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Home My WebLink About20190101.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 December 18, 2018 Dear Sir or Madam: RECEIVED DEC 2 6 2018 WELD COUNTY COMMISSIONERS On December 20, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Cureton Front Range LLC - Miskey 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 tt Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure R,IoGc Review 112/19 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 cc. PL(TP),$,.(JT) 14SCSM1ERICAticv, 12.1Zco/18 2019-0101 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Cureton Front Range LLC - Miskey Compressor Station - Weld County Notice Period Begins: December 20, 2018 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: Cureton Front Range LLC Facility: Miskey Compressor Station Natural gas compressor station NENE Sec 20, T2N, R63W Weld County The proposed project or activity is as follows: Applicant proposes to construct two (2) natural gas dehydration units at a natural gas compressor station. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE1071 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 hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 AO Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Bradley Eadee Package #: 388487: Received Date: 10/3/2018 Review Start Date: 12/10/2018 Section 01- Facility Information Company. Name: Cureton Front Range', LLC County AIRS ID: 123 Plant AIRS ID: 9FFD Facility Name: MiskeyCompressor Statiop l Illyµ, 3 Physical Address/Locatio NENE quadrant of Section 20, Township 2N, Range 63W, in Weld County„Colorado Type of Facility: tupl Ran Compressor St' ati What industry segment? Dii-&NaturaiGas ProductionI Is this facility located in a NAAQS non attainment area? If yes, for what pollutant? on Monoxide (CO) Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range iculate Matter (PM) ne (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance Self Cert Required? Action Engineering Remarks 001 TE De)tydrator ,gyp- FEG2 u (y/ of 18WF1071 P tti tt al t. 6 YSt :� Si a c 3 ;71} // ''. 002 .' %',,H e44y� ratoc I .� _. -- i_. _ T)4'�7 .s._' '../ i v. 't� .. 18WC1071 Section 03 - Description of Project Applicant has submitted applicatio. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Re a contruction pi ku4,rsor Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? ?No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. nits at a natural gas compressor station. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx Is this stationary source a major source? �;�, .y If yes, explain what programs and which pollutants here So2 NOx Prevention of Significant Deterioration (PSD) Title V Operating Pernits (OP) Non -Attainment New Source Review (NANSR) CO VOC PM2.5 PM10 TSP HAPs CO VOC PM2.5 PM10 ❑ CI TSP HAPs ❑ ❑ Glycol Dehydrator Emissions Inventory Section 01 -Administrative information IFecilityAIRs ID: County %y,9Eia sT3z4ss;:...,., :13u3.3313 41}I3fN'-..l Plant Paint Section 02 - Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model:. Serial Number: Design Capacity: Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Max Redreulation Rate: Dehydrator Equipment Flash Tank Reboler Burner Stripping Gas Dehydrator Equipment Description , flash tank, and reboiler burner One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: BBD, Model: TBD, Serial Number: TOD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with one a) (Make:TBD, Model: TBD) electric driven glycol pump with adesign capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flesh tank, and reboiler burner. Emissions from the still vent are routed to a liquids knockout vessel, and then to the Enclosed Flare. Emissions from theflesh Emission Control Device Description: tank are routed to the liquids knockout vessel and then to the Enclosed Flare. Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Dehydrator Still Vent and Flash '3 Tank (if present) Requested Permit limit Throughput = iI I 7301111 MMsd per year Potential to Emit (PTE) Throughput= 7,300.0 MMscf per year Secondary Emissions - Combustion Device(s) for Air Pollution Control Still Vent Control Condenser/Liquids Knockout: Condenser emission reduction claimed: Primary control device: Primary control device. operation: Secondary control device: Secondary control device operation: SthI Vent Gas Heating Value: Still Vent Waste Gas Vent Rate: Flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flesh Tank Waste Gas Vent Rate: Secondary Emissions - Combustor Fuel Emissions Pilot Fuel Flow Pilot HHV TOTAL PILOT FUEL Control Efficiency % 70'?,, hr/yr Control Efflcien hr/yr Btu/scf scih scfh E5,8, bt /scf (based on worst rase) 1.5 MMscf/yr Mscf per month Wet Gas Processed: Still Vent Primary Control: J,300.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 13.2 MMsd/yr Still VentUecondary Control: 0.0 MMscf/yr Wet Gas Processed: Flash Tank Primary Control: 7,300.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas [ambushed: Flash Tank Primary Control: 2.4 MMsd/yr Flash Tank Secondary Control: 0.0 MMsd/yr Glycol Dehydrator Emissions Inventory Section 04- Emissions Factors & Methodologies Input Parameters Inlet Gas Pressure Inlet Gas Temperature - Requested Glycol Redreulate Rate STILL VENT Control Scenario Primary Secondary Pollutant Uncontrolled Qb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC iinikaaii4i98341iiMi 0.49917 0 Benzene MiNaAllaigin 0.093135 0 Toluene laanTi185VCTi3AT 0.092545 0 Ethylbenzene - ia[ 42421 0.02621 0 Xylenes (i 7m1?FG, 0.06044 0 n -Hexane Kim(e:oiat ll 0.005245 0 224-TMP ≥'°(iFHi'n;�i 0 0 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (Ib/hr) Controlled (Ih/hr) VOC 1(1105$II. - - 0.50719 0 Benzene =9.647 =r•i. ;. - 0.00286 0 Toluene ..iiiii!0iti3l.iMi2 0.001865 0 Ethylbenzene -:; ,,, „90062 ,.;> 0.00031 0 Xylenes .i iii ; ,810097 ._... 0.000485 0 n -Hexane gmator0OO20M 0.00464 0 224-TMP gamowngaft 0 0 EmissIon Factors Pollutant Benzene Toluene Ethylbena Xylene n -He 224 TMP Pollutant PM10 Glycol Dehydrator Uncontrolled (lb/MMscf) (Ib/MMscf) (Wet Gas Throughput) (Wet Gas Throughput) Controlled 24.17 1.21E+80 2.30 1.15E-01 2.27 1.13E-01 0:64 3.18E-02 .46 7.31E-02 0.24 1.19E-0 0.00 0.00E+00 Still Vent Primary Control De Uncontrolled (Ih/MMBtu) (Waste Heat Cornbusted) 0.0075 0.0075 0,0006 0.0610 CO ,......... 0.3100. Uncontrolled (Ib/MMscf) (Waste Gas Combusted) 0.8415 0.8415 0.0664 7.6797 GBa 35.0104 Still Vent Secondary Control Device Uncontrolled Uncontrolled Emission Factor Source Emission Factor Source Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source PM10 PM2.5 Pollutant (Waste Heat Combusted) (Waste Sea Combusted) Flash Tank Primary Control Oevtce Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat (Waste Gas Combusted) Combusted) NO '4i:d6ad Pollutant Pollutant 0.8436 444.5704 Flash Tank Secondary Control Device Uncontrolled Uncontrolled (Ib/MMBtu( (lb/MMscf) (Waste Heat Combusted) ECD Pilot (Waste Gas Combusted) Uncontrolled Uncontrolled (Ib/MMBtu) (lb/MMscf) (Waste Heat Combusted) 0.007 •?. 0.0075..:::: SO % u,.,. 0.0006 NO ,_,__,.:.:.. iA:.0600 (Waste Gas Combusted) 9.4478 393.0800 Emission Factor Source Emission Factor Source Glycol Dehydrator Emissions Inventory Section 05- Emissions Inventory Did operator request a buffer? Requested Buffer (%)( • Criteria Pollutants Potential to Emit Uncontrolled (tons/year) - Actual Emissions Uncontrolled Controlled (tons/year) - (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5. sox: NOx CO VOC - - 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 0.2 0.2 0.2 0.24 0.24 1.1 1.1 1.1 1.08 1.08 88.2 88.2 4.4 ' 88.21 4.41 Hazardous Alr Pollutants' - - Potential to Emit Uncontrolled. (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year). Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene Toluene. Ethylbenzena Xylene';. n -Hexane 224TMP 16,818 16,818 841 16,818 041 16,541 16,141 827 16,541 827 4,646 4,646 232 4,646 232 10,674 10,674 534 10,674 534 1,732 1,732 87 - ' 1,732 87 - - - Section 06- Regulatory Summary Analysts Regulation 3, Parts A, B Regulation 7, Section XVII.B,D Regulation 7, Section XVILB.2.e Regulation 7, Section XII.H Regulation 8, Part E, MACE Subpart HH (Area) Regulation 8, Part E, MACT Subpart HH'(Major) Regulation 8, Part E, MACP Subpart HHH (See regulatoryapplirabillty worksheet for detailed analysis) Source requires a permit Dehydrator Is subject to Regulation 7, Section XVII, 9, 0.3 . The control device for this dehydrator Isnotsubject to Regulation 7, Section 0510.810 Dehydrator A subject to Regulation 7, Section XII.H The dehy unit meets the benzene exemption You have Indicated that this facility Is not subject to Major Source requirements of MACT'NH. You have indicatedthat this facility is not subject to MAR HHH. I Section 07 - Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and collected within a year of application submittal? If no, the perms will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device efficiency greater than 95%for a flare or combustion device?" If yes, the permit will contain and Initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling °This facif ti7hasnntisogon cape€alion enr00site-spex fromt[tisdehydrator lha5aurce-ca,,,I plated so ccmld ry �wnbuetsd, and CO nrclude amrs rons:fron§ thecodi6 pollutantswif,0otISO- "dad in the pan AIRS Point 001 Section 09 - Inventory SCC Coding and Emissions Festers Pm ssN 01 SCC Code Requested Permit Limits- ' Uncontrolled Controlled (Ib/ onih) (lb/month) 4:4 -- 4.4 4.4 4.4 0.3 0.3 40.4 40.4 184.0 184,0 14983.6 749.2 pplicant:Erascalculai titl,C0-ernissions 0000erolied Pollutant Emissions Factor Control % P61110 0.007 PM2.5 0.007 50x 0.001 NOx 0.065 VOC 24.2 CO - 0297 Benzene 2.304 Toluene 2.266 Ethylbenzene 0.636 Xyfene 1.462 n -Hexane 0.237 0.0 0.0 0.0 0.0 95.0 0.0 95.0 95.0 95.0 95.0 95.0 Units b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements rce is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? (You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? (Source requires a permit Colorado Regulation 7, Section XII.H 1. Is this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. Is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)? - (Dehydrator Is subject to Regulation 7, Section XII.H Section XII.H — Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a..A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end b. user2 (63360(a)(3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? (Go to MACT HH Area Source Requirement section to determine MALT HH applicability Yes Yes Yes 40 CFR, Part 63, Subpart MACT HI -I, Oil and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))? Exemptions 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3. Is the unit located inside of a UA plus offset and UC boundary area? IThe dehy unit meets thebenzene exemption Subpart A, General provisions per §63.764 (a) Table 2 §63.765 --Emissions Control Standards Do Not Apply §63.773 - Monitoring Standards Do Not Apply §63.774 - Record keeping §63.775 - Reporting Standards Do Not Apply Major Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Large Dehv Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehv Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX' emission limit given by the applicable equation? Yes IYou have indicated that this facility is not subject to Major Source requirements of MACT Hit Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting 40 CFR, Part 63, Subpart MACE HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehv Determination 2a. I's the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))? Small Dehv Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and (3) )? 4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? You have indicated that this facility is not subject to MALT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 - Recordkeeping §63.1285 - Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACT NH Dr HHH (Regulation 7, Section XVII.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? 5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? Dehydrator is subject to Regulation 7, Section XVII, B, O.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 - Emissions Reduction Provisions Alternative Emissions Control (Optional Sectionl 6. - Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? 'The control device for this dehydrator is not subject to Regulation 7, Section XVII.6.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commissioh.regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD . interpretations and recommendations. Mandatory terminology such as 'must' and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. No No Yes Glycol Dehydrator Emissions Inventory Section 01 -Administrative Information 'Facility AIRS ID: County Plant Point Section 02 - Equipment Description Details Dehydrator Information DehydratorType: Make; Model: Serial Number: Design Capacity: Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboiler Burner Stripping Gas Dehydrator Equipment Description Emission Control Device Description: MMscf/day , flash tank, and reboller burner One (1) Methylene glycol (TOG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) with adesign capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TBD, Model: TBD) electric driven glycol pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flesh tank, and reboller burner. Emissions from the Will vent are routed to a liquids knockout vessel, and then to the Enclosed Flare. Emissions from the flash tank are routed to the liquids knockout vessel and then to the Enclosed Flare. Section 03 - Processing Rate Information for Emissions Estimates Primary Emlsslons- Dehydrator Still Vent and Flash Tank (if present) Requested Permit Limit Throughput I _7,3FM)41 MMscfper Year equ P diit3�a'k.�'�`...," Y Potential to Emit (PTE) Throughput = 7,300.0 MMscf per year Secondary Emissions- Combustion Device(s) for Air Pollution Control. Still Vent Control Condenser/liquids knockout: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Fleeting Value: Still Vent Waste Gas Vent Rate: Flash tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flesh Tank Gas Heating Value Rash Tank Waste Gas Vent Rate: Secondary Emissions - Combustor Fuel Emissions Pilot Fuel Flow Pilot HHV TOTAL PILOT FUEL hr/yr 2,9A, etu/scf sclh hr/i hr/yr OW Btu/scf 72;A,,; scfh ',MMscf per month N Control Efficiency % Control Efficiency% 9330 Control Efficiency % Control Efficiency % btu/scf (basedon worst case) 0.0 MMscf/yr Wet Gas Processed: Still Vent Primary Control: 7,300.0 MMsd/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 15.2 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Wet Gas Processed: Flash Tank Primary Control: 7,300.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 2.4 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Glycol Dehydrator Emissions Inventory Section 04- Emissions Factors &Methodologies Dehydrator Input Parameters Inlet Gas Pressure Inlet Gas Ternpeature Requested Glycol Redreulate Rate on the following parem;ete deg F >.... gpm STILL VENT Control Seenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled.(Ib/hr) VOC ommuoiumara 0.49917 0 Benzene 1(06U7yi1,/ll ll(II 0.093135 0 Toluene ,E 85047,13313-' 0.092545 0 Ethylbenzene .' .. 0.58421 l(, F7„,.'', 0.02621 0 Xylenes iatiiii))))M 0.06044 0 n -Hexane 0. 0.005245 0 224-TMP t1P^<er.�,? s'f 3; 0 0 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr( Controlled )lb/hr( Controlled (lb/hr) VOC tt. 10155'8', 3> 0.50779 0 Benzene 0 D5726. _ ))))) 0.00286 0 Toluene 00570..3: .Si3)) 0.001865 0 Ethylbenzene iI--.6)OWallt 0.00031 0 Xylenes 0.000485 0 n -Hexane DA926' 0.00464 0 224-TMP 0.'. ;, �' 0 0 Emission Factor Pollutant Pollutant VOC Ben Toluene 227 ene Glycol Dehydrator Uncontrolled (lb/MM (Wet Gas Throughput) 24.17 2.30 Ethylbenzene 0.64 Xylene 1.46 n -Hexane 0.24 224TMP 0.00 PM10 PM2.5 SOx ,.....0.0006 NOz -0.068 CO 3100 Controlled (lb/MM (Wet Gas Throughpu .21E+00 L15E-0 .13E-01 180-02 7.31E-02 3E-02 0.00E+00 Still Vent Primary Control Device Uncontrolled (Ib/MM Bts) (Waste Heat Combusted) 0075 0.0075 Uncontrolled (lb/MM (Waste Gas Combusted) ) 0.841 0.84 0.0664 7.6797 35.0004 Still Vent Secondary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) CO Combusted) Emission Factor Source Emission Factor Source (Ib/MMscf) Emission Factor Source (Waste Gas Combusted) 0.0000 Flash Tank Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat Combusted) PM10 _ , ;:`0'007 CO Pollutant (Waste Gas Combusted) 10.6054 444.5704 Flash Tank Secondary Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Waste Heat Combusted) (Waste Gas Combusted) Glycol Dehydrator Emissions Inventory Section 05 - Emissions Inventory Did operator request a buffer? Requested Buffer (%): Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tans/year) PM10 PM2.5 SOx NOx ' CO VOC 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 0.2 0.2 0.2 0.17 0.17 0.8 0.8 0.8 0.80 0.80 88.2 88.2 4.4 88.21 4.41 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbeneene Xylene n -Hexane 224 IMP 16,818 16,818 841 16,818 841 16,541 16,541 827 16,541 827 4,646 4,646 232 4,646 232 10,674 10,674 534 10,674 534 1,732 1,732 87 1,732 87 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B,D Regulation 7, Section XVII.B.2.e Regulation 7, Section XILH Regulation 8, Part E, MACT Subpart HH (Area) Regulation 8, Part E, MACT Subpart HH (Major) Regulation 8, Part E, MACE Subpart HHH (See regulatory applicability werbsheet for detailed analysis) Source requires a permit Dehydrator a subject to Regulation 7, Section XVII, 8, 0.3 The control devlcefer this dehydrator is not subject to Regulation 7, Section XVlI.B.2.e Dehydrator is subject to Regulation 7, Section 011.8 The dehy unit meets the benzene exemption You have Indicated that this facility is not subject to Major Source requirements of MACT HH. You have indicated that this facility is not subjectto MAR HUH. Section 07 - Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used in the GlyCalc model/Process model site -specific and collected within a year of application submittal? If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limits Does the company request a control device effidency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 5 cf n 08 Te h I A lyo, N t s _ 'TARP#ivant ihd atesthat th till vent wa gas.i f020y01 th nmhived?em on stream dfrec(l duce the sdf/hr is higher with the mctgsCoh of Wd� througha liquid knock; tv saelito,tei 3 The al Motions above u e, raved tit+ �l� Oirs htu(sci hasisla dlffereii� WW,ar Fhin,acutiyh t bgut, opprjipn anti t sg0Gt41caampiew 'otaV lubleat elm f ppl eat�m.TFie re#or nicibaleiitended gasanaly swd(') ,a e from this dehydrator. _ ....... -: 'sourpe calculated secondarycomhuyP.P.? 4R1081g83:#F0mbothdofiydratorscovereduthioRAttfGi901ana Pv,vt 00Z Ehtissions fromeach de11041 P"1t0 CF d CO inctude,e sons from Rho vmlitutt 0aflp}')ntgas hick my representedgit#te,nor)Y sfortint001.5erw eem ss'ons ofi000,CO.fM0essd, p 11 t pt1 will not be mclydad Irt tha pernren The sum, of emissmns from h;ih dehydcatxrzsls 0.42 TPp NOxand 1188 tpy CO. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 8 001 Processft SCC Code 01 ti n in, hwe hied HHI!'of2 rUS thei0018) ht eremou 41,0 i v remalns,thesame SI11f Ire d with svlf tf't Pollutant PM10 PM2.5 SOx NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane Requested Permit Limos Uncontrolled Controlled (Ib/mdnth). (Ib/month) 3,3 3.3 3.3 3.3 0.3 0.3 29-7 29.7 135.3 135.3 14983.6 749.2 hresfia#ds,nssfo Uncontrolled Emissions Factor 0.005 0.005 0.000 0.048 24.2 0.218 2.304 2.266 0,636 1.462 0.237 Control% 0.0 0.0 0.0 0.0 95.0 0.0 95.0 95.0 95.0 95.0 95.0 Units b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMscf b/MMsef b/MMscf Dehydrator Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section I I.D.3)? 'You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? 'Source requires a permit Colorado Regulation 7, Section XII.H 1. l this glycol natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Reg 7, Section XII.H.1 and 2)? 2. Is this glycol natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor station, natural gas drip station or gas -processing plant (Reg 7 Section 3. is the sum of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary source equal to or greater than 15 tpy (Reg 7, Section XII.H.3.b)? 4. Are actual uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Reg 7, Section XII.H.3.a)? (Dehydrator is subject to Regulation 7, Section XII.H Section XII.H — Emission Reductions from glycol natural gas dehydrators MACT Analysis 1. Is the dehydrator located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end b. user' (63.760(a)(3))? 2. Is the dehydrator located at a facility that is a major source for HAPs? IGo to MACT HH Area Source Requirement section to determine MACT HH applicability Yes 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities Area Source Requirements 1. Is the dehydrator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))? Exemptions 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.764(e)(1)(i)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.764(e)(1)(ii)? 3. Is the unit located inside of a UA plus offset and UC boundary area? 'The dehy unit meets the benzene exemption Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards Do Not Apply §63.773 - Monitoring Standards Do_Not Apply §63.774 - Recordkeeping §63.775 - Reporting Standards Do Not Apply Major Source Requirements 1. Does the facility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility -wide actual annual average hydrocarbon liquid throughput less than 249.7 Small or Large Dehy Determination 2a. , Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per day (63.761)? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.761)? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) and (C )? 4. For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation? 'You have indicated that this facility is not subject to Major Source requirements of MACT NH. Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63:773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting Yes 40 CFR, Part 63, Subpart MACT HHH, Natural Gas Transmission and Storage Facilities 1 Is the facility wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the only HAP emission source (63.1270(f))? Small or Large Dehy Determination 2a. Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per day (63.1270(b)(2))? 2b. Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere less than 1,984.2 lb/yr (63.1270(b)(2))? Small Dehy Requirements 3. Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270)b))2) and (3) )? 4. For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicable equation? You have indicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 - Recordkeeping §63.1285 - Reporting Colorado Regulation 7, Section XVII.D 1. Is the dehydrator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)? 2. Is this dehydrator located at a transmission/storage facility? 3. Is this dehydrator located at an oil and gas exploration and production operation, natural gas compressor station or gas processing plant (Reg 7, Section XVII.D.3)? 4. Was this glycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? If constructed prior to May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 6 tons per year VOC or 2 tpy VOC if the 4a. dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? 5. If constructed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to or greater than 2 tpy VOC (Regulation 7, Section XVII.D.4.a)? Dehydrator is subject to Regulation 7, Section XVII, It, D.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.D.3 -Emissions Reduction Provisions Alternative Emissions Control (Optional Section) 6. Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? IT Section XVII.B.2.e —Alternative emissions control equipment ice for this dehydrator is not subject to Regulation 7 Disclaimer VII 8.2.e This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations,, and Air Quality Control Commission regulations, the language of the'statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name Cureton Front Range LLC 123 9FFD Miskev Compressor Station History File Edit Date Ozone Status 12/1112018 Non -Attainment Uncontrolled Mons Der year EMISSIONS With Controls (tons Der Year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL New Facility - No Previous Total Previous Permitted Facility total 001 18WE1071 TEG DehydratorTEG1 0.2 88.2 1.1 25.2 0.2 4.5 1.1 1.3 NewCP 002 18WE1071 TEG Dehydrator TEG2 0.2 88.2 0.8 25.2 0.2 4.5 0.8 1.3 NewCP 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 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 0.4 176.4 0.0 1.9 50.4 0.0 0.0 0.0 0.0 0.4 9.0 0.0 1.9 2.6 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor B,T,X, Total HAP HH: affected area source ZZZZ: Area Source Permitted Facility Total 0.0 0.0 0.0 0.0 0.4 176.4 0.0 1.9 50.4 0.0 0.0 0.0 0.0 0.4 9.0 0.0 1.9 2.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.4 9.0 0.0 1.9 PubCom will be completed since 18WE1071 contains new synthetic minor limits Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) 9.0 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25 tpy 9.0 Point 001 and 002 share a common combustor. Emissions from combustion of pilot are included with Point 001 (row 10). Note 2 Page 14 of 16 Printed 12/18/2018 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Cureton Front Range LLC County AIRS ID 123 Plant AIRS ID 9FFD Facility Name Miskey Compressor Station Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1071 TEG Dehydrator TEG1 16818 16541 4646 10674 1732 25.2 002 18WE1071 TEG Dehydrator TEG2 16818 16541 4646 10674 1732 25.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 16.8 16.5 4.6 10.7 1.7 0.0 0.0 0.0 0.0 50.4 ol KeportaDle = all I1Ars Wnere uncontrolleo emissions > oe minlmus values Red Text: uncontrolled emissions < de minimus 15 18WE1071.CP1.xlsm 12/18/2018 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name Cureton Front Range LLC County AIRS ID 123 Plant AIRS ID 9FFD Facility Name Miskey Compressor Station Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 18WE1071 TEG Dehydrator TEG1 841 827 232 534 87 1.3 002 18WE1071 TEG Dehydrator TEG2 841 827 232 534 87 1.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.0 0.0 0.0 0.8 0.8 0.2 0.5 0.1 0.0 0.0 0.0 0.0 2.5 16 18WE1071.CP1.xlsm 12/18/2018 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1071 Issuance: 1 Cureton Front Range, LLC Facility Name: Miskey Compressor Station Plant AIRS ID: 123/9FFD Physical Location: NENE SEC 20 T2N R63W County: Weld County General Description: Natural Gas Compressor Station Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TEG1 001 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TBD, Model: TBD) electric driven glycol pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent and flash tank are routed to a liquid knock out vessel and then to an enclosed flare. TEG2 002 One (1) Triethylene glycol (TEG) natural gas dehydration unit (Make: TBD, Model: TBD, Serial Number: TBD) with a design capacity of 20 MMscf per day. This emissions unit is equipped with one (1) (Make: TBD, Model: TBD) electric driven glycol pump with a design capacity of 3.5 gallons per minute. This dehydration unit is equipped with a still vent, flash tank, and reboiler burner. Emissions from the still vent and flash tank are routed to a liquid knock out vessel and then to an enclosed flare. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. COLORADO ution Control Division tbtic r#ceith r• G. Page 1 of 11 on (the ision) no later than fifteen days of the issuance of is permit, by submitting a Notice of rtup f th ;' fo �-nt cov this permit. The Notice of Startup form may be downloaded online at www,colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. Points 001, 002: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • The dehydrator manufacturer name, model number and serial number • The glycol circulation pump manufacturer name and model number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation Number 3, Part B, III.E.) 6. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) .A.4. ) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type PM2.5 NO, VOC CO TEG1 001 -- --- 750 --- Point TEG2 002 --- --- 750 --- Point Note: Monthly limits are based on a 31 -day month. The owner or operator shall calculate monthly emissions based on the calendar month. ;COLORADO Air Pollution Control Division lops*t,lent of Rfblic t fflaf? v E.":rbrs.vfvelt Page 2 of 11 Mutant shall not exceed 1,359 pounds shall not exceed 3,398 pounds per The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TEG1 001 --- --- 4.5 --- Point TEG2 002 --- --- 4.5 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits, for criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 8. Points 001: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: dry gas throughput, lean glycol recirculation rate, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 9. Points 002: Compliance with the emission limits in this permit shall be demonstrated by running the GRI GlyCalc model version 4.0 or higher on a monthly basis using the most recent extended wet gas analysis and recorded operational values, including: dry gas throughput, lean glycol recirculation rate, flash tank temperature and pressure, wet gas inlet temperature, and wet gas inlet pressure. Recorded operational values, except for gas throughput, shall be averaged on a monthly basis for input into the model and be provided to the Division upon request. 10. Points 001, 002: On a monthly basis, the owner or operator shall monitor and record operational values including: flash tank temperature and pressure for each flash tank, wet gas inlet temperature and pressure. These records shall be maintained for a period of five years. 11. The owner or operator shall operate and maintain the emission points in the table below with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. The owner or operator shall operate this dehydration unit so as to prevent any emissions directly to the atmosphere. (Regulation Number 3, Part B, Section III.E.) COLORADO Air Pollution Control Division '1pvtgrxrt-oti :A lietit>t n Environment Page 3 of 11 � . cili ` " 1 E•°•m ID AIRS Point ontrol vice Pollutants Controlled TEG1 001 Still Vent: Enclosed Flare VOC and HAP Flash Tank: Enclosed Flare TEG2 002 Still Vent: Enclosed Flare VOC and HAP Flash Tank: Enclosed Flare PROCESS LIMITATIONS AND RECORDS 12. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) TEG1 001 Dry Gas Throughput 7,300 MMscf 620 MMscf TEG2 002 Dry Gas Throughput 7,300 MMscf 620 MMscf The owner or operator shall monitor monthly process rates based on the calendar month. The volume of dry gas throughput shall be measured by gas meter at the outlet of the dehydrator. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 13. Points 001: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Loot) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) 14. Points 002: This unit shall be limited to the maximum lean glycol circulation rate of 3.5 gallons per minute. The lean glycol recirculation rate shall be recorded weekly in a log maintained on site and made available to the Division for inspection upon request. Glycol recirculation rate shall be monitored by one of the following methods: assuming maximum design pump rate, using glycol flow meter(s), or recording strokes per minute and converting to circulation rate. This maximum glycol circulation rate does not preclude compliance with the optimal glycol circulation rate (Loot) provisions under MACT HH. (Reference: Regulation Number 3, Part B, II.A.4) Air Pollution Control Division k rt ?x:t"�iI aW �E eh:th .'s Et.,r rinsent Page 4 of 11 t nu ,,;er an. z__ -n igit AIRS number assigned by the Division (e.g. sh be irked o e su;-ect equipm- = for ease of identification. (Regulation B, „ I.E.) - nforcea 16. Points 001, 002: This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 17. Points 001, 002: This source is subject to Regulation Number 7, Section XII.H. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for glycol natural gas dehydrators; and • Ensure uncontrolled actual emissions of volatile organic compounds from the still vent and vent from any gas -condensate -glycol (GCG) separator (flash separator or flash tank), if present, shall be reduced by at least 90 percent on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. (Regulation Number 7, Section XII.H.1.) 18. Points 001, 002: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2 General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 19. Points 001, 002: The glycol dehydration unit covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.D.3. Beginning May 1, 2015, still vents and vents from any flash separator or flash tank on a glycol natural gas dehydrator located at an oil and gas exploration and production operation, natural gas compressor station, or gas - processing plant subject to control requirements pursuant to Section XVII.D.4., shall reduce uncontrolled actual emissions of hydrocarbons by at least 95% on a rolling twelve-month basis through the use of a condenser or air pollution control equipment. 20. Points 001, 002: The glycol dehydration units at this facility are subject to National Emissions Standards for Hazardous Air Pollutants for Source Categories from Oil and Natural Gas Production Facilities, Subpart HH. This facility shall be subject to applicable area source provisions of this regulation, as stated in 40 C.F.R Part 63, Subpart A and HH. (Regulation Number 8, Part E, Subpart A and HH) COLORADO Mr Pollution Control Division =.d�7t Ft6k:: Neoth E;vironm nt Page 5 of 11 CT HH •ph Are •urce Requi < e ,a - nzene emi ° • ns exemption §63.764 - General Standards 4 (e) - per or oper - '. exempt from the requirements of paragraph (• o t is section if the cntena listed in paragraph (e)(1)(i) or (ii) of this section are met, except that the records of the determination of these criteria must be maintained as required in §63.774(d)(1). §63.764 (e)(1)(ii) - The actual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere are less than 0.90 megagram per year, as determined by the procedures specified in §63.772(b)(2) of this subpart. §63.772 - Test Methods, Compliance Procedures and Compliance Demonstration §63.772(b) - Determination of glycol dehydration unit flowrate or benzene emissions. The procedures of this paragraph shall be used by an owner or operator to determine glycol dehydration unit natural gas flowrate or benzene emissions to meet the criteria for an exemption from control requirements under §63.764(e)(1). §63.772(b)(2) - The determination of actual average benzene emissions from a glycol dehydration unit shall be made using the procedures of either paragraph (b)(2)(i) or (b)(2)(ii) of this section. Emissions shall be determined either uncontrolled, or with federally enforceable controls in place. $63.772(b)(2)(i) - The owner or operator shall determine actual average benzene emissions using the model GRI-GLYCaIc TM, Version 3.0 or higher, and the procedures presented in the associated GRI-GLYCaIc TMTechnical Reference Manual. Inputs to the model shall be representative of actual operating conditions of the glycol dehydration unit and may be determined using the procedures documented in the Gas Research Institute (GRI) report entitled "Atmospheric Rich/Lean Method for Determining Glycol Dehydrator Emissions" (GRI-95/0368.1); or $63.772(b)(2)(ii) - The owner or operator shall determine an average mass rate of benzene emissions in kilograms per hour through direct measurement using the methods in §63.772(a)(1)(i) or (ii), or an alternative method according to §63.7(f). Annual emissions in kilograms per year shall be determined by multiplying the mass rate by the number of hours the unit is operated per year. This result shall be converted to megagrams per year. §63.774 - Recordkeeping Requirements §63.774 (d)(1) - An owner or operator of a glycol dehydration unit that meets the exemption criteria in §63.764(e)(1)(i) or §63.764(e)(1)(ii) shall maintain the records specified in paragraph (d)(1)(i) or paragraph (d)(1)(ii) of this section, as appropriate, for that glycol dehydration unit. §63.774 (d)(1)(ii) - The actual average benzene emissions (in terms of benzene emissions per year) as determined in accordance with §63.772(b)(2). OPERATING a MAINTENANCE REQUIREMENTS 21. Points 001, 002: Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COLORADO Air Pollution Control Division Deprt_1et f Pubf.l feaiti?'u ti,ionment Page 6 of 11 2 �,._ s 0 ' : - ��.., -r or l demo 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. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) 23. Points 001, 002: The owner or operator shall complete the initial extended wet gas analysis within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit. The owner or operator shall use this analysis to calculate actual emissions, as prescribed in the Emission Limitation and Records section of this permit, to verify initial compliance with the emission limits. The owner or operator shall submit the analysis and the emission calculation results to the Division as part of the self -certification process. (Reference: Regulation Number 3, Part B, Section III.E.) Periodic Testing Requirements 24. Points 001, 002: The owner or operator shall complete an extended wet gas analysis prior to the inlet of the dehydration unit on an annual basis. Results of the wet gas analysis shall be used to calculate emissions of criteria pollutants and hazardous air pollutants per this permit and be provided to the Division upon request. ADDITIONAL REQUIREMENTS 25. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 26. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely COLORADO Air Pollution Control Division po.sttrwrit or Fufgz PiesRn o E.-Trvo meet Page 7 of 11 tion in forcea tation t was established after August 7, 1980, the sou •difi. „--.•n othe - emit a pollutant such as a restriction (Re; rence egul. •n Number 3 r''art D, V.A.7.B). GENERAL TERMS AND CONDITIONS 27. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 28. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 29. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 30. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 31. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 32. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 33. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer COLORADO Air Pollution Control Division sYFu:.t vt puh€+=1 iCei`t' & ErA4c,nr?tet;e Page 8 of 11 is a is Iss COLORADO Air Pollution Control Division eprs[ ^ ^.t a PviAl 44e th. a fi virov,1 rt Description ued to C ;z.n Front Range, LLC Page 9 of 11 pay s for i - p •cessing e for this permit. An invoice for these e iss • aft j the rmit is ued he permit h. ;° er shall pay the invoice within 30 days ipt o nvure . invoice "-suit in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) TEG1 001 Benzene 71432 16,818 841 Toluene 108883 16,541 827 Ethylbenzene 100414 4,646 232 Xylenes 1330207 10,674 534 n -Hexane 110543 1,732 87 TEG2 002 Benzene 71432 16,818 841 Toluene 108883 16,541 827 Ethylbenzene 100414 4,646 232 Xylenes 1330207 10,674 534 n -Hexane 110543 1,732 87 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on information provided in the application and the GRI GlyCalc 4.0 model. Controlled emissions are based on a combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692- 3150. COLORADO it Pollution Control Division ^E:lL i }kthtL� }et& E Arormef t Page 10 of 11 7) is per ful` equire E: y hold a „ �,.�ermlt r ecting the glycol dehydration unit and servation Commission rule 805b(2)(B) 8 Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, benzene, toluene, xylenes, Total HAP NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division ,epar merit FteWth n:E.^,rvorrienc Page 11 of 11 RECEIVED OCT 3 2018 sa APCD n t ry Soufte's Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ' (6 WE 1 °Ili AIRS ID Number: iv) At -ED O01 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: TEG1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Site Location: Cureton Front Range LLC Miskey Compressor Station 1 lJ t L1 NENE E Sec. 20, ; T-63 Mailing Address: (Include Zip Code) 518 17th Street, Suite 650 Denver, CO 80202 E -Mail Address2: nick.holland@curetonmidstrem.com Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Nick Holland Phone Number: 303-324-5967 '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. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 388485 COLORADO 1 IAT' M�>m«.Pc N.ytPf6 g11,4,4P.M11-1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name ❑ Change permit limit ❑ Transfer of ownership' -OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - E] Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: ❑ Add point to existing permit ❑ Other (describe below) 3 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: 20 MMSCFD TEG Dehydration unit equipped with a Combustor for 95% control (design destruction efficiency of 98%) Facility equipment Identification: For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: TEG 1 / / TBD / / ❑r 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 Will this equipment be operated in any NAAQS nonattainment area Is this unit located at a stationary source that is considered a Major Source of (HAP) Emissions days/week Yes Yes 0 weeks/year No No Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 A COLORADO 2I MN== ?i,,Nl16 L�WO oU nM J Upward 0 Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit Y and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.130017,-104.456189 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. ( F) : Flow Rate (ACFM) Velocity. (ft/sec) Combustor 12 1000 6935 9.2 Indicate the direction of the stack outlet: (check one) ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Upward with obstructing raincap ❑✓ Circular Interior stack diameter (inches): 48 0 Square/rectangle Interior stack width (inches): Interior stack depth (inches): 0 Other (describe): Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 II COLORADO 4 Ii [Spans.Mntan. !WWI6uf4;911 lat Permit Number: • AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ 14o If yes please describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO„ CO VOC Combustor ( a.) -t_ 95% HAPs Combustor (6.-.lety.. 95% Other: v,& From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions from source: Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Source Factor (AP -42, Mfg. etc) Actual Annual Emissions msted Annual Permit Reque a ission L�mit(s Uncontrolled (Tons/year) Controlleds (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO„ CO VOC 24.22 Ib/MMSCF Glycalc 88.39 4.42 Benzene 2.30 Ib/MMSCF Glycalc 8.41 0.42 Toluene 2.27 Ib/MMSCF Glycalc 8.27 0.41 Ethylbenzene 0.64 Ib/MMSCF Glycalc 2.32 0.12 Xylenes 1.46 Ib/MMSCF Glycalc 5.34 0.27 n -Hexane 0.24 Ib/MMSCF Glycalc 0.87 0.04 2,2,4- Trimethylpentane Other: a 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. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 COLORADO 6 I �n >enr o Glycol Dehydration Unit APEN - Form APCD-202 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Glycol Dehydration (Dehy) Units only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ( Wll� t AIRS ID Number: III) /of r 1 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: TEG2 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: Site Location: Cureton Front Range LLC Miskey Compressor Station ,K,(,&‘)4 Site Location NENE Sec. 20, R2N, v` County: Weld Mailing Address: p Coe518 17th Street, Suite 650 (Include Zip Code) Denver, CO 80202 E -Mail Address2: nick.holland@curetonmidstrem.com NAICS or SIC Code: 211111 Permit Contact: Nick Holland Phone Number: 303-324-5967 1Please use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. Oce‘ct- Web st Form APCD-202 - Glycol Dehydration Unit APEN - Revision 02/2017 liamtPgratitimenexeat Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Dehydration Unit Equipment Information Manufacturer: Dehydrator Serial Number: Glycol Used: TBD TBD Ethylene Glycol (EG) Model Number: TBD Reboiler Rating: 0.5 ❑ (DEG) DiEthytene Glycol Glycol Pump Drive: 0 Electric O Gas If Gas, injection pump ratio: Pump Make and Model: TBD MMBTU/hr TriEthylene Glycol (TEG) # of pumps: Glycol Recirculation rate (gal/min): Lean Glycol Water Content: Max: 3.5 Wt.% Requested: 3.5 Acfm/gpm 1 Dehydrator Gas Throughput: Design Capacity: 20 MMSCF/day Requested: 7300 MMSCF/year Actual: MMSCF/year Inlet Gas: Pressure: 1000 Water Content: Wet Gas: Flash Tank: Pressure: 35 Cold Separator: Pressure: psig lb/MMSCF psig psig Stripping Gas: (check one) ✓❑ None O Flash Gas O Dry Gas O Nitrogen Flow Rate: scfm Temperature: Saturated Temperature: Temperature: 120 °F Dry gas: 7.0 lb/MMSCF - 130 °F ❑ NA °F ID NA Additional Required Information: ❑ Attach a Process Flow Diagram Attach GRI-GLYCalc 4.0 Input Report Et Aggregate Report (or equivalent simulation report/test results) El Attach the extended gas analysis (including BTEX Et n -Hexane, temperature, and pressure) e&r<o:RA:oa. Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 3 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information Used for control of: ❑ Condenser: Type: Make/Model: Maximum Temp Average Temp Requested Control Efficiency ❑ VRU: Used for control of: Size: Make/Model: Requested Control Efficiency % VRU Downtime or Bypassed El Combustion Device: Used for control of: VOC, HAPs 12/1.216 Rating: MMBtu/hr Type: Combustor Make/Model: TBD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: NA 95 98 % % Waste Gas Heat Content Btu/scf Constant Pilot Light: Ei Yes ❑ No Pilot burner Rating ~0.21 MMBtu/hr Closed 0 Loop System: Used for control of: Description: System Downtime 0 Other: Used for control of: Description: Control Efficiency Requested Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 5 cap:mADO Wrp.ec..+raK?*.se:. itiwamm[a.�na�ui,.n� Permit Number: AIRS ID Number: / I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. 10/9/2018 Signature of Legally Authorized Person (not a vendor or consultant) Date Nick Holland Director of EHS&R Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd cn:f aR.AZa Form APCD-202 -Glycol Dehydration Unit APEN - Revision 02/2017 7 Hello