HomeMy WebLinkAbout20192039.tiffCOLORADO
Department of Public
Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
May 23, 2019
Dear Sir or Madam:
RECEIVED
MAY 28239
WELD COUNTY
COMMISSIONERS
On May 30, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for DCP
Operating Company, LP - Marla 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 Et 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
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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
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128/19
2019-2039
Air Pollution Control Division
Notice Of A Proposed Renewal Title V Operating Permit
Warranting Public Comment
Website Title: DCP Operating Company, LP - Marla Compressor Station - Weld County
Notice Period Begins: May 30, 2019
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: Marla Compressor Station
SESE Section 28, T4N, R64W
Kersey, CO 80644
DCP Operating Company, LP has applied to renew the Operating Permit for the Marla 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: modification of permit limitations and emission factors
to reflect the facility's current mode of operation, as requested in the renewal application, three minor
modification applications and one significant modification application, 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 modified engine and dehydration unit emission limitations
to reflect current facility operations, as requested in three minor modification and one significant
modification applications. The fugitive emissions limitation was removed from the operating permit as
emissions are below de minimis thresholds, however, all applicable state requirements were included in the
permit. 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 95OPWE020 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 Schuchardt 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
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
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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 Schuchardt
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
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Colorado Department
of Public Health
and Environment
OPERATING PERMIT
DCP Operating Company, LP — Marla Compressor Station
First Issued: June 1, 1999
Renewed: DRAFT
AIR POLLUTION CONTROL DIVISION
COLORADO OPERATING PERMIT
FACILITY NAME:
FACILITY ID:
RENEWED:
EXPIRATION DATE:
MODIFICATIONS:
Marla Compressor OPERATING PERMIT NUMBER
Station
123/0243
DATE
DATE
See Appendix F of Permit
95OPWE020
Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et
sew. and applicable rules and regulations.
ISSUED TO:
DCP Operating Company, LP
370 17th Street, Suite 2500
Denver, CO 80202
PLANT SITE LOCATION:
SESE Section 28, T4N, R64W
South of Kersey (Kersey, CO 80644)
Weld County
INFORMATION RELIED UPON
Operating Permit Renewal Application Received:
And Additional Information Received:
Nature of Business:
Primary SIC:
December 28, 2016
October 11, 2017; June 27, 2018; July 23, 2018; March
22, 2019
Natural gas liquids gathering
4922
RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON
Name:
Title:
Phone:
David M. Jost
Vice President of Northern
Operations
(970) 378-6345
Name: Roshini Shankaran
Title: Senior Environmental Engineer
Phone: (303) 605-2039
SUBMITTAL DEADLINES
Semi -Annual Monitoring Period: DRAFT
Semi -Annual Monitoring Report: DRAFT
Annual Compliance Period: DRAFT
Annual Compliance Certification: DRAFT
Note that the Semi -Annual Monitoring reports and the 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 2
3. Non -Attainment New Source Review (NANSR) and Prevention of Significant Deterioration
(PSD) 8
4. Accidental Release Prevention Program (112(r)) 9
5. Compliance Assurance Monitoring (CAM) 9
6. Summary of Emission Units 10
SECTION II - Specific Permit Terms 11
1. C-148/135/151 — Three Waukesha L-7042 GSI, 1,478 HP Engines w/ NSCR (AIRS ID:
052/053/054) 11
C-166/174/176 — Three Waukesha L-7044 GSI, 1,680 HP Engines w/ NSCR (AIRS ID:
059/060/061) 11
2. P-112 TEG Dehydration Unit with an Enclosed Combustion Device (AIRS ID: 062) 29
P-113 TEG Dehydration Unit with an Enclosed Combustion Device (AIRS ID: 063) 29
3. Facility -Wide Hazardous Air Pollutant (HAP) Emission Limitations 44
4. Statewide Controls for Oil and Gas Operations — Facility -Wide 46
5. Compliance Assurance Monitoring 61
SECTION III - Permit Shield 66
1. Specific Non -Applicable Requirements 66
2. General Conditions 66
3. Stream -lined Conditions 67
SECTION IV - General Permit Conditions (8/28/2018) 68
1. Administrative Changes 68
2. Certification Requirements 68
3. Common Provisions 68
4. Compliance Requirements 72
5. Emergency Provisions 73
6. Emission Controls for Asbestos 73
7. Emissions Trading, Marketable Permits, Economic Incentives 73
8. Fee Payment 73
9. Fugitive Particulate Emissions 74
10. Inspection and Entry 74
11. Minor Permit Modifications 74
12. New Source Review 74
13. No Property Rights Conveyed 74
14. Odor 74
15. Off -Permit Changes to the Source 75
16. Opacity 75
17. Open Burning 75
18. Ozone Depleting Compounds 75
19. Permit Expiration and Renewal 75
20. Portable Sources 75
21. Prompt Deviation Reporting 75
22. Record Keeping and Reporting Requirements 76
TABLE OF CONTENTS:
23. Reopenings for Cause 77
24. Requirements for Major Stationary Sources 77
25. Section 502(b)(10) Changes 78
26. Severability Clause 79
27. Significant Permit Modifications 79
28. Special Provisions Concerning the Acid Rain Program 79
29. Transfer or Assignment of Ownership 79
30. Volatile Organic Compounds 79
31. Wood Stoves and Wood burning Appliances 80
APPENDIX A 2
Inspection Information 2
APPENDIX B 6
Monitoring and Permit Deviation Report 6
APPENDIX C 15
Required Format for Annual Compliance Certification Reports 15
APPENDIX D 18
Notification Addresses 18
APPENDIX E 19
Permit Acronyms 19
APPENDIX F 21
Permit Modifications 21
APPENDIX G 22
Compliance Assurance Monitoring Plan - Engines 22
APPENDIX H 25
Compliance Assurance Monitoring Plan - Dehydrators 25
APPENDIX I 28
Applicability Reports 28
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
1. Permitted Activities
1.1
DCP Operating Company, LP
Marla Compressor Station
Page 1
SECTION I - General Activities and Summary
The Marla Compressor Station uses six (6) natural gas -fired internal combustion engines (AIRS 052, 053,
054, 059, 060, 061) to drive compressors to transmit natural gas gathered from gas field laterals to a
primary pipeline. These engines are controlled through non -selective catalytic reduction (NSCR).
The station also includes two (2) triethylene glycol (TEG) dehydration units (AIRS 062, 063) that contact
"dry" triethylene glycol with the natural gas stream to remove moisture prior to entering the primary
pipeline. The "wet" glycol mixture is regenerated in a still for reuse in the process. Each dehydration
unit's flash tank vapors are captured by a vapor recovery unit (VRU) and routed back to the facility inlet.
These units are equipped with an enclosed combustion device for still vent control. Regenerator still vent
emissions are routed through the condenser prior to being destructed in the enclosed combustion device.
It should be noted that no emission control from the condensers is claimed for either dehydration unit.
Liquids from the dehydration units are routed to the pressurized slug catchers.
Emission control devices include: six (6) NSCR beds to control compressor engine exhaust emissions and
one (1) enclosed combustion device (ECD) to control post -condenser still vent emissions from both
dehydration units. Flash tank emissions from each dehydration unit are recompressed with one (1) vapor
recovery unit (VRU) and routed back to the facility inlet.
The plant is located west of the intersection of Weld County Road (WCR) 55 and WCR 40 on the north
side of WCR 40, approximately 13 miles southeast of Greeley. This facility is located in an Area classified
as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the
8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1.
Wyoming is an affected state within 50 miles of the Station. Rocky Mountain National Park is a Federal
Class I designated area within 100 kilometers of the Station.
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 The 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
permit incorporates the applicable requirements (except as noted in Section II) from the following
construction permits:
Construction Permit
Equipment
01WE0499
AIRS 052: Compressor Engine C-148
01 WE0500
AIRS 053: Compressor Engine C-135
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 2
01 WE0501
AIRS 054: Compressor Engine C-151
01WE0503
AIRS 059: Compressor Engine C-166
01WE0504
AIRS 060: Compressor Engine C-174
01WE0505
AIRS 061: Compressor Engine C-176
01WE0506
AIRS 062: TEG Dehydration Unit P-112
05WE0579
AIRS 063: TEG Dehydration Unit P-113
1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air
Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified.
State -only enforceable conditions are:
Section II — Conditions 1.10.2.1 and 1.10.2.2 (Colorado Regulation No. 7, Section XVII.E.2.a, b)
Section II — Conditions 2.11.3 and 4.4 (Colorado Regulation No. 7, Section XVII.B)
Section II — Condition 2.11.4 (Colorado Regulation No. 7, Section XVII.D)
Section II — Condition 4.5 (Colorado Regulation No. 7, Section XVII.F)
Section IV — Condition 3.g, last paragraph (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)
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
(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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed: '�
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
2.1 Engine Replacement
DCP Operating Company, LP
Marla Compressor Station
Page 3
The following AOS is incorporated into this permit in order to deal with a compressor engine breakdown
or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a
temporary or permanent replacement engine. "Temporary" is defined as in the same service for 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.
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, date of manufacture,
model number, horsepower, and serial number of the replacement engine. In addition to the log, the
permittee shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them
available to the Division upon request.
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.
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).
2.1.2 The permittee may permanently replace the existing compressor engine for the emission points
specified in Table 1 with the manufacturer, model, and horsepower engines listed in Table 1
without modifying this permit so long as the permanent replacement engine complies with all
permit limitations and other requirements applicable to the existing engine as well as any new
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 4
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.
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") upless 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 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 I. 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 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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 5
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.
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of
the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month
or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of
operation the test results will be multiplied by the maximum number of hours in the month or year (8760),
whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement
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.
2.3 Applicable Regulations for Permanent Engine Replacements
2.1.3 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 PMio, if the potential to emit
of NOx or SO2 exceeds 40 tons/yr.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 6
For purposes of this AOS, the following shall be considered RACT for natural-gas fired
reciprocating internal combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOx: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PMio: 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.
2.3.1 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E
(State -Only conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area
is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as
specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective
catalyst and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation
catalyst to reduce emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be
operated and maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition
2.1.2.
Emission Standards: Section XVII E — State -only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another
state, after the date listed in the table below shall operate and maintain each engine according to
the manufacturer's written instructions or procedures to the extent practicable and consistent with
technological limitations and good engineering and maintenance practices over the entire life of
the engine so that it achieves the emission standards required in the table below:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 7
Max Engine
HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
100<Hp<500
January 1, 2008
2.0
4.0
1.0
January 1, 2011
1.0
2.0
0.7
500≤Hp
July 1, 2007
2.0
4.0
1.0
July 1, 2010
1.0
2.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition
2.1.2.
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 burn engines greater than or equal to 500 hp and less than 1,350
hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are
subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring,
recordkeeping, and reporting requirements for the permanent engine replacement shall be included
in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is
in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ
can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the
Division, provided that such test is conducted within the time frame specified in Condition 2.2.
Note that under the provisions of Regulation No. 6, Part B, Section I.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 I.C.2.a. Relocation is defined in Section I.C.I.a.
However, as of January 9, 2017 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.
2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the
requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring,
recordkeeping, and reporting requirements for the permanent engine replacement shall be included
in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT
is in addition to that required by this AOS. Note that the initial test required by the MACT can
serve as the testing required by this AOS under Condition 2.2, if approved in advance by the
Division, provided that such test is conducted within the time frame specified in Condition 2.2.
2.4 Additional Sources
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 8
The replacement of an existing engine with a new engine is viewed by the Division as the installation of
a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an
advanced construction permit review. The AOS cannot be used for additional new emission points for
any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-
approved replacement of an existing onsite engine has to go through the appropriate
Construction/Operating permitting process prior to installation.
Table 1
Internal Combustion Engine Information For AOS
Emission
Point _
Replacement Engine
-
Periodic Monitoring _
Subject to
CAM? _. .
C-148
Waukesha Model L-7042 GSI, Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,478 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
C-135
Waukesha Model L-7042 GSI, Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,478 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
C- I51
Waukesha Model L-7042 GSI, Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,478 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
C-166
Waukesha Model L-7044 GSI, Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,680 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
C-174
Waukesha Model L-7044 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,680 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
C-176
Waukesha Model L-7044 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4 -Cycle,
Standard Rich Burn, 1,680 HP; with AFR & NSCR
Portable Monitoring
Quarterly
Yes
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 > 100
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 > 100 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 purposes of determining applicability
of Prevention of Significant Deterioration regulations.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
4. Accidental Release Prevention Program (112(r))
DCP Operating Company, LP
Marla Compressor Station
Page 9
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).
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 052 (C-148) — Compressor RICE (1,478 HP) for NOx and CO
AIRS ID 053 (C-135)
AIRS ID 054 (C-151)
AIRS ID 059 (C-166)
AIRS ID 060 (C-174)
AIRS ID 061 (C-176)
AIRS ID 062 (P-112) -
AIRS ID 063 (P-113) —
— Compressor RICE (1,478 HP) for NOx and CO
— Compressor RICE (1,478 HP) for NOx and CO
— Compressor RICE (1,680 HP) for NOx and CO
— Compressor RICE (1,680 HP) for NOx and CO
— Compressor RICE (1,680 HP) for NOx and CO
TEG Dehydration Unit (45 MMSCFD) for VOC and HAP
TEG Dehydration Unit (55 MMSCFD) for VOC and HAP
See Section II, Condition 5 for compliance assurance monitoring requirements.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Pettnit # 95OPWE020
6. Summary of Emission Units
6.1 The emissions units regulated by this permit are the following:.
DCP Operating Company, LP
Marla Compressor Station
Page 10
AIRS Point
It -,,w-,
Facility
Tdentifi
Description
Pollution Control Device
Permit
052
C-148
(P-102)
Waukesha Model L-7042 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard
Rich Burn w/ AFR Controller, Serial No. 240605, Site Rated at
1,478 HP; Drive for Natural Gas Compressor
Non -Selective Catalytic
Reduction
01 WE0499
053
C-135
(P-103)
Waukesha Model L-7042 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard
Rich Burn w/ AFR Controller, Serial No. C-10605/1, Site Rated at
1,478 HP; Drive for Natural Gas Compressor
Non -Selective Catalytic
Reduction
01 WE0500
054
C-151
(P-104)
Waukesha Model L-7042 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard
Rich Burn w/ AFR Controller, Serial No. 230355, Site Rated at
1,478 HP; Drive for Natural Gas Compressor
Non -Selective Catalytic
Reduction
01 WE0501
059
C-166
(P-109)
Waukesha Model L-7044 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard.
Rich Burn w/ AFR Controller, Serial No. C-13852/1, Site Rated at
1,680 HP; Drive for Natural Gas Compressor
Non -Selective Catalytic
Reduction
01 WE0503
060
C-174
(P-110)
Waukesha Model L-7044 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard
Rich Burn w/ AFR Controller, Serial No. 5283700815, Site Rated
at 1,680 HP; Drive for Natural Gas Compressor
Non -Selective Catalytic
Reduction
01WE0504
061
C-176
(P-111)
Waukesha Model L-7044 GSI Turbocharged Natural Gas Fired
Internal Combustion Reciprocating Engine, 4 -Cycle, Standard
Rich Burn w/ AFR Controller; Serial No. C-17976/1, Site Rated at
1,680 HP; Drive for Natural Gas Compressor
,
Non -Selective Catalytic
Reduction
01WE0505
062
P 112
Triethylene Glycol Dehydration Unit, Rated at 45 MMSCFD,
6.25 gpm TEG recirculation rate
Flash Gas: VRU (100% CE)
Still Vent: ECD (95% CE),
permitted 3% downtime
01WE0506
063
P-113
Triethylene Glycol Dehydration Unit, Rated at 55 MMSCFD, 8.2
gpm TEG recirculation rate
Flash Gas: VRU (100% CE)
Still Vent: ECD (95% CE),
permitted 3% downtime
05WE0579
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed: l "'
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 11
SECTION II - Specific Permit Terms
1. C-148/135/151— Three Waukesha L-7042 GSI, 1,478 HP Engines w/ NSCR (AIRS ID: 052/053/054)
C-166/174/176 — Three Waukesha L-7044 GSI, 1,680 HP Engines w/ NSCR (AIRS ID: 059/060/061)
Parameter
Permit
Condition
Number
*,.
Limitations
Compliance
Emission Factor
Monitoring
Method
Interval
Emission & Consumption Limits
052 & 053 — C-148 & C-135, Waukesha 1,478 HP Natural Gas Fired Internal Combustion Engines
NOx
1.1
28.5 tons/year
0.56 lb/ MMBtu
Recordkeeping and
Twelve Month Rolling -
Total Calculation
Monthly
CO
42.8 tons/year
0.84 lb/ MMBtu
VOC
1.2
14.3 tons/year
0.28 lb/ MMBtu
Natural Gas
Consumption
1.3
99.4 MMSCF/year
Fuel Meter, Twelve
Month Rolling Total
Monthly
Emission & Consumption Limits -
054 — C-151, Waukesha 1,478 HP Natural Gas Fired Internal Combustion Engine
NOx
1.1
14.3 tons/year
0.28 lb/ MMBtu
Recordkeeping and
Twelve Month Rolling
Total Calculation
Monthly
CO
28.5 tons/year
0.56 lb/ MMBtu
VOC
1.2
10.0 tons/year
0.20 1b/MMBtu
Natural Gas
Consumption
1.3
99.4 MMSCF/year
Fuel Meter, Twelve
Month Rolling Total
Monthly
Emissions & Consumption Limits'
059, 061— C-166, C-176 Waukesha 1,680 HP Natural Gas Fired Internal Combustion Engines
NOx
1.1
32.5 tons/year
0.56 lb/ MMBtu
Recordkeeping and
Twelve Month Rolling
Total Calculation
Monthly
CO
32.5 tons/year
0.56 lb/ MMBtu
VOC
1.2
16.2 tons/year
0.28 lb/ MMBtu
Natural Gas
Consumption
1.3
113.4 MMSCF/year
Fuel Meter Twelve
Month Rolling Total
Monthly
Emissions & Consumption Limits
060 — C-174 Waukesha 1,680 HP Natural Gas Fired Internal Combustion Engine
NOx
1.1
16.2 tons/year
0.28 lb/ MMBtu
Recordkeeping and
Twelve Month Rolling
Total Calculation
Monthly
CO
32.5 tons/year
0.56 lb/ MMBtu
VOC
1.2
11.4 tons/year
0.201b/ MMBtu
Natural Gas
Consumption
1.3
113.4 MMSCF/year
Fuel Meter, Twelve
Month Rolling Total
Month' Monthly
Other Requirements'
Fuel Gas Heat
Content
1'4
ASTM Methods or
Equivalent
Semi -
Annually
Hours of
Operation
1.5
Recordkeeping
Monthly
Opacity
1.6
Not to Exceed 20% Except as
Provided for Below
Fuel Restriction — Natural Gas Only
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed i
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 12
Parameter
Permit
Condition
Number
Limitations
Compliance
Emission Factor
Monitoring
Method
Interval
For Startup — Not to Exceed 30%,
for a Period or Periods
Aggregating More than Six (6)
Min in any 60 Consecutive Min
Control Device
Requirements
1.7
Recordkeeping
See
Condition
1.7
Portable
Monitoring
1.8
Flue Gas Analyzer
Quarterly
Compliance
Assurance
Monitoring
(CAM)
1.9
See Condition 1.9
Statewide
Controls for Oil
and Gas
Operations
1.10
See Condition 1.10
40 CFR 63
Subpart ZZZZ
MACT
1.11
See Condition 1.11
C-174 and C-176 Only: Complies by meeting 40 CFR 60 Subpart JJJJ NSPS
40 CFR 63
Subpart A
General
Provisions
MACT
1.12
See Condition 1.12
40 CFR 60
Subpart JJJJ
NSPS
1.13
C-174 Only:
NOx —1.0 g/hp-hr or 82 ppmvd @ 15% O2
CO - 2.0 g/hp-hr or 270 ppmvd @ 15% O2
VOC - 0.7 g/hp-hr or 60 ppmvd @ 15% O2
C-176 Only:
NOx - 2.0 g/hp-hr or 160 ppmvd @ 15% O2
CO - 4.0 g/hp-hr or 540 ppmvd @ 15% O2
VOC -1.0 g/hp-hr or 86 ppmvd @ 15% O2
See Condition 1.13
40 CFR 60
Subpart A
General
Provisions NSPS
1.14
See Condition 1.14
'Emission & Consumption Limitations and Other Requirements apply to each engine individually
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 Permits 01 WE0499, 01 WE0500,
01 WE0501, 01WE0503, 01WE0504 & 01WE0505, 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
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 13
requested emissions identified on the APENs submitted on 3/22/2019 for engine C-148 only and
6/27/2018 for engine C-174 only). The emission factors listed above have been approved by the Division
and shall be used to calculate emissions from these engines, except in the event of a failed portable flue
gas analyzer test, as provided for in Condition 1.8. Compliance with the emission limitations shall be
monitored as follows:
Monthly emissions of each pollutant shall be calculated 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:
tons l
NOx or CO Emissions (month)
Emission Factor lb x Heat Content
I(MMBtu x Fuel Use (MMSCF
(MMBtu� MMSCF� (month
Unit Conversion (2000 lb)
ton J
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 those listed above, and in the absence of
subsequent testing results to the contrary (as approved by the Division), the permittee shall apply
for a modification to this permit to reflect, at a minimum, the higher emission rates/factors within
60 days of the completion of the test.
1.2 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 Permits 01WE0499, 01 WE0500, 01 WE0501,
01WE0503, 01WE0504 & 01WE0505, 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 emissions
identified on the APENs submitted on 6/27/2018 for engine C-174 only). Compliance with the emission
limitations shall be monitored as follows:
1.2.1 Monthly emissions shall be calculated 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 x Fuel Use MMSCF
( tons l __ Emission Factor (MM
Btu) x Heat Content (MMSCF ( month
lmonth/ Unit Conversion (2000 lb)
ton 1
VOC Emissions
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
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 14
twelve months' data. Records of calculations shall be maintained and made available to the
Division upon request.
1.2.2 Emissions of Hazardous Air Pollutants (HAP) shall not exceed the annual facility -wide
limitations set forth in Condition 3.1. Monthly emissions of each HAP shall be calculated by the
end of the subsequent month with the methods required by Condition 3.1 and used in a twelve
month rolling total to monitor compliance with the facility -wide HAP emission limitations.
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 Permits 01WE0499, 01 WE0500, 01 WE0501, 01WE0503, 01WE0504 &
01 WE0505, 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 APENs
submitted on 6/27/2018). Compliance with the consumption limitations shall be monitored as follows:
1.3.1 Facility -wide natural gas consumption shall be recorded using the existing fuel meter on a
monthly basis. The natural gas use shall be measured on the same day that run time hours have
been recorded for each engine, as required by Condition 1.5.
1.3.2 Allocation of natural gas to each engine will be calculated using the following calculation:
Btu
MMSCF _ HREngine (month ) MMSCF
FCEngine month Btu l Btu x FCFacility month
HREngine (month) + Z HRother (month
Where:
HREn ine r Bt7[ BSFC r Btu l x Hours of Operation (-month)
x Site Rated HP h
g \month/ \hp • hr/ p \month/ ( p)
And:
FCEngine = Individual Engine Fuel Consumption, MMSCF/Month
HREngine = Individual Engine Heat Requirement, Btu/Month
HRother = Other Users Heat Requirement, Btu/ Month
FCFacility = Facility Wide Fuel Consumption (metered), MMSCF/Month
BSFC = Brake Specific Fuel Consumption, Btu/hp • hr
Monthly natural gas consumption from each engine shall be used in a twelve month rolling total to
monitor compliance with the annual limitation. Each month, a new twelve month total shall be calculated
using the previous twelve months' data. Records of calculations shall be maintained and made available
to the Division upon request.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 15
Monthly natural gas consumption from each engine shall be used to monitor compliance with the annual
NOx, CO and VOC emission limitations, as required by Conditions 1.1 and 1.2.
1.4 Fuel 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. 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 retained and made available to the Division upon request.
The heat content indicated by the most recent analysis shall be used to monitor compliance with the annual
NOx, CO and VOC emission limitations for each engine, 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 monthly facility -wide fuel gas consumption is measured, as required by
Condition 1.3.1. Monthly hours of operation shall be used in a running total for each annual compliance
period. Records shall be made available for Division review upon request.
The hours of operation shall be used to monitor compliance with the annual fuel gas consumption
limitation, 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 1.6.2 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).
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 permittee shall maintain
records that verify that only natural gas is used as fuel.
1.7 Control Device Requirements
Each engine shall be equipped with both a non -selective catalytic reduction system and an air fuel
controller (as required by Condition 1.10.1.1). Parameters associated with the air -to -fuel ratio controller
(AFR) and non -selective catalyst reduction (NSCR) unit shall be monitored as follows:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 16
1.7.1 The pressure drop across the catalyst shall be monitored and recorded monthly. The 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.
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 seven days of engine/catalyst operation and re-established during the
next regularly scheduled emission test.
1.7.2 The catalyst inlet temperature shall be monitored and recorded daily and kept between 750°F and
1250°F. If the temperature is outside of this range, then appropriate maintenance activities shall
be performed. A log of periods observed outside this range and subsequent maintenance activities
performed shall be maintained and made available for Divisions review upon request.
1.7.3 The millivolt reading for the Air -Fuel Ratio Controller (AFR) O2 sensor for each engine will be
monitored and recorded weekly to assess the air to fuel ratio controller operating condition.
During those weeks when portable monitoring is scheduled, the millivolt reading shall be
monitored and recorded during the portable monitoring event. Recording of the millivolt reading
shall be used to verify that the AFR controller is operated in accordance with the manufacturer's
recommendations.
1.7.4 When portable monitoring is scheduled, the parameters above in Conditions 1.7.1 and 1.7.2 shall
be recorded during the portable monitoring event.
1.7.5 The oxygen concentration in the engine exhaust gas shall be measured and recorded for each
engine during each portable monitoring event required by Condition 1.8.
1.8 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://www.colorado.gov/pacific/cdphe/portable-analyzer-monitoring-protocol
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 17
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.
1.9 Compliance Assurance Monitoring (CAM)
Each engine is subject to the Compliance Assurance Monitoring (CAM) requirements with respect to the
annual emission limitations in Condition 1.1 for NOx and CO. Compliance with the CAM requirements
shall be monitored in accordance with the requirements in Condition 5 and the CAM Plan in Appendix I.
1.10 Statewide Controls for Oil and Gas Operations
1.10.1 Colorado Regulation No. 7, Section XVI. Requirements:
Each engine is subject to the following requirements of Colorado Regulation No. 7, Section
XVI., "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.
Air Pollution Technology Requirements
1.10.1.1 For rich burn reciprocating internal combustion engines, a non -selective catalyst
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 18
reduction and an air fuel controller shall be required. A rich burn reciprocating
internal combustion engine is one with a normal exhaust oxygen concentration of
less than 2% by volume (Colorado Regulation No. 7, Section XVI.B.1.).
1.10.1.2 The emission control equipment required by this Section XVI.B. (Condition
1.10.1.1) shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications (Colorado Regulation No. 7,
Section XVI.B.3.).
Exemptions
1.10.1.3 The following stationary combustion equipment are exempt from the emission
limitation requirements of Section XVI.D.4., the compliance demonstration
requirements in Section XVI.D.5., and the related recordkeeping and reporting
requirements of Sections XVI.D.7.a-f. and XVI.D.8, but these sources must maintain
any and all records necessary to demonstrate that an exemption applies (Condition
1.10.1.8b). 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
XVI.D.6. (Conditions 1.10.1.6 through 1.10.1.7), when required by XVI.D.6.a
(Condition 1.10.1.5).
Once stationary combustion equipment no longer qualifies for any exemption, the
owner or operator must comply with the applicable requirements of this Section
XVI.D. 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 XVI.D.4 (Colorado
Regulation No. 7, Section XVI.D.2.).
a. Any natural gas -fired reciprocating internal combustion engines subject to a work
practice or emission control requirement contained in this Regulation 7, Section
XVI.A. or B. (Condition 1.10.1.1) (Colorado Regulation No. 7, Section
XVI.D.2.e.).
1.10.1.4 [Additional Recordkeeping: Notwithstanding, the owner or operator shall comply
with the recordkeeping requirements of Section XVI. D. 7.. (Condition 1.10.1.8a) for
the combustion process adjustments required under Section XVID.6.b. (Condition
1.10.1.6.)]
Combustion Process Adjustment
1.10.1.5 As of January 1, 2017, this Section XVI.D.6. (Conditions 1.10.1.6) 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 as of June 3, 2016 (Colorado Regulation No. 7, Section XVI.D.6.a.).
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 19
1.10.1.6 Combustion Process Adjustment (Colorado Regulation No. 7, Section XVI.D.6.b.)
a. The owner or operator of a stationary internal combustion engine must conduct
the following inspections and adjustments, as applicable (Colorado Regulation
No. 7, Section XVI.D.6.b.(iv)):
(i) Change oil and filters as necessary (Colorado Regulation No. 7, Section
XVI.D.6.b.(iv)(A)).
(ii) Inspect air cleaners, fuel filters, hoses, and belts and clean or replace as
necessary (Colorado Regulation No. 7, Section XVI.D.6.b.(iv)(B)).
(iii) Inspect spark plugs and replace as necessary (Colorado Regulation No. 7,
Section XVI.D.6.b.(iv)(C)).
b. 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,
Section XVI.D.6.b.(v)).
c. Frequency (Colorado Regulation No. 7, Section XVI.D.6.b.(vi)).
(i)
The owner or operator 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, Section
XVI.D.6.b.(vi)(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
XVI.D.6.c.(i) (Condition 1.10.1.7a) or XVI.D.6.c.(ii) (Condition 1.10.1.7b)
(Colorado Regulation No. 7, Section XVI.D.6.b.(vi)(B)).
Alternative Requirements
1.10.1.7
As an alternative to the requirements described in Sections XVI.D.6.b.(iv) through
XVI.D.6.b.(v) (Conditions 1.10.1.6a through 1.10.1.6b) (Colorado Regulation No. 7,
Section XVI.D.6.c.):
a. The owner or operator may conduct the combustion process adjustment
according to the manufacturer recommended procedures and schedule (Colorado
Regulation No. 7, Section XVI.D.6.c.(i)); or
b. The owner or operator of combustion equipment that is subject to and required
to conduct a period 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
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
Recordkeeping
DCP Operating Company, LP
Marla Compressor Station
Page 20
applicable requirements of 40 CFR Part 60 or 40 CFR Part 63 (Colorado
Regulation No. 7, Section XVI.D.6.c.(ii)).
1.10.1.8 The following records must be kept for a period of five years and made available to
the Division upon request (Colorado Regulation No. 7, Section XVI.D.7.):
a. For stationary combustion equipment subject to the combustion process
adjustment requirements in Section XVI.D.6. (Conditions 1.10.1.6), the
following recordkeeping requirements apply (Colorado Regulation No. 7,
Section XVI.D.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
XVI.D. (Condition 1.10.1.5) and including for each combustion equipment
(Colorado Regulation No. 7, Section XVI.D.7.f.(i)):
(A) The date of the adjustment (Colorado Regulation No. 7, Section
XVI.D.7.f.(i)(A));
(B) Whether the combustion process adjustment under Sections
XVI.D.6.b.(iv) through XVI.D.6.b.(v) (Conditions 1.10.1.6a
through 1.10.1.6b) was followed, and what procedures were
performed (Colorado Regulation No. 7, Section XVI.D.7.f.(i)(B));
(C) Whether a combustion process adjustment under Sections
XVI.D.6.a. and XVI.D.6.b. (Conditions 1.10.1.5 through 1.10.1.6)
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, Section
XVI.D.7.f.(i)(C)); and
(D) A description of any corrective action taken (Colorado Regulation
No. 7, Section XVI.D.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, Section XVI.D.7.f.(i)(E)).
(F) [Additional Recordkeeping: If the owner or operator conducts an
alternative combustion process adjustment under Section
XVI.D.6.c. (Condition 1.10.1.7), the owner or operator shall
document that these requirements were followed, what procedures
were performed, and what New Source Performance or National
Emission Standard for Hazardous Air Pollutants applied, if any.]
(ii) The owner or operator must retain manufacturer recommended procedures,
specifications, and maintenance schedule if utilized under Section
XVI.D.6.a. (Condition 1.10.1.5) for the life of the equipment (Colorado
Regulation No. 7, Section XVI.D.7.f.(ii)).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 21
(iii) As an alternative to the requirements described in Section XVI.D.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, Section XVI.D.7.f.(iii)).
b. All sources qualifying for an exemption under Section XVI.D.2. (Condition
1.10.1.3) must maintain all records necessary to demonstrate that an exemption
applies (Colorado Regulation No. 7, Section XVI.D.7.g.).
1.10.2 Colorado Regulation No. 7, Section XVII Requirements:
Each engine except C-174 and C-176 is subject to the following requirements of Colorado
Regulation No. 7, Section XVII, "Statewide Controls for Oil and Gas Operations and Natural
Gas -Fired Reciprocating Internal Combustion Engines":
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.
For the purposes of permanent replacements made to this engine in accordance with the AOS
provisions of SECTION I - 2, this Condition does not apply to any replacement engine that is
subject to an emissions control requirement in afederal maximum achievable control technology
("MACT ") standard under 40 CFR Part 63, a Best Available Control Technology ("BACT ")
limit, or a New Source Performance Standard under 40 CFR Part 60.
1.10.2.1 [State -Only Enforceable]: Except as provided in Section XVII.E.2.b., the owner or
operator of any natural gas fired reciprocating internal combustion engine that is
either constructed or relocated to the state of Colorado from another state, on or after
the date listed in the table below shall operate and maintain each engine according to
the manufacturer's written instructions or procedures to the extent practicable and
consistent with technological limitations and good engineering and maintenance
practices over the entire life of the engine so that it achieves the emission standards
required in the table below (Colorado Regulation No. 7, Section XVII.E.2.a.).
1.10.2.2 [State -Only Enforceable]: Actual emissions from natural gas fired reciprocating
internal combustion engines shall not exceed the emission performance standards in
the table below as expressed in units of grams per horsepower -hour (g/hp-hr)
(Colorado Regulation No. 7, Section XVII.E.2.b.).
Maximum
Engine Hp
Construction or
Relocation Date
Emission Standard in g/hp-hr
NOx
CO
VOC
> 500 HP
On or after July 1, 2007
2.0
4.0
1.0
On or after July 1, 2010
1.0
2.0
0.7
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 22
[Additional 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 ofg/hp-hr to assess
compliance with the NOx and CO emission limitations in this Condition 1.10.2.1.]
[Compliance Demonstration: In the absence of credible evidence to the contrary,
compliance with the VOC limitation is presumed provided the portable monitoring
indicates compliance with the NOx and CO emission limitations in this Condition
1.10.2.1.]
1.10.2.3 Except as provided in Sections XVII.E.3.a.(i)(B) and (C) and XVII.E.3.a.(ii), all rich
burn reciprocating internal combustion engines with a manufacturer's name plate
design rate greater than 500 horsepower, constructed or modified before February 1,
2009 shall install and operate both a non -selective catalytic reduction system and an
air fuel controller by July 1, 2010. A rich burn reciprocating internal combustion
engine is one with a normal exhaust oxygen concentration of less than 2% by volume
(Colorado Regulation No. 7, Section XVII.E.3.a.(i)).
All control equipment required by Section XVII.E.3.a. shall be operated and
maintained pursuant to manufacturer specifications or equivalent to the extent
practicable, and consistent with technological limitations and good engineering and
maintenance practices. The owner or operator shall keep manufacturer specifications
or equivalent on file. (Colorado Regulation No. 7, Section XVII.E.3.a.(i)(A)).
1.11 40 CFR Part 63 Subpart ZZZZ MACT
Each engine is subject to the National Emissions Standards for Hazardous Air Pollutants requirements of
Regulation No. 8, Part E, Subpart ZZZZ (40 CFR Part 63, Subpart ZZZZ) "National Emissions Standards
for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines", including, but
not limited to, the following:
The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart
ZZZZ published in the Federal Register on February 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 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.
What This Subpart Covers
1.11.1 Engines C-174 and C-176 only: Stationary RICE subject to Regulations under 40 CFR Part
60. An affected source that meets any of the criteria in paragraphs (c)(1) (Condition 1.11.1.1)
through (7) of this section must meet the requirements of this part by meeting the requirements
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 23
of 40 CFR part 60 subpart JJJJ (Condition 1.13), for spark ignition engines. No further
requirements apply for such engines under this part (§63.6590(c)).
1.11.1.1 A new or reconstructed stationary RICE located at an area source (§63.6590(c)(1)).
General Requirements
1.11.2 You must be in compliance with the emission limitations, operating limitations, and other
requirements in this subpart that apply to you at all times (§63.6605(a)).
1.11.3 At all times you must operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions
does not require you to make any further efforts to reduce emissions if levels required by this
standard have been achieved. Determination of whether such operation and maintenance
procedures are being used will be based on information available to the Administrator which may
include, but is not limited to, monitoring results, review of operation and maintenance
procedures, review of operation and maintenance records, and inspection of the source
(§63.6605(b)).
Emission Limitations, Operating Limitations and Work Practices
1.11.4 If you own or operate an existing stationary RICE located at an area source of HAP emissions,
you must comply with the requirements in Table 2d (Condition 1.11.4.1) to this subpart that
apply to you (§63.6603(a)).
1.11.4.1 Table 2d Item 11 for non -emergency, non -black start 4SRB remote stationary RICE
>500HP:
a. Change oil and filter every 2,160 hours of operation or annually, whichever
comes first (Table 2d, Item 11.a).
b. Inspect spark plugs every 2,160 hours of operation or annually, whichever comes
first, and replace as necessary (Table 2d, Item 11.b).
c. Inspect all hoses and belts every 2,160 hours of operation or annually, whichever
comes first, and replace as necessary (Table 2d, Item 11.c).
1.11.4.2 Sources have the option to utilize an oil analysis program as described in §63.6625(j)
(Condition 1.11.7) in order to extend the specified oil change requirement in Table
2d (Condition 1.11.4.1a) of this subpart (Table 2d, Footnote 1).
1.11.5 An existing non -emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than
500 HP located at area sources of HAP must meet the definition of remote stationary RICE in
§63.6675 of this subpart on the initial compliance date for the engine, October 19, 2013, in order
to be considered a remote stationary RICE under this subpart. Owners and operators of existing
non -emergency SI 4SLB and 4SRB stationary RICE with a site rating of more than 500 HP
located at area sources of HAP that meet the definition of remote stationary RICE in §63.6675
of this subpart as of October 19, 2013 must evaluate the status of their stationary RICE every 12
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed: '�
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 24
months. Owners and operators must keep records of the initial and annual evaluation of the status
of the engine. If the evaluation indicates that the stationary RICE no longer meets the definition
of remote stationary RICE in §63.6675 of this subpart, the owner or operator must comply with
all of the requirements for existing non -emergency SI 4SLB and 4SRB stationary RICE with a
site rating of more than 500 HP located at area sources of HAP that are not remote stationary
RICE within 1 year of the evaluation (§63.6603(f)).
Testing and Initial Compliance Requirements
1.11.6 If you operate a new, reconstructed, or existing stationary engine, you must minimize the engine's
time spent at idle during startup and minimize the engine's startup time to a period needed for
appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the
emission standards applicable to all times other than startup in Table 2d (Condition 1.11.4.1) to
this subpart apply (§63.6625(h)).
1.11.7 You have the option of utilizing an oil analysis program in order to extend the specified oil change
requirement in Tables 2d (Condition 1.11.4.1a) to this subpart. The oil analysis must be
performed at the same frequency specified for changing the oil in Table 2d (Condition 1.11.4.1a)
to this subpart. The analysis program must at a minimum analyze the following three parameters:
Total Acid Number, viscosity, and percent water content. The condemning limits for these
parameters are as follows: Total Acid Number increases by more than 3.0 milligrams of
potassium hydroxide (KOH) per gram from Total Acid Number of the oil when new; viscosity
of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent
water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded,
the engine owner or operator is not required to change the oil. If any of the limits are exceeded,
the engine owner or operator must change the oil within 2 business days of receiving the results
of the analysis; if the engine is not in operation when the results of the analysis are received, the
engine owner or operator must change the oil within 2 business days or before commencing
operation, whichever is later. The owner or operator must keep records of the parameters that are
analyzed as part of the program, the results of the analysis, and the oil changes for the engine.
The analysis program must be part of the maintenance plan for the engine (§63.6625(j)).
Continuous Compliance Requirements
1.11.8 You must demonstrate continuous compliance with each emission limitation, operating
limitation, and other requirements in Table 2d (Condition 1.11.4.1) to this subpart that apply to
you according to methods specified in Table 6 (Condition 1.11.8.1) to this subpart (§63.6640(a)).
1.11.8.1 Table 6 Item 9 for existing non -emergency 4SLB and 4SRB stationary RICE >500
HP located at an area source of HAP that are remote stationary RICE:
a. Work or Management practices
(i)
Operating and maintaining the stationary RICE according to the
manufacturer's emission -related operation and maintenance instructions
(Table 6, Item 9.a.i); or
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 25
(ii) Develop and follow your own maintenance plan which must provide to the
extent practicable for the maintenance and operation of the engine in a
manner consistent with good air pollution control practice for minimizing
emissions (Table 6, Item 9.a.ii).
1.11.9 You must report each instance in which you did not meet each emission limitation or operating
limitation in Table 2d (Condition 1.11.4.1) to this subpart that apply to you. These instances are
deviations from the emission and operating limitations in this subpart. These deviations must be
reported according to the requirements in §63.6650 (Condition 1.11.11). If you change your
catalyst, you must reestablish the values of the operating parameters measured during the initial
performance test. When you reestablish the values of your operating parameters, you must also
conduct a performance test to demonstrate that you are meeting the required emission limitation
applicable to your stationary RICE (§63.6640(b)).
1.11.10 You must also report each instance in which you did not meet the requirements in Table 8
(Condition 1.12) to this subpart that apply to you (§63.6640(e)).
Reporting Requirements
1.11.11 Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 or
71 must report all deviations as defined in this subpart (Condition 1.11.9) in the semiannual
monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A)
(§63.6650(f)).
Recordkeeping Requirements
1.11.12 If you must comply with the emission and operating limitations (Condition 1.11.4.1), you must
keep the records described in paragraphs §63.6655(a)(1) through (a)(5) of this subpart
(§63.6655(a)).
1.11.13 You must keep the records required in Table 6 (Condition 1.11.8.1) of this subpart to show
continuous compliance with each emission or operating limitation that applies to you
(§63.6655(d)).
1.11.14 You must keep records of the maintenance conducted on the stationary RICE in order to
demonstrate that you operated and maintained the stationary RICE and after -treatment control
device (if any) according to your own maintenance plan (§63.6655(e)).
1.11.15 Your records must be in a form suitable and readily available for expeditious review according
to §63.10(b)(1). (Condition 1.12.2) (§63.6660(a)).
1.11.16 As specified in §63.10(b)(1), (Condition 1.12.2), you must keep each record for 5 years following
the date of each occurrence, measurement, maintenance, corrective action, report, or record
(§63.6660(b)).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 26
1.11.17 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 1.12.2) (§63.6660(c)).
1.12 40 CFR Part 63 Subpart A MACT
Each engine is subject to the requirements in 40 CFR Part 63 Subpart A "General Provisions", as adopted
by reference in Colorado Regulation No. 8, Part E, Section I as specified in 40 CFR Part 63 SubpartZZZZ
§63.6665. These requirements include, but are not limited to the following:
1.12.1 §63.4 — Prohibited activities and circumvention
1.12.2 §63.10 — Recordkeeping and reporting requirements
1.13 40 CFR Part 60 Subpart JJJJ NSPS
Engine C-174 and C-176 only are 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 August 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
1.13.1 Owners and operators of stationary SI ICE with a maximum engine power greater than or equal
to 75 KW (100 HP) (except gasoline and rich burn engines that use LPG) must comply with the
emission standards in Table 1 (Condition 1.13.1.1) to this subpart for their stationary SI ICE
(§60.4233(e)).
1.13.1.1 Table 1: NOx, CO, and VOC Emission Standards for Stationary Non -Emergency SI
Engines >100 HP
Engine
and
Fuel
Type
Engine
Maximum
Power
Manufacture
Date
Emission
(g/hp-hr)
Standards
Emission
(ppmvd
at
Standards
15%
02)
NOx
CO
VOC
NOx
CO
VOC
Non
SI
-Emergency
Natural
Gas
HP
> 500
July
1,
2007
2.0
4.0
1.0
160
540
86
July
1,
2010
1.0
2.0
0.7
82
270
60
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 27
a. Owners and operators of stationary non -certified SI engines may choose to
comply with the emission standards in units of either g/HP-hr or ppmvd at 15
percent O2 (Table 1 and Footnote (a) of Subpart JJJJ).
b. 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).
1.13.2 Owners and operators of stationary SI ICE must operate and maintain stationary SI ICE that
achieve the emission standards as required in §60.4233 (Condition 1.13.1) over the entire life of
the engine (§60.4234).
Compliance Requirements for Owners and Operators
1.13.3 If you are an owner or operator of a stationary SI internal combustion engine and must comply
with the emission standards specified in §60.4233(e) (Condition 1.13.1), you must demonstrate
compliance according to the methods specified in paragraph (b)(1) and (b)(2) of this section
(§60.4243(b)).
1.13.3.1 Purchasing an engine certified according to procedures specified in this subpart, for
the same model year and demonstrating compliance according to one of the methods
specified in §60.4243(a) of this subpart (§60.4243(b)(1)).
1.13.3.2 Purchasing a non -certified engine and demonstrating compliance with the emission
standards specified in §60.4233(e) (Condition 1.13.1) and according to the
requirements specified in §60.4244 (Condition 1.13.5), as applicable, and according
to paragraph (b)(2)(ii) (Condition a) of this section (§60.4243(b)(2)).
a. If you are an owner or operator of a stationary SI internal combustion engine
greater than 500 HP, you must keep a maintenance plan and records of conducted
maintenance and must, to the extent practicable, maintain and operate the engine
in a manner consistent with good air pollution control practice for minimizing
emissions. In addition, you must 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)).
1.13.4 It is expected that air -to -fuel ratio controllers will be used with the operation of three-way
catalysts/non-selective catalytic reduction. The AFR controller must be maintained and operated
appropriately in order to ensure proper operation of the engine and control device to minimize
emissions at all times (§60.4243(g)).
Testing Requirements for Owners and Operators
1.13.5 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 28
1.13.6 Owners or operators of stationary SI ICE must meet the following notification, reporting and
recordkeeping requirements (§60.4245):
1.13.6.1 Owners and operators of all stationary SI ICE must keep records of the information
in paragraphs (a)(1) through (4) of this section (§60.4245(a)).
a. All notifications submitted to comply with this subpart and all documentation
supporting any notification (§60.4245(a)(1)).
b. Maintenance conducted on the engine (§60.4245(a)(2)).
c. If the stationary SI internal combustion engine is a certified engine,
documentation from the manufacturer that the engine is certified to meet the
emission standards and information as required in 40 CFR parts 90, 1048, 1054,
and 1060, as applicable (§60.4245(a)(3)).
d. If the stationary SI internal combustion 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)).
1.13.6.2 Owners and operators of stationary SI ICE that are subject to performance testing
must submit a copy of each performance test as conducted in §60.4244 (Condition
1.13.5) within 60 days after the test has been completed. Performance test reports
using EPA Method 18, EPA Method 320, or ASTM D6348-03 (incorporated by
reference —see 40 CFR 60.17) to measure VOC require reporting of all QA/QC data.
For Method 18, report results from sections 8.4 and 11.1.1.4; for Method 320, report
results from sections 8.6.2, 9.0, and 13.0; and for ASTM D6348-03 report results of
all QA/QC procedures in Annexes 1-7 (§60.4245(d)).
1.14 40 CFR 60 Subpart A NSPS
Engines C-174 and C-176 only are subject to the requirements in 40 CFR Part 60 Subpart A "General
Provisions", as specified in 40 CFR Part 60 Subpart JJJJ §60.4246. These requirements include, but are
not limited to the following:
1.14.1 Notification and recordkeeping (§60.7)
1.14.2 Performance tests (§60.8)
1.14.3 Compliance with standards and maintenance requirements (§60.11)
1.14.4 Circumvention (§60.12)
1.14.5 General notification and reporting requirements (§60.19)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air. Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 29
2. P-112 TEG Dehydration Unit with an Enclosed Combustion Device (AIRS ID: 062)
P-113 TEG Dehydration Unit with an Enclosed Combustion Device (AIRS ID: 063)
Note: These limitations apply to each dehydration unit individually.
Parameter
Permit
Condition
Number
Limitations
Compliance
Emission Factor
Monitoring
Method , Interval
P-112
P -1B
Emission & Throughput Limits
VOC Emissions
2.1
10.6 tons/year
14.3 tons/year
GRI GLYCaIc,
Version 4.0 or
Higher
Process
Simulation and
Twelve Month
Rolling Total
Calculation
Monthly
Wet Gas
Throughput
Limitations
2.2
Total: 16,425
MMSCF/year
Uncontrolled: Not
to exceed 3% of
total actual
throughput
Total: 20,075
MMSCF/year
Uncontrolled: Not
to exceed 3% of
total actual
throughput
Lean Glycol
Circulation Rate
2.3
6.25 gallons/minute
8.2 gallons/minute
Other Requirements
Extended Gas
Analysis
2.4
Unit Inlet
Meters and
Twelve Month
Rolling Total
Calculation
Monthly
Recordkeeping
Daily
ASTM
Methods or
Equivalent
Annually
Parametric
Monitoring
2.5
Recordkeeping
Weekly
Hours of Operation
2.6
Not to exceed 30% for a period or periods
aggregating more than six (6) minutes in
any sixty (60) consecutive minutes
Recordkeeping
& Calculation
Monthly
Opacity
2.7
See Condition 2.7
Still Vent Emissions
Routing
2.8
See Condition 2.8
Control Device
Requirements
2.9
See Condition 2.9
Compliance
Assurance
Monitoring (CAM)
2.10
See Condition 2.10
Statewide Controls
for Oil and Gas
Operations
2.11
See Condition 2.11
40 CFR 63 Subpart
HH MACT
2.12
See Condition 2.12
40 CFR 63 Subpart
A General
Provisions MACT
2.13
See Condition 2.13
Operating Permit 95OP.WE020
First Issued: June 1, 1999
Renewed
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
2.1 VOC Emission Limitations & Compliance Monitoring
DCP Operating Company, LP
Marla Compressor Station
Page 30
Emissions of Volatile Organic Compounds (VOC) from each dehydration unit shall not exceed the
limitations listed in Summary Table 2 above. (Colorado Construction Permits 01 WE0506 and 05WE0579,
as modified under the provisions of Section I, Condition 1.3 and Colorado Regulation No. 3, Part C,
Section I.A.7 and Section III.B.7, based on requested emissions identified on the APEN submitted on
7/23/2018). Compliance with the emission limitations shall be monitored as follows:
2.1.1 Monthly determination of VOC and HAP emissions shall be conducted by the end of the
subsequent month using the Gas Research Institute's GLYCalc Model, Version 4.0 or higher.
2.1.1.1 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 2.4.
b. The average daily gas throughput, as required by Condition 2.2.1.
c. The average monthly value of the lean glycol circulation rate, as required by
Condition 2.3, and the monthly average inlet wet gas temperature and pressure
and the flash tank operating temperature and pressure, as required by Condition
2.5.
2.1.1.2 Control Efficiencies
a. A control efficiency (CE) of 95% shall apply to the enclosed combustion device
(ECD) when it is operational and emissions from each dehydration unit are
routed to it and combusted, provided the requirements of Conditions 2.8, 2.11.1
and 2.11.3 are met.
2.1.1.3 Operating Hours
a. Total hours of operation for each dehydration unit, as required by Condition
2.6.1, and uncontrolled hours of operation, as required by Condition 2.6.2, shall
be input to the equation below, along with the corresponding control efficiency
(CE) of 95% for the ECD, to determine actual emissions of VOC during periods
of ECD operation, in which still vent emissions are routed to the ECD and
combusted.
b. Uncontrolled hours of operation, as required by Condition 2.6.2, shall be input to
the equation below, to determine actual emissions of VOC during periods of
uncontrolled operation, in which still vent emissions are routed uncombusted to
atmosphere.
2.1.1.4 Monthly emissions of VOC shall be monitored using the following equations:
lb hrs lb hrs ( hrs CE(%)
tons _ SVvoc (hr) x OHU (month) SVvoc (hr) x [[OHT (month) OH° (month) x (1 100 )
VOC Emissions (month) 20001b + 2000 lb
Unit Conversion ( ton ) Unit Conversion ( ton )
Where:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
SVvoc = Uncontrolled Still Vent Emissions of VOC, lb/hr
OHT = Total Dehydration Unit Hours of Operation, hrs/month
OHu = Uncontrolled Hours of Operation, hrs/month
CE = Control Efficiency of ECD, 95%
DCP Operating Company, LP
Marla Compressor Station
Page 31
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.
2.1.2 Emissions of Hazardous Air Pollutants (HAP) shall not exceed the annual facility -wide
limitations set forth in Condition 3.1. Monthly emissions of each HAP from each dehydration
unit shall be calculated using the same method as indicated above for VOC and used in a twelve
month rolling total to monitor compliance with the facility -wide HAP emission limitations.
2.2 Wet Gas Throughput Limitations & Compliance Monitoring
2.2.1 Total Throughput: The total amount of wet gas processed by each dehydration unit shall not
exceed the limitations listed in Summary Table 2 above (Colorado Construction Permits
01WE0506 and 05WE0579, 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 the requested
limitations identified on the APEN submitted on 10/11/2017). The gas throughput shall be
monitored and recorded monthly using existing inlet flow meters to each dehydration unit. The
monthly wet 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 gas throughput rate shall be used as an input to the monthly process model run,
as required by Condition 2.1. This average daily gas throughput rate shall be calculated by
dividing the total monthly wet gas throughput by the total hours of operation, as required by
Condition 2.6.1, as follows:
Total Monthly Gas Throughput MMSCF x Unit Conversion /24 hrs)
MMSCF) month day
Average Daily Gas Throughput ( _
day Total Hours of Operation ( hrs )
month
2.2.2 Uncontrolled Wet Gas Throughput: The total amount of wet gas processed by each glycol
dehydration unit during uncontrolled hours of operation shall not exceed 3% of the total wet gas
throughput to 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 B, Section II.A.6 and
Part C, Section X based on the requested limitations identified on the APEN submitted on
10/11/2017). Uncontrolled hours of operation is defined as periods when either dehydration unit
is operating and still vent emissions from that dehydration unit are routed uncombusted to
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 32
atmosphere. The uncontrolled wet gas throughput to each dehydration unit shall be determined
monthly as the amount of wet gas throughput to each dehydration unit, as indicated by the inlet
flowmeters (Condition 2.2.1), during uncontrolled hours of operation, as determined in Condition
2.6.2. The monthly uncontrolled wet 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.
2.3 Lean Glycol Circulation Rate Limitations & Compliance Monitoring
The lean glycol circulation rate for each dehydration unit shall not exceed the limitations listed in
Summary Table 2 above (Colorado Construction Permits 01WE0506 and 05 WE0579, 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 the requested limitations identified on the APENs submitted on 10/11/2017). The
lean glycol circulation rate shall be recorded daily and obtained using the methods outlined below:
2.3.1 P-112 only: The lean glycol flowrate shall be calculated by recording the pump strokes per minute
and using manufacturer correlations to convert this parameter into the lean glycol flowrate in
gallons per minute. Records of the pump make/model and strokes per minute/circulation rate
relationship shall be made available to the Division upon request.
2.3.2 P-113 only: The lean glycol flowrate shall be recorded using the dedicated glycol flowmeter.
Records of the daily lean glycol circulation rate shall be maintained and made available for Division
review upon request.
A monthly average of the lean glycol circulation rate shall be calculated from the daily recorded values
from that month for each dehydration unit. This monthly average shall be used as an input to the monthly
process model run, as required by Condition 2.1.
2.4 Extended Gas Analysis
An extended gas analysis of the inlet wet gas to the dehydration units shall be performed annually
according to appropriate ASTM methods, or equivalent, if approved in advance by the Division. The
extended analysis shall identify the relevant 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 2.1.
2.5 Parametric Monitoring
The following operating parameters for each 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 33
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 2.1.
2.6 Hours of Operation
Hours of operation shall be monitored as follows:
2.6.1 Total Hours of Operation: Hours of operation for each dehydration unit shall be monitored
and recorded monthly 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 emission limitation, as required
by Condition 2.1, and to determine the average daily gas throughput, as required by Condition
2.2.1.
2.6.2 Uncontrolled Hours of Operation: Uncontrolled hours of operation for each dehydration unit,
defined as periods during which the dehydration unit is operating and still vent emissions from
that dehydration unit are routed uncombusted to atmosphere, shall be determined monthly using
the still vent emissions routing records for each dehydration unit, as required by Condition 2.8.
Monthly uncontrolled hours of operation shall be used to monitor compliance with the VOC
emission limitation, as required by Condition 2.1, and the uncontrolled wet gas throughput
limitation, as required by Condition 2.2.2. Records of uncontrolled hours of operation shall be
maintained and made available to the Division upon request.
2.7 Opacity
The following opacity requirements apply to the enclosed combustion device (ECD):
2.7.1 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 2.9.2 and 4.4.2.2 are met.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
2.8 Still Vent Emissions Routing
DCP Operating Company, LP
Marla Compressor Station
Page 34
The routing of still vent emissions from each dehydration unit to the ECD or atmosphere shall be
monitored and recorded daily in a log to be made available to the Division upon request. Valve position
indicators shall be used to determine the routing configuration and the duration for which that routing
configuration is applicable. The log shall indicate the date and time at which each new routing
configuration commences.
The length of time for which each routing configuration was applicable shall be used to determine the
uncontrolled hours of operation for each dehydration unit, as required by Condition 2.6.2.
2.9 Control Device Requirements
The following requirements apply to the operation of the enclosed combustion device (ECD):
2.9.1 The ECD shall be operated with the pilot light present at all times, except during periods of
permitted downtime. The pilot light shall be monitored as follows:
2.9.1.1 The pilot light shall be monitored continuously using a flame rod. A daily log of the
flame rod indication shall be maintained and made available to the Division upon
request.
2.9.1.2 In the event the pilot light presence cannot be verified by the flame rod, 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.
2.9.1.3 Records of pilot light outage events and the duration of such events shall be
maintained and made available to the Division upon request.
2.9.2 EPA Method 22 observations shall be conducted daily to determine whether 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 the daily visual observations shall be kept on file and made available to
the Division upon request.
2.9.2.1 In the event visible emissions are observed, an EPA Reference Method 9 opacity
observation shall be performed to monitor compliance with the opacity standard. The
result(s) of the visual observations and the Method 9 observations shall be kept on
file and made available for Division review upon request.
2.9.2.2 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.
2.9.2.3 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 2.7) 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
opacity is less than the opacity limit.
2.10 Compliance Assurance Monitoring (CAM)
DCP Operating Company, LP
Marla Compressor Station
Page 35
Each dehydration unit is subject to the Compliance Assurance Monitoring (CAM) requirements with
respect to the annual emission limitations in Condition 2.1 for VOC and Condition 3.1 for HAP.
Compliance with the CAM requirements shall be monitored in accordance with the requirements in
Condition 5 and the CAM Plan in Appendix,.
2.11 Statewide Controls for Oil and Gas Operations
2.11.1 Colorado Regulation No. 7, Section XII.C. Requirements:
Each dehydration unit is subject to the "General Requirements for Air Pollution Control
Equipment — Prevention of Leakage" of Colorado Regulation No. 7, Section XII, "Volatile
Organic Compound Emissions from Oil and Gas Operations", as required by Conditions 4.1.1
and 4.1.2.
2.11.2 Colorado Regulation No. 7, Section XII.H. Requirements:
Each dehydration unit is subject to the following "Emission Reductions from Glycol Natural
Gas Dehydrators" of Colorado Regulation No. 7, Section XII, "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.
Section XII.H. Control Requirements
2.11.2.1
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 XII.H.3. (Condition 2.11.2.2), 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, Section XII.H.1).
[Compliance Demonstration: In absence of credible evidence to the contrary,
compliance with the VOC reduction requirements of Condition 2.11.2.1 shall be
presumed as long as the control device requirements in Conditions 2.8 and 2.11.1
are met]
2.11.2.2 The control requirements of Sections XII.H.1. (Condition 2.11.2.1) apply where:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 36
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, Section XII.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,
Section XII.H.3.b.).
2.11.2.3 For purposes of Section XII.H. (Condition 2.11.2), 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, Section XII.H.4.).
Section XII.H Monitoring and Recordkeeping Requirements
2.11.2.4 [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 Condition 2.11.2.1 apply. Such records shall be maintained and
made available for the Division upon request.
Dehydrators that are not subject to the control requirements in Condition 2.11.2.1
that increase uncontrolled actual emissions from the dehydrator and/or group of
dehydrators at the facility above the thresholds listed in Conditions 2.11.2.2a and/or
2.11.2.2b shall comply with the control requirements of Condition 2.11.2.1 within 60
days of discovery of the emission increase.]
2.11.2.5 Monitoring and Recordkeeping (Colorado Regulation No. 7, Section XII.H.5.)
a. Beginning January 1, 2017, owners or operators of glycol natural gas dehydrators
subject to the control requirements of Sections XII.H.1. (Condition 2.11.2.1)
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, Section XII.H.5.a.), and document:
(i) The date of each inspection (Colorado Regulation No. 7, Section
XII.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,
Section XII.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, Section XII.H.5.a.(iii)).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
f
DCP Operating Company, LP
Marla Compressor Station
Page 37
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, Section XII.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, Section
XII.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,
Section XII.H.5.d.).
Section XII.H. Reporting Requirements
2.11.2.6 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, Section XII.H.6.a.)
a. A list of the glycol natural gas dehydrator(s) subject to Section XII.H (Colorado
Regulation No. 7, Section XII.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, Section XII.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, Section XII.H.6.a.(iii)).
2.11.3 [State -Only Enforceable] Colorado Regulation No. 7, Section XVII.B Requirements
Each dehydration unit is subject to the State -Only Enforceable "General Provisions" of
Colorado Regulation No. 7, Section XVII, "Statewide Controls for Oil and Gas Operations and
Natural Gas -Fired Reciprocating Internal Combustion Engines", as required by Conditions 4.4.1
and 4.4.2.
2.11.4 [State -Only Enforceable] Colorado Regulation No. 7, Section XVII.D. Requirements:
Each dehydration unit is subject to the following State -Only Enforceable "Emission
Reductions from Glycol Natural Gas Dehydrators" of Colorado Regulation No. 7, Section XVII,
"Statewide Controls for Oil and Gas Operations and Natural Gas -Fired Reciprocating Internal
Combustion Engines":
Conditions shown in italic text below represent monitoring, recordkeeping and recording
provisions that are not included in Colorado Regulation No. 7 as of the issuance date of this
permit, but are being included as per Colorado Regulation No. 3, Part C, Section V.C.5.b.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
Section XVII.D. Control Requirements
2.11.4.1
DCP Operating Company, LP
Marla Compressor Station
Page 38
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 XVII.D.2. (Condition 2.11.4.2), 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, Section XVII.D.1.).
[Compliance Demonstration: In absence of credible evidence to the contrary,
compliance with the requirements VOC reduction requirements of Condition
2.11.4.1 shall be presumed as long as the control device requirements in Conditions
2.8 and 2.11.3 are met.]
2.11.4.2 The control requirement in Section XVII.D.1. (Condition 2.11.4.1) 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 (Colorado
Regulation No. 7, Section XVII.D.2.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 two tons per year (Colorado Regulation No. 7,
Section XVII.D.2.b.).
2.11.4.3 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. (Condition 2.11.4.4), shall
reduce 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, Section XVII.D.3.).
[Compliance Demonstration: In absence of credible evidence to the contrary,
compliance with the hydrocarbon reduction requirements of Condition 2.11.4.3
shall be presumed as long as the control device requirements in Conditions 2.8 and
2.11.3 are met.]
If a combustion device is used (to meet the requirements of Condition 2.11.4.3), it
shall have a design destruction efficiency of at least 98% for hydrocarbons except
where:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 39
a. The combustion device has been authorized by permit prior to May 1, 2014; and
(Colorado Regulation No. 7, Section XVII.D.3.a.).
b. A building unit or designated outside activity area (as defined in Section
XVII.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, Section
XVII.D.3.b.).
[Compliance Demonstration: In absence of credible evidence to the contrary,
compliance with the design destruction efficiency requirements of Condition
2.11.4.3 shall be presumed as long as the requirements in Conditions 2.11.4.6 and
2.11.4.7 are met.]
2.11.4.4 The control requirements in Section XVII.D.3. (Condition 2.11.4.3) apply where:
a. Uncontrolled actual emissions of VOCs from a single glycol natural gas
dehydrator constructed before May 1, 2015, are equal to or greater than
(Colorado Regulation No. 7, Section XVII.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 XVII.D.4.c.).
Section XVII.D. Recordkeeping Requirements
2.11.4.5
2.11.4.6
[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 2.11.4.1 or 2.11.4.3 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 2.11.4.1
or 2.11.4.3 that increase uncontrolled actual emissions from the dehydrator and/or
group of dehydrators at the facility above the thresholds listed in Conditions
2.11.4.2 and/or 2.11.4.4 shall comply with the control requirements of Conditions
2.11.4.1 and/or 2.11.4.3 within 60 days of discovery of the emission increase.]
[Additional Monitoring: If the owner or operator is claiming an exemption from
the control requirements of Condition 2.11.4.3 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 2.11.4.3
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 2.11.4.3 within 60 days of discovery of the changes.]
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 40
2.11.4.7 [Compliance Demonstration: The owner or operator shall maintain records that
document the design efficiency of the combustion device used to meet the
requirements of Condition 2.11.4.3. Such records shall be maintained and made
available for Division review.]
2.12 40 CFR Part 63 Subpart HH MACT
Each 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 August 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
2.12.1 The provisions set forth in this subpart shall apply at all times (§63.762(a)).
General Standards
2.12.2 Except as specified in paragraph (e)(1) (Condition 2.12.3.1) 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 2.12.2.1) of this
section (§63.764(d)).
2.12.2.1
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)).
a. Determine the optimum glycol circulation rate using the following equation
(§63.764(d)(2)(i)):
( gal TEG) F x (I — 0)
Lon,= 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 41
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 2.12.8) 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)).
2.12.3 §63.764(e) Exemptions
2.12.3.1 The owner or operator of an area source is exempt from the requirements of
paragraph (d) (Condition 2.12.2) of this section if the criteria listed in paragraph
(e)(1)(i) (Condition a, below) or (ii) (Condition b, 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 2.12.7) (§63.764(e)(1)).
a. 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 2.12.5.1) of this subpart
(§63.764(e)(1)(i)); or
b. 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 2.12.5.2) of
this subpart (§63.764(e)(1)(ii)).
2.12.4 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 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 42
2.12.5 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)).
2.12.5.1 The determination of actual flowrate of natural gas to a glycol dehydration unit shall
be made using the procedures of either 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)).
2.12.5.2 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-GLYCa1cTM, 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
2.12.6 Except as specified in paragraphs (d) (Condition 2.12.7) and (f) (Condition 2.12.8) of this
section, each owner or operator of a facility subject to this subpart shall maintain the records
specified in paragraphs (b)(1) (Condition 2.12.6.1) through (2) (Condition 2.12.6.2) of this
section (§63.774(b)):
2.12.6.1 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. Records shall be maintained in accordance with §63.774(b)(1)(i) through (iv)
of this subpart (§63.774(b)(1)).
2.12.6.2 Records specified in §63.10(b)(2) (Condition 2.13.2) (§63.774(b)(2)).
2.12.7 An owner or operator of a glycol dehydration unit that meets the exemption criteria in
§63.764(e)(1)(i) (Condition 2.12.3.1a) or §63.764(e)(1)(ii) (Condition 2.12.3.Ib) shall maintain
the records specified in paragraph (d)(1)(i) (Condition 2.12.7.1) or paragraph (d)(1)(ii)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 43
(Condition 2.12.7.2) of this section, as appropriate, for that glycol dehydration unit
(§63.774(d)(1)).
2.12.7.1 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 2.12.5.1) (§63.774(d)(1)(i)), or
2.12.7.2 The actual average benzene emissions (in terms of benzene emissions per year) as
determined in accordance with §63.772(b)(2) (Condition 2.12.5.2)
(§63.774(d)(1)(ii)).
2.12.8 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 2.12.2.1a) or §63.764(d)(2)(ii) (Condition
2.12.2.1b), as applicable (§63.774(f)).
2.13 40 CFR Part 63 Subpart A MACT
Each 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:
2.13.1 Prohibited activities and circumvention (§63.4)
2.13.2 Recordkeeping and reporting requirements (§63.10)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
tons l
month
l
HAP Emissions ( _
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
3. Facility -Wide Hazardous Air Pollutant (HAP) Emission Limitations
DCP Operating Company, LP
Marla Compressor Station
Page 44
Parameter
Permit
Condition
Number
Limitation
Compliance
Emission Factor
Monitoring
Method
Interval
Emission & Throughput Limits
HAP
3.1
8.0 tons/year single HAP
20.0 tons/year total HAP
See Condition
3.1.1
Recordkeeping and
Twelve Month
Rolling Total
Calculation
Monthly
3.1 HAP Emission Limitations & Compliance Monitoring
Emissions of Hazardous Air Pollutants (HAP) from the engines and dehydration units shall not exceed
the limitations listed in Summary Table 3 above (Colorado Construction Permits 01WE0506 and
05WE0579, as modified under the provisions of Section I, Condition 1.3). Compliance with the emission
limitations shall be monitored as follows:
3.1.1 Monthly emission calculations shall be completed for each HAP emitted at this facility. Point -
specific calculations of HAP emissions are outlined as follows:
3.1.1.1 For Natural Gas Fired Reciprocating Internal Combustion Engines:
a. Uncontrolled emission factors (EF) for each HAP shall be obtained from the most
recent edition of EPA's AP -42: Compilation of Emission Factors, Section 3.2 for
Natural Gas Fired Reciprocating Engines, Final Section, Table 3.2-3
"Uncontrolled Emission Factors for 4 -Stroke Rich -Burn Engines".
b. The following control efficiencies (CE) shall be applied to the referenced HAP
species
Hazardous Air Pollutant
Control Efficiency
Formaldehyde
76%
Other HAP
50%
c. Monthly emissions of each HAP with uncontrolled actual emissions above the de
minimis reporting threshold shall be calculated for each engine by the end of the
subsequent month using the above emission factors (EF) and control efficiencies
(CE), 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:
Emission Factor (( MMBtulb) IMMSx Heat Content ((MMBtu x Fuel Use
month MMSCF x (1 CE(%)1
CF� 100 )
3.1.1.2 For Dehydration Units:
Unit Conversion (2 00 ton )
ton J
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
a. See Condition 2.1
DCP Operating Company, LP
Marla Compressor Station
Page 45
3.1.2 Determination of Compliance with the Facility -Wide Individual HAP Limit
3.1.2.1 Facility -wide emissions for an individual HAP shall be the sum total emissions of
that HAP from the engines and dehydration units 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.
3.1.3 Determination of Compliance with the Facility -Wide Total HAP Limit
3.1.3.1 Facility -wide emissions for total HAP shall be the sum total of all HAP emitted from
the engines and dehydration units 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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
4. Statewide Controls for Oil and Gas Operations — Facility -Wide
4.1 Colorado Regulation No. 7, Section XII.C. Requirements:
DCP Operating Company, LP
Marla Compressor Station
Page 46
This facility is subject to the following "General Requirements for Air Pollution Control Equipment" of
Colorado Regulation No. 7, Section XII, "Volatile Organic Compound Emissions from Oil and Gas
Operations":
4.1.1 All air pollution control equipment used to demonstrate compliance with this Section XII. shall
be operated and maintained consistent with manufacturer specifications and good engineering
and maintenance practices. The owner or operator shall keep manufacturer specifications on file.
In addition, all such air pollution control equipment shall be adequately designed and sized to
achieve the control efficiency rates required by this Section XII. 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, Section XII.C.1.a.).
4.1.2 All condensate collection, storage, processing and handling 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 Regulation No. 7, Section
XII.C.1.b.).
4.1.3 All air pollution control equipment used to demonstrate compliance with Section XII.J.
(Condition 4.2) must meet a control efficiency of at least 95%. Failure to properly install, operate,
and maintain air pollution control equipment at the locations indicated in the Division -approved
spreadsheet is a violation of this regulation (Colorado Regulation No. 7, Section XII.C.1.c.).
4.1.4 If a flare or other combustion device is used to control emissions of volatile organic compounds
to comply with Section XII.J., (Condition 4.2) it shall be enclosed, have no visible emissions,
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, such as a continuous
monitoring device, approved by the Division, determine whether it is operating properly
(Colorado Regulation No. 7, Section XII.C.1.d.).
4.1.5 All combustion devices used to control emissions of volatile organic compounds to comply with
Section XII.J. (Condition 4.2) shall be equipped with and operate an auto -igniter as follows
(Colorado Regulation No. 7, Section XII.C.1.e.):
4.1.5.1 All combustion devices installed on or after January 1, 2018, and used to comply
with Sections XII.J. (Condition 4.2) must be equipped with an operational auto -
igniter upon installation of the combustion device (Colorado Regulation No. 7,
Section XII.C.1.e.(iv)).
4.2 Colorado Regulation No. 7, Section XII.J. Requirements:
Each compressor is subject to the following "Compressor Requirements" of Colorado Regulation No. 7,
Section XII, "Volatile Organic Compound Emissions from Oil and Gas Operations":
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 47
4.2.1 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, Section XII.J.2.a.).
4.2.2 As an alternative to the requirement described in Section XII.J.2.a. (Condition 4.2.1), beginning
May 1, 2018, the owner or operator may collect rod packing volatile organic compound emissions
using a rod packing emissions collection system that operates under negative pressure and routes
the rod packing emissions through a closed vent system to a process (Colorado Regulation No.
7, Section XII.J.2.b.).
4.2.2.1 The owner or operator must conduct annual visual inspections of the cover and closed
vent system for defects that could result in air emissions. Defects of the closed vent
system include, but are not limited to, visible cracks, holes, gaps in piping, loose
connections, liquid leaks, or broken or missing caps or other closure devices. Defects
of the cover include, but are not limited to, visible cracks, holes, gaps in the cover or
between the cover and separator wall, broken or damaged seals or gaskets on closure
devices, broken or missing hatches or other closure devices (Colorado Regulation
No. 7, Section XII.J.2.b.(i)).
4.2.2.2 The owner or operator must conduct annual EPA Method 21 inspections of the cover
and closed vent system to determine whether the cover and closed vent system
operates with volatile organic compound emissions less than 500 ppm (Colorado
Regulation No. 7, Section XII.J.2.b.(ii)).
4.2.2.3 In the event that a defect that could result in air emissions or leak is detected, the
owner or operator must make a first attempt to repair no later than five (5) days after
detecting the defect or leak and complete repair no later than thirty (30) days after
detecting the defect or leak (Colorado Regulation No. 7, Section XII.J.2.b.(iii)).
4.2.2.4 Owners or operators may delay inspection or repair of a cover or closed vent. system
if:
a. Repair is technically infeasible without a shutdown. 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,
Section XII.J.2.b.(iv)(A)).
b. The cover or closed vent system is unsafe to inspect or repair because personnel
would be exposed to an immediate danger as a consequence of completing the
inspection or repair (Colorado Regulation No. 7, Section XII.J.2.b.(iv)(B)).
c. The cover or closed vent system is difficult to inspect or repair because personnel
must be elevated more than two (2) meters above a supported surface or are
unable to inspect or repair via a wheeled scissor -lift or hydraulic type scaffold
that allows access up to 7.6 meters (25 feet) above the ground (Colorado
Regulation No. 7, Section XII.J.2.b.(iv)(C)).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 48
d. The cover or closed vent system is inaccessible to inspect or repair because the
cover or closed vent system is buried, insulated, or obstructed by equipment or
piping that prevents access (Colorado Regulation No. 7, Section
XII.J.2.b.(iv)(D)).
Recordkeeping Requirements
4.2.3 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, Section XII.J.2.c.(i)):
4.2.3.1 Identification of each reciprocating compressor (Colorado Regulation No. 7, Section
XII.J.2.c.(i)(A))
4.2.3.2 The hours of operation or the number of months since the previous rod packing
replacement, or a statement that emissions from the rod packing are being routed to
a process through a closed vent system under negative pressure (Colorado Regulation
No. 7, Section XII.J.2.c.(i)(B))
4.2.3.3 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,
Section XII.J.2.c.(i)(C))
4.2.3.4 Each cover and closed vent system inspection and any resulting responsive actions
(Colorado Regulation No. 7, Section XII.J.2.c.(i)(D)), and
4.2.3.5 Each cover or closed vent system on the delay of inspection or repair list, the reason
for and duration of the delay of inspection or repair, and the schedule for inspecting
or repairing such cover or closed vent system (Colorado Regulation No. 7, Section
XII.J.2.c.(i)(E)).
4.2.4 As an alternative to the inspection, repair, and recordkeeping provisions in Sections XII.J.2.b.
(Condition 4.2.2), XII.J.2.c.(i)(D) (Condition 4.2.3.4), and XII.J.2.c.(i)(E) (Condition 4.2.3.5),
the owner or operator may inspect, repair, and document the cover and closed vent system in
accordance with the leak detection and repair program in Section XII.L. (Condition 4.3),
including the inspection frequency (Colorado Regulation No. 7, Section XII.J.2.d.).
Alternate Compliance Option
4.2.5 As an alternative to the emission control, inspection, repair, and recordkeeping provisions
described in Sections XII.J.2.a. (Condition 4.2.1) through XII.J.2.d. (Condition 4.2.4), 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, Section XII.J.2.e.).
4.3 Colorado Regulation No. 7, Section XII.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, Section XII, "Volatile Organic Compound Emissions from Oil and Gas Operations":
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 49
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.
4.3.1 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, Section XII.L.1.a)
4.3.2 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, Section XII.L.3.).
4.3.2.1 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, Section XII.L.3.a.).
4.3.2.2 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, Section XII.L.3.b.).
4.3.2.3 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, Section XII.L.3.c.).
4.3.3 Leaks requiring repair: Only leaks from components exceeding the thresholds in this Section
XII.L.4. require repair under Section XII.L.5 (Condition 4.3.4) (Colorado Regulation No. 7,
Section XII.L.4.).
4.3.3.1 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, Section XII.L.4.a.).
4.3.3.2 For infra -red camera, 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, Section XII.L.4.b.).
4.3.3.3 For other approved instrument monitoring methods or programs, leak identification
requiring repair will be established as set forth in an approval under Section XII.L.8
(Condition 4.3.8) (Colorado Regulation No. 7, Section XII.L.4.c.).
4.3.3.4 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 XII.L.5. (Condition 4.3.4) 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 XII.L.4.a. (Condition
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 50
4.3.3.1), the leak must be repaired and remonitored in accordance with Section
XII.L.5 (Condition 4.3.4) (Colorado Regulation No. 7, Section XII.L.4.d.).
4.3.3.5 Owners or operators must maintain and operate approved nonquantitative instrument
monitoring methods according to manufacturer recommendations (Colorado
Regulation No. 7, Section XII.L.4.e.).
4.3.4 Repair and remonitoring (Colorado Regulation No. 7, Section XII.L.5.)
4.3.4.1 First attempt to repair a leak must be made no later than five (5) working days after
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, Section XII.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, Section XII.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, Section XII.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, Section XII.L.5.a.(iii)).
4.3.4.2 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, Section XII.L.5.b.).
4.3.4.3 Leaks discovered pursuant to the leak detection methods of Section XII.L.4.
(Condition 4.3.3) are not subject to enforcement by the Division unless the owner or
operator fails to perform the required repairs in accordance with Section XII.L.5.
(Condition 4.3.4) or keep required records in accordance with Section XII.L.6
(Condition 4.3.5) (Colorado Regulation No. 7, Section XII.L.5.c.).
4.3.5 Recordkeeping (Colorado Regulation No. 7, Section XII.L.6.)
4.3.5.1 Documentation of the initial approved instrument monitoring method inspection for
well production facilities and natural gas compressor stations (Colorado Regulation
No. 7, Section XII.L.6.a.);
4.3.5.2 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, Section
XII.L.6.b.);
4.3.5.3 A list of the leaks requiring repair and the monitoring method(s) used to determine
the presence of the leak (Colorado Regulation No. 7, Section XII.L.6.c.);
4.3.5.4 The date of first attempt to repair the leak and, if necessary, any additional attempt
to repair (Colorado Regulation No. 7, Section XII.L.6.d.);
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 51
4.3.5.5 The date the leak was repaired and type of repair method applied (Colorado
Regulation No. 7, Section XII.L.6.e.);
4.3.5.6 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 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, Section XII.L.6.f.);
4.3.5.7 The date the leak was remonitored and the results of the remonitoring (Colorado
Regulation No. 7, Section XII.L.6.g.); and
4.3.5.8 A list of components that are designated as unsafe, difficult, or inaccessible to
monitor, as described in Section XII.L.3. (Condition 4.3.2), an explanation stating
why the component is so designated, and the schedule for monitoring such
component(s) (Colorado Regulation No. 7, Section XII.L.6.h.).
4.3.5.9 Records must be maintained for a minimum of five years and made available to the
Division upon request (Colorado Regulation No. 7, Section XII.L.6.i.).
4.3.6 [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 Section XII.L.4. (Condition 4.3.3) because they qualms 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.]
4.3.7 Reporting: The owner or operator of each facility subject to the leak detection and repair
requirements in Section XII.L. (Condition 4.3) 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, Section XII.L.7.):
4.3.7.1 The total number of well production facilities and total number of natural gas
compressor stations inspected (Colorado Regulation No. 7, Section XII.L.7.a.);
4.3.7.2 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, Section XII.L.7.b.);
4.3.7.3 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 XII.L.7.b. (Condition 4.3.7.2) 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, Section XII.L.7.c.);
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 52
4.3.7.4 The total number of leaks repaired for each inspection frequency tier of well
production facilities as reported in Section XII.L.7.b. (Condition 4.3.7.2) and the
total number of leaks repaired for natural gas compressor stations (Colorado
Regulation No. 7, Section XII.L.7.d.);
4.3.7.5 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 XII.L.7.b. (Condition 4.3.7.2) or natural gas compressor station, and the
basis for each delay of repair (Colorado Regulation No. 7, Section XII.L.7.e.);
4.3.7.6 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, Section XII.L.7.f.); and
4.3.7.7 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, Section XII.L.7.g.).
4.3.8 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 XII.L. (Condition 4.3), if the following conditions are
met (Colorado Regulation No. 7, Section XII.L.8.):
4.3.8.1 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, Section XII.L.8.a.):
a. The proposed alternative approved instrument monitoring method manufacturer
information (Colorado Regulation No. 7, Section XII.L.8.a.(i));
b. A description of the proposed alternative approved instrument monitoring
method including, but not limited to (Colorado Regulation No. 7, Section
XII.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, Section
XII.L.8.a.(ii)(A));
(ii) Whether the proposed alternative approved instrument monitoring method
is commercially available (Colorado Regulation No. 7, Section
XII.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,
Section XII.L.8.a.(ii)(C));
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 53
(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 locations, detection limits,
and any restrictions on use, as well as supporting data (Colorado Regulation
No. 7, Section XII.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, Section XII.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,
Section XII.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, Section XII.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,
Section XII.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 XII.L. (Condition 4.3) (Colorado Regulation
No. 7, Section XII.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, Section
XII.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, Section XII.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, Section XII.L.8.a.(v)).
4.4 [State -Only Enforceable] Colorado Regulation No. 7, Section XVII.B. Requirements
This facility is subject to the following State -Only Enforceable "General Provisions" of Colorado
Regulation No. 7, Section XVII, "Statewide Controls for Oil and Gas Operations and Natural Gas -Fired
Reciprocating Internal Combustion Engines":
4.4.1 General Requirements
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 54
4.4.1.1 All intermediate hydrocarbon liquids collection, storage, processing, and handling
operations, regardless of size, shall be designed, operated, and maintained so as to
minimize leakage of VOCs and other hydrocarbons to the atmosphere to the extent
reasonably practicable (Colorado Regulation No. 7, Section XVII.B.1.a.).
4.4.1.2 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, Section
XVII.B.1.b.).
4.4.2 General Requirements for Air Pollution Control Equipment
4.4.2.1 All air pollution control equipment shall 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 shall keep manufacturer specifications or equivalent on file. In
addition, all such air pollution control equipment shall 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, Section XVII.B.2.a.).
4.4.2.2 If a combustion device is used to control emissions of VOCs and other hydrocarbons,
it shall 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, Section
XVII.B.2.b.).
4.4.2.3 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, Section XVII.B.2.d.):
a. 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,
Section XVII.B.2.d.(ii)).
4.4.3 Requirements for Compressor Seals and Open -Ended Valves or Lines
4.4.3.1 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
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed: ''
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 55
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 XVII.A.5., and may be
monitored under the provisions of Section XVII.F (Condition 4.5) (Colorado
Regulation No. 7, Section XVII.B.3.a.).
4.4.3.2 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, Section XVII.B.3.c.).
4.5 [State -Only Enforceable] Colorado Regulation No. 7, Section XVII.F. Requirements:
This facility is subject to the following State -Only Enforceable "Leak Detection and Repair Program for
Well Production Facilities and Natural Gas Compressor Stations" of Colorado Regulation No. 7, Section
XVII "Statewide Controls for Oil and Gas Operations and Natural Gas -Fired Reciprocating Internal
Combustion Engines":
Conditions shown in italic text below represent monitoring, recordkeeping and recording provisions that
are not included in Colorado Regulation No. 7 as of the issuance date of this permit, but are being included
as per Colorado Regulation No. 3, Part C, Section V.C.5.b.
4.5.1 Owners or operators of well production facilities or natural gas compressor stations that monitor
components as part of Section XVII.F. 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, Section XVII.F.2.).
4.5.2 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, Section XVII.F.3.):
*For the purposes of this condition, approved instrument monitoring method means
an infra -red camera, or EPA Method 21.
4.5.2.1 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 (Colorado Regulation No. 7, Section XVII.F.3.a.).
4.5.2.2 Following the first approved instrument monitoring method inspection, owners or
operators must continue conducting approved instrument monitoring method
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 56
inspections in accordance with the Inspection Frequency in Table 3 (Colorado
Regulation No. 7, Section XVII.F.3.c.):
Table 3 — Natural Gas Compressor Station Component Inspections
Fugitive VOC Emissions (tpy)
Inspection Frequency
> 0 and < 12
Annually
> 12 and < 50
Quarterly
> 50
Monthly
4.5.2.3 For purposes of Section XVII.F.3. (Condition 4.5.2), 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, Section XVII.F.3.d.).
4.5.3 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, Section XVII.F.5.)
4.5.3.1 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, Section XVII.F.5.a.).
4.5.3.2 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, Section XVII.F.5.b.).
4.5.3.3 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, Section XVII.F.5.c.).
4.5.4 Leaks requiring repair: Leaks must be identified utilizing the methods listed in Section XVII.F.6.
(Conditions 4.5.4.1 through 4.5.4.3 below). Only leaks from components exceeding the
thresholds in Section XVII.F.6. (Conditions 4.5.4.1 through 4.5.4.3 below) require repair under
Section XVII.F.7. (Condition 4.5.5) (Colorado Regulation No. 7 Section XVII.F.6.).
4.5.4.1 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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 57
device actuation and crank case ventilation (Colorado Regulation No. 7, Section
XVII.F.6.a., except for requirements that apply only to well production facilities).
4.5.4.2 For infra -red camera monitoring, repair is required for leaks with any detectable
emissions not associated with normal equipment operation, such as pneumatic device
actuation and crank case ventilation (Colorado Regulation No. 7, Section
XVII.F.6.c., except for requirements associated with AVO monitoring, which only
apply to well production facilities).
4.5.4.3 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 XVII.F.7. (Condition 4.5.5)
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 XVII.F.6. (this Condition
4.5.4), the leak must be repaired and remonitored in accordance with Section
XVII.F.7. (Condition 4.5.5). (Colorado Regulation No. 7, Section XVII.F.6.e.,
except for requirements that apply only to well production facilities)
4.5.5 Repair and remonitoring (Colorado Regulation No. 7, Section XVII.F.7.):
4.5.5.1 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 Section XVII.F.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, Section XVII.F.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, Section XVII.F.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, Section XVII.F.7.a.(iii)).
4.5.5.2 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 Section XVII.F.7.b.).
4.5.5.3 Leaks discovered pursuant to the leak detection methods of Section XVII.F.6.
(Condition 4.5.4) are not subject to enforcement by the Division unless the owner or
operator fails to perform the required repairs in accordance with Section XVII.F.7.
(this Condition 4.5.5) or keep required records in accordance with Section XVII.F.8.
(Condition 4.5.6). (Colorado Regulation No. 7 Section XVII.F.7.c.)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 58
4.5.6 Recordkeeping: The owner or operator of each facility subject to the leak detection and repair
requirements in Section XVII.F. (Condition 4.5) must maintain the following records and make
them available to the Division upon request (Colorado Regulation No. 7, Section XVII.F.8.):
[Note: 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.]
4.5.6.1 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, Section
XVII.F.8.b.);
4.5.6.2 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, Section
XVII.F.8.c.);
4.5.6.3 The date of first attempt to repair the leak and, if necessary, any additional attempt
to repair the leak (Colorado Regulation No. 7, Section XVII.F.8.d.);
4.5.6.4 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,
Section XVII.F.8.e.);
4.5.6.5 The delayed repair list, including the basis for placing leaks on the list (Colorado
Regulation No. 7, Section XVII.F.8.f.);
4.5.6.6 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, Section XVII.F.8.g.);
4.5.6.7 The date the leak was remonitored and the results of the remonitoring (Colorado
Regulation No. 7, Section XVII.F.8.h.); and
4.5.6.8 A list of components that are designated as unsafe, difficult, or inaccessible to
monitor, as described in Section XVII.F.5. (Condition 4.5.3), an explanation stating
why the component is so designated, and the schedule for monitoring such
component(s) (Colorado Regulation No. 7, Section XVII.F.8.i.).
4.5.7 [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 Section XVII.F.6. (Condition 4.5.4) because they qualms as
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 59
"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.]
4.5.8 Reporting: The owner or operator of each facility subject to the leak detection and repair
requirements in Section XVII.F. (Condition 4.5) must submit a single annual report on or before
May 31st of each year that includes, at a minimum, the following information regarding leak
detection and repair activities at their subject facilities conducted for calendar years prior to
January 1, 2018: (Colorado Regulation No. 7, Section XVII.F.9.):
4.5.8.1 The number of facilities inspected (Colorado Regulation No. 7, Section XVII.F.9.a.);
4.5.8.2 The total number of inspections (Colorado Regulation No. 7, Section XVII.F.9.b.);
4.5.8.3 The total number of leaks identified, broken out by component type (Colorado
Regulation No. 7, Section XVII.F.9.c.);
4.5.8.4 The total number of leaks repaired (Colorado Regulation No. 7, Section XVII.F.9.d.);
4.5.8.5 The number of leaks on the delayed repair list as of December 31st (Colorado
Regulation No. 7, Section XVII.F.9.e.); and
4.5.8.6 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, Section XVII.F.9.f.).
4.5.9 Reporting, beginning with the reporting year of 2019: The owner or operator of each facility
subject to the leak detection and repair requirements in Section XVII.F. (Condition 4.5) 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, Section XVII.F.10.):
4.5.9.1 The total number of well production facilities and total number of natural gas
compressor stations inspected (Colorado Regulation No. 7, Section XVII.F.10.a.);
4.5.9.2 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, Section XVII.F.10.b.);
4.5.9.3 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 XVII.F.10.b. (Condition 4.5.9.2), or inspection frequency tier of
natural gas compressor stations (Colorado Regulation No. 7, Section XVII.F.10.c.);
4.5.9.4 The total number of leaks repaired for each inspection frequency tier of well
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 60
production facilities, as reported in Section XVII.F.10.b. (Condition 4.5.9.2), or
inspection frequency tier of natural gas compressor stations (Colorado Regulation
No. 7, Section XVII.F.10.d.);
4.5.9.5 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 XVII.F.10.b. (Condition 4.5.9.2), or inspection frequency tier of
natural gas compressor stations, and the basis for each delay of repair (Colorado
Regulation No. 7, Section XVII.F.10.e.);
4.5.9.6 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, Section XVII.F.10.f.); and
4.5.9.7 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, Section XVII.F.10.g.).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
5. Compliance Assurance Monitoring
DCP Operating Company, LP
Marla Compressor Station
Page 61
5.1 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:
5.1.1 C-148, C-135, C-151, C-166, C-174, C-176 — Natural Gas Fired Reciprocating Internal
Combustion Engines for NOx and CO (Condition 1.1)
5.1.1.1 The permittee shall follow the CAM Plan provided in Appendix G.
5.1.1.2 Excursions, for the purposes of reporting, are defined as any instance for which the
catalyst inlet temperature is less than 750°F or greater than 1250°F, or if the catalyst
differential pressure is more than 3 inches of water from the baseline pressure drop
established during the most recent performance test.
5.1.2 P-112, P-113 — Triethylene Glycol Dehydration Units for VOC and HAP (Conditions 2.1 and
3.1)
5.1.2.1 The permittee shall follow the CAM Plan provided in Appendix H.
5.1.2.2 Excursions, for the purposes of reporting, are defined as any absence of the enclosed
combustion device (ECD) pilot flame, except for during periods of permitted
downtime.
Excursions shall be reported as required by Section IV, Conditions 21 and 22.d of this permit.
5.1.3 Operation of Approved Monitoring
5.1.3.1 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).
5.1.3.2 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 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).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 62
5.1.3.3 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).
5.1.3.4 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).
5.1.4 Quality Improvement Plan (QIP) Requirements
5.1.4.1 Based on the results of a determination made under the provisions of Condition
5.1.3.3b, the Division may require the owner or operator to develop and implement
a QIP (40 CFR Part 64 § 64.8(a), as adopted by reference in Colorado Regulation
No. 3, Part C, Section XIV).
5.1.4.2 The owner or operator shall maintain a written QIP, if required, and have it available
for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 63
5.1.4.3 The QIP initially shall include procedures for evaluating the control performance
problems and, based on the results of the evaluation procedures, the owner or
operator shall modify the plan to include procedures for conducting one or more of
the following actions, as appropriate:
a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as
adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii),
as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
d. Other steps appropriate to correct control performance (40 CFR Part 64 §
64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C,
Section XIV).
e. More frequent or improved monitoring (only in conjunction with one or more
steps under Conditions a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as
adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
5.1.4.4 If a QIP is required, the owner or operator shall develop and implement a QIP as
expeditiously as practicable and shall notify the Division if the period for completing
the improvements contained in the QIP exceeds 180 days from the date on which the
need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by
reference in Colorado Regulation No. 3, Part C, Section XIV).
5.1.4.5 Following implementation of a QIP, upon any subsequent determination pursuant to
Condition 5.1.3.3b, the Division or the U.S. EPA may require that an owner or
operator make reasonable changes to the QIP if the QIP is found to have:
A. Failed to address the cause of the control device performance problems (40 CFR
Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part
C, Section XIV); or
b. Failed to provide adequate procedures for correcting control device performance
problems as expeditiously as practicable in accordance with good air pollution
control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as
adopted by reference in Colorado Regulation No. 3, Part C, Section XIV).
5.1.4.6 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).
5.1.5 Reporting and Recordkeeping Requirements
5.1.5.1 Reporting Requirements: The reports required by Section IV, Condition 22.d, shall
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 64
5.1.5.2
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
5.1.4 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).
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 5.1.4 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 recordkeeping
requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado
Regulation No. 3, Part C, Section XIV).
5.1.6 Savings Provisions
5.1.6.1
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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed: DATE
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 65
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).
5.1.6.2 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).
5.1.6.3 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 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
SECTION III - Permit Shield
DCP Operating Company, LP
Marla Compressor Station
Page 66
Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 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-148 Waukesha L-7042 GSI 1478 HP
C-135 Waukesha L-7042 GSI 1478 RP
C-151 Waukesha L-7042 GSI 1478 HP
C-166 Waukesha L-7044 GSI 1680 HP
C-174 Waukesha L-7044 GSI 1680 I -IF'
C-176 Waukesha L-7044 GSI 1680 HP
Colorado Regulation No. 1,
Section III.A.1.b - Particulate
emissions from fuel -burning
equipment
Internal combustion engines are not considered fuel burning
equipment for the applicable requirements of Colorado
Regulation No. 1.
Facility -Wide
Colorado Regulation No. 7
Section VI.B.1
Colorado Regulation No. 7
Section VI.B.2
These regulations are intended to apply to gasoline
storage and loading facilities and are therefore not
applicable to condensate at a compressor station.
Colorado Regulation No. 7
Section VII.C
This regulation requires storage tanks over 40,000
gallons to comply with selected requirements from
Colorado Regulation No. 7 Section VI. Section VI is
intended to regulate gasoline storage and loading
facilities and is therefore not applicable to condensate
at a compressor station.
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;
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 67
2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-
111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal
act;
2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to
Regulation No. 3, Part C, § XIII.
2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to
permit issuance.
3. Stream -lined Conditions
The following applicable requirements have been subsumed within this operating permit using the
pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield,
compliance with the listed permit conditions will also serve as a compliance demonstration for purposes
of the associated subsumed requirements.
Permit Condition
I Streamlined (Subsumed) Requirements
Section II, Conditions
4.5.2 & 4.5.4
Colorado Regulation No. 7, Section XVII.A.2. [definition of Approved Instrument
Monitoring Method — only with respect to other Division -approved alternatives] — State -Only
Enforceable Requirement.
Section IV, Conditions
22.b and 22.c
Colorado Regulation No. 7, Section XVII.F.8 [only the requirement to maintain records for
two years] — State -Only Enforceable Requirement.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 68
SECTION IV - General Permit Conditions (8/28/2018)
1. Administrative Changes
Regulation No. 3, 5 CCR 1001-5, Part A, § III.
The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that
are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of the
application to the Division.
2. Certification Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.& e. and V.C.17.
a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division
pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the
truth, accuracy and completeness of such form, report or certification stating that, based on information and belief
formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.
b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution
Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the
Division in the Operating Permit.
c. Compliance certifications shall contain:
(i) the identification of each permit term and condition that is the basis of the certification;
(ii) the compliance status of the source;
(iii) whether compliance was continuous or intermittent;
(iv) method(s) used for determining the compliance status of the source, currently and over the reporting
period; and
(v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the
source.
d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental
Protection Agency at the addresses listed in Appendix D of this Permit.
e. If the permittee is required to develop and register a risk management plan pursuant to § 112(r) of the federal act, the
permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents
of the risk management plan as a permit term or condition.
3. Common Provisions
Common Provisions Regulation, 5 CCR 1001-2 §§ II.A., II.B., II.C., II.E., II.F., II.I, and 11.7
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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
b. Emission Monitoring Requirements
DCP Operating Company, LP
Marla Compressor Station
Page 69
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 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 70
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 71
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
g.
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.
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 72
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 any other federally enforceable performance standard or
emission limit with an averaging time greater than twenty-four hours. In addition, an affirmative
defense cannot be used by a single source or small group of sources where the excess emissions
have the potential to cause an exceedance of the ambient air quality standards or Prevention of
Significant Deterioration (PSD) increments.
In making any determination whether a source established an affirmative defense, the Division shall consider the
information within the notification required above and any other information the Division deems necessary, which
may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the
maintenance and operation of process and air pollution control equipment.
4. Compliance Requirements
Regulation No. 3, 5 CCR 1001-5, Part C, III.C.9., V.C.11. & 16.d. and $ 25-7-122.1(2), C.R.S.
a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to
federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and
Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the
state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens
under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either
statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for
denial of a permit renewal application.
b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a
permit termination, revocation or modification action or action denying a permit renewal application that it would
have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of
the permit.
c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by
the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned
changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and XI. of
Regulation No. 3, Part C.
d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the
Division, any information that the Division may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the Division copies of records required to be kept by the permittee, including
information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically
identified and submitted separately from information not subject to the claim.
e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of
permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on
which it is based.
f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of
permit issuance, the permittee shall submit, at least every 6 months unless a more frequent period is specified in the
applicable requirement or by the Air Pollution Control Division, progress reports which contain the following:
(i)
dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and
dates when such activities, milestones, or compliance were achieved; and
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 73
g.
(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.
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.
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.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 74
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.1.
The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate
emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § III.D.1.
10. Inspection and Entry
Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b.
Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution
Control Division, or any authorized representative, to perform the following:
a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is
conducted, or where records must be kept under the terms of the permit;
b. have access to, and copy, at reasonable times, any records that must be kept under the conditions of the permit;
c. inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),
practices, or operations regulated or required under the Operating Permit;
d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or
applicable requirements, any substances or parameters.
11. Minor Permit Modifications
Regulation No. 3, 5 CCR 1001-5, Part C, §& X. & XI.
The permittee shall submit an application for a minor permit modification before making the change requested in the
application. The permit shield shall not extend to minor permit modifications.
12. New Source Review
Regulation No. 3, 5 CCR 1001-5, 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.11.d.
This permit does not convey any property rights of any sort, or any exclusive privilege.
14. Odor
Regulation No. 2, 5 CCR 1001-4, Part A
As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 75
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, §§ I., II.
The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ I.- II.
17. Open Burning
Regulation No. 9, 5 CCR 1001-11
The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions
of Regulation No. 9.
18. Ozone Depleting Compounds
Regulation No. 15, 5 CCR 1001-19
The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds.
Sections I., II.C., II.D., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only.
19. Permit Expiration and Renewal
Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2.
a. The permit term shall be five (5) years. The permit shall expire at the end of its term. Permit expiration terminates
the permittee's right to operate unless a timely and complete renewal application is submitted.
b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the
expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit
that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the
previous permit. A copy of any materials incorporated by reference must be included with the application.
20. Portable Sources
Regulation No. 3, 5 CCR 1001-5, Part C, § II.D.
Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location.
21. Prompt Deviation Reporting
Regulation No. 3, 5 CCR 1001-5, Part C, $ V.C.7.b.
The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction
conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures
taken.
"Prompt" is defined as follows:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 76
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.
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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 77
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. A revised
APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, §
II.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new
control equipment is installed; whenever a different type of control equipment replaces an existing type of control
equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a
period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution
Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires.
Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by
April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a
request for permit revision. APENs for changes in control equipment must be submitted before the change occurs.
Annual fees are based on the most recent APEN on file with the Division.
23. Reopenings for Cause
Regulation No. 3, 5 CCR 1001-5, Part C, § XIII.
a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and
reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that
proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists.
b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major
source with a remaining permit term of three or more years, unless the effective date of the requirements is later than
the date on which the permit expires, or unless a general permit is obtained to address the new requirements;
whenever additional requirements (including excess emissions requirements) become applicable to an affected
source under the acid rain program; whenever the Division determines the permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit;
or whenever the Division determines that the permit must be revised or revoked to assure compliance with an
applicable requirement.
c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a
shorter notice may be provided in the case of an emergency.
d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and
reissuance procedure.
24. Requirements for Major Stationary Sources
Regulation No. 3, 5 CCR 1001-5, Part D, §§ V.A.7, 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, § II.A.
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;
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 78
(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.
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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
26. Severability Clause
DCP Operating Company, LP
Marla Compressor Station
Page 79
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.I.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, $$ III & V.
The requirements in paragraphs a, b and e apply to sources located in an ozone non -attainment area or the Denver 1 -hour ozone
attainment/maintenance area. The requirements in paragraphs c and d apply statewide.
a. All storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support
structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when
opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use
shall be limited so as to minimize vapor loss.
Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a
portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC
concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section
VIII.C.3.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit # 95OPWE020
DCP Operating Company, LP
Marla Compressor Station
Page 80
b. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids,
transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be
transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches
of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom.
c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably
Available Control Technology (RACT) is utilized.
d. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in
Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored
in open containers, or disposed of in any other manner that would result in evaporation.
e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds
with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b,
above.
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 95OPWE020
First Issued: June 1, 1999
Renewed:
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 - CAM PLAN - ENGINES
H - CAM PLAN - DEHYS
I - 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 the permit, and is presented to assist the source,
permitting authority, inspectors, and citizens.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 2
APPENDIX A
Inspection Information
Directions to Plant:
The station is in the southeast quarter of Section 28, Township 4 North, Range 64 West in Weld County.
The station is located west of the intersection of Weld County Road (WCR) 55 and WCR 40 on the north
side of WCR 40. The Marla Station is located south of Kersey, Colorado.
Directions from Denver: Take I-76 north out of the Denver Metro area, go approximately 3 miles past the
town of Hudson and exit I-76 at CO Road 49 and proceed north. Travel north on CO Road 49 for
approximately 10 miles and turn east on CO Road 34. Proceed eastbound on CO Road 34 for 2 miles, turn
north on CO Road 53. Proceed north on CO Road 53 for 3 miles and turn east on CO Road 40. Proceed
for 1 mile. The Marla Compressor Station is located at the NW corner of CO Road 40 and CO Road 55.
Safety Equipment Required:
Hard Hat
Safety Shoes (Steel -Toed Boots)
Hearing Protection
Eye Protection with Side Shield
Flame Retardant Clothing
Facility Plot Plan:
The attached figure (following page) shows the plot plan as submitted with the permit modification
application received on 7/23/2018.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
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Air Pollution Control Division
Colorado Operating Permit
Inspection Information
List of Insignificant Activities:
Appendix A
Page 4
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) 1,000 gal Methanol Tank
• One (1) 100 bbl Methanol Tank
• One (1) 1,000 gal TEG Tank
• One (1) 1,000 gal Norkool Glycol Tank
• Two (2) 30,000 gal Pressurized Condensate Storage Tank
• One (1) Pressurized Condensate Truck Loadout
• One (1) 20 bbl Stormwater Tank
• Four (4) 80 bbl Stormwater Tanks
• C-148 Vent Blowdown
• C-135 Vent Blowdown
• C-151 Vent Blowdown
• C-166 Vent Blowdown
• C-174 Vent Blowdown
• C-176 Vent Blowdown
• One (1) 8" Pig Launcher to Mewbourn
• One (1) 16" Pig Launcher to Enterprise
• One (1) 12" Pig Launcher to Mewbourn
• One (1) 10" Inlet Pig Receiver
• Two (2) 8" Inlet Pig Receivers
*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) 0.85 MMBtu/hr Dehy Reboiler (H-112)
• One (1) 0.75 MMBtu/hr Dehy Reboiler (H-113)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Inspection Information
Appendix A
Page 5
*Colorado Regulation No. 3, Part C, Section II.E.3.uu: Oil production wastewater (produced water
tanks), containing less than one percent by volume annual average crude oil, except for commercial
facilities that accept oil production wastewater for processing.
• Four (4) 80 bbl Produced Water Tanks (TK-0515, TK-0516, TK-0175, TK-1080)
• One (1) 110 bbl Produced Water Tank
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) 1,000 gal Lube Oil Tank (TK-8)
• One (1) 210 bbl Lube Oil Tank (TK-8A)
• One (1) 20 bbl slop oil tank
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
APPENDIX B
Monitoring and Permit Deviation Report
ver. 8/20/14 w/ codes
Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly:
Appendix B
Page 6
(A) makes any false material statement, representation, or certification in, or omits material information from,
or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or
other document required pursuant to the Act to be either filed or maintained (whether with respect to the
requirements imposed by the Administrator or by a State);
(B) fails to notify or report as required under the Act; or
(C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to
be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18
of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any
person under this paragraph is for a violation committed after a first conviction of such person under this
paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment.
The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes
a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or for denial of a permit renewal application.
The Part 70 Operating Permit program requires three types of reports to be filed for all permits.
All required reports must be certified by a responsible official.
Report #1: Monitoring Deviation Report (due at least every six months)
For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six
months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements
must be clearly identified in such reports.
For purposes of this operating permit, monitoring means any condition determined by observation, by data from
any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping
associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel
analyses, and operational or control device parameter monitoring.
Report #2: Permit Deviation Report (must be reported "promptly")
In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement
of the permit is subject to deviation reporting. The reports must address deviations from permit requirements,
including those attributable to malfunctions as defined in this Appendix, the probable cause of 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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 7
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:
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8=CAM:
9 = Other:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
When the requirement is monitoring
When the requirement is testing
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 8
to how the information potentially affects compliance status), that information must be identified and addressed
in the compliance certification. The compliance certification must include the following:
• The identification of each term or condition of the permit that is the basis of the certification;
• Whether or not the method(s) used by the owner or operator for determining the compliance status
with each permit term and condition during the certification period was the method(s) specified in
the permit. Such methods and other means shall include, at a minimum, the methods and means
required in the permit. If necessary, the owner or operator also shall identify any other material
information that must be included in the certification to comply with section 113(c)(2) of the
Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material
information;
• The status of compliance with the terms and conditions of the permit, and whether compliance was
continuous or intermittent. The certification shall identify each deviation and take it into account
in the compliance certification. Note that not all deviations are considered violations.'
• Such other facts as the Division may require, consistent with the applicable requirements to which
the source is subject, to determine the compliance status of the source.
The Certification shall also identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance
Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM)
Note the requirement that the certification shall identify each deviation and take it into account in the compliance
certification. Previously submitted deviation reports, including the deviation report submitted at the time of the
annual certification, may be referenced in the compliance certification.
' 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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Startup, Shutdown, Malfunctions and Emergencies,
Appendix B
Page 9
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
APPENDIX B: Monitoring and Permit Deviation Report - Part I
Appendix B
Page 10
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 — Marla Compressor Station
OPERATING PERMIT NO: 95OPWE020
REPORTING PERIOD: (see first page of the permit for specific reporting period and dates)
Operating
Permit Unit
ID
Unit Description
Deviations noted
During Period?1
Deviation Code 2
Malfunction/Emergency
Condition Reported
During Period?
YES
NO
YES
NO
C-148
Waukesha Model L-7042 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,478 HP
C-135
Waukesha Model L-7042 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,478 HP
C-151
Waukesha Model L-7042 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,478 HP
C-166
Waukesha Model L-7044 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,680 HP
C-174
Waukesha Model L-7044 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,680 HP
C-176
Waukesha Model L-7044 GSI Turbocharged Natural Gas
Fired Internal Combustion Reciprocating Engine, 4-
Cycle, Standard Rich Burn w/ AFR Controller, Site
Rated at 1,680 HP
P-112
Triethylene Glycol Dehydration Unit, Rated at 45
MMSCFD, 6.25 gpm TEG recirculation rate
P-113
Triethylene Glycol Dehydration Unit, Rated at 55
MMSCFD, 8.2 gpm TEG recirculation rate
General
Conditions
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 11
Operating
Permit Unit
ID
Unit Description
Deviations noted
During Period?1
Deviation Code 2
Malfunction/Emergency
Condition Reported
During Period?
YES
NO
YES
NO
Insignificant
Activities
' See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall
be based on a reasonable inquiry using readily available information.
2 Use the following entries, as appropriate
1= Standard:
2 = Process:
3 = Monitor:
4 = Test:
5 = Maintenance:
6 = Record:
7 = Report:
8=CAM:
9 = Other:
When the requirement is an emission limit or standard
When the requirement is a production/process limit
When the requirement is monitoring
When the requirement is testing
When required maintenance is not performed
When the requirement is recordkeeping
When the requirement is reporting
A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the
Compliance Assurance Monitoring (CAM) Rule) has occurred.
When the deviation is not covered by any of the above categories
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
APPENDIX B: Monitoring and Permit Deviation Report - Part II
FACILITY NAME: DCP Operating Company, LP - Marla Compressor Station
OPERATING PERMIT NO: 95OPWE020
REPORTING PERIOD:
Appendix B
Page 12
Is the deviation being claimed as an: Emergency Malfunction N/A
(For NSPS/MACT) Did the deviation occur during: Startup Shutdown
Normal Operation
OPERATING PERMIT UNIT IDENTIFICATION:
Operating Permit Condition Number Citation
Explanation of Period of Deviation
Duration (start/stop date & time)
Action Taken to Correct the Problem
Measures Taken to Prevent a Reoccurrence of the Problem
Dates of Malfunctions/Emergencies Reported (if applicable)
Deviation Code Division Code QA:
SEE EXAMPLE ON THE NEXT PAGE
Malfunction
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
EXAMPLE
FACILITY NAME: Acme Corp.
OPERATING PERMIT NO: 96OPZZXXX
REPORTING PERIOD: 1/1/04 - 6/30/06
Is the deviation being claimed as an:
(For NSPS/MACT) Did the deviation occur during:
OPERATING PERMIT UNIT IDENTIFICATION:
Emergency
Appendix B
Page 13
Malfunction XX N/A
Startup Shutdown Malfunction
Normal Operation
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)
5/30/06 to A. Einstein, APCD
Deviation Code
Division Code QA:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Monitoring and Permit Deviation Report
Appendix B
Page 14
APPENDIX B: Monitoring and Permit Deviation Report - Part III
REPORT CERTIFICATION
SOURCE NAME: DCP Operating Company, LP - Marla Compressor Station
FACILITY IDENTIFICATION NUMBER: 123-0243
PERMIT NUMBER: 95OPWE020
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 25-7122.1,
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 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 15
APPENDIX C
Required Format for Annual Compliance Certification Reports
ver. 8/20/14 w/ codes
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 - Marla Compressor Station
OPERATING PERMIT NO: 95OPWE020
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
Permit Unit
ID
Unit Description
Deviations
Reported I
ng
1 eg
M thod p
Permit?'
Was compliance continuous or
intermittent?3
Previous
Current
YES
NO
Continuous
Intermittent
C-148
Waukesha Model L-7042 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,478 HP
C-135
Waukesha Model L-7042 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,478 HP
C-151
Waukesha Model L-7042 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,478 HP
C-166
Waukesha Model L-7044 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,680 HP
C-174
Waukesha Model L-7044 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,680 HP
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 16
Operating
p g
Permit Unit
ID
Unit Description
Deviations
Reported I
Monitoring
Method per
Permit?2
Was compliance continuous or
intermittent? 3
Previous
Current
YES
NO
Continuous
Intermittent
C-176
Waukesha Model L-7044 GSI Turbocharged
Natural Gas Fired Internal Combustion
Reciprocating Engine, 4 -Cycle, Standard Rich
Burn w/ AFR Controller, Site Rated at 1,680 HP
P-112
Triethylene Glycol Dehydration Unit, Rated at
45 MMSCFD, 6.25 gpm TEG recirculation rate
P-113
Triethylene Glycol Dehydration Unit, Rated at
55 MMSCFD, 8.2 gpm TEG recirculation rate
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.
2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the
permit. If it was not, mark "no" and attach additional information/explanation.
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.
4 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
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Certification Report
Appendix C
Page 17
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Notification Addresses
Appendix D
Page 18
APPENDIX D
Notification Addresses
ver. 2/5/14
1. Air Pollution Control Division
Colorado Department of Public Health and Environment
Air Pollution Control Division
Operating Permits Unit
APCD-SS-B 1
4300 Cherry Creek Drive S.
Denver, CO 80246-1530
ATTN: Matt Burgett
2. United States Environmental Protection Agency
Compliance Notifications:
Office of Enforcement, Compliance and Environmental Justice
Mail Code 8ENF-AT
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
502(b)(10) Changes, Off Permit Changes:
Office of Partnerships and Regulatory Assistance
Mail Code 8P -AR
U.S. Environmental Protection Agency, Region VIII
1595 Wynkoop Street
Denver, CO 80202-1129
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 19
APPENDIX E
Permit Acronyms
Listed Alphabetically:
AIRS - Aerometric Information Retrieval System
AP -42 - EPA Document Compiling Air Pollutant Emission Factors
APEN - Air Pollution Emission Notice (State of Colorado)
APCD - Air Pollution Control Division (State of Colorado)
ASTM - American Society for Testing and Materials
BACT - Best Available Control Technology
BTU - British Thermal Unit
CAA - Clean Air Act (CAAA = Clean Air Act Amendments)
CCR - Colorado Code of Regulations
CEM - Continuous Emissions Monitor
CF - Cubic Feet (SCF = Standard Cubic Feet)
CFR - Code of Federal Regulations
CO - Carbon Monoxide
COM - Continuous Opacity Monitor
CRS - Colorado Revised Statute
EF - Emission Factor
EPA - Environmental Protection Agency
FI - Fuel Input Rate in MMBtu/hr
FR - Federal Register
G - Grams
Gal - Gallon
GPM - Gallons per Minute
HAP - Hazardous Air Pollutants
HP - Horsepower
HP -HR - Horsepower Hour (G/HP-HR = Grams per Horsepower Hour)
LAER - Lowest Achievable Emission Rate
LBS - Pounds
M - Thousand
MM - Million
MMscf - Million Standard Cubic Feet
MMscfd - Million Standard Cubic Feet per Day
N/A or NA - Not Applicable
NOx - Nitrogen Oxides
NESHAP - National Emission Standards for Hazardous Air Pollutants
NSPS - New Source Performance Standards
P-
PE -
PM -
PMio -
Process Weight Rate in Tons/Hr
Particulate Emissions
Particulate Matter
Particulate Matter Under 10 Microns
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Acronyms
Appendix E
Page 20
PSD -
PTE -
RACT -
SCC -
SCF -
SIC -
SO2-
TPY -
TSP -
VOC-
Prevention of Significant Deterioration
Potential To Emit
Reasonably Available Control Technology
Source Classification Code
Standard Cubic Feet
Standard Industrial Classification
Sulfur Dioxide
Tons Per Year
Total Suspended Particulate
Volatile Organic Compounds
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Permit Modifications
Appendix F
Page 21
APPENDIX F
Permit Modifications
DATE OF
REVISION
SECTION NUMBER,
CONDITION NUMBER
DESCRIPTION OF REVISION
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Assurance Monitoring Plan - Engines
Appendix G
Page 22
APPENDIX G
Compliance Assurance Monitoring Plan - Engines
I. Background
a. Emission Unit Description:
AIRS ID 052 (C-148) — Waukesha L-7042 GSI Compressor RICE (1,478 HP) for NOx and CO
AIRS ID 053 (C-135) — Waukesha L-7042 GSI Compressor RICE (1,478 HP) for NOx and CO
AIRS ID 054 (C-151) — Waukesha L-7042 GSI Compressor RICE (1,478 HP) for NOx and CO
AIRS ID 059 (C-166) — Waukesha L-7044 GSI Compressor RICE (1,680 HP) for NOx and CO
AIRS ID 060 (C-174) — Waukesha L-7044 GSI Compressor RICE (1,680 HP) for NOx and CO
AIRS ID 061 (C-176) — Waukesha L-7044 GSI Compressor RICE (1,680 HP) for NOx and CO
b. Applicable Regulation, Emission Limit, Monitoring Requirements:
Engines C-148 & C-135:
Regulations:
Emission Limitations:
Monitoring Requirements:
Engine C-151:
Regulations:
Emission Limitations:
Monitoring Requirements:
Engine C-166:
Regulations:
Emission Limitations:
Operating Permit Condition 1.1
NOx 28.5 tons/year
CO 42.8 tons/year
Catalyst inlet temperature
Catalyst differential pressure
Operating Permit Condition 1.1
NOx 14.3 tons/year
CO 28.5 tons/year
Catalyst inlet temperature
Catalyst differential pressure
Operating Permit Condition 1.1
NOx 32.5 tons/year
CO 32.5 tons/year
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Assurance Monitoring Plan - Engines
Appendix G
Page 23
Monitoring Requirements:
Engine C-174:
Regulations:
Emission Limitations:
Monitoring Requirements:
Engine C-1 76:
Regulations:
Emission Limitations:
Monitoring Requirements:
c. Control Technology:
Catalyst inlet temperature
Catalyst differential pressure
Operating Permit Condition 1.1
NOx 16.2 tons/year
CO 32.5 tons/year
Catalyst inlet temperature
Catalyst differential pressure
Operating Permit Condition 1.1
NOx 32.5 tons/year
CO 32.5 tons/year
Catalyst inlet temperature
Catalyst differential pressure
Non -Selective Catalytic Reduction (NSCR)
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Compliance Assurance Monitoring Plan - Engines
Appendix G
Page 24
II. Monitoring Approach
Indicator No. 1
Indicator No. 2
I. Indicator
Catalyst Inlet Temperature
Catalyst Pressure Drop
Measurement Approach
The temperature of the exhaust gas into the
catalyst will be measured using an in -line
thermocouple installed prior to the catalyst.
The pressure drop across the catalyst shall be
measured locally with differential pressure
transmitters installed on either side of the
catalyst.
II. Indicator Range
Excursions, for the purposes of reporting, are
defined as an inlet catalyst temperature that is
less than 750°F or greater than 1250°F.
Excursions above 1250° F trigger engine
shutdown. Excursions below 750° F trigger
notification of excursion. Excursions trigger the
permittee to investigate the engine performance
and make any repairs or adjustments necessary.
Any high -temperature shutdowns, adjustments
or repairs shall be recorded in a log, to be made
available to the Division upon request.
Excursions, for the purposes of reporting, are
defined as a catalyst pressure drop deviating
more than three inches of water column from
the baseline pressure drop measured during the
initial performance test (or deviating more than
three inches from the manufacturer's specified
range if the baseline differential pressure was
not determined during the initial performance
test).
Excursions trigger the permittee to investigate
the catalyst 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.
Pressure drop is measured across the catalyst
while the engine is operating.
b. Verification of Operational
Status
Thermocouple manufacturer guarantee.
Manometer manufacturer guarantee.
c. QA/QC Practices/Criteria
Proper thermocouple operation shall be verified
annually. Thermocouples shall be replaced if
proper operation cannot be verified as
expeditiously as practicable. The results of this
verification and any replacements made shall be
maintained in a log to be made available to the
Division upon request.
Manometer shall be calibrated, maintained and
replaced per manufacturer recommendations.
d. Monitoring Frequency
Continuously.
Monthly.
f. Data Collection Procedures
The catalyst inlet temperature is automatically
recorded in the Distributed Control System
(DCS). The catalyst inlet temperature shall be
manually or automatically recorded daily,
provided the engine is operating, in a log to be
made available to the Division upon request.
Pressure drop shall be manually recorded
monthly in a log to be made available to the
Division upon request..
e. Averaging Time
None.
None.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix H
Page 25
APPENDIX H
Compliance Assurance Monitoring Plan - Dehydrators
I. Background
a. Emission Unit Description:
AIRS ID 062 (P-112) — TEG Dehydration Unit (45 MMSCFD) for VOC and HAP
AIRS ID 063 (P-113) — TEG Dehydration Unit (55 MMSCFD) for VOC and HAP
b. Applicable Regulation, Emission Limit, Monitoring Requirements:
TEG Dehydration Unit (P-112):
Regulations:
Emission Limitations:
Operating Permit Conditions 2.1, 3.1
VOC 10.6 tons/year
HAP 8 tons/year individual, 20 tons/year total (Facility -Wide)
TEG Dehydration Unit (P-113):
Regulations:
Emission Limitations:
c. Control Technology:
Operating Permit Conditions 2.1, 3.1
VOC 14.3 tons/year
HAP 8 tons/year individual, 20 tons/year total (Facility -Wide)
Enclosed Combustion Device (ECD)
Still vent emissions are routed to the enclosed combustion device (ECD) with a DRE of 95%. This
ECD is permitted 3% annual downtime for maintenance and malfunctions, during which time the
dehydration units' still vents are routed uncombusted to atmosphere.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix H
Page 26
II. Monitoring Approach
Indicator No. 1
I. Indicator
Pilot Flame Presence
Measurement Approach
Presence of a flame is continuously monitored with thermocouple or equivalent
temperature sensing device.
This enclosed combustion device is permitted 3% annual downtime, during which the
presence of a flame is not required.
II. Indicator Range
Excursions, for the purposes of reporting, are defined as any absence of a pilot flame,
except during periods of permitted downtime.
Excursions will trigger an investigation to determine the problem and corrective
action shall be performed as necessary. Periods of pilot flame outage and any
adjustments or repairs made in response shall be recorded in a log to be made
available to the Division upon request.
III. Performance Criteria
a. Data Representativeness
A thermocouple or equivalent heat sensing device will determine the presence or
absence of the flame.
b. Verification of
Operational Status
Visual observations of the pilot flame will be conducted daily to verify the indication
from the thermocouple or equivalent heat sensing device.
c. QA/QC
Practices/Criteria
Proper thermocouple operation shall be verified annually. Thermocouples shall be
replaced if proper operation cannot be verified as expeditiously as practicable. The
results of this verification and any replacements made shall be maintained in a log to
be made available to the Division upon request.
d. Monitoring Frequency
Continuously.
f. Data Collection
Procedures
The presence of the pilot light shall be monitored continuously using a thermocouple
or equivalent heat sensing device. Pilot light status, including all instances of pilot
light absence and the duration of each absence, except during periods of permitted
downtime, shall be recorded daily in a log to be made available to the Division upon
request.
e. Averaging Time
N/A.
III. Justification
a. Background:
The pollutant specific emission units are two TEG dehydration units, P-112 and P-113, which
function to remove water from the facility natural gas prior to pipeline discharge. Flash tank
emissions are routed through a vapor recovery unit (VRU) and returned to the plant inlet. Still vent
emissions are routed to a shared enclosed combustion device (ECD). This CAM plan applies to
the operation of the ECD.
b. Rationale for Selection of Performance Indicators and Indicator Ranges:
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix H
Page 27
The enclosed combustion device (ECD) has a manufacturer's guaranteed VOC destruction,
efficiencyof 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 ECD must have a pilot light that is continuously lit to ensure the
still vent vapors from the TEG dehydration units 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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 28
APPENDIX I
Applicability Reports
ver 10/12/12 (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.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-reporting-forms
DISCLAIMER:
These are only example reports and do not cover all possible requirements.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 29
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 30
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
H 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.
n Does apply to this engine and applicable emissions controls have been installed.
Regulation No. 7, § XVILE
n 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.
n Does apply to this engine. The following emission limits apply to the engine:
NOx (g/hp-hr):
CO (g/hp-hr):
VOC (g/hp-hr):
2.0
4.0
1.0
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 31
Max Engine
HP
Construction or
Relocation Date
Emission Standards in g/hp-hr
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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 32
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.I.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.
❑ 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 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 33
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
(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.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
Engine AOS Applicability Reports
Appendix I
Page 34
(b)
Performance tests may not be conducted during periods of startup, shutdown, or
malfunction, as specified in 60.8(c). If the engine is non -operational when a performance
test is due, the engine does not need to be started up just to test it, but will need to be
tested immediately upon startup.
(c) Three separate test runs must be conducted for each performance test as specified by
60.8(f). Each run must be within 10% of max load and be at least 1 hour in duration.
(d)
To determine compliance with the NOR, CO, and VOC mass per unit output emission
limitations, the measured concentration must be converted using the equations outlined in
this section of NSPS JJJJ.
60.4245 Notification, Reports, and Records for Owners and Operators
(a) Owners of all stationary SI ICE must keep records of the following:
(1) All notifications submitted to comply with this subpart;
(2) Maintenance conducted on the engine;
(3) N/A - Manufacturer information for certified engines, and
(4) Documentation that shows non -certified engines are in compliance with the emission
standards.
(b) N/A — For emergency engines only.
(c) Owners of non -certified engines > 500HP must submit an initial notification as required
in 60.7(a)(1) which includes the following information:
(1) Name and address of the owner or operator;
(2) The address of the affected source;
(3) Engine information including make, model, engine family, serial number, model
year, maximum engine power, and engine displacement;
(4) Emission control equipment; and
(5) Fuel used.
CONCLUSION OF FINDINGS (EXAMPLE ONLY)
In general, Acme's 1,235HP, Waukesha 7042 GSI engine is subject to the emissions limitations summarized in
Table 1 of NSPS JJJJ. ACME will meet these emission limitations using an AFRC and a non -selective catalytic
converter (NSCR). These emission rates will be met throughout the 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 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix I
Page 35
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?
(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
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix I
Page 36
(a)
The engine is subject to the emission limits in table la and the operating limits in table
1 b. 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%
(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.
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix I
Page 37
(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)
(b)
63.6645 Notifications
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).
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.
(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.
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix I
Page 38
(d) thru (f) 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.
(f) Applicable. Compliance reports are submitted with title v reports. Compliance reports
under Subpart ZZZZ include all necessary info for title v deviation report with respect to
Subpart ZZZZ requirements.
(g) Not applicable. Acme engine not firing landfill or digester gas.
63.6655 Recordkeeping
(a) Retain records as follows: copy of each notification and report (including all
documentation supporting any initial notification or notification of compliance status),
records in 63.6(e)(iii) thru (v) related to SSM, and records of performance tests and
evaluations.
(b) CPMS records including records in 63.10(b)(2)(vi) thru (xi), previous versions of the
performance evaluation plan required by 63.8(d)(3) and requests for alternatives to the
relative accuracy test for CPMS as required by 63.8(f)(6)(i).
(c) Not applicable. Acme engine not firing landfill or digester gas.
(d) Will keep records required in Table 6 (monthly pressure drop readings, 4 -hr averages of
catalyst inlet temperature) to show continuous compliance with emission and operating
limits.
63.6660 Form and length of records
(a) Records must be in a form suitable and readily available for expeditions review.
(b) Records must be retained for five years.
(c) Records must be retained on -site for first 2 years, may be retained off -site for the
remaining 3 years.
63.6665 General Provisions
Operating Permit 95OPWE020 First Issued: June 1, 1999
Renewed:
Air Pollution Control Division
Colorado Operating Permit
AOS Applicability Reports
Appendix I
Page 39
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 report
Operating Permit 95OPWE020
First Issued: June 1, 1999
Renewed:
TECHNICAL REVIEW DOCUMENT
For
RENEWAL OF OPERATING PERMIT 95OPWE020
DCP Operating Company, LP - Marla Compressor Station
Weld County
Source ID 123-0243
January 2018 —
Operating Permit Engineer:
Operating Permit Supervisor review:
Field Services Unit review:
PURPOSE
Elie Schuchardt
Blue Parish
Rebecca Wilson
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 Marla Compressor Station. The
previous Operating Permit for this facility was issued on 6/1/1999, was renewed on
1/1/2013 and expired on 1/1/2018. 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.
Prior to submittal of the renewal application, the source submitted the following
modification applications:
• Minor Modification (rec'd 10/11/2017) — Request to permit 3% downtime for
individual condensers and shared enclosed combustion device (ECD)
controlling TEG dehydration units P-112 and P-113, increase inlet gas
throughput to P-113, increase condenser maximum temperature from 140°F to
160°F, and update applicable MACT HH requirements. This modification results
in an overall increase in VOC emissions at the facility.
• Minor Modification (rec'd 6/27/2018) — Request to increase fuel consumption
limitations based on a lower fuel heat content for all engines, and updated the
emission limitations and emission factors of engine C-174. This alteration results
in an overall decrease in NOx and VOC emissions for engine C-174, and no
change in all other engine emissions.
• Significant Modification (rec'd 7/23/2018) — Request to remove condensers as
control devices for TEG dehydration units P-112 and P-113. Inclusion of a
compliance schedule to return engine C-176 to compliance with NSPS JJJJ.
• Minor Modification (rec'd 3/22/2019) — Request to reduce the NOx emission
limitation for engine C-148, pursuant to an alternative operating scenario (AOS)
executed in February 2019.
123/0243 Page 1 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
The significant modifications must be processed as required by Colorado Regulation
No. 3, Part C, Section I.A.7.c. A significant modification is processed under the same
procedures as a renewal, i.e. it must go through a 30 -day public comment period and
EPA 45 -day review period. Therefore, since the renewal application has been submitted
the Division is incorporating the modification with the renewal. Each of these
modifications is summarized in Section VI of this document.
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 12/28/2016,
comments on the draft permit submitted on 4/10/2019, 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 https://www.colorado.gov/cdphe/title-v-operating-permits. 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
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 Marla Compressor Station uses six (6) natural gas -fired internal combustion
engines (AIRS 052, 053, 054, 059, 060, 061) to drive compressors to transmit natural
gas gathered from gas field laterals to a primary pipeline. These engines are controlled
through non -selective catalytic reduction (NSCR).
The station also includes two (2) triethylene glycol (TEG) dehydration units (AIRS 062,
063) that contact "dry" triethylene glycol with the natural gas stream to remove moisture
prior to entering the primary pipeline. The "wet" glycol mixture is regenerated in a still
for reuse in the process. Each dehydration unit's flash tank vapors are captured by a
vapor recovery unit (VRU) and routed back to the facility inlet. These units are equipped
with an enclosed combustion device for still vent control. Regenerator still vent
emissions are routed through the condenser prior to being destructed in the enclosed
combustion device. It should be noted that no emission control from the condensers is
claimed for either dehydration unit. Liquids from the dehydration units are routed to the
pressurized slug catchers.
Emission control devices include: six (6) NSCR beds to control compressor engine
exhaust emissions and one (1) enclosed combustion device (ECD) to control post -
condenser still vent emissions from both dehydration units. Flash tank emissions from
123/0243 Page 2 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
each dehydration unit are recompressed with one (1) vapor recovery unit (VRU) and
routed back to the facility inlet.
The plant is located west of the intersection of Weld County Road (WCR) 55 and WCR
40 on the north side of WCR 40, approximately 13 miles southeast of Greeley. This
facility is located in an Area classified as attainment for all pollutants except ozone. It is
classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as
defined in Regulation No. 7, Section II.A.1.
Wyoming is an affected state within 50 miles of the Station. Rocky Mountain National
Park is a Federal Class I designated area within 100 kilometers of the Station.
This facility is categorized as a NANSR major stationary source (Potential to Emit of
VOC or NOx ≥ 100 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 ≥ 100 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:
AIRS ID
Facility ID
Source
Controlled Emissions (tons/year)
NOx
CO
VOC
Reportable
HAP
052
C-148
1,478 HP Compressor Engine
28.54
42.82
14.27
0.46
053
C-135
1,478 HP Compressor Engine
28.54
42.82
14.27
0.46
054
C-151
1,478 HP Compressor Engine
14.27
28.54
9.99
0.46
059
C-166
1,680 HP Compressor Engine
32.45
32.45
16.22
0.53
060
C-174
1,680 HP Compressor Engine
16.22
32.45
11.36
0.53
061
C-176
1,680 HP Compressor Engine
32.45
32.45
16.22
0.53
062
P-112
45 MMSCFD TEG Dehydration Unit
--
--
10.62
6.31
063
P-113
55 MMSCFD TEG Dehydration Unit
--
--
14.26
8.29
Total Permitted Facility Emissions (tons/year)
152.47
211.53
107.21
17.58
2017 Actual Facility Emissions (tons/year)
167.88
193.74
82.96
3.45
It should be noted that NOx emissions for 2017 were higher than the current permitted
facility total. This is a result from the minor modification submitted on 6/27/2018, which
requested a decrease in permitted NOx emissions from engine C-174. Because these
actual emissions are from the 2017 data year and the minor modification to decrease
NOx emissions was not accepted by the Division until 2018, actual 2017 NOx emissions
are greater than the current permitted facility total.
III. APPLICABLE REQUIREMENTS
123/0243
Page 3 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
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, this facility 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 052 (C-148) — Compressor RICE (1,478 hp) for NOx and CO
AIRS ID 053 (C-135) — Compressor RICE (1,478 hp) for NOx and CO
AIRS ID 054 (C-151) — Compressor RICE (1,478 hp) for NOx and CO
AIRS ID 059 (C-166) — Compressor RICE (1,680 hp) for NOx and CO
AIRS ID 060 (C-174) — Compressor RICE (1,680 hp) for NOx and CO
AIRS ID 061 (C-176) — Compressor RICE (1,680 hp) for NOx and CO
AIRS ID 062 (P-112) — TEG Dehydration Unit (45 MMSCFD) for VOC and HAP
AIRS ID 063 (P-113) — TEG Dehydration Unit (55 MMSCFD) for VOC and HAP
The Marla Compressor Station is a synthetic minor source for HAP and is subject to
facility -wide HAP limits. It has been determined that a facility -wide limit (as opposed to
a point -specific limit) does not preclude an emissions unit from CAM, since it is
theoretically possible for that single unit to emit HAP in excess of the major source
thresholds for HAP. As such, pollutant -specific emissions units with pre -control
emissions of HAP that exceed major source thresholds are considered to be subject to
CAM.
The emissions from each of the dehydration units' flash tanks are recompressed with a
vapor recovery unit and routed back to the process inlet. This method of controlling
emissions is not subject to the requirements of CAM. Pursuant to the CAM preamble
(62 FR 54902, October 22, 1997) CAM requirements are intended "to establish
monitoring for the purpose of (1) Documenting continued operation of the control
measures within ranges of specified indicators of performance (such as emissions,
control device parameters and process parameters) that are designed to provide a
reasonable assurance of compliance with applicable requirements; (2) indicating any
123/0243 Page 4 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
excursions from these ranges; and (3) responding to the data so that excursions are
corrected." VRUs are different than other typical control devices in that they do not have
indicators of performance that can be identified and monitored. There are no
parameters with identifiable setpoints or operational ranges that indicate proper
performance. The unit is either in operation (and thus removing all VOC and HAP
emissions directed to it), or it is not in operation due to maintenance, malfunction, etc.
Therefore, no CAM requirements for monitoring indicators and identification of
excursions are included for emission units using a VRU as a control device. Because
the VRU controlling the flash tank emissions is not subject to CAM, the flash tank
emissions were deducted from the uncontrolled emissions totals for the dehydration
units P-112 and P-113. After this deduction, the remaining uncontrolled emissions from
each still vent are in excess of the major source threshold of 100 tons/year VOC, 10
tons/year individual HAP and 25 tons/year total HAP. As a result, each dehydration unit
is subject to CAM for VOC and HAP emissions.
Hazardous Air Pollutants (HAPs)
The Marla Compressor Station is a synthetic minor source of HAP emissions. In order
to maintain its area source designation for the various applicable MACTs, synthetic
minor HAP limits of 8 tons/year individual HAP and 20 tons/year total HAP were included
in this operating permit. These lower limits (i.e., less than the major source threshold of
10 tons/year individual HAP and 25 tons/year total HAP) are Division -standard
limitations that are assumed to leave sufficient buffer to accommodate insignificant
activities. As such, a source subject to these limitations does not have to track
insignificant activity HAP emissions since it is presumed that if the permitted points are
in compliance with the 8/20 limitations, the insignificant activity HAP emissions should
not trigger major source requirements. Once a source's controlled potential to emit
exceeds these 8/20 limitations, insignificant activity tracking is required. The Marla
Compressor Station has a controlled potential to emit below the 8/20 limitations. As
such, this facility does not have to track insignificant activities for the purposes of HAP
limitation compliance. It should be noted, however, that emissions from some
insignificant activities are required to be tracked under the provisions of Colorado
Regulation No. 3, Part C, Section II.E. These activities were clearly denoted as such in
Appendix A of the operating permit.
A summary of the permitted facility HAP emissions is as follows:
Pollutant
Uncontrolled Emissions
Controlled Emissions
Actual Emissions
tons/year
tons/year
tons/year
Acetaldehyde
0.91
0.45
0.41
Acrolein
0.86
0.43
0.21
Methanol
1.00
0.50
0.46
Formaldehyde
6.67
1.60
1.47
n -Hexane
12.91
0.37
0.06
Benzene
50.24
3.73
0.45
Toluene
77.17
5.84
0.30
Ethylbenzene
4.18
0.32
0.01
123/0243 Page 5 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
Xylenes
56.06
4.34
0.07
Facility Total
210.00
17.58
3.45
For a more detailed discussion on the HAP limitations incorporated into this operating
permit, refer to the Condition 3 discussion in Section V of this document.
Source Determination
With this permit action, the Division revisited the source determination in regards to the
natural gas operations in the area surrounding the Maria Compressor Station to verify
that the proper pollutant emitting activities are included in this permit as part of this
facility. The applicant did not identify any other pollutant emitting activities in the vicinity
of the Marla Compressor Station on that are dependent upon this facility to maintain
operations. The Division considers the current determination for this facility to be
accurate, and the proper pollutant emitting activities are included in this permit.
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 Marla 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
e quipment (as defined in this section)) and emissions from any pipeline
compressor station or pump station shall not be aggregated with emissions from
o ther 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 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
e quipment is physically affixed." Pursuant to this clarification, only emissions
points from the Marla 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 Marla Compressor Station.
123/0243 Page 6 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
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 Marla 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 Marla 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 Marla 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 Marla Compressor Station does not
have any combustion turbines on -site. The condensate accumulated at the Marla
Compressor Station comes from high pressure sources (i.e., the slug catcher
and any compressor knock -out pots). To accommodate flashing from the higher
pressure of the slug catcher and knock -out pots, all condensate storage at the
Marla Compressor Station is accomplished via pressurized bullets, the vents of
which are entirely closed and therefore do not emit to atmosphere (i.e., bullets
are not designed to emit any contents to atmosphere under any normal operating
condition and therefore do not have the potential for emissions, flashing or
otherwise). As such, although these tanks do have flashing condensate, there
are no emissions associated with these storage tanks. Therefore, for the
purposes of major source determination, only emissions from the glycol
dehydration units and reciprocating internal combustion engines were
aggregated 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 Marla Compressor Station, as it is not a part of the
transmission segment.
123/0243 Page 7 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
Pursuant to the definition of major source set forth in §62.3, the HAP emissions from
this facility, when considering only the glycol dehydration units and reciprocating internal
combustion engines, are below the major source thresholds of 10 tons/year individual
and 25 tons/year total HAP. Therefore, for the purposes of Subpart ZZZZ, the Maria
Compressor Station is considered to be an area source of HAP emissions.
Section 63.6590(c)(1) of Subpart ZZZZ requires that new or reconstructed stationary
RICE located at an area source meet the requirements of Subpart 777Z by meeting the
requirements of NSPS JJJJ for spark ignition engines. For the purposes of subpart
ZZZZ, a stationary RICE located at an area source of HAP is considered new if
construction is commenced after 6/12/2006 (§63.6590(a)(2)(iii)). The following table
summarizes the commenced construction date reported on the most recent APENs
submitted on 6/27/2018 and source comments received 5/6/2019:
AIRS ID
Facility
Identifier
Date of Commenced
Construction
40 CFR 63 Subpart ZZZZ
Classification
052
C-148
1973
Existing
053
C-135
After 6/22/1992
Existing
054
C-151
Before 2001
Existing
059
C-166
Before 1/2002
Existing
060
C-174
2010
New
061
C-176
3/2008
New
Based on this data, C-174 (AIRS 060) and C-176 (AIRS 061) are classified as "new"
engines under Subpart Z777. Pursuant to the subpart, these engines shall meet the
requirements of Subpart ZZZZ by complying with NSPS JJJJ, and are not subject to
any other requirements under Subpart ZZZZ.
Under Subpart ZZZZ, a source is subject to work practice requirements if it is classified
as a "remote stationary RICE". To be considered a "remote stationary RICE", the facility
must currently meet any one of the three listed criteria in §63.6675, and, pursuant to
§63.6603(f), have met that same criteria on the initial compliance date for those engines
(10/19/2013). The Marla Compressor Station was found to meet the second criteria,
which states:
A pipeline segment with 10 or fewer buildings intended for human occupancy and no
buildings with four or more stories within 220 yards (200 meters) on either side of the
centerline of any continuous 1 -mile (1.6 kilometers) length of pipeline. Each separate
dwelling unit in a multiple dwelling unit building is counted as a separate building
intended for human occupancy, AND
The pipeline segment does not lie within 100 yards (91 meters) of either a building or a
small, well-defined outside area (such as a playground, recreation area, outdoor
theater, or other place of public assembly) that is occupied by 20 or more persons on at
least 5 days a week for 10 weeks in any 12 -month period. The days and weeks need
not be consecutive. The building or area is considered occupied for a full day if it is
occupied for any portion of the day.
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
A "pipeline segment" is defined in §63.6675 as "all parts of those physical facilities
through which gas moves in transportation, including but not limited to pipe, valves, and
other appurtenance attached to pipe, compressor units, metering stations, regulator
stations, delivery stations, holders, and fabricated assemblies". A compressor station
could, therefore, be interpreted to be part of a pipeline segment. At the time of permit
issuance, the Marla Compressor Station meets the above criteria, and, pursuant to
DCP's annual remote status report prepared under the provisions of §63.6603(f), met
the remote definition by the initial compliance date. Therefore, the existing engines at
the Marla Compressor Station can therefore be classified remote engines for the
purposes of Subpart ZZZZ.
In summary, each compressor engine at the Marla Compressor Station is classified as
an existing, remote engine at an area source of HAP for the purposes of Subpart ZZZZ
EXCEPT for C-174 and C-176 which, as new engines, must comply with the applicable
requirements of NSPS JJJJ. For more detailed applicability determinations,
requirements and/or exemptions for these engines, please refer to Section V 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 Marla Compressor Station, this subpart
applies to the dehydration units.
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:
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 Marla Compressor Station surface
site were aggregated for the purposes of major source determination.
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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 Marla 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 Marla 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 Marla Compressor Station is subsequently routed to the
Roggen Natural Gas Processing Plant. Pursuant to the definition of custody
transfer, the Marla Compressor Station is located upstream of the point of
custody transfer. The condensate accumulated at the Marla Compressor Station
comes from high pressure sources (i.e., the slug catcher and any compressor
knock -out pots). To accommodate flashing from the higher pressure of the slug
catcher and knock -out pots, all condensate storage at the Marla Compressor
Station is accomplished via pressurized bullets, the vents of which are entirely
closed and therefore do not emit to atmosphere (i.e., bullets are not designed to
emit any contents to atmosphere under any normal operating condition and
therefore do not have the potential for emissions). As such, there are no
emissions associated with these storage tanks. Therefore, for the purposes of
major source determination, only emissions from the glycol dehydration units
were aggregated 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 the glycol dehydration units combined are below the
major source thresholds of 10 tons/year individual and 25 tons/year total HAP.
Therefore, for the purposes of subpart HH, the Marla 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
these TEG dehydration units, please refer to Section V of this document.
40 CFR Part 60 Subpart JJJJ NSPS - Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines
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Technical Review Document — Renewal Operating Permit
This section addresses the final version of Subpart JJJJ, last updated 8/30/2016. For
the purposes of the Marla Compressor Station, this subpart applies to compressor
engines C-174 and C-176.
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 commenced construction, the date of order and the date of manufacture, as
indicated by the most recent APENs submitted on 6/27/2018 and source comments
received 5/6/2019, are summarized in the table below:
AIRS
ID
Facility
Identifier
Date of Commenced
Construction
Date of Order
Date of
Manufacture
40 CFR 60 Subpart
JJJJ Applicability
052
C-148
1973
1973
1/23/1973
No
053
C-135
After 6/22/1992
Before 6/22/1992
6/22/1992
No
054
C-151
Before 2001
Before 2001
5/26/1972
No
059
C-166
Before 1/2002
Before 1/2002
8/21/2001
No
060
C-174
2010
2011
8/2010
Yes
061
C-176
3/2008
12/2007
3/27/2008
Yes
Pursuant to the dates listed in the table above, engines C-174 and C-176 only are
subject to the requirements of Subpart JJJJ. Additionally, it should be noted that under
the MACT ZZZZ requirements (see 40 CFR 63 Subpart ZZZZ discussion above),
engines C-174 and C-176 are classified as a "new" stationary RICE at an area source
of HAP and, under this MACT ZZZZ, must comply with NSPS JJJJ.
For more detailed applicability determinations, requirements and/or exemptions for this
engine, please refer to Section V of this document.
Colorado Regulation No. 7 Section XII — Volatile Organic Compound Emissions from
Oil and Gas Operations
This section addresses the final version of Colorado Regulation No. 7 Section XII, last
updated 1/14/2019. For the purposes of the Marla Compressor Station, this section
applies on a facility -wide basis since the station is classified as oil and gas operation
located within the ozone non -attainment area.
Requirements applicable to the Marla Compressor Station are as follows:
• Section XII.C.1 — General Requirements, including good engineering practice
requirements, and, for air pollution control equipment used to comply with
Section XII.J, requirements to meet a 95% control efficiency, no visible emissions
(if combustion device used) and to operate a combustion device (if used) with an
auto -igniter.
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o It should be noted that although Section XII.J.2 for reciprocating
compressors does not explicitly require the use of a control device to
achieve compliance, the applicability requirements Section XII.A.6
mandate that Section XII.C.1.c, d and e be complied with for reciprocating
compressors. As such, these requirements were included in the operating
permit.
• Section XII.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 XII.J.2 — Reciprocating compressor requirements, addressing periodic
rod packing replacements and rod packing emissions collection systems.
• Section XII.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 for the
affected operations, please refer to Section V of this document.
The following requirements from Section XII were found to be non -applicable to the
Marla Compressor Station pursuant to the provided justification:
• Section XII.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. The condensate storage tank at the Marla Compressor
Station is a pressurized vessel that is routed to a vapor recovery unit (VRU). If
the VRU is inoperable, pressure will build within the condensate storage tank
until it can overcome the pressure at the plant inlet. At this juncture, a pressure
regulating valve opens, allowing the condensate storage tank overhead vent to
flow into the lower pressure facility inlet. Since these are the only two routing
configurations for the condensate tank overhead emissions, and both routes
result in zero emissions, there are no uncontrolled actual emissions from the
condensate storage tank and this section is not applicable.
• Section XII.C.2 — This condition applies to condensate storage tanks subject to
Section XII.D. The condensate storage tank at the Marla Compressor Station are
not subject to Section XII.D (see below determination). As such, the
requirements of Section XII.C.2 does not apply to this facility.
• Section XII.D — This section applies to atmospheric condensate storage tanks at
affected operations. "Affected Operations" are defined in Section XII.B.1 as "oil
and gas exploration and production operations, natural gas compressor stations
and natural gas drip stations to which Section X11. applies". Although the Marla
Compressor Station is, under this definition, an "affected operation", the
condensate storage tanks at this facility are all pressurized bullet tanks in lieu of
atmospheric tanks. Because there are no atmospheric condensate storage tanks
at the Marla Compressor Station, Section XII.D does not apply to this facility.
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• Section XII.E — This section addresses monitoring for condensate tanks
operating in a non -attainment area that are "controlled pursuant to this Section
XII". The control requirements for condensate tanks in Section XII are contained
within Section XII.D, which is only applicable to atmospheric condensate storage
tanks. The Marla Compressor Station uses only pressurized bullet tanks for
condensate storage (see above). As such, the condensate tanks at the Marla
Compressor Station are not subject to XII.D and are therefore not being
"controlled pursuant to this Section XII". This facility is therefore not subject to
Section XII.E.
• Section XII.F — This section applies to "any atmospheric condensate storage tank
subject to control pursuant to Section XII.D.2.". The condensate tanks at the
Maria Compressor Station are not subject to XII.D (see discussion above) and
are therefore not subject to the requirements of XII.F.
• Section XII.G — This section applies to natural gas processing plants located in
the 8 -hour ozone control area. Although the Marla 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 (see the definition for
natural gas processing plants in Section XII.B.19). Therefore, this facility is not
subject to the requirements of XII.G.
• Section XII.I — These exemptions exclude certain natural gas compressor
stations and drip stations from the atmospheric storage tank requirements of
Section XII. The condensate storage tanks at the Marla Compressor Station are
pressurized bullet -style tanks. Because these tanks are not atmospheric, the
exemptions for atmospheric storage tanks set forth in Section XII.I do not apply.
• Section XII.K — This section sets forth requirements for natural gas driven
pneumatic pumps operating in the ozone non -attainment area. This section is
applicable only to natural gas processing plants (Section XII.K.1) and well
production facilities (Section XII.K.2). The Marla Compressor Station is
considered to be a natural gas compressor station for the purposes of Section
XII, as defined in Section XII.B.17. It is not considered to be a natural gas
processing plant, as defined in Section XII.B.19, because it does not engage in
the extraction of natural gas liquids. Additionally, this facility is not considered to
be a well production facility, as defined in Section XII.B.25, because it is not
directly associated with one or more gas wells. As such, Section XII.K does not
apply to this facility.
Colorado Regulation No. 7 Section XVI — 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 Section XVI, last
updated 1/14/2019. For the purposes of the Marla Compressor Station, this section
applies to stationary engines located within the ozone non -attainment area.
Requirements applicable to the Marla Compressor Station are as follows:
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Technical Review Document — Renewal Operating Permit
• Section XVI.B — Air pollution control technology requirements
o Section XVI.B applies to natural gas fired stationary internal combustion
engines operating in the 8 -Hour Ozone Control Area. All engines at the
Marla Compressor Station, which is located in the ozone non -attainment
area, are rated to greater than 500 hp. As such all engines are subject to
the applicable air pollution control technology requirements of this section.
• Section XVI.D — Combustion Process Adjustment requirements
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.
The Marla Compressor Station is a major source of NOx emissions, and
was designated as such prior to 6/3/2016. However, Section XVI.D.2
exempts natural gas fired reciprocating internal combustion engines
subject to emission control requirements set forth in Section XVI.B from
the emission limitation (Section XVI.D.4) and performance testing
(Section XVI.D.5) requirements, but not the combustion process
adjustments (Section XVI.D.6). Because all engines at the Marla
Compressor Station are subject to Section XVI.B (see above), these
engines are required to comply only with the combustion process
adjustment requirements and associated recordkeeping.
For more detailed applicability determinations, requirements and/or exemptions for the
affected operations, please refer to Section V of this document.
Colorado Regulation No. 7 Section XVII — Statewide Controls for Oil and Gas
Operations and Natural Gas -Fired Reciprocating Internal Combustion Engines
This section addresses the final version of Colorado Regulation No. 7 Section XVII, last
updated 1/14/2019. For the purposes of the Marla Compressor Station, this section
applies to oil and gas operations and RICE located within the state of Colorado.
Requirements applicable to the Marla Compressor Station are as follows:
• Section XVII.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
rod packing requirements.
• Section XVII.D — Dehydration Unit Requirements, addressing VOC and
hydrocarbon emission reductions.
• Section XVII.E — Natural Gas Fired RICE Requirements, addressing emissions
standards for NOx, CO and VOC, AFR and NSCR installation and good
engineering practices for air pollution control equipment.
• Section XVII.F — Leak Detection and Repair Program for compressor stations,
including approved instrument monitoring methods (AIMM), leak identification,
repair, remonitoring and recordkeeping requirements.
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For more detailed applicability determinations, requirements and/or exemptions for the
affected operations, please refer to Section V of this document.
The following requirements from Section XVII were found to be non -applicable to the
Marla Compressor Station pursuant to the provided justification:
o Section XVII.C — This section applies to condensate storage tanks. Pursuant to
Section XVII.A.16, a condensate storage tank is defined as "any fixed roof
storage vessel or series of storage vessels that are manifolded together via liquid
line. Storage vessel is as defined in 40 CFR Part 60, Subpart OOOO." The
definition of storage vessel in Subpart OOOO specifically exempts "pressure
vessels designed to operate in excess of 204.9 kilopascals (-30 psi) and without
emissions to the atmosphere." The condensate storage tanks at the Marla
Compressor Station are bullet -style tanks. The condensate stored is from high-
pressure sources, such as the inlet slug catcher and the compressor knockout
pots. Pursuant to source correspondence received on 6/26/2018, the high
pressure condensate is flashed to roughly 50 psig in these condensate storage
bullet tanks. Flash emissions are recompressed with a vapor recovery unit (VRU)
and routed back to the plant inlet. If the VRU goes down, the condensate storage
bullets are designed to accommodate the accumulating pressure from the inlet
pressurized condensate. Once this pressure accumulates to a point at which it
exceeds the station inlet pressure, a pressure regulating valve will open, directing
the pressurized gas back to the facility inlet. As such, these vessels are not
designed to vent to atmosphere. Because these storage vessels are designed to
operate in excess of 30 psi and do not vent to atmosphere, even during periods
of VRU downtime, the condensate storage vessels at the Marla Compressor
Station are not considered to be storage vessels for the purposes of NSPS
OOOO. As such, these vessels are not considered to be condensate storage
tanks for the purposes of Colorado Regulation No. 7, Section XVII, pursuant to
the NSPS OOOO reference. Therefore, the condensate storage tank
requirements of Section XVII.C do not apply to these vessels.
o Section XVI I.B.5 — This section allows for an exemption for dehydration units and
engines from complying with the Section XVII requirements, provided these units
"are subject to an emissions control requirement in a federal maximum
achievable control technology ("MA CT") standard under 40 CFR Part 63, a Best
Available Control Technology ("BA CT") limit, or a New Source Performance
Standard ("NSPS') under 40 CFR Part 60 are not subject to Section XVII., except
for the leak detection and repair requirements in Section XVII. F'. The natural gas
dehydration units are subject to 40 CFR 63 Subpart HH (MACT). However, as
an area source, these units are subject to area source 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 V
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 or the requirement to install and
operate a control device) for the purposes of the XVII.B.5 exemption. As such,
the dehydration units at the Marla Compressor Station are subject to the
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provisions of Section XVII. Similarly, the internal combustion engines at the Marla
Compressor Station, which are subject to 40 CFR 63 Subpart ZZZZ (MACT), are
only required to comply with the requirements for remote area sources under this
subpart. These requirements include only work practices. These practices are
not considered to be a qualifying "emissions control requirement". Therefore,
these engines must comply with the applicable requirements of Section XVII. It
should be noted, however, that engines C-174 and C-176, which are considered
new engines under Subpart ZZZZ must comply with NSPS JJJJ, pursuant to
Subpart ZZZZ (see the Subpart ZZZZ and JJJJ discussion above). NSPS
Subpart JJJJ does set forth numerical emissions limitations for NOx, CO and
VOC. These limitations are considered by the Division to be a sufficient
"emissions control requirement", and, as such, engines C-174 and C-176 only
are exempt from the requirements of Colorado Regulation No. 7 Section XVII.
Non -Applicable Regulations
Please note that the Marla 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 Marla
Compressor Station operates natural gas fired heaters as reboilers to provide sufficient
heat to regenerate the TEG from the dehydration unit. 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
Marla 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 the glycol dehydration unit and tanks with the potential for flash
emissions were considered for major source determination. The condensate
accumulated at the Marla Compressor Station comes from high pressure sources (i.e.,
the slug catcher and any compressor knock -out pots). To accommodate flashing from
the higher pressure of the slug catcher and knock -out pots, all condensate storage at
the Marla Compressor Station is accomplished via pressurized bullets, the vents of
which are entirely closed and therefore do not emit to atmosphere (i.e., bullets are not
designed to emit any contents to atmosphere under any normal operating condition and
therefore do not have the potential for emissions). As such, there are no emissions
associated with these storage tanks. Therefore, for the purposes of major source
determination, only emissions from the glycol dehydration units were aggregated to
determine major source applicability. The HAP emissions from the dehydration units are
below the major source thresholds of 10 tons/year individual HAP and 25 tons/year total
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HAP. Therefore, the Marla 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 Marla Compressor Station
operates natural gas fired heaters as reboilers to provide sufficient heat to regenerate
the TEG from the dehydration unit. Pursuant to the definition set forth in §63.11237, a
boiler is "an enclosed device using controlled flame combustion in which water is heated
to recover thermal energy in the form of steam and/or hot water." The heaters at the
Marla Compressor Station are not used to transfer heat to water. Furthermore, this
definition specifically exempts "process heaters", which are defined as "an enclosed
device using controlled flame, and the unit's primary purpose is to transfer heat indirectly
to a process material (liquid, gas, or solid) or to a heat transfer material (e.g., glycol or
a mixture of glycol and water) for use in a process unit, instead of generating steam."
As explicitly indicated in the process heater definition, the TEG reboilers at the Marla
Compressor Station are used to transfer heat to glycol, thereby regenerating it. As such,
these units are considered process heaters for the purposes of Subpart JJJJJJ and are
not subject to these requirements.
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 Marla
Compressor Station are significantly below the 10 MMBtu/hr applicability threshold set
forth in Subpart Dc. Therefore, the Marla 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 storage
tanks at the Marla Compressor Station are bullet -style tanks. The condensate stored
from these tanks are from high-pressure sources, such as the inlet slug catcher and the
compressor knockout pots. Pursuant to source correspondence received on 6/26/2018,
the high pressure condensate is flashed to roughly 50 psig in these condensate storage
bullet tanks. Flash emissions are recompressed with a vapor recovery unit (VRU) and
routed back to the plant inlet. If the VRU goes down, the condensate storage bullets are
designed to accommodate the accumulating pressure from the inlet pressurized
condensate. Once this pressure accumulates to a point at which it exceeds the station
inlet pressure, a pressure regulating valve will open, directing the pressurized gas back
to the facility inlet. As such, these vessels are not designed to vent to atmosphere.
Pursuant to §60.110b(d)(2), Subpart Kb does not apply to "pressure vessels designed
to operate in excess of 204.9 kPa (-30 psi) and without emissions to the atmosphere."
Because these vessels are designed to operate in excess of 30 psi and do not vent to
atmosphere, even during periods of VRU downtime, the condensate storage tanks at
the Marla Compressor Station are not subject to Subpart Kb.
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NSPS Subpart KKK — Subpart KKK applies to equipment leaks of VOC from onshore
natural gas processing plants. The Marla Compressor Station is not considered to be a
natural gas processing plant for the purposes of this Subpart, because it does not
engage in the extraction of natural gas liquids (NGLs) or fractionate these NGLs
(§60.631). As such, the Marla Compressor Station is not subject to Subpart KKK.
NSPS Subpart OOOO - Subpart OOOO applies to crude oil and natural gas production,
transmission and distribution facilities for which construction, modification or
reconstruction commenced between 8/23/2011 and 9/18/2015. 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. Applicability for each of these units is addressed below:
• Natural Gas Wells — The Marla Compressor Station does not operate any natural
gas wells.
• Centrifugal Compressors — The Marla Compressor Station does not operate any
centrifugal compressors.
• Reciprocating Compressors — The Marla Compressor Station does operate
reciprocating compressors. However, pursuant source correspondence received
4/10/2019, these compressors have not undergone a qualifying modification
within the applicability timeframe of this Subpart. As such, these compressors
are not affected facilities for the purposes of this Subpart.
• Natural Gas Driven Pneumatic Controllers — The Marla Compressor Station
operates pneumatic controllers. However, pursuant to source correspondence
received on 6/28/2018, all pneumatic controllers at the Marla Compressor Station
are instrument air driven. As such, these controllers are not affected facilities for
the purposes of the Subpart.
• Storage Vessels — The Marla Compressor Station operates storage tanks onsite.
It should be noted that the condensate storage vessels are exempt from the
storage vessel definition in Subpart 0000, as they are "pressure vessels
designed to operate in excess of 204.9 kilopascals (-30 psi) and without
emissions to the atmosphere" (§60.5430). These condensate storage vessels
are pressurized bullet tanks that return all condensate flash gas to the plant inlet
via VRU or, if the VRU is down, pressure accumulates until it can overcome the
plant inlet pressure and is then routed to inlet by a pressure control valve. As
such, these vessels are designed to operate in excess of 30 psi and without
emissions to atmosphere, thereby fulfilling the NSPS OOOO exemption criteria.
Pursuant to the insignificant activities list provided in the 7/23/2018 permit
modification application, uncontrolled emissions from all storage tanks in
aggregate at the Marla Compressor Station are 0.94 tons/year, which is well
below the applicability threshold of 6 tons/year set forth in NSPS OOOO
§60.5365(e). As such, these storage vessels are not affected facilities for the
purposes of this Subpart.
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• 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 Marla 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 Marla Compressor Station are not affected facilities under Subpart
OOOO.
• Sweetening Units — The Marla Compressor Station does not operate any
sweetening units.
Pursuant to the justifications outlined above, there are no affected facilities under NSPS
OOOO at the Marla Compressor Station, and, as such, this Subpart does not apply to
this facility.
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 Marla Compressor
Station does not operate any wells.
• Centrifugal Compressors — As noted in the NSPS OOOO discussion above, the
Marla Compressor Station does not operate any centrifugal compressors.
• Reciprocating Compressors — As noted in the NSPS OOOO discussion above,
the Marla Compressor Station does operate reciprocating compressors,
however, pursuant to source correspondence received 4/10/2019, none of these
compressors have undergone a qualifying modification. As such, 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 Marla Compressor Station does operate pneumatic
controllers, however, pursuant to source correspondence received 6/28/2018, all
pneumatic controllers are instrument air driven. As such, these controllers are
not affected facilities for the purposes of this Subpart.
• Storage Vessels — As noted in the NSPS OOOO discussion above, the
condensate storage vessels at the Marla Compressor Station are not considered
storage vessels for the purposes of NSPS OOOO. It should be noted that an
identical exemption for storage vessels is set forth in §60.5430a of Subpart
OOOOa. Therefore, the condensate storage tanks are not affected facilities
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under Subpart OOOOa. Similarly, the 6 tons/year threshold for storage vessel
applicability in NSPS OOOO is unchanged for NSPS 0000a (§60.5365a(e)).
Because all storage vessels at the Marla Compressor Station in aggregate
produce uncontrolled emissions of less than 1 ton/year, these storage tanks are
not affected sources under NSPS OOOOa.
• Process Units — All equipment within a process unit is an affected facility under
this Subpart. As noted in the NSPS OOOO discussion above, the definition of
process unit (which, it should be noted, is identical to the definition set forth in
NSPS 0000a §60.5430a) includes only operations inherent to natural gas
processing plants. The Marla Compressor Station does not engage in the
activities outlined for process units and is not considered to be a natural gas
processing plant. As such, process units at the Marla Compressor Station are
not affected facilities under either Subpart OOOO or Subpart OOOOa.
• Sweetening Units — As noted in the NSPS OOOO discussion above, the Marla
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 Marla
Compressor Station does not operate wells and, as discussed in the NSPS
OOOO section above, the Marla 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 Marla Compressor Station.
• Fugitive Emissions — Fugitive emissions from both well sites and compressor
stations are regulated under Subpart OOOOa. As noted above, the Marla
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 Marla 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 June 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. Pursuant to source correspondence received 4/10/2019, no
qualifying modifications to any compressor has occurred within the applicability
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
timeframe of NSPS OOOOa. 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 Marla Compressor Station, and, as such, this Subpart does not apply to
this facility.
Colorado Regulation No. 7, Section VI - Section VI establishes requirements for the
storage and transfer of petroleum liquid. Per the definitions set forth in Section VI,
petroleum liquids are defined as "crude oil, condensate and any finished or intermediate
product manufactured or extracted in a petroleum refinery". The Marla Compressor
Station stores condensate on its premises. However, the Division has determined that
the original intent of this rule was to regulate gasoline storage and loading facilities.
Because the Marla Compressor Station is not considered a gasoline storage or loading
facility, the requirements of Section VI do not apply to this facility.
Colorado Regulation No. 7, Section XVIII — Section XVIII pertains to natural gas
actuated pneumatic controllers associated with oil and gas operations. Per source
correspondence received 6/28/2018, there are no natural gas actuated pneumatic
controllers present at the Marla Compressor Station. All pneumatic controllers are
instrument air -driven. As such, this section does not apply to this facility.
IV. MODIFICATIONS REQUESTED BY THE SOURCE
In their modification applications submitted on since the last renewal of the operating
permit on 1/1/2013, the source requested that the permit be revised to reflect the
changes described in each application. A summary of each application and the changes
requested is as follows:
The renewal application received on 12/28/2016 requested the following
modifications:
• Update compressor serial numbers for engines C-148, C-166, C-174 and C-176
(AOS executions)
o Since the receipt of the operating permit application, engines C-135, C-
151 and C-174 underwent AOS execution. All engine serial numbers were
updated in the operating permit to reflect the most current AOS.
• Cancel fugitive emissions point P-106 (AIRS 056)
o A cancellation request for this fugitive emission point was received on
5/1/2015. Pursuant to Colorado Regulation No. 7, Section XVII.F.2,
facilities subject to the LDAR requirements of Section XVII.F 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 Marla Compressor Station is subject to Section XVII.F, 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
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
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 I I. D.1.a). As such, the fugitive emissions at the Marla 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 Ill, 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, Sections
XII.L and XVII.F, these emissions cannot be classified as an insignificant
activity. The applicable requirements of Sections XII.L and XVII.F for
fugitive emissions at compressor stations were included in the operating
permit (refer to the Condition 4 discussion in Section V of this document
below) .
• Update insignificant activities list
O The permit modification submitted on 7/23/2018 included an updated
version of the insignificant activities list for the Marla Compressor Station,
thereby superseding the list included with the 12/28/2016 renewal
application. The insignificant activity list in Appendix A was therefore
updated pursuant to the 7/23/2018 list.
• It should be noted that Colorado Regulation No. 7, Section
XVII.C.1.b. requires control devices for storage tanks with
uncontrolled actual emissions of VOC greater than or equal to 6
tons/year. Pursuant to the insignificant activities summary provided
with the 7/23/2018 permit modification application, all listed storage
tanks in aggregate produce VOC emissions of 0.94 tons/year. At
the time of permit issuance on XX/XX/XXXX, these tanks are not
subject to the requirements of Colorado Regulation No. 7, Section
XVII.C.1.b.
The permit modification received on 10/11/2017 requested the following changes:
• Add 3% downtime for the condensers and the enclosed combustion device used
to control dehydration units P-112 and P-113. During periods of downtime,
emissions are routed uncombusted to atmosphere (i.e., are uncontrolled).
• Increase the natural gas throughput limit for dehydration unit P-113 to 55
MMSCFD.
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
• Modify the glycol circulation pump for dehydration unit P-113 to be electric
instead of gas -injected.
• Update GLYCaIc model runs with new extended gas analysis.
• Increase condenser outlet temperature limitation to 160°F for both condensers
associated with the dehydration units.
• Modify the MACT HH permit language to include the optimum glycol recirculation
rate requirements, in the event that the throughput or benzene exemption is not
met. It should be noted that as permitted, potential benzene emissions exceed
the benzene exemption limitation of 0.9 Mg/year. However, because the MACT
HH exemption is based on actual emissions, the dehydration units at the Marla
Compressor Station currently meet the benzene exemption criteria and the
MACT HH applicability remains unchanged for this modification.
• Modify the compliance assurance monitoring (CAM) plan for the dehydration
units to reflect permitted downtime.
• Update the insignificant activities list in Appendix A of the operating permit.
The net effect of this modification resulted in an increase of VOC below the significance
threshold of 40 tons/year for PSD/NANSR purposes. Because the aforementioned
modification does not: result in an increase in emissions above the significance
threshold (40 tons/year), trigger a Title I modification (i.e., is not defined as a
modification under an NSPS or MACT), require a case -by -case determination of
emission limitations, require determinations for temporary sources, require or change a
visibility or increment analysis, significantly alter monitoring requirements, relax
reporting or recordkeeping 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.
The following should be noted with respect to the modification submitted on 7/23/2018:
• The condenser control efficiency was removed from the calculation methodology
for VOC emissions from the dehydration units in the 7/23/2018 modification. As
such, neither condenser downtime, nor the condenser outlet temperature limit
increase requests were incorporated into the operating permit.
• An updated insignificant activities list was provided in the 7/23/2018 modification
application. As such, the operating permit was updated with this revised list
instead of the list submitted with the 10/11/2017 modification application.
• An updated CAM plan was submitted with the 7/23/2018 modification application
to account for the removal of the condenser control efficiencies, thereby
superseding the CAM plan included with the 10/11/2017 modification application.
As such, the CAM plan associated with the 10/11/2017 application was not
incorporated into the operating permit.
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
It should be noted that this application requested numerical throughput limitations for
the 3% downtime. Numerical limitations are necessarily based on 8760 hours of
o peration at full permitted throughput capacity, and do not account for instances in
which a unit is not operated at 8760 hours/year or not run at full capacity. As such, a
n umerical limitation based on 8760 hours of operation or full capacity could allow the
source to experience downtime in excess of the 3% requested, potentially violating the
dehydration unit emission reduction requirements of Colorado Regulation No. 7, Section
XII.H and XVII.D. As such, these requested throughput limitations were modified to
instead be based on 3% of the actual annual throughput to each unit, measured on a
rolling 12 month basis. For a more detailed discussion regarding how the downtime
limitations were incorporated into the operating permit, refer to the NOTE at the end of
the Condition 2 discussion in Section V below.
The permit modification received on 6/27/2018 and source correspondence
received on 6/29/2018 requested the following changes:
• Update engine serial numbers for engines C-135, C-151 and C-174 pursuant to
the alternative operating scenario (AOS) executions. NOx and VOC emissions
from C-174 only decreased as a result of this modification.
• Update the fuel usage limitations for all engines based on a heating value of 1020
Btu/SCF (lowered from 1200 Btu/SCF). Emissions of criteria and non -criteria
pollutants did not change as a result of this alteration.
Because the aforementioned modification does not: result in an increase in emissions
above the significance threshold (40 tons/year), trigger a Title I modification (i.e., is not
defined as a modification under an NSPS or MACT), require a case -by -case
determination of emission limitations, require determinations for temporary sources,
require or change a visibility or increment analysis, significantly alter monitoring
requirements, relax reporting or recordkeeping 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, Pad C, Section X provisions for minor
modifications.
The permit modification received on 7/23/2018 requested the following changes:
• Remove condenser control efficiency for the purposes of emission calculations
for dehydration units P-112 and P-113. This modification results in an increase
in VOC emissions below the significance level for both dehydration units.
• Submit compliance schedule for engine C-176, which was out of compliance with
the NSPS Subpart JJJJ performance testing and notification requirements.
• Modify the compliance assurance monitoring (CAM) plan for the dehydration
units to reflect the condenser removal.
This modification request does not: result in an increase in emissions above the
significance threshold (40 tons/year), trigger a Title I modification (i.e., is not defined as
a modification under an NSPS or MACT), require a case -by -case determination of
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
emission limitations, require determinations for temporary sources, require or change a
visibility or increment analysis, establish a limit with the purpose of avoiding an
otherwise applicable requirement, or establish a plant -wide emission limitations.
However, significant changes to the monitoring requirements for the dehydration units,
including a reduction in recordkeeping requirements, result from the request to remove
the condenser control efficiency. A maximum condenser outlet temperature limitation is
no longer required for these units and, as such, periodic condenser temperature
monitoring is no longer necessary. Because these requests result in a significant
change and relaxation in monitoring requirements, this application cannot be processed
under the minor modification provisions of Colorado Regulation No. 3, Part C, Section
X. This application was therefore processed as a significant modification, as required
by Colorado Regulation No. 3, Part C, Section I.A.7.f.
It should be noted that the removal of the condenser control efficiencies results in a
modification to the emission calculation methodology only (i.e., a condenser is not used
in the monthly GLYCaIc model runs to determine still vent emissions). Both condensers
are still physically present and operational at the Marla Compressor Station.
In the application, the NOx and CO emissions associated with the still vent for each
dehydration unit did not change from the limitations requested in the 10/11/2017
modification application. The calculation methodology set forth in the application
included two GLYCaIc runs for each dehydration unit: one without the condenser to
determine the appropriate VOC emission limitation, and one with the condenser to
determine the appropriate Btu content and throughput to the enclosed combustion
device (ECD), from which the NOx and CO emission limitations are derived. In doing
this, the NOx and CO emissions are estimated more realistically, since in actual
operations, the condensers will still be operational and much of the volume from the still
vents will be condensed prior to the vapors entering the ECD. As verification, the still
vent stream from the GLYCaIc run without the condenser was evaluated for NOx and
CO emissions to determine if emissions would be significantly different. With the entire,
non -condensed still vent stream, all water is assumed to remain in the still vent. As
such, the volume of the still vent sent to the ECD increased by an order of magnitude.
However, this was offset by the change in heat content of the still vent emissions, which
decreased by an order of magnitude (due to the high water concentration). As a result,
emissions of NOx and CO were not significantly different than the emissions derived
from the lower throughput and higher heat content of the condensed still vent stream.
In an effort to permit the more realistic operation, the NOx and CO emissions were
based on the still vent volume and heat content obtained from the GLYCaIc run including
the condenser, as requested in the permit modification application. It should be noted,
however, that neither total emissions of NOx nor CO exceed the permitting threshold of
1 ton/year NOx or 2 tons/year CO. As such, the requested limitations from the
application were not included in the operating permit.
The compliance schedule submitted for C-176 to return it to compliance with NSPS
Subpart JJJJ is as follows:
NSPS Subparts A & JJJJ
Submission
Citation
Requirement
Deadline
Date
123/0243
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
§60.4233(e)
& Table
1
NOx,
standards
CO
& VOC emission
In
compliance
N/A
§60.4245(c)
& §60.7(a)(1)
Submit
initial
notification
In
compliance
N/A
§60.7(a)(3)
Submit
startup
notification
of
date
of
In
compliance
N/A
§60.8(d)
Submit
test
notice
of
performance
9/30/2018
7/25/2018
§60.8(a)
Conduct
performance
test
10/30/2018
8/21/2018
§60.4245(d)
& §60.8(a)
Submit
results
performance
test
12/31/2018
10/10/2018
§60.4243(b)(2)(ii)
Keep
maintenance
records
In
compliance
N/A
§60.4245(a)
Keep
and
supporting
records
of
documentation
all
notifications
12/31/2018
12/31/2018
In source correspondence received 1/15/2019, it was indicated that the final compliance
requirements for this engine were submitted on 12/31/2018 thereby fulfilling this
compliance plan. As such, there are no outstanding requirements of the compliance
schedule that require inclusion in the operating permit. As such, this specific compliance
plan was not included in the operating permit. It should be noted, however, that all
applicable NSPS Subpart JJJJ and Subpart A requirements were incorporated into the
operating permit (refer to the Condition 1.13 and 1.14 discussion in Section V below).
The permit modification received on 3/22/2019 requested the following changes:
• Update engine C-148 equipment description and NOx emission limitation
pursuant to an alternative operating scenario (AOS) executed in February 2019.
This modification resulted in a decrease in NOx emissions.
Because the aforementioned modification does not: result in an increase in emissions
above the significance threshold (40 tons/year), trigger a Title I modification (i.e., is not
defined as a modification under an NSPS or MACT), require a case -by -case
determination of emission limitations, require determinations for temporary sources,
require or change a visibility or increment analysis, significantly alter monitoring
requirements, relax reporting or recordkeeping 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.
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
The source's requested modifications were addressed as follows:
Page Following Cover Page
• Updated company name, responsible official and permit contact based on
request received 3/2/2017.
Section I — General Activities and Summary
• Condition 1.1 —Permitted Activities
o Modified activities summary to remove all references to the condensers,
as requested in the 7/23/2018 permit modification application.
o Updated activities summary to include downtime operation, as requested
in the 10/11/2017 permit modification application.
• Condition 6.1 — Summary Table
o Removed reference to fugitive equipment leaks, as requested in the
12/28/2016 permit renewal application.
o Updated serial numbers of engines having undergone alternative
operating scenario (AOS) execution, as requested in the 12/28/2016
permit renewal application, the 6/27/2018 permit modification application
and the 3/22/2019 permit modification application.
o Modified glycol circulation rate and natural gas throughput rate for
dehydration unit P-113 as requested in the 10/11/2017 permit modification
application.
Section II — Specific Permit Terms
• Condition 1 Table - Engines
o Modified NOx and VOC emission limitations for engine C-174, as
requested in the 6/27/2018 permit modification application and 6/29/2018
source correspondence.
o Modified natural gas throughput limitations, as requested in the 6/27/2018
permit modification application.
o Modified the NOx emission limitation for engine C-148, as requested in
the 3/22/2019 permit modification application.
• PREVIOUS Condition 2 — Fugitive Emissions
o Removed this condition from the operating permit, pursuant to the
cancellation received on 5/1/2015 and the request in the 12/28/2016
permit renewal application.
• Condition 2 — TEG Dehydration Units
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Updated VOC and downtime limitations for dehydration unit P-112 based
on the requests in the 10/11/2017 and 7/23/2018 modification
applications.
o Updated VOC, downtime and glycol circulation rate limitations for
dehydration unit P-113 based on the requests in the 10/11/2017 and
7/23/2018 modification applications.
o Removed condenser outlet temperature limitation based on the request in
the 7/23/2018 modification applications.
o Updated MACT HH language to include the optimum glycol circulation
rate requirements, as requested in the 10/11/2017 modification
application.
For more information on each of these modifications, refer to the Condition
discussion in Section V of this document below.
Appendices
• Appendix A — Inspection Information
o Included driving directions submitted with the 7/23/2018 permit
modification application.
o Updated plot plan with drawing submitted in the 7/23/2018 permit
modification application.
o Updated list of insignificant activities based on the information provided in
the 7/23/2018 permit modification application.
■ It should be noted that the list of insignificant activities submitted
with the 7/23/2018 significant modification application listed fugitive
equipment leaks. Pursuant to Colorado Regulation No. 3, Part C,
Section II.E, paragraph 2, insignificant activity exemptions cannot
apply 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 Ill, National
Emission Standards for Hazardous Air Pollutants, Title V, and
Colorado Maximum Achievable Control Technology or Generally
Available. Control Technology." Fugitive equipment leaks located at
compressor stations are affected facilities subject to the applicable
requirements of Colorado Regulation No. 7 Sections XII.L and
XVII.F. As such, these activities cannot be classified as
insignificant under Colorado Regulation No. 3, Part C, Section II.E.
The fugitive equipment leaks were therefore not included in the
insignificant activities list in Appendix A of the operating permit. It
should be noted that the applicable requirements of Colorado
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
Regulation No. 7, Sections XII.L and XVII.F for fugitive emissions
were included in the operating permit.
• Appendix B — Monitoring and Permit Deviation Report
o Updated company name based on request received 3/2/2017.
• Appendix C — Compliance Certification Report
o Updated company name based on request received 3/2/2017.
• Appendix G — Compliance Assurance Monitoring (CAM) Plan for Engines
o Updated NOx emission limitation for C-174 to reflect new limitation
requested in the 6/27/2018 permit modification application and source
correspondence received 6/29/2018.
o Updated NOx emission limitation for C-148 to reflect new limitation
requested in the 3/22/2019 permit modification application.
o Updated CAM plan pressure drop monitoring approach to allow for
differential pressure transmitters, per source comments received
4/10/2019, 5/6/2019 and 5/20/2019.
o Updated QA/QC practices for thermocouples, per source comments
received 4/10/2019 and 5/6/2019.
• Appendix H — Compliance Assurance Monitoring (CAM) Plan for Dehydration
Units
o Removed condenser temperature monitoring from the CAM plan, as
requested in the 7/23/2018 permit modification application.
o Updated CAM plan to exclude pilot light monitoring requirements during
periods of permitted downtime, as requested in the 10/11/2017 and
7/23/2018 permit modification applications.
o Updated QA/QC practices for thermocouples, per source comments
received 4/10/2019 and 5/6/2019.
V. 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:
Section I — General Activities and Summary
• Condition 1.3 — Underlying Construction Permits
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Created table to summarize each permit and the permitted equipment, for
ease of reference.
o Removed reference to fugitive emissions point, permitted under
01 WE0502, pursuant to the fugitive point cancellation request received on
5/1/2015.
• Condition 1.4 — State -Only Enforceable Conditions
o Revised the language in Condition 1.4 include current conditions that are
state -only enforceable.
• Condition 2 — Alternative Operating Scenarios (AOS)
o Updated natural gas fired engine AOS language to most current Division -
standard language (ver. 10/12/2012)
• Condition 3 — Prevention of Significant Deterioration / Non -Attainment New
Source Review
o Updated source description (NANSR/PSD) to most current Division -
standard language (ver. 9/4/2015)
Section II — Specific Permit Terms
Condition 1 — C-148/135/151 — Three Waukesha L-7042 GSI, 1,478 HP Engines w/
N SCR (AIRS ID: 052/053/054)
C-166/174/176 — Three Waukesha L-7044 GSI, 1,680 HP Engines wl
N SCR (AIRS ID: 059/060/061)
• Condition
1.1
NOx and CO Emission Limitations & Compliance Monitoring
o Separated VOC and HAP limitations from NOx and CO condition into
separate condition (see below). The NOx and CO limitations are subject
to portable monitoring requirements. These limitations and associated
emission factors may be altered based on the results of this portable
monitoring. Conversely, the VOC and HAP emission limitations and
associated emission factors are not measured with nor affected by
portable monitoring. As such, these limitations were moved to a new
condition without the portable monitoring requirements to avoid confusion.
o Removed reference to lower heating value — this requirement is contained
in the Fuel Gas Heat Content condition (see Condition 1.4 below).
o Added requirement to use the heat content from the most recent analysis.
o Added requirement to maintain records of the rolling twelve month
calculations to be made available to the Division upon request.
• Condition 1.2 — VOC Emission Limitations & Compliance Monitoring
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Created this condition to separate out VOC and HAP emission limitations
and compliance requirements from the NOx and CO condition. Portable
monitoring requirements are specific to NOx and CO only, and were
therefore omitted from this condition.
o Added requirement to calculate HAP emissions in accordance with the
methods set forth in the facility -wide HAP condition (see Condition 3
below).
• Condition
1.3
Natural Gas Consumption Limitations & Compliance Monitoring
o Updated calculation methodology to include fuel gas usage from other
sources (i.e., reboilers for the dehydration units, pilot gas for enclosed
combustion device, etc.) that may contribute to the fuel gas consumption
read from the facility -wide meter. This was done to ensure accurate
partitioning of the fuel gas throughput read from the facility -wide meter to
each user.
• Condition
1A
Fuel Gas Heat Content
o Added requirement to maintain records of the fuel gas analysis to be made
available to the Division upon request.
o Changed condition to require monitoring of the higher heating value of the
fuel gas, instead of the lower heating value. Pursuant to source comments
received 4/10/2019 and 5/6/2019, the NOx, CO and VOC emission factors
are based on a manufacturer specification that uses the higher heating
value (HHV) of the fuel. As such, the higher heating value of the fuel
should be used in emissions calculations to be consistent with the
manufacturer emission factors. Therefore, this condition was corrected to
refer to the higher heating value. A heating value of 1,020 Btu/SCF was
used to determine the emission limitations set forth in this permit.
• Condition 1.5 — Hours of Operation
o Added requirement to record runtime hours for each engine on the same
day that the facility -wide fuel gas consumption reading is taken. This was
done to ensure accurate partitioning of fuel gas among its users.
• Condition
1.6
Opacity
o Updated opacity requirement to match current Division -standard format.
o Removed reference to construction permit requirements. Typically, the
construction permit is not cited for requirements that stem directly from a
state or federal regulation.
o Added requirement to maintain records to verify that only natural gas is
used as fuel for these engines as a method to demonstrate compliance
with the Colorado Regulation No. 1 limitations.
• Condition
1.7
Control Device Requirements
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Added the following monitoring requirements to ensure proper operation
of each engine's control devices:
■ Catalyst Pressure Drop — monitored and recorded monthly, not to
exceed 2" of water column from the baseline established in the
portable monitoring test. If pressure drop deviates from allowable
range, maintenance is required to bring the catalyst pressure drop
back into an acceptable range. Records shall be maintained of the
recorded monthly pressure drop and maintenance activities
performed.
■ Catalyst Inlet Temperature — monitored and recorded daily, to be
kept between 750°F and 1250°F. If temperature deviates from the
allowable range, maintenance is required to bring the catalyst
temperature back into the acceptable range. Records shall be
maintained of the recorded monthly inlet temperature and
maintenance activities performed.
It should be noted that these requirements are Division -standard practice
and are included in all operating and maintenance (O&M) plans for rich
burn engines. The monitoring frequencies were set based on facility -wide
emissions of criteria pollutants (> 100 tons/year).
o Updated monitoring frequency of the millivolt reading for the air to fuel
ratio controller (AFR) to weekly, pursuant to the most recent Division -
standard version of the operating and maintenance plan for rich burn
engines operating at a major source of NOx and/or CO.
• Condition
1.8
Portable Monitoring
o Updated portable monitoring condition to most current Division -standard
language (ver. 6/26/2014)
• Condition
1.9
Compliance Assurance Monitoring
o Updated condition to specifically identify that each engine is subject to
CAM for the NOx and CO emission limitations listed in the operating
permit.
• Condition
1.10
— Statewide Controls for Oil and Gas Operations
o Colorado Regulation No. 7, Section XVI
■ Colorado Regulation No. 7, Section XVI.B — Air Pollution
Technology Requirements
• This condition was moved from the control device
requirements condition to this condition that specifically
addresses all applicable requirements of Colorado
Regulation No. 7 as they pertain to oil and gas facilities. It
should be noted that all engines at the Marla Compressor
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Technical Review Document — Renewal Operating Permit
Station are fitted with the required NSCR and AFR
controller, as required by Section XVI.B.
• Colorado Regulation No. 7, Section XVI.D — Combustion Process
Adjustment
It should be noted that the requirements of Colorado Regulation
No. 7, Section XVI were not yet promulgated at the time of previous
permit issuance. Therefore, the operating permit was updated with
the applicable requirements of Section XVI, including the following:
• Section XVI.D.2 — Exemption from emission limitation
requirements, compliance demonstration requirements and
certain recordkeeping and reporting requirements, provided
the engines are subject to the emission control requirements
of Section XVI.B.
o It should be noted that all engines at the Marla
Compressor Station are greater than 500 hp and
have installed an NSCR and air -to -fuel ratio
controller, as required under Section XVI.B.1. As
such, these engines fulfill the exemption requirement
of Section XVI.D.2.e. and are subject only to
combustion process adjustment and recordkeeping
requirements.
o As written, Section XVI.D.2. precludes the source
from complying with the combustion process
adjustment recordkeeping, despite being required to
perform combustion process adjustments. Because
these adjustments are required, proper
documentation must be maintained to demonstrate
compliance with these requirements, pursuant to
Colorado Regulation No. 3, Part C, Section V.C.5.b.
Therefore, an explicit requirement to keep records in
accordance with Colorado Regulation No. 7, Section
XVI.D.7.f. was included in the operating permit.
These additional requirements were clearly denoted
in the operating permit with italicized text
• Section XVI.D.6.a — Requirement to perform combustion
process adjustments if uncontrolled actual NOx emissions
exceed 5 tons/year.
• Section XVI.D.6.b — Combustion process adjustment
requirements, including annual inspection and as -needed
replacement of oil filters, air cleaners, fuel filters, belts and
spark plugs. Requirement to maintain engines pursuant to
manufacturer specification. Alternative requirements to
follow manufacturer recommended procedures or
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Technical Review Document — Renewal Operating Permit
procedures required under a federal MACT (40 CFR Part
63) or NSPS (40 CFR Part 60) in lieu of performing the
combustion process adjustment set forth in Section XVI.D.6.
• Section XVI.D.F.7 — Recordkeeping requirements, including
a report with the date of adjustment, nature of the
adjustment, a list of applicable federal requirements, a
description of corrective actions taken, engine hours of
operation and the fuel type used by the engine.
o As written, Section XVI does not include
recordkeeping requirements sufficient to
demonstrate that a proper alternative combustion
process adjustment was performed. Because
alternative combustion process adjustments are
allowed pursuant to Section XVI.D.6.c., proper
documentation is required to demonstrate
compliance with the alternative combustion process
adjustment provisions, pursuant to Colorado
Regulation No. 3, Part C, Section V.C.5.b. Therefore,
an explicit requirement to keep records of any
alternative combustion process adjustments
performed, the procedures used and what NSPS or
MACT (if any) applied, was included in the operating
permit. These additional requirements were clearly
denoted in the operating permit with italicized text. It
should be noted that these requirements exactly
mirror Colorado Regulation No. 7, Section
XVI.D.7.f.(i)(C), and these requirements were
present in the 11/17/2016 promulgation of Colorado
Regulation No. 7 Section XVI.
o Colorado Regulation No. 7 Section XVII
Colorado Regulation No. 7, Section XVII.E sets forth requirements for new
and existing engines located in the state of Colorado. New engines
(constructed or relocated to Colorado on or after 7/1/2007 for engines
greater than 500 hp) are required to comply with numerical emissions
limitations (Section XVII.E.2.), and existing engines (constructed prior to
2/1/2009) must comply with control device installation requirements
(Section XVII.E.3.). The following table summarizes the requirements of
Section XVII.E.2 and 3 as they apply to each engine:
AIRS ID
Facility
Identifier
Date of
Construction
Date of
Relocation to CO
CO Reg. No. 7
Section XVII.E.2
Requirement
CO Reg. No. 7
Section XVII.E.3
Requirement
052
C-148
1973
2/16/2009
July 1, 2007 Std.
--
053
C-135
After 6/22/1992
Before 8/2003
--
NSCR and AFR
054
C-151
Before 2001
Before 2001
--
NSCR and AFR
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Technical Review Document — Renewal Operating Permit
AIRS
ID
Identifier
Facility
Construction
Date
of
Relocation
Date
of
to
CO
CO
Section
Requirement
Reg.
XVII.E.2
No.
7
E.2
Section
CO
Requirement
Reg.
XVII.E.3
No.
7
E.3
059
C-166
Before
1/2002
Before
1/2002
--
NSCR
and
AFR
060
C-174
2010
2018
Exempt
Exempt
061
C-176
3/2008
N/A
Exempt
Exempt
It should be noted that pursuant to Section XVII.B.5, "internal combustion
engines that 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 ("BA CT') limit, or a
New Source Performance Standard ("NSPS') under 40 CFR Pad 60 are
not subject to Section XVII., except for the leak detection and repair
requirements in Section XVII.F". Engines C-174 and C-176 only are
subject to a qualifying "emissions control requirement" (i.e., numerical
emissions limitations) under NSPS JJJJ (see Section III of this document).
As such, these engines only are exempt from all engine -related
requirements of Section XVII.E. Pursuant to Section XVII.B.5, the LDAR
requirements of Section XVII.F were included in the operating permit
under a separate facility -wide oil and gas general requirements condition
(see Section V of this document).
The following requirements of Colorado Regulation No. 7, Section XVII.E
were included in the operating permit:
• Section XVIl.E.2 (State -Only Enforceable) — New engines shall
comply with the numerical emission limitations based on the date
of construction or relocation of the engine to Colorado.
• Section XVI I. E.3 — Existing engines shall install AFR controllers
and an NSCR system.
• Condition
— 40 CFR Part 63 Subpart ZZZZ MACT
o Removed "federal -only" label on condition, pursuant to current Division
standard practice.
o Updated date of newest publication of Subpart ZZZZ to 2/27/2014.
o Removed all outdated Subpart ZZZZ requirements and replaced with the
applicable requirements from the 2/27/2014 publication of Subpart ZZZZ.
It should be noted that the requirements from the previous version of this
operating permit were incorporated prior to various revisions to the
requirements for engines located at area sources, including those affected
the remote engine designation (see Section III of this document), which
were published on 1/30/2013. As such, the operating permit has been
updated to include the applicable Subpart ZZZZ requirements from the
most recent version of this Subpart (2/27/2014) as follows:
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
■ Existing Engines (C-148, C-135, C-151 and C-166)
• General Requirements: Comply with the requirements of
Subpart ZZZZ at all times and operate all equipment in
accordance with good air pollution control practices
(§63.6605).
• Work Practices of Table 2d: Change oil and filter every
2,160 hours of operation or annually, inspect spark plug,
hoses and belts every 2,160 hours of operation or annually
and replace as necessary (§63.6603(a)).
• Remote Status Certification: Submit annual report to confirm
remote status of facility (§63.6603(f)).
• Initial Requirements: Operate engine in accordance with
manufacturer specifications or site -specific maintenance
plan, minimize engine idle time and option to analyze oil to
extend life (§63.6625)
• Continuous Compliance Requirements Table 6: Work
management practices including maintaining stationary
RICE pursuant to manufacturer specifications or developing
a site -specific maintenance plan (§63.6640(a)).
• Notification requirements for failing to comply with the work
practices of Table 2d, which are considered deviations for
the purposes of this Subpart (§63.6640(b)).
• Notification requirements for failing to comply with the
general requirements of Subpart A (§63.6640(e)).
• Requirement to submit semi-annual report pursuant to 40
CFR Part 70 (§63.6650(f)).
• Recordkeeping requirements for applicable work practices,
maintenance procedures, and any maintenance conducted
according to maintenance plan (§63.6655).
• Records form and retention schedule (§63.6660).
■ New Engines (C-174, C-176)
• Requirement to comply with NSPS JJJJ (§63.6590(c)).
• Condition 1.12 — 40 CFR Pad 63 Subpart A MACT
o Removed performance testing (§63.7), monitoring (§63.8) and notification
(§63.9) references. With the updated Subpart ZZZZ requirements
(described above), these sections no longer apply to the engines at the
Marla Compressor Station.
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Added reference to recordkeeping and reporting requirements (§63.10)
since records are required for the applicable work practices, maintenance
activities and the remote designation status (see above requirements)
• Condition
1.13
40 CFR Part 60 Subpart JJJJ NSPS
o Added new NSPS JJJJ requirements as they apply to C-174 and C-176
only.
It should be noted that engines C-174 and C-176 had not yet undergone
the AOS that triggered NSPS JJJJ requirements prior to the previous
operating permit issuance. The AOS triggering NSPS JJJJ requirements
was submitted on 3/21/2018 for C-174 and 3/3/2016 for C-176. As such,
the operating permit has been updated to include the applicable Subpart
JJJJ requirements from the most recent version of this Subpart
(8/30/2016) as follows:
■ Emission Standards from Table 1: The affected engine must
comply with the emission limitations in table 1 of NSPS JJJJ
(§60.4233(e)).
• Applicable footnotes, including the option to comply with
either the g/hp-hr or ppmv standard and the requirement to
omit formaldehyde in the calculation of VOC emissions,
were included in the operating permit.
• Emission Standard Duration: The affected engine must comply with
the emission standards over the lifetime of the engine (§60.4234)
■ Compliance Requirements: Option to purchase a certified or non -
certified engine in order to comply with the emission standards of
this subpart (§60.4243(b))
• AFR Controller: Expectation to use an air -to -fuel ratio controller for
engines operating with NSCR (§60.4243(g))
• Testing Requirements: Reference to the applicable testing
methodologies set forth in this section of Subpart JJJJ (§60.4244)
• Reporting Requirements: List of the required records, including
notifications, maintenance, certified engine documentation,
documentation that non -certified engines meet the emission
standards and copies of performance tests (§60.4245)
• Condition
1.14
40 CFR Part 60 Subpart A NSPS
o Referenced new applicable NSPS Subpart A requirements as they apply
to the requirements under Subpart JJJJ, including:
• Notification and recordkeeping (§60.7)
■ Performance tests (§60.8)
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Technical Review Document — Renewal Operating Permit
• Compliance with standards and maintenance requirements
(§60.11)
• Circumvention (§60.12)
• General notification and reporting requirements (§60.19)
Condition 2: P-112 TEG Dehydration Unit with an Enclosed Combustion
Device (AIRS ID: 062)
P-113 TEG Dehydration Unit with an Enclosed Combustion
Device (AIRS ID: 063)
• Condition
2.1
VOC Emission Limitations & Compliance Monitoring
o Relocated requirements to monitor the inlet and flash tank operating
temperatures and pressures to a separate condition for clarity.
o Relocated extended gas analysis requirement to a separate condition for
clarity.
o Removed requirement to monitor condenser temperature, pursuant to the
7/23/2018 permit modification application, which requested the removal of
condensers as control devices for each dehydration unit.
■ It should be noted that the condensers were not physically removed
from the dehydration systems; only the control efficiency
associated with the condensers was removed for emission
calculation purposes.
o Updated calculation methodology to reflect the incorporation of ECD
downtime, as requested in the 10/11/2017 permit modification application
and source comments received 4/10/2019, 5/6/2019 and 5/20/2019. The
calculation shall now estimate emissions based on the output from the
monthly GLYCaIc model, in conjunction with a 95% control efficiency for
the ECD when it is operating, and effectively a 0% control efficiency during
uncontrolled hours of operation, when the ECD is experiencing downtime
and still vent emissions are routed uncombusted to atmosphere.
■ It should be noted that each dehydration unit is also equipped with
a flash tank. Pursuant to the operating and maintenance (O&M)
plan submitted with the 7/23/2018 permit modification application,
flash tank emissions are hard -piped to the pressurized condensate
storage tank. Overhead emissions from this storage tank are piped
to a vapor recovery unit (VRU) which returns the vapors to the plant
inlet to be compressed. If the VRU is inoperable, pressure
accumulates in the condensate storage tank until a pressure
regulating valve opens, allowing the overhead emissions to be
routed directly to the plant inlet, without the assistance of the VRU.
As such, there is no operational pathway for which flash tank
emissions can be released. As such, flash tank emissions were not
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
addressed in the calculation methodology, since these emissions
are effectively zero.
• Condition
2.2
Wet Gas Throughput Limitations & Compliance Monitoring
o Added requirement to maintain records of the total wet gas throughput to
each dehydration unit, to be made available to the Division upon request.
o Included requirement to monitor wet gas throughput during periods of
uncontrolled hours of operation (i.e., uncontrolled wet gas throughput), as
requested in the 10/11/2017 modification application, not to exceed 3% of
the total wet gas throughput to the dehydration units.
■ The 10/11/2017 modification application requested that the ECD
be allowed 3% annual downtime, during which still vent emissions
are diverted from the ECD using control valves and routed to
atmosphere. In order to monitor compliance with this requirement,
the actual percentage of ECD downtime shall be calculated as a
function of the total wet gas throughput to the dehydration units and
the amount of time during which emissions were routed
u ncontrolled to atmosphere (i.e., uncontrolled hours of operation).
The total wet gas throughput to the dehydration unit during
u ncontrolled hours of operation (i.e., during periods when still vent
emissions are directed to atmosphere) is not to exceed 3% of the
total wet gas throughput to the dehydration unit on a rolling twelve
month basis. The limitation listed in the permit is based on a
percentage of actual wet gas throughput. This was done pursuant
to the justification presented in the "NOTES" section of this
dehydration unit condition below.
• Condition — Lean Glycol Circulation Rate Limitations & Compliance
Monitoring
o Updated frequency of monitoring from weekly to daily, pursuant to current
Division standards for major sources. It should be noted that per the 2017
inspection report, the source is currently monitoring the lean glycol
circulation rate daily.
o Updated condition to reflect the appropriate monitoring requirements for
each pump, as requested in source comments received 4/10/2019. The
P-112 circulation pump is gas driven and is not equipped with a dedicated
flowmeter. As such, the P-112 lean glycol circulation rate shall be
determined by recording pump strokes per minute and using a
manufacturer correlation to obtain the circulation rate. The P-113
circulation pump is electric and has its own dedicated flowmeter, from
which the lean glycol circulation rate shall be recorded.
o Included requirement to determine an average monthly lean glycol
circulation rate from the daily recorded values, to be used in the monthly
GLYCaIc model runs.
2.3
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
• Condition 2.4 — Extended Gas Analysis
o Created this condition to explicitly address the extended gas analyses
separately from the VOC emission limitation requirements for clarity.
o Updated frequency of the extended gas analysis to annually, regardless
of HAP content, pursuant to current Division standards for dehydration
units located at major sources.
o Added requirement to maintain records of the extended gas analyses, to
be made available to the Division upon request.
■ It should be noted that each dehydration unit is fed with exactly the
same gas from inlet compression. As such, only one sample of this
gas is required to be taken; individual samples for each dehydration
unit are not necessary.
• Condition 2.5 — Parametric Monitoring
o Created this condition to explicitly address the parametric monitoring
separately from the VOC emission limitation requirements for clarity.
o Included requirement to determine a monthly average from the weekly
recordings of the parameters monitored, to be used in the monthly
GLYCaIc model runs.
o Added requirement to maintain records of the parameters monitored to be
made available to the Division upon request.
• Condition
2.6
Hours of Operation
o Removed requirement to track days of operation. Hours of operation are
sufficient to determine the average daily gas throughput to be input in to
the required monthly GLYCaIc run.
o Added requirement to monitor uncontrolled hours of operation, which is
defined as times during which the dehydration units were operating and
still vent emissions from the dehydration units were routed uncombusted
to atmosphere, as determined using the still vent emissions routing
records, required by Condition 2.8. Uncontrolled hours of operation are
required to monitor compliance with the uncontrolled wet gas throughput
limit and to determine monthly VOC emissions from each dehydration unit.
• Condition
2.7
— Opacity
o Included Colorado Regulation No. 1 Section II.A.5 30% opacity limitation
for flares. The enclosed combustion device at the Marla Compressor
Station is considered to be a flare for the purposes of Colorado Regulation
No. 1 and, as such, this opacity limitation is applicable.
• Condition 2.8 — Still Vent Emissions Routing
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
o Included condition to monitor and record the position indication of the
control valves used to route the still vent emissions from each dehydration
unit either to the ECD or to atmosphere. Records of the length of time
during which emissions were routed to atmosphere will be used to
determine the uncontrolled hours of operation for each dehydration unit.
• Condition
2.9
Control Device Requirements
o Removed requirement to vent the flash tank back to process at all times.
As noted above, flash tank emissions are hard -piped directly back to the
pressurized condensate storage tank. The emissions from this tank are
either returned to inlet via VRU, or, if the VRU is not operating, via
pressure regulator. As such, there is no possible way for flash tank
emissions to vent. Because this process design inherently achieves zero
emissions and there is no alternate routing of flash tank emissions, this
condition is not required and was removed from the operating permit.
o Included requirement to monitor the pilot light continuously using a flame
rod, or, if the flame rod malfunctions, to perform a daily visual inspection
of the pilot light, pursuant to the operating and maintenance (O&M) plan
submitted with the 7/23/2018 permit modification application.
Supplemented O&M conditions with the requirement to maintain daily
records of the flame rod indication and records of any pilot light outage
events and the duration of those events.
o Added requirement to perform Method 9 readings, in the event a Method
22 reading (as required by the most recent operating and maintenance
(O&M) plan submitted with the 7/23/2018 modification application)
indicates visible emissions are present. Method 9 readings are required
to monitor compliance with the Colorado Regulation No. 1, Section II.A.5
30% opacity limitation for flares. Pursuant to current Division -standard
Method 9 language, the Method 9 observation shall be performed by a
certified observer and a copy of the observer's certification shall be
maintained and made available to the Division upon request.
o Since the previous issuance of this operating permit, the no visible
emissions requirement of Colorado Regulation No. 7, Section XVII.B.1.c.
has been relocated to Colorado Regulation No. 7, Section XVII.B.2.b.,
pursuant to the most recent revision to this regulation. This requirement
has been relocated within the operating permit to a separate, general
condition addressing all facility -wide Colorado Regulation No. 7
requirements. A reference to this facility -wide condition was included in
Condition 2.11 below.
• Condition
2.10
Compliance Assurance Monitoring (CAM)
o Updated condition to reference specific VOC and HAP limitations to which
CAM applies.
• Condition
2.11
Statewide Controls for Oil and Gas Operations
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
This section addresses the Colorado Regulation No. 7 requirements applicable
to dehydration units. At the time of previous permit issuance, these requirements
had not yet been promulgated. The applicable requirements from the 1/14/2019
revision of Colorado Regulation No. 7 have been incorporated into the operating
permit as follows:
o Colorado Regulation No. 7 Section XII
■ Section XII.C. — The TEG dehydration units at the Marla
Compressor Station are subject to the general requirements for
facilities (Section XII.C.1). All general requirements of Section XII.C
are addressed in the facility -wide requirements condition (see
below).
■ Section XII.H.1. — Glycol Dehydrator Emissions Limitations —
Actual uncontrolled emissions of VOC shall be reduced by at least
90%.
• Supplemented condition with a compliance demonstration
method to presume compliance with the 90% VOC reduction
provided the control device requirements set forth in the
O&M plan (see Condition 2.9 above) and the applicable
general requirements of Colorado Regulation No. 7, Section
XII.C are met.
■ Section XII.H.3. — The 90% reduction requirement shall apply to a
single dehydration unit with actual uncontrolled emissions of VOC
greater than 1 ton/year, or to a group of dehydration units with
actual uncontrolled emissions greater than 15 tons/year.
■ Section XII.H.4 — Emission calculations methods shall be approved
in advance by the Division.
• Supplemented condition with additional monitoring to
provide a timeline of compliance, should the dehydration
units' actual uncontrolled emissions drop below the
applicability threshold of Section XII.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 XII.H. requirements.
■ Section XII.H.5. H .5. - Weekly inspections of air pollution control
equipment to verify pilot light presence, proper valve configuration
for fuel gas routing pilot, no smoke emanating from combustion
device and certification that operation of the control device is
consistent with manufacturer specifications.
■ Section XII.H.6. — Reports shall be submitted semi-annually
included a list of affected dehydration units, the air pollution control
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Technical Review Document — Renewal Operating Permit
equipment used to control those dehydrators and inspection dates
and results required under Section XII.H.
a Colorado Regulation No. 7 Section XVII
■ Section XVII.B (State -Only Enforceable) — The TEG dehydration
units at the Marla Compressor Station are subject to the general
requirements for facilities (Section XVII.B.1) and control devices
(Section XVII.B.2). All general requirements of Section XVII.B are
addressed in the facility -wide requirements condition (see below).
■ Section XVII.D.1 (State -Only Enforceable) — Actual uncontrolled
emissions of VOC from glycol dehydration units shall be reduced
by at least 90%.
• Supplemented condition with a compliance demonstration
method to presume compliance with the 90% VOC reduction
provided the control device requirements set forth in the
O&M plan (see Condition 2.9 above) and the applicable
general requirements of Colorado Regulation No. 7, Section
XVII.B are met.
■ Section XVII.D.2 (State -Only Enforceable) — The requirement of
Section XVII.D.1 D.1 applies where actual uncontrolled emissions of
VOC are greater than or equal to 2 tons/year and the sum of
uncontrolled actual emissions of VOC from all dehydration units is
greater than or equal to 15 tons/year.
■ Section XVII.D.3 (State -Only Enforceable) — Actual uncontrolled
emissions of hydrocarbons from glycol dehydration units shall be
reduced by at least 95% and combustion devices shall have a
design destruction rating of at least 98%.
• Supplemented condition with a compliance demonstration
method to presume compliance with the 95% hydrocarbon
reduction provided the control device requirements set forth
in the O&M plan (see Condition 2.9 above) and the
applicable general requirements of Colorado Regulation No.
7, Section XVII.B are met.
• Supplemented condition with compliance demonstration
method to assume compliance with the destruction
efficiency requirements for the combustion device, 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 although the combustion devices
were authorized by permit prior to 2014 (exemption criterion
of Section XVII.D.3.a), there are multiple building units
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Technical Review Document — Renewal Operating Permit
within 1,320 feet of the Maria Compressor Station
(exemption criterion of Section XVII.D.3.b). As such, the
requirement to operate a combustion device with a design
destruction efficiency of 98% was included in the operating
permit.
■ Section XVII.D.4 (State -Only Enforceable) — The requirements of
Section XVI I. D.3 apply where actual uncontrolled emissions of
VOC are greater than or equal to 6 tons/year and 2 tons/year if
located within 1,320 feet from a building unit
■ The following additional monitoring requirements were included in
the operating permit to ensure compliance with the Colorado
Regulation No. 7 Section XVII.D requirements:
• Requirement to maintain a rolling 12 month calculation of
total emissions for the dehydration unit to determine whether
the control requirements of Section XVII.D.1., and/or
XVII.D.3. apply.
• Requirement to comply with Section XVII.D within 60 days
for instances in which the dehydration unit had actual
uncontrolled emissions below the thresholds set forth in
Section XVII.D.2. and XVII.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
2.12
40 CFR Part 63 Subpart HH MACT
o Updated introductory language to the most recent Division -standard
version, including the applicable Colorado Regulation No. 8 reference and
the requirement to follow the most recent version of MACT HH should
revisions be published prior to the subsequent renewal of the operating
permit.
o Added affirmative defense provisions of §63.762(a). These requirements
were not included in the previous version of the operating permit, but are
applicable to the Marla Compressor Station.
o As requested in the 10/11/2017 permit modification application, the
o ptimum glycol circulation rate requirements for area source dehydration
u nits not located in a UA plus offset and UC boundary (§63.764(d) and
(d)(2)) were included in the operating permit. These requirements are to
be complied with if the dehydration units are not otherwise exempted on
benzene emissions or natural gas throughput. Pursuant to the significant
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Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
modification application received on 7/23/2018, both TEG dehydration
units at the Marla Compressor Station are permitted to emit benzene in
excess of the 0.9 megagrams per year ('-1,984 lb/year) threshold
(63.764(e)(1)(i) exemption), and are also permitted to process natural
gas in excess of the 85 thousand standard cubic meters per day ('-s 3
MMSCFD) threshold (63.764(e)(1)(ii) exemption). As such, the optimal
glycol circulation rate requirements could be triggered without either
dehydration unit exceeding a permit limit. Therefore, the lean glycol
circulation rate requirements were included in the operating permit.
o Added general good air pollution control provisions of §63.764(j). These
requirements were not included in the previous version of the operating
permit, but are applicable to the Marla Compressor Station.
a Explicitly included the relevant recordkeeping requirements pursuant to
MACT HH. These include:
■ Maintaining records for 5 years (§63.774(b)(1)).
■ Maintaining the records specified in §63.10(b)(2) (§63.774(b)(2)).
■ Maintaining records of actual annual benzene emissions and/or
natural gas throughput (§63.774(d)(1)).
■ Maintaining records of the optimum glycol circulation rate in the
event neither the benzene nor natural gas throughput exemptions
are met (63.774(f)).
• Condition 2.13 — 40 CFR Part 63 Subpart A MACT
o Created this condition to explicitly identify each part of the general
provisions of the MACT rules that is applicable to the dehydration units at
the Marla Compressor Station, pursuant to Subpart HH. The applicable
requirements are as follows:
Prohibited activities and circumvention (§63.4)
■ Recordkeeping and reporting requirements i;§63.10)
NOTES: Please note the following in regards to the permit modification application
received 10/11/2017:
Each dehydration unit is permitted to operate with 3% ECD downtime, during which
e missions from the still vents are routed uncombusted to atmosphere. The intent of
downtime is to allow for periods of ECD maintenance in response to malfunctions,
during which the dehydration unit emissions cannot be safely or practicably
destructed by the ECD, and are therefore routed to atmosphere. It has been
determined that downtime should be permitted as a function of actual operating time,
n ot as a hard numerical limitation based on the maximum number of operational
hours and/or maximum throughput. Numerical limits on hours, throughput or VOC
e missions would necessarily be based on maximum operating parameters, or 3% of
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OP1/1/E020
Technical Review Document — Renewal Operating Permit
8,760 hours of operation and/or 3% of the maximum wet 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
wet 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
3% (i.e., an hours limitation on downtime of 262.8 hours, or 3% of a maximum 8,760
hours of operation, would theoretically permit the source to route still vent emissions
to atmosphere for 262.8 hours, even if the source only operates for 262.8 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 Section XII.H. and XVII.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 wet gas throughput to 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
wet gas throughput to each dehydration unit. The applicable downtime limitation was
incorporated into the operating permit as a wet gas throughput limitation. Wet gas
throughput to the dehydration unit during periods of ECD downtime (i.e.,
uncontrolled hours of operation; defined as periods of time when still vent emissions
from the dehydration units are routed uncombusted to atmosphere) shall not exceed
3% of the total wet gas throughput to the dehydration units on a rolling twelve month
basis
Condition 3: Facility -Wide Hazardous Air Pollutant (HAP) Emission Limitations
Pursuant to the summary table in Section III above, the Marla Compressor Station
is a synthetic minor source of Hazardous Air Pollutants (HAP). As such, synthetic
minor HAP limitations were included in the operating permit to ensure that the facility
maintains its synthetic minor HAP status for the purposes of MACT applicability. The
Division -standard synthetic minor limits of 8 tons/year individual HAP and 20
tons/year total HAP were included in the operating permit. These lower limits (i.e.,
less than the major source threshold of 10 tons/year individual HAP and 25 tons/year
total HAP) allow sufficient buffer for insignificant activities. It should be noted that
the permitted points at the Marla Compressor Station have a controlled potential to
emit below the 8 tons/year individual HAP and 20 tons/year total HAP limitations. As
such, insignificant activity tracking is not required for this facility.
The requirements associated with the HAP limitation were incorporated as follows:
• HAP Emission Limitations & Compliance Monitoring
o Included HAP calculation methodology for 4 -stroke rich burn engines,
using emission factors from EPA's AP -42: Compilation of Emission
Factors, Section 3.2, Table 3.2-3 (dated 7/2000), the Division -
123/0243 Page 46 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OP\A/E020
Technical Review Document — Renewal Operating Permit
approved HAP control efficiencies of 76% for formaldehyde and 50%
for all other HAP, the monthly natural gas consumption and the natural
gas heat content.
o Included reference to the HAP calculation methodology for the
dehydration units, which was retained in the dehydration unit condition
since the calculation of HAP emissions is identical to the VOC
calculation set forth in the dehydration unit condition.
o Added requirements to calculate both individual and total monthly HAP
emissions for the engines and dehydration units, to be used in a rolling
12 month total to monitor compliance with the 8 tons/year individual
HAP and 20 tons/year total HAP limitations.
Condition 4: 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, Section XII (for facilities
operating in non -attainment areas) and Section XVII (for oil and gas facilities state-
wide). It should be noted that many of these requirements were not promulgated at
the time of previous permit issuance. All general requirements that were otherwise
contained in the operating permit were relocated to this condition. The applicable
requirements are as follows:
• Colorado Regulation No. 7, Section XII.C — General Requirements
o Section XII.C.1.a — Requirement to maintain air pollution control
equipment used to comply with Section XII pursuant to manufacturer's
specifications and good engineering practices, and to design such devices
to accommodate foreseeable process changes
o Section XII.C.1.b — Requirement to maintain all condensate handling
operations to minimize VOC emissions
o Section XII.C.1.c — Requirement for control devices used to comply with
the compressor emissions of Section XII.J to achieve a 95% control
efficiency
■ It should be noted that although Section XII.J.2 for reciprocating
compressors does not explicitly require the use of a control device
to achieve compliance, the applicability requirements Section
XII.A.6 mandate that Section XII.C.1.c be complied with for
reciprocating compressors. As such, this condition was included in
the operating permit.
o Section XII.C.1.d — Requirement for combustion devices used to comply
with Section XII.J to be enclosed and have no visible emissions
■ It should be noted that although Section XII.J.2 for reciprocating
compressors does not explicitly require the use of a control device
123/0243 Page 47 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
to achieve compliance, the applicability requirements Section
XII.A.6 mandate that Section XII.C.1.d be complied with for
reciprocating compressors. As such, this condition was included in
the operating permit.
o Section XII.C.1.e — Requirement for combustion devices used to comply
with Section XII.J to operate with an auto -igniter
■ It should be noted that although Section XII.J.2 for reciprocating
compressors does not explicitly require the use of a control device
to achieve compliance, the applicability requirements Section
XII.A.6 mandate that Section XII.C.1.e be complied with for
reciprocating compressors. As such, this condition was included in
the operating permit.
o Colorado Regulation No. 7, Section XII.J — Compressor Requirements
• Section XII.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).
■ Section XII.J.2.b — As an alternative to the rod packing
replacement, rod packing emissions may be routed back to
process via a closed vent system operating under negative
pressure. The packing system shall be inspected annually for
defects and use EPA Method 21 to verify VOC leakages are less
than 500 ppm. If a leak in excess of this threshold is detected, it
shall be repaired unless technically infeasible or unsafe.
• Section XII.J.2.c — Records shall be kept of the reciprocating
compressor identity, hours of operation/number of months since
last packing replacement, date of packing replacement or
installation of closed vent system, each inspection resulting in
responsive actions and a list of each delay of repair or inspection.
• Section XII.J.2.d — Option to comply with the LDAR requirements
of Section XII.L in lieu of the inspection, repair and recordkeeping
provisions of Sections XII.J.2.b and c.
• Section XII.J.2.e — Option to comply with a federal NSPS in lieu of
the entire Section XII.J.2.
o Colorado Regulation No. 7, Section XII.L — LDAR Requirements
• Section XII.L.1 — Inspect facilities using approved instrument
monitoring methods (AIMM) at least quarterly.
• Section XJI.L.3 — Definition of "difficult to monitor" components.
• Section XII.L.4 — Definition of leaks requiring repair.
123/0243 Page 48 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
■ Section XII.L.5 — Repair and remonitoring schedule.
■ Section XII.L.6 — Recordkeeping requirements documenting AIMM,
identifying facility, leaks detected, repair and remonitoring
attempts, delayed repair components and unsafe components.
• Supplemented condition with an additional monitoring
requirement to identify any leaks that qualify as normal
equipment operation, for the purposes of determining leaks
that require repair in accordance with Colorado Regulation
No. 7, Section XII.L.4.
• Section XII.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.
■ Section XII.L.8 — Alternative AIMM proposition requirements,
including application requirements and the approval process.
o Colorado Regulation No. 7, Section XVII.B (State -Only Enforceable) —
General Requirements
■ Section XVII.B.1.a — General requirement to handle all
hydrocarbon liquids in a manner that minimizes the leakage of
VOCs.
■ Section XVII.B.1.b — General requirement to operate facility in
accordance with good air pollution control practices.
• Section XVII.B.2.a — Requirement to maintain air pollution control
equipment pursuant to manufacturer specifications and to design
this equipment to handle foreseeable process fluctuations.
■ Section XVII.B.2.b — Requirement to operate enclosed combustion
device with no visible emissions.
• Section XVII.B.2.d — Requirement to operate combustion device
with an auto -igniter.
■ Section XVII.B.3.a — Requirement to cap all open ended lines or
valves.
• Section XVII.B.3.c. — Requirement to replace all compressor rod
packing every 26,000 hours of operation (or 3 years).
o Colorado Regulation No. 7, Section XVII.F (State -Only Enforceable) —
LDAR Requirements
• Section XVII.F.2 — Allowance to use EPA -453 Table 2-8 in the
estimation of fugitive emissions for compressor stations for the
purposes of Colorado Regulation No. 3.
123/0243 Page 49 of 58
DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
■ Section XVII.F.3 — Requirement to perform AIMM pursuant to the
frequency specified based on calculated fugitive VOC emissions,
using EPA -453 Table 2-4.
■ Section XVII.F.5 — Definition of "difficult to monitor" components.
■ Section XVII.F.6 — Definition of leaks requiring repair.
■ Section XVII.F.7 — Repair and remonitoring schedule.
■ Section XVII.F.8 — Recordkeeping requirements, including facility
identification, leaks identified and repair attempts.
• Supplemented condition with an additional monitoring
requirement to identify any leaks that qualify as normal
equipment operation, for the purposes of determining leaks
that require repair in accordance with Colorado Regulation
No. 7, Section XVI I . F.6.
■ Section XVI I .F.9 — Reporting requirements PRIOR to 1/1/2018,
including an annual report identifying the number of facilities
inspected, leaks identified, leaks repaired, leaks on the delayed
repair list and responsible official certification.
■ Section XVII.F.10 — Reporting requirements beginning 1/1/2019,
including an annual report identifying the number of facilities
inspected, leaks identified, leaks repaired, leaks on the delayed
repair list and responsible official certification.
Condition 5: Compliance Assurance Monitoring
• Updated CAM condition to most current Division -standard language (ver.
4/16/2009)
Section III— Permit Shield & Streamlining
• The justifications for the following permit shields were updated for clarity:
o Colorado Regulation No. 7 Section VI.B.1 — Storage of Petroleum
Distillates
■ The Marla Compressor Station is not subject to any part of
Colorado Regulation No. 7 Section VI, as these requirements were
not intended to apply to liquids stored at compressor stations (see
discussion in Applicable Requirements Section III of this
document). Because Section VI would not apply to the Marla
Compressor Station even if a storage tank greater than 40,000
gallons were present at the facility, the permit shield justification
was updated to reflect this.
o Colorado Regulation No. 7 Section VI.B.2 — Storage of Petroleum
Distillates
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
■ The Marla Compressor Station is not subject to any part of
Colorado Regulation No. 7 Section VI, as these requirements were
not intended to apply to liquids stored at compressor stations (see
discussion in Applicable Requirements Section III of this
document). Because Section VI would not apply to the Marla
Compressor Station even if a storage tank greater than 40,000
gallons were present at the facility, the permit shield justification
was updated to reflect this.
o Colorado Regulation No. 7 Section VII.C — Crude Oil Storage
■ This requirement subjects crude oil storage tanks in excess of
40,000 gallons to comply with selected requirements from
Colorado Regulation No. 7, Section VI. The Marla Compressor
Station is not subject to any part of Colorado Regulation No. 7
Section VI, as these requirements were not intended to apply to
liquids stored at compressor stations (see discussion in Applicable
Requirements Section III of this document). Because Section VI
would not apply to the Marla Compressor Station even if a storage
tank greater than 40,000 gallons were present at the facility, the
permit shield justification was updated to reflect this.
• The following permit shields were removed from the operating permit pursuant
to the following justifications:
o Colorado Regulation No. 1 Section VI.B.5.a — for engines only
■ 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 pursuant to the Colorado Common
Provisions Regulation, 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 Marla
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 Colorado Regulation No. 4 — Wood -burning stoves
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
■ The requirements of Colorado Regulation No. 4 are not addressed
by the operating permit program. Therefore, the permit shield was
removed from the operating permit.
o Colorado Regulation No. 6 Part A — Federal NSPS requirements
■ The Marla Compressor Station is currently subject to NSPS JJJJ.
As of the issuance date of this operating permit, NSPS JJJJ has
not been adopted into Colorado Regulation No. 6. However,
because the Marla Compressor Station could become subject to
this regulation if NSPS JJJJ is adopted in the future, and that a
qualifying modification could occur within the permit term (or be
determined to have occurred in the past) thereby subjecting the
facility to other state -adopted NSPS rules (i.e., Subpart OOOO),
this shield was removed from the operating permit.
o Colorado Regulation No. 6 Part B — State -only NSPS requirements
■ The permit shield for State -only NSPS requirements was removed
from the operating permit. It is the Division's experience that
multiple modifications are frequently submitted for oil and gas
facilities during the five-year permit term. Because a qualifying
modification during the permit term could potentially subject the
Marla Compressor Station to an applicable state -only NSPS
requirement, this shield was removed from the operating permit.
o Colorado Regulation No. 7 Section V.C — Disposal of Volatile Organic
Compounds
■ Section V.C has been removed from Colorado Regulation No. 7.
Therefore, this permit shield is not applicable and the permit shield
was removed from the operating permit.
o Colorado Regulation No. 10 — Criteria for Analysis of Transportation
Conformity
■ The requirements of Colorado Regulation No. 10 do not apply to
stationary sources. Therefore, this permit shield was removed from
the operating permit.
• The following conditions were removed from the streamlining table:
o Colorado Regulation No. 7, Section XVII.E.2.b and XVII.E.3.b.(i)
■ These requirements were originally streamlined from the operating
permit because all engines at the Marla Compressor Station were
exempted from compliance with Section XVII pursuant to Section
XVII.B.5, since the engines were subject to formaldehyde emission
limitations set forth in Subpart ZZZZ. However, with this renewal of
the operating permit, it was determined that engines C-148, C-135,
C-151 and C-166 were considered to be "remote" for the purposes
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
of MACT ZZZZ (see discussion in Section III above). Remote
engines under MACT ZZZZ are subject to only work practice
standards, which the Division does not consider to be a qualifying
emission control requirement for the purposes of the Section
XVII.B.5 exemption. As such, these engines are now required to
comply with the applicable requirements of Section XVII.E.
Therefore, these conditions were removed from the streamlining
table and were included in the operating permit. For a more
detailed discussion on how these conditions were included in the
operating permit, refer to Condition 1.10 above.
o Colorado Regulation No. 1, Section II.A.5
■ The 30% opacity requirement for the enclosed combustion device
was originally streamlined from the operating permit in favor of the
Colorado Regulation No. 7 Section XVII.B.2.b no visible emissions
requirement, which is more stringent. However, the Colorado
Regulation No. 1 30% opacity requirement is federally enforceable,
whereas the Colorado Regulation No. 7, Section XVII.B.2.b
requirement is state -only enforceable. Because federally
enforceable conditions cannot be streamlined for state -only
enforceable conditions, the Colorado Regulation No. 1, Section
II.A.5 30% opacity requirement was removed from the streamlining
table and included in the operating permit. It should be noted that
compliance with this condition is presumed, provided the zero
visible emissions requirement of Colorado Regulation No. 7,
Section XVII.B.2.b is met.
o Colorado Regulation No. 7, Section XVII.D
■ Since the previous issuance of the operating permit, Colorado
Regulation No. 7, Section XVII.D has expanded to include more
detailed requirements that cannot be streamlined in favor of the
95% control requirement set forth in the previous issuance of the
operating permit. As such, this condition was removed from the
streamlining table and all applicable Colorado Regulation No. 7,
Section XVII.D requirements were included in the operating permit.
For a more detailed discussion on the incorporation of these
requirements, refer to Condition 2.11 above.
• The following conditions were added to the streamlining table:
o Colorado Regulation No. 7, Section XVII.A.2
■ The Colorado Regulation No. 7 Section XVII.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 through the Colorado Regulation No. 7 language
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
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.
o Colorado Regulation No. 7 Section XVII.F.8
■ The Colorado Regulation No. 7 Section XVII.F.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 XVII.F.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.
Section IV — General Permit Conditions
• Updated to most current Division -standard version (8/28/2018)
Appendices
• Appendix A — Inspection Information
o Added recordkeeping requirements for certain insignificant activities, as
denoted by an asterisk pursuant to Colorado Regulation No. 3, Part C,
Section II.E.
• Appendix B — Monitoring and Permit Deviation Report
o Updated to most current Division -standard version (8/20/2014 w/ codes)
• Appendix C — Compliance Certification Report
o Updated to most current Division -standard version (8/20/2014 w/ codes)
• Appendix D — Notification Addresses
o Updated to most current Division -standard version (2/5/2014)
• Appendix G — Compliance Assurance Monitoring (CAM) for Engines
o Removed all references to the Colorado Regulation No. 7, Section XVII.E
emission limitations. Since the previous issuance of this operating permit,
various engines have undergone Alternative Operating Scenario (AOS)
execution. As a result, no engine at the Marla Compressor Station is
currently subject to the numerical emission standards set forth in Colorado
Regulation No. 7, Section XVII.E.2 for new engines. Engines C-148, C-
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
135, C-151 and C-166 are considered to be existing engines for the
purposes of Section XVII.E and are therefore required only to install
NSCR and operate with AFR. Engines C-174 and C-176 are considered
new engines for the purposes of Section XVII.E., however, both are
subject to the numerical NSPS Subpart JJJJ emission standards, thereby
exempting them from compliance with Section XVII.E.2, pursuant to
Section XVII.B.5.
o Updated catalyst pressure drop measurement approach to reflect the use
of local differential pressure transmitters, as requested in source
comments received 4/10/2019 and 5/6/2019.
o Added requirement to maintain records of any high temperature engine
shutdowns, in addition to records of adjustments and repairs made in
response to a catalyst inlet temperature excursion.
o Updated QA/QC practices for thermocouples to require annual verification
of proper operation and replacement if necessary, pursuant to source
comments received 4/10/2019.
o Updated monitoring frequency of catalyst inlet temperature to
continuously. The catalyst inlet temperature is continuously monitored via
the Distributed Control System (DCS). It should be noted that, for the
purposes of recordkeeping, the catalyst inlet temperature must be
recorded once daily from these continuous readings.
o Added exclusion from collecting the catalyst inlet temperature for periods
where the engine is not operating, as requested in source comments
received 4/10/2019.
• Appendix H — Compliance Assurance Monitoring (CAM) for Dehydration Units
o Updated VOC emission limitations for P-112 and P-113 based on the
7/23/2018 permit modification application.
o Added exclusions for monitoring the pilot flame during permitted periods
of downtime, as requested in the 10/11/2017 and 7/23/2018 permit
modification applications.
o Added explicit requirement to maintain records of all pilot light outages
and corrective actions taken in response.
o Updated QA/QC practices for thermocouples to require annual verification
of proper operation and replacement if necessary, pursuant to source
comments received 4/10/2019.
o Included requirement to conduct daily visual inspections of the pilot light
to verify the operability of the thermocouple. It should be noted that daily
visual inspection of the pilot light is required pursuant to the operating and
maintenance (O&M) plan for dehydration units, which was incorporated
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No. 95OPWE020
Technical Review Document — Renewal Operating Permit
into the control device condition for the dehydration units (see Condition
2.9
above).
o Supplemented CAM condition with the required "Justification" section.
This summary includes a listing of the indicator chosen, an explanation of
how the indicator is related to emission control device performance, and
a rationale of the ranges for the indicator selected. Justifications are
required for CAM indicators that are not determined to be presumptively
acceptable, pursuant to §64.4(b) of the CAM rule.
• Appendix I — AOS Applicability Reports
o Updated to the most current Division -standard version (10/12/2012 w/
updated citations)
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No 95OPWE020
Technical Review Document — Renewal Operating Permit
VI. FACILITY -WIDE EMISSION SUMMARY
AIRS ID
Facility ID
Source
Controlled Emissions (tons/year)
Uncontrolled Emissions (tons/year)
NOx
CO
VOC
Reportable
HAP
NOx
CO
VOC
Reportable
HAP
052
C-148
1,478 HP Compressor Engine
28 54
42 82
14 27
0 46
156 99
114 18
2141
147
053
C-135
1,478 HP Compressor Engine
28 54
42 82
14 27
0 46
156 99
114 18
2141
147
054
C-151
1,478 HP Compressor Engine
14 27
28 54
9 99
0 46
156 99
114 18
2141
147
059
C-166
1,680 HP Compressor Engine
32 45
32 45
16 22
0 53
178 45
129 78
24 33
1 68
060
C-174
1,680 HP Compressor Engine
16 22
32 45
11 36
0 53
178 45
129 78
24 33
1 68
061
C-176
1,680 HP Compressor Engine
32 45
32 45
16 22
0 53
178 45
129 78
24 33
1 68
062
P-112
45 MMSCFD TEG Dehydration Unit
--
--
10 62
6 31
--
--
455 51
89 77
063
P-113
55 MMSCFD TEG Dehydration Unit
--
--
14 26-
8 29
--
--
300 24
110 79
Total Permitted Facility Em ssions (tons/year)
152 47
211 53
107 21
17 58
1006 32
73188
892 97
210 00
Information Relied Upon
Facility ID
Information Source
C-148
APEN rec'd 3/22/2019, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled S02, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
C-135
APEN rec'd 6/27/2018, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled 502, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
C-151
APEN rec'd 6/27/2018, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled S02, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
C-166
APEN rec'd 6/27/2018, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled S02, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
C-174
APEN rec'd 6/27/2018, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled S02, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
C-176
APEN rec'd 6/27/2018, mfg EF's for NOx, CO, VOC, AP -42 Table 3 2-3 for uncontrolled S02, PM and HAP EF's, MACT ZZZZ for CH2O CE, assume 50% CE for all other HAP
P-112
APEN rec'd 7/23/2018, VOC and HAP emissions based on 7/2/2018 GLYCaIc run and 6/28/2017 extended gas analysis from 7/23/2018 permit modification application
P-113
APEN rec'd 7/23/2018, VOC and HAP emissions based on 7/2/2018 GLYCaIc run and 6/28/2017 extended gas analysis from 7/23/2018 permit modification application
ECD
NOx and CO EF's from AP -42 Table 13 5-1 and 13 5-2, emissions based on 7/23/2018 permit modification application
i
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DCP Operating Company, LP — Marla Compressor Station
Operating Permit No 95OPWE020
Technical Review Document — Renewal Operating Permit
Uncontrolled HAP Emissions (Reportable)
AIRS ID
Facility ID
Source
Calculated Reportable Uncontrolled HAP Emissions (tons/year)
Acetaldehyde
Acrolein
Methanol
Formaldehyde
n-
Hexane
Benzene
Toluene
Ethyl
benzene
Xylenes
052
C-148
1,478 HP Compressor Engine
014
013
016
104
--
--
--
--
--
053
C-135
1,478 HP Compressor Engine
0 14
0 13
0 16
1 04
--
--
--
--
--
054
C-151
1,478 HP Compressor Engine
0 14
- 0 13
0 16
1 04
--
--
--
--
--
059
C-166
1,680 HP Compressor Engine
0 16
0 15
0 18
1 19
--
--
--
--
--
060
C-174
1,680 HP Compressor Engine
0 16
0 15
0 18
1 19
--
--
--
--
--
061
C-176
1,680 HP Compressor Engine
0 16
0 15
0 18
1 19
--
--
--
--
--
062
P-112
45 MMSCFD TEG Dehydration Unit
--
--
--
--
7 72
22 02
33 74
1 84
24 45
063
P-113
55 MMSCFD TEG Dehydration Unit
--
--
--
--
5 19
28 22
43 43
2 34
31 61
Total Permitted Facility Emissions (tons/year)
0 91
0 86
1 00
6 67
12 91
50 24
77 17
4 18
56 06
Controlled HAP Emissions (Reportable)
AIRS ID
Facility ID
- Source
Calculated Reportable Controlled HAP Emissions (tpy)
Acetaldehyde
Acrolein
Methanol
Formaldehyde
n-
Hexane
Benzene
Toluene
Ethyl
benzene
Xylenes
052
C-148
1,478 HP Compressor Engine
0
07
0
07
0
08
0 25
--
--
--
--
--
053
C-135
1,478 HP Compressor Engine
0
07
0
07
0
08
0 25
--
--
--
--
--
054
- C-151
1,478 HP Compressor Engine
0
07
0
07
0
08
0 25
--
--
--
--
--
059
C-166
1,680 HP Compressor Engine
0
08
0
08
0
09
0 28
--
--
--
--
--
060
C-174
1,680 HP Compressor Engine
0
08
0
08
0
09
0 28
--
--
--
--
--
061
C-176
1,680 HP Compressor Engine
0
08
0
08
0
09
0 28
--
--
--
--
--
062
P-112
45 MMSCFD TEG Dehydration Unit
--
--
--
--
0
16
1
60
2
52
0
14
1
89
063
P-113
55 MMSCFD TEG Dehydration Unit
--
--
--
--
0
21
2
13
3
32
0
18
2
45
Total Permitted Facility Emissions (tons/year)
0
45
0
43
' 0
50
1 60
0
37
3
73
5
84
0
32
4
34
2017 Actual Facility Emissions (tons/year)
0
41
0
21
0
46
147
0
06
0
45
0
30
0
01
0
07
123/0243
Page 58 of 58
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