002 1.95e+002 Ethylbenzene 3.33e-004 4.270+000 Xylenes 2.95e-003 3.780+001 C8+ Heavies 2.24e-002 4.60e+002 Total Components 100.00 2.700+005 LEAN GLYCOL STREAM Temperature: 120.00 deg. F Flow Rate: 3.500+001 gpm Component Conc. Loading (wt%) (lb/hr) TEG 9.850+001 1.94e+004 Water 1.500+000 2.950+002 Carbon Dioxide 2.63e-011 5.18e-009 Page 5 Aggregate.txt Nitrogen 2.21e-013 4.35e-011 Methane 8.47e-018 1.67e-015 Ethane 1.10e-007 2.17e-005 Propane 8.47e-O09 1.67e-006 Isobutane 1.44e-009 2.84e-007 n-Butane 3.47e-009 6.84e-007 Isopentane 2.14e-004 4.22e-002 n-Pentane 2.73e-004 5.36e-002 Cyclopentane 5.33e-005 1.05e-002 n-Hexane 1.01e-004 1.99e-002 Cyclohexane 7.44e-034 1.47e-001 Other Hexanes 2.98e-004 5.86e-002 Heptanes 1.33e-004 2.61e-002 Benzene 7.31e-003 1.44e+000 Toluene 1.42e-002 2.81e+000 Ethyl.benzene 5.13e-004 1.O1e-001. Xylenes 8.27e-003 1.63e+000 CB+ Heavies 5.16e-003 1.02e+000 Total Components 100.00 i.97e+004 RICH GLYCOL STREAM Temperature: 120.00 deg. F Pressure: 964.70 psia Flow Rate: 3.56e+001 gpm NOTE: Stream has more than one phase. Component Conc. Loading (wt%) (1b/hr) TED 9.46e+001 1.94e+004 Water 3.68e+000 7.55e+002 Carbon Dioxide 2.53e-001 5.18e+001 Nitrogen 2.13e-003 4.36e-001 Methane 2.42e-001 4.96e+001 Ethane 2.24e-001 4.59e+001 Propane 2.00e-001 4.10e+001 Isobutane 4.63e-002 9.48e+000 n-Butane 1.35e-001 2.76e+001 Isopentane 4.12e-002 8.44e+000 n-Pentane 5.25e-002 1.08e+001 Cyclopentane 1.02e-002 2.10e+000 n-Hexane 1.95e-002 3.99e+000 Cyclohexane 2.23e-002 4.56e+000 Other Hexanes 2.86e-002 5.86e+000 Heptanes 2.55e-002 5.22e+000 Benzene 1.40e-001 2.88e+001 Toluene 1.73e-001 3.55e+001 Ethylbenzene 4.74e-003 9.71e-001 Xylenes 6.15e-002 1.26e+001 C8+ Heavies 4.12e-002 8.44e+000 Total Components 100.00 2.05e+004 FLASH TANK OFF GAS STREAM Temperature: 130.00 deg. F Pressure: 64.70 psia Flow Rate: 2.42e+003 scfh Component Conc. Loading (OO1%) (lb/hr) Water 3.12e-001 3.59e-001 Carbon Dioxide 1.20e+001 3.38e+-O01 Page 6 Aggregate.txt Nitrogen 2.34e-001 4.17e-001 Methane 4.64e+001 4.74e+001 Ethane 2.06e+001 3.96e+001 Propane 1.08e+001 3.04e+001 Isobutane 1.685+000 6.24e+000 n-Butane 4.42e+000 1.64e+001 Isopentane 1.03e+000 4.72e+000 n-Pentane 1.185+000 5.455+000 Cyclopentane 9.78e-002 4.38e-001 n-Hexane 2.64e-001 1.45e+000 Cyclohexane 1.05e-001 5.66e-001 Other Hexanes 4.56e-001 2.51e+000 Heptanes 1.80e-001 1.15e+000 Benzene 1.10e 001 5.49e-001 Toluene 7.28e-002 4.28e-001 Ethylbenzene 9,81e-004 6.65e-003 Xylenes 8.56e-003 5.80e-002 C8+ Heavies 1.82e-002 1.97e-001 Total Components 100.00 1.92e+002 FLASH TANK GLYCOL STREAM Temperature: 130.00 deg. F Flow Rate: 3.62e+001 gpm Component Conc. Loading (wt) (lb/hr) TEG 9.5Se+001 1.94e+004 Water 3.72e+000 7.545+002 Carbon Dioxide 8.89e-002 1.81e+001 Nitrogen 9.12e-005 1.65e-002 Methane 1.07e-002 2.18e+000 Ethane 3.10e-002 6.30e+000 Propane 5.20e-002 1.06e+001 Isobutane 1.60e-002 3.24e+000 n-Butane 5.50e-002 1.12e+001 Isopentane 1.83e-002 3.72e+000 n-Pentane 2.62e-002 5.32e+000 Cyclopentane 8.19e-003 1.665+000 n-Hexane 1.25e-002 2.53e+000 Cyclohexane 1.98e-002 4.01e+000 Other Hexanes 1.65e-002 3.35e+000 Heptanes 2.OOe-002 4.07e+000 Benzene 1.39e-001 2.62e+001 Toluene 1.73e-001 3.51e+001 Ethylbenzene 4.7Se-003 9.64e-001 Xylenes 6.18e-002 1.25e+001 C8+ Heavies 4.06e-002 8.24e+000 Total Components 100.00 2.03e+004 FLASH GAS EMISSIONS Control Method: Recycle/recompression Control Efficiency: 100.00 Note: Flash Gas Emissions are zero with the Recycle/recompression control option. REGENERATOR OVERHEADS STREAM Temperature: 212.00 deg. F Pressure: 14.70 psia Page 7 Aggregate.txt Flow Rate: 1.D6e+004 scfh Component Conc. Loading (vol%) (lb/br) Water 9.140+001 4.59e+002 Carbon Dioxide 1.47e+000 1.81e+001 Nitrogen 2.37e-003 1.85e-002 Methane 4.87e-001 2.18e+000 Ethane 7.52e-001 6.30e+000 Propane 8.59e-001 1.06e+001 Isobutane 2.00e-001 3.24e+000 n-Butane 6.89e-001 1.120+001 Isopentane 1.83e-001 3.67e+000 n-Pentane 2.62e-001 5.26e+000 Cyclopentane 9.45e-002 i.65e+000 n-Hexane 1.05e-001 2.51e+000 Cyclohexane 1.65e-001 3.B7e+000 Other Hexanes 1.370-001 3.29e+000 Heptanes 1.45e-001 4.04e+000 Benzene 1.23e+00^ 2.68=_+001 Toluene 1.26e+000 3.23e+001 Ethylbenzene 2.92e-002 8.63e-001 Xylenes 3.69e-001 1.09e+001 C8+ Heavies 1.52e-001 7.23e+000 Total Components 100.00 6.13-e+0.02 CONDENSER PRODUCED WATER STREAM Temperature: 140.00 deg. F Flow Rate: 8.94e-001 gpm Component Conc. Loading (wt%) (lh/hr) (ppm) Water 9.99e+001 4.47e+002 999086. Carbon Dioxide 8.94e-003 4.00e-002 89. Nitrogen 2.74e-007 1.23e-006 0. Methane 5.930-005 2.65e-004 1. Ethane 1.88e-004 8.39e-004 2. Propane 3.65e-004 1.63e-003 4. Isobutane 5.94e-005 2.66e-004 1. n-Butane 2.65e-004 1.18e-003 3. Isopentane 5.82e-005 2.60e-004 1. n-Pentane 8.74e-005 3.91e-004 1. Cyclopentane 1.79e-004 7.99e-004 2. n-Hexane 3.19e-005 1.43e-004 0. Cyclohexane 2.49e-004 1.12e-003 2. Other Hexanes 3.50e-005 1.57e-004 0. Heptanes 2.42e-005 1.08e-004 0. Benzene 4.25e-002 1.90e-001 425. Toluene 3.21e-002 1.44e-001 321. Ethylbenzene 3.75e-004 1.68e-003 4. Xylenes 5.95e-003 2.66e-002 60. C8+ Heavies 4.08e-007 1..82e-006 D. Total Components 100.00 4.47e+002 1000000. CONDENSER RECOVERED OIL STREAM Temperature: 140.00 deg. F Flow Rate: 7.51e-002 gpm Component Conc. Loading (wt%) (lb/hr) Water 5.64e-002 1.80e-002 Page 8 Aggregate.txt Carbon Dioxide 4.18e-002 1.34e-002 Nitrogen 2.14e-005 6.85e-006 Methane 1..49e-003 4.75e-004 Ethane 2.46e-002 7.85e-003 Propane 1.98e-001 6.32e-002 Isobutane 1.15e-001 3.68e-002 n-Butane 5.35e-001 1.71e-001 Isopentane 4.61e-001 1.47e-001 n-Pentane B.23e-001 2.63e-001 Cyclopentane 3.10e-001 9.90e-002 n-Hexane 7.14e-001 2.28e-001 Cyclohexane 1.54e+000 4.92e-001 Other Hexanes 7.21e-001 2.30e-001 Heptanes 2.63e+000 8.39e-001 Benzene 1.27e+001 4.06e+000 Toluene 3.36e+001 1.07e+001 Ethylbenzene 1.63e+000 5.20e-001 Xylenes 2.16e+001 6.89e+000 C8+ Heavies 2.23e+001 7.12e+000 Total Components 100.00 3.19e+001. CONDENSER VENT STREAM Temperature: 140.00 deg. F Pressure: 12.00 psia Flow Rate: 1..04e+003 scfh Component Conc. Loading (vole) (lb/hr) Water 2.42e+001 1-19e+001 Carbon Dioxide 1.50e+001 1.80e+001 Nitrogen 2.42e-002 1.85e-002 Methane 4.97e+000 2.18e+000 Ethane 7.65e:000 6.29e+000 Propane 8.70e+000 1.05e+001 Isobutane 2.C2e+000 3.21e+000 n-Butane 6.92e+000 1.i0e+001 Isopentane 1.79e+000 3.53e+000 n-Pentane 2.53e+000 5.00e+000 Cyclopentane 8.09e-001 1.55e+000 n-Hexane 9.70e-001 2.29e+000 Cyclohexane 1.47e+000 3.37e+000 Other Hexanes 1.30e+000 3.06e+000 Heptanes 1.17e+000 3.20e+000 Benzene "1.06e+001 2.25e+001 Toluene 8.49e+000 2.14e+001 Ethylbenzene 1.18e-001 3.41e-001 Xylenes 1.38e+000 4.00e+000 C8+ Heavies 2.27e-002 1.06e-001 Total Components 100.00 1..33e+002 COMBUSTION DEVICE OFF GAS STREAM Temperature: 1000.00 deg. F Pressure: 14.70 psia Flow Rate: 3.16e+001 scfh Component Conc. Loading (vole) (lb/hr) Methane 8.16e+00C 1.09e-001 Ethane 1.26e+001 3.15e-001 Propane 1.43e+001 5.25e-001 Isobutane 3.32e+000 1.60e-001 n-Butane 1.14e+0l1 5.50e-001 Page 9 Aggregate.txt Isopentane 2.94e+000 1.76e-001 n-Pentane 4.16e+000 2.50e-001 Cyclopentane 1.33e+000 7.76e-002 n-Hexane 1.59e+000 1.14e-001 Cyclohexane 2.41e+000 1.69e-001 Other Hexanes 2.14e+000 1.53e-001 Heptanes 1.92e+000 1.60e-001 Benzene 1.73e+001 1.13e+000 Toluene 1.40e+001 1.07e+000 Ethylbenzene 1.93e-001 1.71e-002 Xylenes 2.26e+000 2.OOe-00i C8+ Heavies 3.73e-002 5.28e-003 Total Components 100.00 5.18e+000 Page 10 MPACT ANALYTICAL SYSTEMS INc. 365 S.MAIN ST. BRIGHTON,CO 80601 303.637.0160 EXTENDED NATURAL GAS ANALYSIS("DHA1 GLYCALC INFORMATION PROJECT NO. : 201103130 ANALYSIS NO.: 02 COMPANY NAME: DCP MIDSTREAM-LP ANALYSIS DATE: MARCH 19,2011 ACCOUNT NO. : SAMPLE DATE : MARCH 18,2011 PRODUCER : CYLINDER NO.: 888 LEASE NO. : SAMPLED BY : STEPHEN ONDAK NAME/DES CRIP: ENTERPRISE INLET PRE DEHY®14:30 ""FIELD DATA'"" SAMPLE TEMP.: 100 SAMPLE PRES.: 900 AMBIENT TEMP.: VAPOR PRES. : GRAVITY . COMMENTS : SPOT;NO PROBE Componet Mole% Wt% Helium 0.01 0.00 Hydrogen 0.00 0.00 Carbon Dioxide 2.59 5.09 Nitrogen 0.32 0.40 Methane 73.60980 52.69890 Ethane 13.4435 18.0401 Propane 5.7833 11.3416 Isobutane 0.8191 2.1247 n-Butane 1.8738 4.8604 Isopentane 0.5005 1.6116 n-Pentane 0.5144 1.6563 Cyclopentane 0.0240 0.0751 n-Hexane 0.1123 0.4319 Cyclohexane 0.0286 0.1074 Other Hexanes 0.2068 0.7920 Heptanes 0.0782 0.3486 Methycyctohexane 0.0227 0.0995 2,2,4 Trimethylpentane 0.0000 0.0000 Benzene 0.0251 0.0875 Toluene 0.0204 0.0839 Ethylbenzene 0.0004 0.0019 Xylenes 0.0038 0.0181 C8+Heavies 0.0227 0.1190 Sebfolof 99.98940 99.98840 Oxygen/Argon 0.01 0.01 Alcohols 0.0008 0.0016 Total 100.00000 100.00000 THE DATA PRESENTED HEREIN HAS BEEN ACQUIRED THROUGH JUDICIOUS APPLICATION OF CURRENT STATE.OF•THE ART ANALYTICAL TECHNIQUES THE APPLICATIONS OF THIS INFORMATION IS THE RESPONSIBILITY OF THE USER. EMPACT ANALYTICAL SYSTEMS,INC.ASSUMES NO RESPONSIBILITY FOR ACCURACY OF THE REPORTED INFORMATION NOR ANY CONSEQUENCES OF ITS APPLICATION. Hello